Introduction

The UK Deposit Return Scheme (DRS) is reshaping how retailers and producers plan packaging, point‑of‑sale infrastructure and sustainability messaging. Although the scheme targets drinks containers, not every CBD product will be swept up by the rules. Still, the 2026 planning cycle — including published RVM technical specifications and an expected producer registration window — is already forcing CBD brands and retailers to rethink amber bottle design, low‑volume exemptions and the economics of in‑store refills well ahead of the Oct 2027 go‑live.

What’s trending

Several converging developments in 2026 are pushing change across the CBD sector:

• Clear DRS scope: The scheme targets single‑use drinks containers between 150ml and 3L made from PET, aluminium and steel. Glass is excluded throughout Great Britain except in Wales, where a four‑year transition brings glass into scope. Most common CBD oil bottles (10–30ml) therefore sit below the 150ml threshold and are likely out of scope.
• Refillable containers are excluded: That exclusion creates a tangible regulatory and marketing incentive for CBD brands to offer refillable amber bottles or install in‑store refill points — a sustainability differentiator as well as a way to avoid deposit mechanics for particular SKUs.
• Low‑volume product line exemption: Product lines selling under 5,000 units per year can qualify for a low‑volume exemption. Micro‑brands may therefore avoid charging deposits on small runs, though they will still need to register with the DMO and submit reports.
• Technical and timing milestones: Exchange for Change (the DMO) published RVM specifications in spring 2026, and producer registration is expected to open in Q3 2026. That creates a short runway for updating artwork, barcodes/ID markers and reporting systems.
• Deposit and handling economics: Consultation has suggested a single flat deposit (Exchange for Change consulted on a 20p level) while handling and retailer fee models remain under discussion — changes here will materially affect unit economics for in‑scope containers and any multipacks that include drink components.
• Retail impacts and support: Small retailers can be exempt from hosting a return point (for instance an urban exemption for shops under 100m²). Discussions over grants and handling payments are ongoing — ACS has reported potential RVM reimbursements and proposed grants to support independent retailers.
• Identification markers required: In‑scope containers must carry machine‑readable ID markers (barcodes/QRs) to allow RVM acceptance and fraud control. Any CBD brand that sells beverage SKUs or multipacks containing drinks will need bottle and label redesigns that meet technical specs.
• Permitted development changes: April 2026 changes make installing RVMs easier — outdoor or adjacent placements are now simpler to carry out — accelerating retailer decisions on store layout and whether to host refill facilities for non‑DRS formats.

Why it matters to CBD brands and retailers

At first glance many CBD oils are unaffected because of the 150ml lower bound. But the planning cycle matters for three practical reasons:

• Design and artwork lead times: New ID marker specifications and producer registration timetables mean brands must update artwork, barcode data and label files now to avoid last‑minute redesigns that disrupt fulfilment.
• Retail economics and distribution choices: Deposit levels, handling fees and the costs of fitting an RVM or opting into grant schemes will influence whether larger retailers accept multipacks with drinks, and whether smaller independents choose to host return points or install refill options instead.
• Marketing and sustainability positioning: Because refillable containers are excluded from the DRS, offering a refill service is both a compliance advantage and a brand differentiator. Refill offerings can be positioned around reduced waste, lower carbon footprint and repeat customer engagement — while staying within ASA/CAP advertising rules (no medical claims).

Examples in practice

Here are practical pivots brands are making now.

• Label and barcode updates: A small drinks SKU or a CBD‑infused RTD that crosses the 150ml threshold must be machine‑readable at RVMs. Brands selling beverage lines or multipacks are updating label files, enlarging scannable areas and embedding unique IDs so automated machines can accept returns and prevent fraud.
• Refill and reusable amber bottle programmes: Refillable amber bottles are an obvious design response. Brands are investing in durable, UV‑blocking amber bottles and refill stations for retail partners. For product examples that sit in the familiar amber dropper format, see Wylde Natural Cold‑Pressed Drops 1000mg CBD Oil 10ml, Wylde Natural Cold‑Pressed Drops 2000mg CBD Oil 10ml and Wylde Natural Cold‑Pressed Drops 4000mg CBD Oil 10ml as familiar examples of the amber dropper form factor many brands are adapting for refillable schemes.
• Micro‑brand decisions under the low‑volume exemption: Smaller producers selling under 5,000 units per product line are modelling whether to apply for the exemption. It reduces immediate deposit charging obligations but not registration and reporting duties — so bookkeeping and traceability remain essential.
• Updating systems to meet RVM specs: With RVM technical guidance published in spring 2026 and producer registration due in Q3, brands must ensure their supply chain, EAN/GTIN issuance and ERP reporting can deliver container identifiers to the DMO on schedule. Even for non‑DRS SKUs, this is a sensible opportunity to clean up barcode hygiene and version control.
• High‑strength or multipack implications: Where tinctures or higher‑volume wellness beverages cross thresholds, unit economics are rapidly affected by the likely flat deposit and potential handling fees — brands should run scenario analysis using the consulted 20p deposit and proposed retailer handling payment models to understand margin impacts.

Future outlook — what to expect before Oct 2027

Between now and the go‑live date, expect several consequential developments:

• Final deposit and fee models: A flat deposit and confirmed handling fees will allow brands to finalise pricing and multipack strategies. If a modest flat deposit is adopted, many small CBD single‑bottle SKUs will remain out of scope; multipacks with drinks or larger volume formats will need close attention.
• Retail layout decisions accelerate: Easier permitted development for RVMs makes retailer uptake quicker. Some independents will choose grants and hosting RVMs; others will prefer to differentiate through refill islands or off‑site return points.
• More brands will offer refillable formats: Expect refill programmes and durable amber bottles to become a standard sustainability story for premium CBD brands — both as a consumer convenience and a compliance hedge.
• Traceability and data become standard operating practice: The need for ID markers and producer reporting will professionalise SKU data management across the sector.

Conclusion — practical next steps for CBD brands

Even where a product sits outside the 150ml threshold, the DRS planning cycle is a timely catalyst for clearer packaging strategy and retail partnerships. Short checklist:

• Audit SKUs to identify any lines that could be in scope (beverages, multipacks, larger formats).
• Update label templates and barcode schemes so they can accommodate the RVM specifications published in spring 2026.
• Decide whether to design refillable amber formats or roll out in‑store refill partnerships now — refillable containers are excluded and carry marketing value.
• Model the low‑volume exemption for micro‑brands; ensure registration and reporting workflows are in place even if exempt from deposit charging.
• Engage early with retail partners about RVM placement, grants and handling payments — retailers’ space decisions will determine the feasibility of refill points and local distribution strategies.

Planning now — on artwork, barcodes, refill economics and retailer conversations — converts regulatory change from a disruption into an opportunity to demonstrate responsible packaging and build stronger retail relationships ahead of Oct 2027.