GreenBargains Initiative

A Systems Perspective on the Implementation of Deposit Return Schemes in the UK and EU

Deposit Return Schemes (DRS) are now a key policy tool for reducing packaging waste, enhancing material recovery, and advancing circular-economy objectives in the UK and the EU. The rationale is well established, and the policy direction is clear.
However, as schemes move from design to large-scale implementation, a growing gap is emerging between policy design and system operability, rather than between ambition and intent.
This article examines the practical challenges facing current DRS frameworks and argues that a more integrated, multidisciplinary approach is needed for consistent delivery across markets.

Alignment in intent, fragmentation in execution

At a high level, UK and EU DRS frameworks share common objectives:
• Increasing return rates
• Reducing litter and leakage
• Improving recycling quality
• Shifting responsibility upstream
However, implementation varies significantly across jurisdictions. Differences in labelling rules, eligible containers, reporting requirements, scheme operators, and infrastructure models create a fragmented environment for producers operating in multiple markets.
From a systems perspective, DRS consists of interdependent components rather than a single mechanism. Friction arises when these components are not aligned.

Where current frameworks show stress

1. Policy timelines and infrastructure readiness
   DRS legislation often specifies outcomes precisely, assuming infrastructure will adapt. In practice, physical infrastructure, such as return points and logistics, and digital infrastructure, such as data capture and validation, are often developed unevenly.
   This results in clear accountability, but control is distributed among actors with varying readiness.
2. Data abundance without coherence
   Most DRS ecosystems generate significant volumes of data. However, that data is often:
   • Dispersed across multiple stakeholders
   • Collected in incompatible formats
   • Reconciled retrospectively
   This leads to limited real-time visibility and frequent disputes over accuracy. From a governance perspective, it weakens trust and increases administrative burden without necessarily improving environmental outcomes.
3. Packaging and SKU complexity as an unintended outcome
   Market-specific labelling and barcode requirements have increased SKU variation. While this supports local compliance, it introduces operational and environmental inefficiencies that are often overlooked during policy design.
   This tension highlights a broader issue: compliance mechanisms can generate waste and cost if system-wide impacts are not assessed.
4. Behavioural dynamics under-integrated
   Return rates ultimately depend on consumer behaviour. However, behavioural factors such as convenience, feedback, habit formation, and trust are often secondary to regulatory enforcement in scheme design.
   Evidence from high-performing systems indicates that behavioural design is foundational rather than supplementary.
5. Limited multidisciplinary integration
   DRS design has largely been driven by regulatory and waste-management perspectives. In practice, effective schemes operate at the intersection of:
   • Policy and law
   • Supply chain operations
   • Digital systems and data governance
   • Behavioural science
   • Brand and reputational management
   When these perspectives are not integrated early, misalignment often occurs later in the process.

Towards a more integrated DRS model
Addressing these gaps often requires better system integration rather than additional regulation:
• Policy informed by operational constraints
• Interoperable digital infrastructure
• Transparent and auditable data flows
• Behaviour-aware system design
• Cross-sector collaboration
Emerging initiatives, including research-led and technology-enabled programmes, are exploring how existing infrastructure and data systems can be more coherently connected. The goal is not to replace existing schemes, but to improve their coordination.

Conclusion
UK and EU Deposit Return Schemes are not failing; however, they are expected to operate as coherent systems, even though they were not designed to do so.
As DRS matures, the key challenge is no longer whether schemes should exist, but how they are integrated across policy, infrastructure, data, and behaviour.
A shift towards systems thinking is essential for DRS to deliver lasting environmental outcomes at scale.

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