John Twitchen, CIWM Fellow and founder of circular economy company Stuff4Life, asks is Wales, including glass in its DRS, the right thing for the right reason?
When the UK’s long-awaited deposit return scheme (DRS) for drink containers finally arrives in October 2027, Wales will be doing something slightly different.
Westminster has granted Wales permission to depart from UK-wide consistency on glass containers – a notable development in a policy process that has spent years trying to align the four nations.
It raises an interesting question: is Wales in fact piloting the right thing, for the right reasons?
Glass has been the most contentious material throughout the DRS saga – from the early policy debates through to negotiation and implementation.
Once again, it has become the focal point, and yet, in many ways, for us middle-older folk, it merely marks a back-to-the-future moment.
What Wales is doing differently
Under the Welsh model, glass containers are effectively ‘in’ from day one of the deposit return system.
Glass bottles will be able to be collected alongside plastic and metal drink containers through the scheme’s infrastructure.
However, there will be no deposit charged and no DRS labelling requirement, to keep the system interoperable with the rest of the UK’s DRS arrangements, where glass was excluded after sustained lobbying by manufacturers and the drinks industry.
To make this work, Wales had to secure an exemption from parts of the UK’s Internal Market Act 2020, legislation designed to ensure smooth trade between the UK’s four nations following Brexit.
That same legislation is widely considered to be the factor that ultimately derailed Scotland’s earlier attempt at launching its own deposit return scheme.
Wales now has a four-year transition period during which it plans to develop something even more ambitious: a system that includes reuse for glass containers.
All of this still needs approval from the Senedd Cymru, and the Welsh scheme will also include the option for consumers to donate their deposits to charity. If everything proceeds as planned, the scheme will begin in October 2027, which still feels like a lifetime away.
This may seem familiar to some, perhaps to those of us old enough to remember deposits on bottles from our childhood. In my case, it was a small but reliable source of income: scavenging empty bottles from building sites and returning them to the shop for the deposit satisfied my sweet tooth.
Those earlier deposit systems were fundamentally tied to refill. Bottles weren’t simply returned to be recycled, they were washed, refilled and delivered locally.
Deposit logic naturally favours refill and refill systems tend to favour glass
Interestingly, the UK Government itself reaffirmed the importance of reuse and refill in the transition to a circular economy. In its official response to the Welsh request, it states that reusable and refillable packaging systems should become the norm, helping to move away from the linear ‘take, make, throw’ model.
I’ve previously highlighted how Extended Producer Responsibility (EPR) is having the unintended consequence of driving investment into commercial reuse and refill iniatives. This worth reflecting on because the relationship between deposit systems, recycling and reuse is not always straightforward.
Packaging policy currently places significant emphasis on high recycling rates, and less so on reducing the overall amount of material used in the system (the ‘waste’ denominator, if you like).
Deposit return schemes are widely recognised as a powerful way to achieve high recycling rates, particularly for drink containers, but refill systems work differently.
High recycling rates encourage sustained, large volumes of single-use containers to be manufactured and collected. Refill systems require far fewer containers entering the system, are designed for longevity, and demanding local servitisation.
Put simply, if bottles are reused many times, you don’t need to make as many, and fewer need to be recycled. This tension sits at the heart of the debate.
Industry concerns about the Welsh approach
Wales’s glass decision has prompted pushback from the glass and drinks sectors. British Glass says there is a ‘credible risk of complexity and confusion’ arising from Wales operating a different approach.
Meanwhile, the Wine and Spirits Trade Association has described the situation as ‘disingenuous’, perhaps referring to the 0p deposit.
One practical issue frequently raised by critics is that glass jars will still be collected through kerbside recycling, while glass drinks bottles may appear within the DRS infrastructure, arguing this could introduce inefficiencies and additional costs.
Throughout the development of packaging, EPR and DRS policies, the glass industry has maintained several consistent arguments.
First, glass already achieves relatively high recycling rates through existing kerbside and bottle-bank systems. Second, introducing DRS for glass could split collection streams, potentially removing high-quality material from kerbside recycling programmes.
For this reason, the sector has generally supported strengthening kerbside collection and EPR, rather than adding deposit systems for glass.
Status quo, tweaked.
There have also been concerns around fee fairness under EPR. Glass is heavier than other packaging materials, which means higher fees under weight-based systems. Some fear this could encourage beverage companies or retailers to shift towards plastic packaging to reduce costs.
Another common point raised is that glass is ‘infinitely recyclable’; it can theoretically be recycled endlessly without degradation.
All reasonable arguments. But they don’t quite address the circular economy conundrum.
Recycling alone isn’t the ultimate goal
Glass containers can indeed be recycled indefinitely, but they can also be washed and refilled many times before recycling is even necessary, and that changes the conversation.
The Ellen MacArthur Foundation defines a circular economy not as ‘recycle as much as possible’, but as a system designed to:
- Eliminate waste and pollution
- Circulate products and materials
- Regenerate natural systems
In practical terms, that means designing systems where:
- Products last longer
- Items are repaired, reused or refilled
- Materials stay in circulation
- Waste is designed out from the start, and
- Consequently, new business opportunities are created
Recycling still plays an important role, but it is not the primary or sole objective, which makes the current debate around glass particularly interesting.
The refill question
Glass manufacturers themselves acknowledge that the material is well-suited to reusable packaging.
In a 2025 position statement, British Glass noted that reusable glass packaging is already widely used across Europe and globally, and that products currently sold in single-use glass could easily transition to refillable formats.
It states that replacing single-use plastic packaging with reusable glass could deliver significant environmental and health benefits.
So why aren’t refill systems more prominent in UK policy discussions? Part of the answer lies in the evolution of the packaging industry itself.
Over the past few decades, manufacturers have invested heavily in lightweighting glass containers, reducing material use and transport emissions by making bottles thinner and lighter.
That approach works perfectly well in a largely linear, centralised, single-use recycling model, but it is less compatible with multiple refill cycles.
The legacy of the 1980s
Deposit schemes for refillable bottles largely disappeared in the UK during the 1980s. The common explanation is ‘consumer demand’ – people supposedly preferred the convenience of disposable containers, particularly plastic.
We are still seeing that argument used today. Yet consumers ultimately purchase what is available to them. Consumers cannot choose options that don’t exist, even though they may be prepared to use reuse and refill alternatives.
Convenience has become the dominant lens through which packaging systems are designed, but it is worth asking a simple question: convenient for whom? Just for consumers? Or is it really about convenience for retailers and manufacturers?
The Welsh pilot
Which brings us back to Wales and what to me looks like designing in intended consequences rather than hoping for the best.
By allowing glass into the deposit regime – even without an actual deposit initially – the Welsh Government is opening a door that has remained largely closed in the rest of the UK.
If the four-year transition period genuinely leads towards glass reuse systems, the Welsh approach could become an important test case for the wider circular economy.
Yes, it introduces complexity. Yes, it may be inconvenient for some parts of the supply chain, but policy is not always about preserving convenience; sometimes it exists precisely to shift the system.
In this case, the shift would be from single-use recycling towards reuse and refill. This is much closer to the true, proper and functioning definition of a circular economy.
For now, Wales is taking a different path. We will find out soon enough where it takes us.
