A Wales-only glass DRS puts UK trade at risk

The WSTA has worked closely with glass manufacturers, bottlers, importers, producers, SMEs and colleagues from drinks hospitality and retail to try and introduce a long-term and effective recycling system that works for the environment, businesses and consumers.

Freddie Joosten, the WSTA’s Associate Director of Environmental Policy, takes us through the arguments against creating a unique glass scheme in Wales.

Why Glass Must Stay Out of DRS in Wales

The Welsh Government’s decision to create a unique Wales-only Deposit Return Scheme (DRS) is out of step with other schemes in the rest of the UK. By including glass Welsh Government risk fracturing UK trade, reducing choice for Welsh consumers, and undermining one of the most successful recycling schemes in the world.

As the representative body for the UK wine and spirit industry—the largest users of container glass packaging — we are calling for an urgent rethink. While we fully support the ambition of a circular economy, the current proposals for Wales are economically impractical, incentivise fraud, and could be environmentally counterproductive.

A Threat to the UK Internal Market

The most immediate concern for our members is a loss of trade caused by this divergence. England, Scotland, and Northern Ireland will have a glass-free DRS by the end of 2027. By going it alone, Wales is creating a regulatory island.

For a wine importer or a craft gin distiller, this means unique Welsh only labels (or labels indicating products are not to be sold in Wales) and separation of stock. Our members tell us this administrative nightmare will lead to mass de-listings and withdrawal from the Welsh market as most producers will find complying too complex and expensive.

The Welsh Government wants to introduce their scheme at the same time as the rest of the UK (October 2027), but with no governance in place and glass needing different deposit and return infrastructure to plastic and cans, this is highly unlikely. The supply chain, including hospitality and retailers will need far more time to prepare for a unique Wales only scheme. Only by excluding glass can the Welsh scheme start without delay, alongside the rest of the UK.

The “Zero-Deposit” Paradox

Wales is already a global leader in recycling, boasting glass collection rates of over 90% through its highly effective kerbside system (using EPR fees to fund it). The Welsh Government has proposed a “zero-deposit” transition, from 2027 to 2030, to bring glass in scope of DRS. This creates a muddled policy as both kerbside (funded by EPR) and DRS will be unfunded during this time! This raises a number of important issues:

  • No Incentive: Without a deposit to reclaim, why would a consumer carry heavy glass bottles back to a shop instead of using their doorstep bin? How will zero deposit reduce littering?
  • Sunken costs: Retailers will still be forced to invest in expensive unique glass infrastructure and storage for a system that lacks a financial driver.
  • Collections: With no DRS, EPR or PRN funding or identification, it is not clear how Local Authorities will be paid to collect this packaging.

Environmental Consequences

Excluding glass and aligning with the UK has environmental benefits: it will prevent wasteful production of additional labels and stock, ensure economies of scale, prevent fraud, and allow Welsh glass packaging waste to continue to be sorted and reprocessed in England.

Glass is heavy and fragile. Moving it through a “return-to-retail” model—where consumers drive bottles back to shops and heavy vehicles make additional pick-ups from numerous collection points can increase carbon emissions and reduce the quality of glass collection compared to optimised kerbside collection.

Glass packaging is infinitely recyclable, however, as the costs and complexities of glass become too high, producers are incentivised to move toward plastic (PET) packaging or metal cans with liners.

The Welsh Government also want to introduce a Wales only glass reuse scheme. We support reuse where the evidence clearly demonstrates it will benefit the environment but for wine and spirits the evidence suggests there is no or limited net environmental gains for glass re-use. DRS does not necessarily lead to reuse, and, as the research shows reuse is contingent on short distances to cleaning and refill, high packaging velocity (FMCG), and standardised vessels – none of which applies to Wales, which is largely reliant on imports and has no large scale reuse infrastructure.

The Path Forward

In November 2025, the Welsh Government admitted it would need to apply for an exemption to the Internal Market Act – an admission its plans breach mutual recognition and discrimination principals (a similar exemption caused the collapse of the Scottish DRS scheme). We expect an outcome to be announced soon, with three possible decisions*:

  1. Approved – Wales would be allowed to include glass in its DRS on all packaging sold in the UK. As we have told the Welsh Government we expect many companies to be forced to withdraw stock from Wales as these plans are too complex and will not be cost-effective.
  2. Not approved – Wales could either apply the law to Welsh producers only, or align their scheme with the rest of the UK (our preferred outcome). The Welsh Government has indicated it would drop its plans for DRS completely, however this would not align with the rest of the UK, and it would allow plastic bottle and can littering to continue.
  3. No decision – the application process requires all nations of the UK to agree on a final decision, if this isn’t possible the matter will be referred to the UK Minister to decide. The Minister could take up to 6 months, and this would jeopardise UK alignment.

We urge the Welsh Government to align with the rest of the UK and prevent any further delay. A consistent, UK-wide DRS focusing on “on-the-go” materials like plastic and cans, while leaving glass to the proven success of kerbside recycling, is the only way to protect Welsh businesses, consumers, and the environment.

*NB the UKIMA exemption application wording has not been shared publicly so we have had to assume the contents!

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