The UK glass industry has raised concerns over the Welsh Government’s plans to include glass within its upcoming Deposit Return Scheme (DRS).

It warns that the policy is “not practically feasible” in its current form and could leave domestic producers facing unfair costs and regulatory confusion, as well as hampering the scheme delivery for other materials.

An exclusion to the UK Internal Market Act (UKIMA) principles has been agreed to allow Wales to include glass as well as metal and plastic under the scheme, which is due to launch in October 2027.

However, industry bodies say it is increasingly unlikely that a workable agreement can be reached in time.

British Glass has called on policymakers to recognise the growing risks and to take corrective action that is in the best interest of Welsh businesses and citizens before implementation.

British Glass policy advisor, Jenni Richards, said: “As it stands, the policy is heading towards a situation where the glass provisions simply cannot be delivered effectively.

“We are supportive of high recycling ambition, but the current model raises fundamental practical and legal challenges, whilst removing the supporting policies for recycling and reuse of glass in Wales.

“There is now an opportunity for Plaid Cymru to make a decisive difference by reconsidering glass within the scheme and helping to ensure a system that is both workable and genuinely world leading.”

Double charging for producers

One of the most pressing concerns centres on the potential for producers placing glass on the market to be charged twice under overlapping waste management schemes.

Under current proposals, producers in Wales could be liable for both Extended Producer Responsibility (pEPR) fees and the upfront costs of establishing the DRS system until October 2027.

British Glass understands that double charging is inevitable without intervention from the Welsh Government.

Jenni Richards said: “Producers selling their products in glass beverages containers in Wales would end up paying twice for the same material collection.

“That is clearly unsustainable.”

Although ministers have previously indicated that glass beverage producers may not be required to contribute directly to DRS set-up costs, the mechanism for funding glass collection infrastructure remains unclear until a DMO is appointed.

Legal concerns under UKIMA rules

There is also concern that the Welsh Government may have inadvertently breached the conditions required for exemption under the UK Internal Market Act.

The introduction of glass collection targets before the end of the agreed transition period could mean that only Welsh producers are legally bound to comply, allowing competitors elsewhere in the UK to avoid contributing.

Jenni Richards added: “If this isn’t corrected, you effectively have a system where there may only be Welsh businesses footing the bill.

“That creates a clear market distortion and raises serious questions about compliance within UK internal market principles.”

Beyond legal and financial risks, fundamental questions remain about how the scheme will operate in practice.

Recyclers would need to distinguish between glass originally placed on the Welsh market and glass from elsewhere in the UK, something the industry says is extremely difficult to achieve, as well as whether it was part of a beverage or other glass container.

There is currently no credible mechanism to track glass in the way the proposals would require.

Jenni Richards explained: “Glass is collected, sorted and reprocessed in mixed streams.

“Trying to attribute origin at that level is not feasible and introduces cost, complexity and a high risk of error.”

Loss of circular economy incentives

The inclusion of glass in a DRS risks undermining existing circular economy mechanisms that currently support high-quality recycling outcomes.

The Packaging Recovery Note (PRN) system currently incentivises the remelting of glass into new containers delivering strong environmental benefits compared with lower value uses such as aggregate.

However, British Glass is concerned that removing those incentives without a clear replacement risks pushing material down the waste hierarchy rather than up it.

The industry warns that including glass in a DRS will not make reuse easier - instead it could make it harder.

By diverting material and investment away from reuse infrastructure and removing existing incentives, the policy risks delaying progress towards a viable reuse system in Wales.

At the same time, reusable packaging incentives tied to reduced packaging EPR fees would also fall away from October 2027, in contradiction to the stated ambition of introducing a glass reuse system in Wales.

Without the certainty that the Reuse Regulations would bring around financial incentives, there would be no financial benefit for introducing reuse in Wales.

Additional uncertainty surrounds the Welsh Government’s introduction of “reuse-capable” packaging targets within its 2026 regulations, until a further UKIMA exclusion is granted and the Reuse Regulations are laid.

These targets have not yet received UKIMA approval and could therefore apply only to Welsh producers, meaning any resulting obligations would currently fall disproportionately on domestic firms.

Jenni Richards concluded: “The way the targets are framed is problematic.

“If you increase material use without ensuring reuse actually happens, you risk making the system less efficient.

“The Regulations focus on packaging that is capable of reuse, not packaging that is actually reused.

“Without infrastructure, that distinction matters enormously.”