DRS Scope: Bottles and Cans to Three Litres, With Wine, Spirits and Milk Outside

The mandated scope joins two axes: the container - single-use plastic bottles and single-use metal containers (cans and bottles) - and the drink, up to a capacity of three litres. Outside the mandate stand defined categories the regulation leaves to member-state choice or other collection routes: wine and spirits in their typical containers, milk and the dairy family in theirs, and containers for specified medical and special-nutrition purposes. Refillable containers are not DRS scope at all - they live in reuse systems, and the same physical bottle can be in either regime depending on the system it circulates in.

National systems may extend scope beyond the mandated floor (several existing systems include more drinks categories), so the operative scope is always per-market. This guide maps the floor and the borderlines.

Four borderlines recur. Drink classification: juices, nectars, soft drinks, waters, beers and energy drinks sit squarely in; mixed and novel categories (ready-to-drink coffee, kombucha, hard seltzers, plant drinks on the milk border) classify by the national rules' definitions, and the classification - not the marketing name - decides. Container material: plastic-coated or composite constructions (a can with plastic elements, a bottle with a metal closure) test against the container's main material and the registration's determination. Size: the three-litre line cuts through party formats and water gallons, which fall outside while their smaller siblings are in. And multipacks: the unit container is scoped; the multipack's outer is EPR packaging, not DRS - with the consumer-information consequence the marking guide covered.

Single-use glass drinks bottles are outside the Article 50 mandate - the system's material logic and breakage economics differ - but several member states run glass within their deposit or return traditions (refillable glass above all), and glass collection targets apply through the general framework. Producers in glass should therefore read the mandate's silence correctly: no EU-wide one-way glass deposit is imposed, national pictures vary and can change, and the refillable-glass systems of the beer and water sectors continue under reuse rules. The scope map in the launch checklist is per market for glass as for everything else.

For any borderline product, the scope question is settled in practice at registration: the system operator's determination, against the national rules, recorded against the container's registration. Producers should seek the determination early for the genuinely borderline (novel drinks, hybrid containers, size-edge formats), file it, and design the marking and deposit handling to it. A scope argument improvised after launch - with stock marked and deposits uncharged - is the expensive version of the same conversation. The checklist guide builds the determination step into the launch sequence, before artwork.

The portfolio habit to build: a scope register - per SKU, per market, the determination (in, out, borderline-determined), its basis and its review date - maintained with the registration data it feeds. Scope questions recur (line extensions, recipe changes moving a drink across a category line, a national extension pulling a new family in), and the register converts each recurrence from a research project into a lookup plus a delta. In a regulation whose obligations so often turn on classification, the habit of recording determinations is worth more than any single determination.

A drinks portfolio sorted against the floor: waters, colas and juices in PET to 1.5 litres - in scope, every market. The 3-litre sharing format - in, exactly at the line; its 4-litre sibling - out, with the labelling and shelf conversation that follows. Beer in cans - in; the same brand's wine line in glass and its spirits - outside the mandate, tracked per market for national choices. Milk-based drinks - outside the mandate, with two destination markets consulting on inclusion, diarised in the scope register. Ready-to-drink coffee in a plastic-coated cup format - borderline, determination requested. Six decisions, three categories, one register: scope work is portfolio hygiene, done once and maintained.