Opting out
Who does not have to host a return point
Exemption from hosting a return point is a real, published pathway — and the criteria were extended in June 2026. The catch is that you still have to charge the deposit.
The criteria
Five routes to exemption
One automatic route and four application-based routes. All applications are approved by the scheme administrator.
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Urban store under 100m²
Retailers with a retail footprint of less than 100m² in an urban area are automatically exempt from operating a return point. No application needed.
No action required
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Urban 100m²–199m² or rural under 200m²
Following the June 2026 extension agreed with regulators, these stores may apply for a size-based exemption. Approval is at the discretion of Exchange for Change.
Apply for exemption
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Proximity to an existing return point
Where a suitable return point is already within close proximity, an exemption may be granted. The regulations set out how proximity is measured.
Apply for exemption
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Heritage or listed building restrictions
Stores in listed buildings, conservation areas or heritage properties that cannot make the required physical alterations may be eligible.
Apply for exemption
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Site access or lack of utilities
Sites where vehicle access, floor loading or the absence of suitable power, water or drainage makes installation impracticable may be eligible.
Apply for exemption
The size line
There is a presumption above 200m²
Groceries retailers with a retail space above 200m² may apply for an exemption based on size, but the criteria uphold a presumption against granting it. If you are a large store, plan on hosting a return point.
Discretionary grounds — proximity, heritage, site access, lack of utilities — remain available above the line, but they need to be evidenced.
How to apply
What to do, and when
The scheme administrator approves exemptions and publishes the full application process. The process is intended to be light touch. Detailed eligibility criteria and the application route were scheduled for release in Q3 2026.
- 1
Measure your sales area
Get the figure right — it is the threshold that determines whether you are automatic, eligible to apply, or presumed against. Urban versus rural classification also matters.
- 2
Check proximity first
If there is already a suitable return point close by, that is the strongest and simplest ground for an application. Exemption decisions are also contingent on sufficient local provision of return points.
- 3
Gather evidence for discretionary grounds
Listed building consent, conservation area status, site access constraints, vehicle movements, and confirmation that power, water or drainage is unavailable at the intended position.
- 4
Apply through the official channel
Applications are made to the scheme administrator, not through this site. Register with them and follow their published process.
Exemption approval is at the discretion of the scheme administrator, and the extension of criteria is contingent on there being sufficient local provision of return points. Build your business case on the assumption that you will be a return point, and treat an exemption as upside. For small stores, that upside is often the £6,000 grant.
Not sure where you fall?
The exemption checker takes your sales area and location type and tells you which route applies — automatically, by application, or not at all.