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Singapore: a deposit mark from 1 October 2026, and no general recycling label
Singapore does not require a general on-pack recycling or sorting label. What it does require, from 1 October 2026, is the prescribed Beverage Container Return Scheme deposit mark and a barcode on covered plastic and metal drinks containers. Mandatory Packaging Reporting under the Resource Sustainability Act is an off-pack data duty. The two instruments are easy to collapse and are not the same.
S$0.10Prescribed or scheme wording — not production artwork
Deposit mark + barcodePrescribed or scheme wording — not production artwork
Wording lock-ups and sourced marks are for identification and commentary. They are not production artwork.
The question this report answers
Part 4B of the Resource Sustainability Act 2019, inserted by the 2023 amendment, creates the Beverage Container Return Scheme. The scheme operator is Beverage Container Return Scheme Ltd, licensed by the National Environment Agency. The consumer-facing brand is Return Right. The labelling instrument is S 123/2026, the Resource Sustainability (Beverage Container Return Scheme) Regulations 2026. Regulation 7 sets the prescribed date under section 23P(1) at 1 October 2026. From that date, supplying or offering to supply a regulated beverage in Singapore without the deposit mark and a barcode is an offence.
NEA ran a transition from 1 April to 30 September 2026 during which marked containers entered the market and unmarked stock was cleared; unmarked packs are not refundable. This report treats 1 October 2026 as the artwork backstop, not 1 April. Completing Mandatory Packaging Reporting does not authorise a recycling pictogram, and omitting a recycling logo is not an MPR offence. There is no Singapore Triman, no ARL mandate, and no How2Recycle statute.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| BCRS deposit mark and barcode | mandatory | From 1 October 2026 on regulated beverage products. Mark is the Schedule drawing in two colour schemes. Deposit S$0.10. |
| Transition (1 April–30 September 2026) | mixed | Scheme operating; unmarked stock still on shelf and not refundable. Not a licence to skip the 1 October backstop. |
| Mandatory Packaging Reporting | mandatory; off-pack | Producers above S$10 million annual turnover report packaging data and 3R plans. No recycling pictogram. |
| General recycling / sorting label | none | No Singapore Triman, no ARL mandate, no How2Recycle statute. |
What section 23P and S 123/2026 put on the container
Section 23P, as described in the Ministry of Sustainability and the Environment’s second-reading speech of 21 March 2023, requires two things on the container: a deposit mark so that customers can identify covered products, and a barcode so that return points can accept them. S 123/2026 regulation 6 prescribes “the mark in the Schedule” in two colour schemes as that deposit mark. This library does not reconstruct the Schedule drawing. Production files are the operator’s current download, not a photograph and not this lock-up. The Act and S 123/2026 prescribe the Schedule drawing, not a millimetre table. BCRS’s published FAQ (scheme operator, licensed by NEA) recommends 11.7 × 11 mm, minimum 9.7 × 9 mm, placed near the barcode with a maximum 10 mm gap and 2 mm clearance. That is operator specification, labelled as such.
In-scope packs are pre-packaged beverages in plastic or metal, either alone or in combination with each other but not with any other material (reg. 3), of 150 ml to 3,000 ml inclusive (reg. 4). Regulation 5 excludes special-medical-purpose liquids labelled for use under medical supervision; decorative or flavour liquids; flavouring agents; meat, yeast or vegetable extracts and soups; semi-liquid or viscous foods; medicinal products; and health products. Glass, cartons, and pouches that combine plastic with a third material are outside that definition. Regulation 9 sets the deposit at $0.10 for each beverage product affixed with a deposit mark. Section 23Q, as characterised in the same speech, treats the deposit as not part of the price of the beverage, the container, or the use of the container, and therefore not subject to GST. GST regulations amended for 1 April 2026 allow (but do not require) the deposit to appear as a separate, un-taxed line on an invoice. A damaged mark or unreadable barcode is a stated ground for refusing a refund. There is no digital substitute. The mark and barcode are on the container.
The bound parties are producers of beverage products as defined in RSA s. 23M, and any person who supplies or offers to supply a regulated beverage in Singapore from 1 October 2026, including retailers. Regulation 8 sets the chain-of-supply circumstances in which the mark need not yet be affixed — essentially, a supply to the next participant who will supply onward to the specified end supplier, and the specified end supply itself as defined. Those are not a general printer’s opt-out. From 1 October 2026, NEA and BCRS state that it is an offence for any person, including supermarket operators, to supply or offer to supply a regulated beverage whose container lacks the mark and a barcode. Affixation of the mark on a non-beverage container is restricted by the Act.
Reporting is not labelling
Mandatory Packaging Reporting sits in a different part of the same Act. Producers of packaged products — brand owners, manufacturers, importers, and retailers such as supermarkets — with annual turnover of more than S$10 million submit packaging data (weight by material and form) and 3R plans to NEA. The 2026 window for 2025 data ran 1 January to 31 March. Nothing in the MPR framework, as published by NEA, requires a recycling pictogram on the pack. Completing a 3R plan does not authorise a “recyclable” claim. The MPR turnover threshold (S$10 million, all revenue) is not the BCRS producer test. They are different thresholds in different parts of the Act.
A pan-Asian drinks SKU that carries a Malaysian, Thai or Australian deposit or recycling mark in lieu of the Schedule drawing does not discharge section 23P. Singapore’s mark is prescribed. Dating the duty to 1 April 2026 and treating transition stock as a standing exemption is the second collapse this report is written to prevent. SSO HTML of Part 4B did not yield a clean section dump on this pass; s. 23P is characterised from the second-reading speech and from S 123/2026 as retrieved. Millimetre figures are BCRS FAQ, not the Act, and are labelled as such. The Schedule drawing is not reproduced.
Primary sources and verification
Singapore. Resource Sustainability (Beverage Container Return Scheme) Regulations 2026, S 123/2026. Open source
Singapore. Resource Sustainability Act 2019, Part 4B (deposit mark, barcode, deposit). Open source
MSE. Second-reading speech on the Resource Sustainability (Amendment) Bill, 21 March 2023 (s. 23P characterisation). Open source
NEA. Beverage Container Return Scheme (scope, transition, Return Right). Open source
NEA. Mandatory Packaging Reporting. Open source
BCRS Ltd. Producer FAQ: 1 October 2026 offence; recommended 11.7 × 11 mm mark (operator spec). Open source
SSO HTML of Part 4B did not yield a clean section dump on this pass; s. 23P is characterised from the second-reading speech and from S 123/2026 as retrieved. Millimetre figures are BCRS FAQ, not the Act, and are labelled as such. The Schedule drawing is not reproduced. Last verified: 23 August 2026.