Deposit-refund schemes and the PPWR – how is the regulation changing the approach to returnable packaging?

In October 2025, a deposit-refund scheme was launched in Poland for selected single-use packaging – PET bottles up to 3 litres, glass bottles up to 1.5 litres and aluminium cans up to 1 litre. It is no coincidence that the deposit-refund scheme has been launched at this particular time – its introduction is directly linked to the requirements of the PPWR Regulation, which imposes an obligation on all EU Member States to achieve ambitious targets for the collection of beverage packaging. For beverage producers and distributors, the PPWR fundamentally changes the rules of the game when it comes to returnable packaging. For food manufacturers, the new regulations also include a number of requirements concerning packaging that comes into contact with food, recyclability and the content of recycled materials.

What the PPWR says about deposit-refund schemes – Member States’ obligations

Article 50 of the PPWR imposes a specific, measurable obligation on all EU Member States: by 1 January 2029, they must ensure the separate collection of at least 90 per cent by weight of single-use plastic beverage bottles and metal beverage containers with a capacity of up to 3 litres. To this end, they must establish deposit return schemes (DRS) with deposits collected at the point of sale.

This requirement leaves Member States no choice as to the instrument to be used – a deposit return scheme (DRS) is explicitly identified as the mechanism for achieving the target. By launching its deposit-return system in October 2025, Poland is thereby anticipating the obligations under the PPWR and building the infrastructure necessary to achieve the required collection rates ahead of the EU deadline.

The PPWR allows Member States to use the harmonised EU colour-coded label for packaging covered by the deposit-return system, although this is not mandatory. At the same time, no Member State may prohibit the affixing of DRS labels from other countries on products available on its market – which is of particular importance to producers selling the same products in several EU countries simultaneously.

The impact of the deposit-refund scheme on beverage manufacturers and distributors

For beverage manufacturers and distributors, the introduction of a deposit-refund scheme involves much more than simply changing the label on a bottle. It alters financial, logistical and operational models throughout the supply chain.

What are the obligations of a beverage manufacturer under the deposit-refund scheme? A manufacturer placing beverages in packaging covered by the scheme on the market must register with the deposit-refund scheme, pay deposit fees for each item of packaging placed on the market, and mark the packaging in accordance with the scheme’s requirements. The deposit is collected from the consumer at the point of sale and refunded when the empty packaging is returned – the producer finances the scheme by paying the relevant fees to the deposit-refund scheme operator.

What about packaging covered by the deposit-refund scheme and the PPWR’s requirements regarding minimisation and recyclability? Packaging covered by the deposit-refund scheme is treated in a specific manner under the PPWR. Exemptions apply to transport packaging (with the exception of e-commerce), packaging covered by the deposit-return scheme, and packaging for medicinal products and medical devices used exclusively by professional end-users. This means that some of the general requirements of the PPWR – such as those concerning maximum void space – do not apply to packaging covered by the DRS. However, this does not exempt manufacturers from the requirements regarding recyclability and the content of recycled materials, which apply to all packaging.

How is the logistics of returns changing? A deposit-refund system requires the establishment of a reverse logistics chain – from the consumer, via the point of sale, to the system operator and on to the recycling facility. For distributors and retail chains, this means an obligation to accept empty packaging and to operate reverse vending machines or collection points. For manufacturers, it means the need to design packaging so that it can be recognised by sorting systems and reverse vending machines.

The deposit-refund scheme and the PPWR’s packaging waste reduction targets

The deposit-refund scheme is one of the tools for achieving the PPWR’s broader environmental objectives regarding the reduction of packaging waste. The Regulation sets ambitious quantitative targets: packaging waste must be reduced by 5% by 2030, by 10% by 2035 and by 15% by 2040 compared with 2018 levels.

The high collection rates for beverage packaging achieved through deposit-refund schemes translate directly into the availability of high-quality recyclates – recycled materials that can be reused in the production of new packaging. This, in turn, supports compliance with the PPWR’s requirements regarding the minimum content of recycled materials in plastic packaging, which will increase gradually up to 2040.

In this sense, the deposit-refund system and the PPWR’s requirements regarding recyclability and PCR content form a closed loop: high collection rates provide the raw material, the raw material enables compliance with recyclate requirements, and the recyclate requirements incentivise the maintenance of high collection rates.

The manufacturer’s perspective – how exactly does the PPWR change the approach to returnable packaging?

For companies that have hitherto treated packaging as disposable and have not been involved in return schemes, the PPWR sets a new strategic direction. Packaging ceases to be a unit cost and becomes part of the material circulation system – with the manufacturer bearing full responsibility for its entire life cycle.

Specific actions that manufacturers and distributors should take in relation to the deposit-refund system and the PPWR requirements:

• Registration with the deposit-refund system – verifying which of the packaging placed on the market is subject to the deposit requirement in Poland and in other EU countries to which products are exported
• Designing packaging for the system – packaging covered by the DRS must be identifiable by reverse vending machines and sorting systems; technical requirements should be taken into account as early as the design or redesign stage
• Analysis of the impact on product price – the deposit is collected from the consumer and refunded upon return of the packaging, but involves operational costs for the system, which are settled between the producer and the operator
• Monitoring of requirements in export countries – deposit-refund schemes operate in various EU countries in different configurations; producers exporting to multiple markets must keep track of the requirements of each market and ensure that packaging complies with local DRS schemes

Implementing these measures requires a combination of knowledge of regulations, packaging design and the organisation of processes within the company.