The deposit-refund scheme and the PPWR – how do EU regulations affect the collection of packaging?

The PPWR deposit-refund scheme is a topic that needs to be understood from two perspectives. Poland already has its own deposit-refund scheme for selected beverage packaging, whilst the PPWR – the EU Packaging Regulation – sets out the overarching framework for the collection, recycling and reuse of packaging across the European Union. The Polish deposit-refund scheme has been in operation since 1 October 2025, and the Ministry of Climate and Environment states that it covers packaging marked with a deposit symbol, for which consumers can reclaim the deposit upon returning it to a collection point.

The PPWR does not replace the Polish deposit scheme, but it does influence the way in which collection schemes are to operate in Member States. The European Commission states that by 2029, EU countries must achieve a separate collection rate of at least 90% for single-use plastic and metal beverage packaging, and if they cannot achieve this by other means, they must implement deposit-refund schemes.

The key takeaway for businesses is simple: the Polish deposit-refund scheme is an operational tool, whilst the PPWR is a broader EU framework that will strengthen requirements regarding collection, labelling, data, recycling and producer responsibility.

What is the deposit scheme in Poland?

A deposit-refund scheme is a mechanism whereby a consumer pays an additional amount when purchasing a drink in specific packaging, and then recovers that amount upon returning the empty packaging. The Ministry of Climate and Environment describes the deposit-refund scheme as a mechanism that promotes the recycling and reuse of packaging.

In Poland, the deposit-refund scheme covers three main groups of beverage packaging:

– single-use plastic bottles, i.e. PET, with a capacity of up to 3 litres,
– metal tins with a capacity of up to 1 litre,
– reusable glass bottles with a capacity of up to 1.5 litres.

The deposit is 50 groszy for PET bottles and metal cans, and 1 zł for reusable glass bottles. The deposit is charged when you buy a drink, and you can get a refund without having to show a receipt, provided the container is covered by the scheme and is correctly labelled.

The Polish deposit-refund scheme is a practical mechanism for collecting beverage packaging, designed to increase the rate at which it is returned to circulation and reduce material waste.

What is DRS in PPWR?

DRS, or the deposit return scheme, is a deposit-refund system provided for in EU legislation as a means of increasing the selective collection of packaging. Under the PPWR, the DRS is one of the mechanisms designed to achieve high levels of collection of beverage packaging.

The European Commission points out that the PPWR supports deposit-return schemes, as they help to increase collection rates, improve the quality of recycling and reduce littering in public spaces. By 2029, Member States must ensure at least 90% of separate collection of single-use plastic and metal beverage packaging.

The DRS at PPWR is not just a bottle return machine. It is part of the EU’s packaging management system, which is designed to ensure a high-quality supply of raw materials for recycling.

The deposit-refund scheme in Poland versus the PPWR – the key difference

The most significant difference lies in the level of regulation. The Polish deposit scheme sets out specific rules governing the domestic market: which types of packaging are covered by the scheme, who collects the deposit, how the refund process works, which types of packaging must be labelled, and how collection points are organised.

The PPWR, on the other hand, sets out general EU requirements for Member States. It sets a target of 90% for the selective collection of specific beverage packaging by 2029, supports deposit-refund schemes and requires such schemes to meet certain minimum conditions, such as clear labelling and an appropriate deposit amount.

Area	The Polish deposit system	PPWR
Regulation level	National law	EU Regulation
Main function	The organisation of deposit collection and refunds in Poland	Harmonisation of waste collection and recycling across the EU
Key date	Starting on 1 October 2025.	Target 90% for selective collection by 2029.
Scope	PET bottles up to 3 litres, tins up to 1 litre, reusable glass containers up to 1.5 litres	Single-use plastic and metal drinks containers
Main responsibility	Manufacturers, importers, brand owners, shops and operators	Member States and entities participating in the packaging scheme
Character	Operational refund system	An EU-wide regulatory framework

Does the PPWR change the Polish bail system?

The PPWR does not abolish the Polish deposit-refund scheme nor does it replace its national rules. It may, however, influence its further adaptation, as EU legislation sets out a common target for separate collection and minimum requirements for deposit-refund schemes.

In practice, this means that the Polish system will have to be assessed not only in the light of national legislation, but also in terms of its effectiveness in achieving EU objectives. If the system fails to ensure adequate collection rates, there will be pressure for organisational, operational and accounting changes.

The Ministry of Climate and Environment reported that between October and November 2025, deposits were refunded for 500,000 containers, and from 1 January 2026 producers participating in the scheme were only permitted to place drinks on the market in packaging bearing the deposit mark. This shows that the scheme was implemented in stages and required adjustments on the part of both producers and retailers.

What are the responsibilities of drinks manufacturers?

The greatest responsibility lies with businesses placing beverages in packaging covered by the scheme on the market. The Ministry points out that the scheme comprises manufacturers, importers, brand owners and shops where products in packaging covered by the deposit scheme are sold. Those placing beverages on the market must affix labelling to the packaging indicating that it is part of the scheme and stating the amount of the deposit.

For a drinks manufacturer, this means that several areas need to be sorted out:

– identifying packaging covered by the scheme,
– signing a contract with the system operator,
– labelling packaging with a deposit mark,
– to provide data on the number and weight of packages,
– monitoring the flow of deposits,
– monitoring collection levels,
– the links between the deposit-refund scheme and the BDO and packaging obligations,
– adapting processes to meet PPWR requirements regarding collection, recycling and data.

If a company manufactures, imports or places beverages on the market, it should combine its analysis of the deposit scheme with PPWR audit and a broader assessment of packaging obligations.

The deposit scheme and BDO – why are these topics linked?

The deposit-refund scheme and the BDO are not the same thing, but in practice they cover the same packaging streams. The deposit-refund scheme organises the return of selected beverage packaging, whilst the BDO relates to record-keeping, reporting and environmental obligations concerning, amongst other things, packaging and waste.

Businesses should check whether the data used in the deposit scheme is consistent with the data reported to the BDO. This applies in particular to manufacturers, importers, wholesalers, retailers and companies operating across several sales channels.

The EKOPRO guide is a useful supplementary resource BDO and the deposit-refund scheme – the obligations of manufacturers, wholesalers and retailers. When carrying out a more detailed analysis of the register, it is also worth checking BDO packaging, particularly if the company markets packaged products or operates a multi-channel sales strategy.

What does PPWR mean for shops and collection points?

For shops, the deposit scheme involves not only accepting empty containers, but also organising space, procedures and accounting. The Ministry states that collection points include, amongst others, all shops larger than 200 m² that sell drinks in containers covered by the scheme, shops smaller than 200 m² selling drinks in reusable glass bottles, other shops that have joined the scheme, deposit-return machines and other collection points.

In practice, a point of sale must address a number of operational issues:

– where to take packaging,
– whether collection will be manual, automatic or a combination of both,
– how to process a deposit refund,
– how to store empty packaging,
– how to separate packaging covered by the scheme from other packaging,
– how to train staff,
– how to prevent errors relating to labelling, barcodes and damaged packaging,
– how to ensure that the collection point meets standards of order, hygiene and logistics.

That is precisely why the deposit scheme is not only a legal change, but also an organisational change within shops, factories, warehouses and distribution networks.

PPWR and the quality of packaging collection

The PPWR emphasises the importance of collection quality. It is not simply a matter of collecting as much packaging as possible, but of ensuring that the recovered material is suitable for recycling. The deposit-refund scheme has an advantage over traditional municipal collection, as it allows for the recovery of relatively clean and more easily identifiable material.

For drinks manufacturers, this is of strategic importance. PET plastic bottles and metal cans collected through a deposit-refund scheme can form a valuable stream of secondary raw materials. This ties in with other requirements of the PPWR, particularly those concerning recycled content, the design of packaging for recycling, and the reduction of material waste.

PPWR regards collection as part of the entire life cycle of packaging: from design, through to sale, and on to recycling and the reuse of raw materials.

The deposit-refund scheme and the circular economy

The deposit-refund scheme is a practical tool for the circular economy. Packaging does not end up in a mixed waste bin or in a random waste stream, but is returned to a controlled collection system.

From a circular economy perspective, the three most important outcomes are:

– a higher return rate for packaging,
– better quality raw material for recycling,
– the possibility of reusing reusable packaging, particularly glass.

Companies should therefore combine a deposit scheme with a broader materials strategy. It is not enough simply to ask whether the packaging is subject to a deposit. It is necessary to check whether it is recyclable, whether it contains recycled material, whether it is suitable for reuse, whether it is correctly labelled, and whether the information about it is consistent with the environmental documentation.

A good point of reference is GOZ package, which allows us to view packaging not only in terms of regulatory obligations, but also in terms of material efficiency and planning for change within the company.

The Polish deposit-refund scheme and the PPWR – where is the synergy?

The greatest synergy lies in the fact that the Polish deposit scheme can help to achieve the objectives of the PPWR. If the scheme proves effective, it could increase the level of separate collection, improve the quality of raw materials and make it easier for beverage producers to meet packaging requirements.

The common areas are:

– the selective collection of beverage packaging,
– clear labelling on packaging,
– the contribution of manufacturers and importers to the financing of the scheme,
– operators’ liability,
– creating a clean stream of raw materials for recycling,
– reducing the amount of packaging discarded in the environment,
– linking waste collection to recycling and the circular economy.

The Ministry points out that the costs of implementing and maintaining the deposit-refund scheme in Poland are borne by businesses placing beverages in packaging covered by the scheme onto the market, such as manufacturers and importers.

Where do the differences between the deposit system and the PPWR lie?

The differences are just as important as the similarities. The Polish deposit scheme is a specific mechanism for certain types of beverage packaging. The PPWR is a broader regulation covering all packaging and packaging waste, not just beverages.

Key differences:

– PPWR covers, more broadly, design, recyclability, recycled content, labelling and the minimisation of packaging,
– the Polish deposit-refund scheme focuses on beverage containers,
– the Polish scheme covers reusable glass bottles of up to 1.5 litres,
– The PPWR sets an EU target of 90% for the selective collection of certain plastic and metal beverage packaging by 2029,
– the national scheme requires the ongoing management of collection points, deposits, signage and operators,
– The PPWR will contribute to the further harmonisation and evaluation of the effectiveness of systems in EU Member States.

The deposit-refund scheme is one tool. The PPWR provides an overview of the EU’s entire packaging policy.

What should a drinks manufacturer do?

A drinks manufacturer should treat the deposit-refund scheme and the PPWR as a single compliance project, rather than two separate obligations. First, they need to check which products are covered by the scheme, and then organise labelling, contracts, packaging data and accounting.

Checklist for beverage manufacturers

1. Does all packaging covered by the scheme bear the correct deposit mark?
2. Does the company have a contract with the relevant system operator?
3. Are the figures for weight and the number of packages consistent across sales, BDO and internal reporting?
4. Is the plant able to separate returnable packaging from other waste streams?
5. Are the labels, barcodes and markings legible to the return system?
6. Does the company monitor collection rates and the risk of a product levy?
7. Has the packaging been assessed for recyclability and compliance with PPWR requirements?
8. Is the planned new packaging being designed with 2029, 2030 and subsequent stages of the PPWR in mind?

For companies that manufacture, import or package drinks, it is worth combining environmental audit including an analysis of the deposit scheme, BDO and PPWR.

What should a shop or wholesaler do?

The shop and the wholesaler should focus on running the collection point, correctly collecting and refunding deposits, organising the site and training staff. In a decentralised system, it is particularly important that staff understand the difference between packaging subject to a deposit and similar packaging that does not bear the system’s logo.

Checklist for retail

1. Do staff know which packaging items are returnable?
2. Does the shop have space to store empty packaging?
3. Does the returns procedure work without a receipt?
4. Does the till system calculate the deposit correctly?
5. Does the shop distinguish between packaging bearing the deposit mark and stock without the mark?
6. Is there a procedure for damaged packaging?
7. Do the contracts with the operator set out the arrangements for the financing and collection of packaging?
8. Does the collection point disrupt the shop’s operations and delivery logistics?

The EKOPRO practical guide may be helpful in this area The deposit system in practice: how to account for deposits in-store and on invoices.

How do you prepare a site for the collection of packaging?

In a production facility, distribution centre or warehouse, a deposit-refund system requires the flow of packaging to be organised. The issue is not just consumer returns, but also the handling of packaging throughout the supply chain: production, warehousing, dispatch, returns, complaints and waste.

The company should check:

– where the streams of packaging covered by the scheme originate,
– who is responsible for the packaging data,
– how batches of products are labelled,
– how can one tell the difference between packaging covered by the scheme and other packaging,
– Are staff familiar with the collection and storage procedures,
– whether the BDO documentation is consistent with the sales data,
– does the ERP/WMS system allow you to track packages,
– Does the plant have a plan to comply with the PPWR requirements?.

If a company needs external support to organise these processes, a good solution is comprehensive environmental consulting for companies and ongoing environmental services.

The deposit scheme, PPWR and exports

Companies selling beverages or packaged goods outside Poland should not assume that the Polish deposit-refund scheme covers everything. Each EU country may have its own EPR mechanisms, deposit-refund schemes, registration requirements and producer responsibility organisations.

Example: a company exporting to Germany must analyse not only the PPWR, but also the VerpackG and LUCID. In this regard, it is worth making use of compliance with packaging obligations in EU markets and LUCID audit.

This is particularly important for beverage manufacturers, importers, marketplaces, wholesalers and e-commerce companies that ship products to consumers in several countries.

The most common mistakes made by companies

The first mistake is to treat PPWR and the deposit scheme as two separate issues. In practice, both relate to the same packaging, data and processes.

The second mistake is to focus exclusively on consumers. A deposit-refund scheme requires changes to production, trade, warehousing, finance, documentation and reporting.

The third mistake is a lack of consistent data. If a company counts packages one way when selling, another way in its BDO records, and yet another way in its settlements with the operator, the risk of errors increases.

The fourth mistake is the assumption that the deposit-refund scheme fulfils all the obligations under the PPWR. It does not. The PPWR also covers recyclability, recycled content, restrictions on certain types of packaging, labelling and minimisation.

The fifth mistake is analysing new packaging too late. Packaging designed today should also be assessed in the light of the EU’s requirements for 2029 and 2030.

FAQ - Frequently asked questions

Is PPWR introducing a deposit scheme in Poland?

Not directly. Poland has introduced its own deposit scheme, which has been in operation since 1 October 2025. The PPWR, on the other hand, sets out the EU’s targets and requirements for collection schemes and deposit-refund schemes.

What types of packaging are covered by the Polish deposit scheme?

The Polish scheme covers single-use plastic bottles of up to 3 litres, metal cans of up to 1 litre and reusable glass bottles of up to 1.5 litres.

What is the purpose of the collection as set out in the PPWR?

The European Commission states that Member States must achieve a target of at least 90% for the selective collection of single-use plastic and metal beverage packaging by 2029.

Can you get your deposit back without a receipt?

Yes. The Ministry of Climate and Environment states that the scheme does not require a receipt, and consumers can return packaging to a collection point without showing proof of purchase, provided the packaging is covered by the scheme.

Does the deposit scheme replace the BDO?

No. The deposit scheme does not replace the BDO. The company must still analyse its registration, record-keeping and reporting obligations relating to packaging and waste.

Does a drinks manufacturer have to comply with both the deposit scheme and the PPWR?

Yes. A drinks manufacturer should analyse the national obligations under the deposit-refund scheme and the EU’s PPWR requirements regarding collection, recyclability, labelling, data and packaging strategy.

Adapt the collection systems at the plant

The deposit scheme and the PPWR are moving in the same direction: beverage packaging is to be returned to a controlled circulation system, and companies must be able to demonstrate what they place on the market, how much they collect and how they manage the packaging stream.

If your company produces drinks, imports products, or runs a shop, a wholesale business, a warehouse or a facility with its own collection system, check whether your processes are compliant with national and EU requirements. Make use of PPWR audit, environmental audit or find out our full range of services for businesses. You can also go to the tab Contact Eko-Pro and describe how packaging is collected at your site.