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Deposit-refund scheme coming in 2025

by Alicja Szyrner

20 March 2024

What is it?

In the deposit-refund scheme (also known as a container-deposit system, deposit-return system, or bottle bill), a monetary deposit is collected on beverages at the point of sale and refunded upon return of the container. It is designed to promote separate waste collection. The deposit-refund scheme will go live in Poland on 1 January 2025.

The Deposit-Refund Act transposes the European directive which obliges Member States to ensure the separate collection of packaging waste left from single-use plastic beverage bottles, with a capacity of up to three litres, including caps and lids – at the level of 77% in 2025 and 90% in 2029. The deposit-refund scheme will be nation-wide and publicly available.

The deposit-refund scheme will cover:

single-use plastic bottles up to 3 litres;
reusable glass bottles up to 1.5 litres;
metal cans up to 1 litre.

A deposit will be added to the above-listed containers in the amount set in an official regulation. To recover the deposit in a shop, there will be no need to show a cash register receipt confirming the purchase in that shop. The legislation does not provide for a refund in another form, e.g. a voucher for future purchases in the respective shop or chain shop. However, it does not rule out automatic collection points. Any uncollected deposit will be spent on financing the scheme operations.

Deposit-refund scheme – new obligations for businesses

The deposit-refund scheme will impose a number of obligations on manufacturers and importers as well as retailers and wholesalers. Shops larger than 200 square meters will be obliged to collect empty containers. Smaller outlets may join the scheme voluntarily.

Marketers of beverages in plastic containers will have to:

collect containers to achieve the statutory targets – or else they must pay a product fee on every kilogram of raw materials left on the market;
collect containers from retail and wholesale outlets;
keep records and compile reports;
account for the deposits with retail and wholesale outlets as well as other collection points participating in the scheme, especially with deposit payment outlets;
finance the collection of waste and packaging waste by operators of retail and wholesale outlets or other waste collection points participating in the scheme.

In the context of these obligations, companies that market beverages in containers as well as those that sell them should start preparing for the introduction of the deposit-refund scheme.

Contact

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Alicja Szyrner

Attorney at law (Poland)

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