Deposit Refund System: which deposits will be non-taxable under the new rules, and which will remain subject to VAT?

With the launch of the first deposit return systems in October 2025, new rules will come into force for beverage containers included in the system and marked with the “DEPOSIT” on a label. However, many beverage containers will remain on the market—either temporarily or permanently—that are not included in the deposit system. This will significantly impact VAT treatment and may lead to confusion among accounting staff, system participants, and consumers alike.

Below is a summary of the key changes to the deposit return system and their VAT implications.

Deposit Refund System 2025 – containers covered and not covered

Although the new regulations take effect on 1 October 2025, this does not mean that all beverages will be sold with a deposit from that day onwards. Containers placed on the market before the producer joins the system (i.e. before signing a contract with the operator and applying the “DEPOSIT” label) will not be subject to the new rules.

As a result, identical beverages may appear on store shelves both with and without the deposit label. Only containers marked with the “DEPOSIT” symbol will be subject to the new regime, including the obligation to collect a VAT-exempt deposit.

VAT treatment of deposits

Deposits under the deposit refund system – no VAT

The new rules specify that:

• Deposits collected upon the sale of beverages in containers covered by the deposit system will not be subject to VAT—both at retail and wholesale stages.
• The refund of the deposit at collection points (such as stores or dedicated return stations) will also not be subject to VAT.
• The full deposit amount indicated on the label must be refunded to the consumer, without charging any VAT.

Settlements between stores and the system operator

Stores:

• Transfer collected deposits to the system operator in accordance with their agreement.
• Receive funds to cover deposit refunds if they operate a return point.
• Do not issue VAT invoices for deposit settlements, as these funds are outside the scope of VAT.

The operator collecting the containers is responsible for refunding the deposit to the entity managing the return point.

Deposits outside the system – current VAT rules still apply

Not all deposits will be covered by the new system. 

Examples include:

• Reusable glass bottles under private deposit systems (e.g. certain breweries),
• Transport packaging such as pallets or crates.

For these cases, the current VAT rules remain applicable, meaning:

• If the packaging is not returned within 60 days (or another contractual period), VAT must be charged on the retained deposit.
• This obligation applies broadly, not only to participants in the new deposit system.

Summary – VAT and the 2025 deposit system

The introduction of a national deposit return scheme represents a major regulatory shift. It requires businesses to adapt their labelling, deposit collection, and settlement procedures. While the VAT exemption for deposits under the new system simplifies accounting, the parallel operation of the “old” and “new” regimes may initially lead to confusion—both in bookkeeping and at the point of sale.

Businesses should prepare in advance by reviewing accounting procedures, entering into contracts with system operators, and training staff accordingly.

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