Deposit Refund System

Starting from 2025, in accordance with European Union law, introducers will have to meet new requirements regarding the increase in selective collection levels of packaging waste and the content of recyclables in new single-use plastic packaging.

One of the ways to meet these requirements from 2025 is the implementation of a deposit system, which will cover the collection of three types of used beverage containers, namely:

  • reusable glass bottles up to 1.5 liters,
  • single-use plastic bottles up to 3 liters, including their caps and closures,
  • metal cans up to 1 liter.

Entrepreneurs face significant financial and logistical challenges in the coming years.

According to the already adopted regulations, the deposit system will operate nationwide, without receipts, and will be independently organized by entrepreneurs. This means that entrepreneurs must establish and finance the operation of a deposit system operator or join such an operator by signing an agreement. Polish regulations allow the possibility of multiple operators running a deposit system.

The preparation of the deposit system’s logistics is a lengthy and complicated process. In essence, smaller stores will have to collect deposits, while larger stores will have to retrieve used packaging from consumers. This is just a part of the complex logistics that must be organized to implement the deposit system.

The current challenge is to broaden the knowledge and competencies of entrepreneurs regarding the operation of the deposit system, especially understanding the legal and tax obligations awaiting individual companies and when they will be imposed.

To facilitate your tax reporting related to these economic events, we offer tax support within your industry.

How can we help?


Tax challenges for the beverage industry

The beverage sector includes entities introducing various types of drinks to the market, including producers and importers of beverages such as non-alcoholic, alcoholic, and dairy drinks.

The upcoming regulations will have a significant impact on the beverage sector, as the selective collection system will only cover three types of used beverage packaging, including alcoholic, non-alcoholic, and dairy drinks. It is worth noting that other packaging introduced to the market, such as single-use glass bottles, liquid food cartons, etc., will not be subject to deposits or collected in the system.

Entities introducing products whose packaging is covered by the system must now decide whether they want to invest in creating a deposit system operator (becoming a shareholder in the operator) or prefer to join such an operator by signing an agreement in the future.

It is crucial to examine the costs associated not only with joining the operator but also with fulfilling other legal obligations, such as labeling, packaging, recycling acquisition, new logistics for reusable glass bottles that will return to the manufacturer for refilling.

For beverage producers, the classification of tax expenses related to joining the deposit system and its operation will also be essential, especially determining which ones and when they can be considered tax-deductible expenses (either one-time or spread over time). Additionally, producers should prepare for new VAT settlement rules for reusable glass packaging, where VAT will not be charged in relation to them upon return deadline expiration but at the end of the year based on the number of bottles introduced and returned within the deposit system. This will involve the obligation to maintain a new tax record for glass bottles. Some returnable packaging (e.g., crates, pallets) will be settled based on existing regulations outside the deposit system, meaning that adapting to new tax regulations requires an analysis of the types of packaging used.

From the operator’s perspective, one of the crucial aspects will be the correct tax accounting of income from uncollected deposits and the sale of materials derived from processing packaging waste, as well as the proper allocation of operator costs related to the deposit system. The content of agreements between entrepreneurs (introducers) and the operator (operators) will be of significant importance for settlements between them.

What do we offer?

  • Ongoing tax support related to participation in the deposit system.
  • Tax advice for deposit system operators.
  • Deposit system – how will it work? – general tax training (basic level).

Logistical revolution for stores and consumers

Another market segment facing significant logistical challenges is stores and retail chains.

Small points of sale will have to participate in the system, collecting deposits that they will then have to settle with the operator. Although only retail spaces with a sales area exceeding 200 square meters will be required to participate in the mandatory collection of used packaging, experiences from other countries show that even smaller stores will want to participate in such a return system.

Stores planning to collect used packaging must already start planning the deployment of waste and packaging infrastructure, including compliance with building regulations, spatial requirements, occupational health and safety, etc. They must check property titles and, if necessary, obtain environmental permits.

From the store’s perspective, it is essential to address the following issues:

  • Determine the method of tax classification of costs related to joining the deposit system and incurring expenses for the collection of packaging and packaging waste.
  • Determine the tax consequences of accounting for collected and returned deposits.
  • Introduce a logistics system for the selective collection of packaging and packaging waste, maintenance, and operation of the required records according to the law.
  • Determine which packaging will be settled for VAT on current principles (settlement outside the system, VAT calculation after the return deadline).

What do we offer?

  • Deposit system – how will it work? – general legal and tax training (basic level).
  • Ongoing tax support related to participation in the deposit system.
  • Deposit system roadmap – key obligations for your company (advanced level, workshops).
  • Tax advice for deposit system operators.

Challenges related to the deposit system are not limited to companies introducing drinks to the market or stores.

It should be noted that there is a large group of companies that are not legally obliged but would like to participate in the deposit system, for example, through the collection of used beverage packaging, such as gas stations, municipalities, large multi-sector stores, etc.

Another group consists of entrepreneurs involved in the logistics of the deposit system, especially manufacturers of equipment, technological infrastructure, and IT, transportation companies, and other entities operating in the field of packaging waste or packaging.

What do we offer?

  • Deposit system – how will it work? – general legal and tax training (basic level).
  • Ongoing tax support related to participation in the deposit system.

Feel free to contact us

Tomasz Michalik

Partner | Tax adviser | Head of the VAT Practice
T: +48 501 733 720

Marek Przybylski

Manager | Tax adviser | Attorney at Law
T: +48 509 567 231

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