Poland’s national deposit return system entered its first full year of operation in 2026.

The system covers specified plastic bottles, metal cans and reusable glass bottles. Consumers pay a deposit when purchasing a marked beverage and recover it by returning the empty packaging to a participating collection point.

For beverage producers and importers, the system creates obligations that go beyond adding a deposit to the retail price. Companies must identify the responsible legal entity, select an authorised system operator, register packaging formats, apply the Polish deposit mark, maintain detailed records and finance the collection system.

Participation is not expressed as a simple prohibition on selling beverages outside the system. However, a producer that remains outside the system cannot rely on system collections to meet the statutory collection targets and faces a substantially higher product fee.

For most companies placing covered beverage packaging on the Polish market, joining an operator is therefore the practical route to compliance.

Poland’s deposit system is fully operational

Poland launched its deposit return system on 1 October 2025. The final months of 2025 served as a transitional period during which marked packaging was gradually introduced.

From 1 January 2026, producers participating in the system may introduce covered beverages only in packaging carrying the official deposit mark. Unmarked products that were lawfully placed on the market during the transition can continue to be sold until the remaining stock has been exhausted.

This distinction concerns the date on which the packaged beverage was placed on the Polish market. It does not provide an open-ended right to continue producing new unmarked packaging for sale in Poland.

The system has therefore moved from gradual implementation to ordinary producer compliance. New product launches, label changes and imported beverage lines must be assessed before they enter the Polish supply chain.

Which beverage packaging is covered?

The Polish system currently covers three packaging categories:

• single-use plastic beverage bottles with a capacity of up to three litres;
• metal beverage cans with a capacity of up to one litre;
• reusable glass beverage bottles with a capacity of up to 1.5 litres.

The deposit is PLN 0.50 for covered plastic bottles and metal cans. Covered reusable glass bottles carry a deposit of PLN 1.00.

The packaging type, capacity and use for a beverage all form part of the scope assessment. The system does not cover every container holding a liquid and should not be assessed solely from the packaging material.

Certain beverage categories and packaging formats are subject to specific exclusions under Polish law. Companies should therefore classify the packaged product and not assume that every bottle or can below the capacity threshold is automatically included.

The rules also distinguish between single-use plastic and metal packaging, which is collected for recycling, and reusable glass packaging, which is returned for further rotations. These categories require different operational and reporting arrangements.

Must every producer sign a contract with an operator?

Polish law does not describe operator membership as an absolute market-entry condition in the same way as some collective EPR systems.

A producer is nevertheless required to achieve the statutory selective collection targets. Only packaging and packaging waste collected within the deposit return system can be counted towards those targets.

The target is 77% during the initial period and increases to 90% from 2029.

A producer that signs a contract with a licensed operator can use the operator’s collection network and results to meet its obligations. If the required target is missed, the producer and operator generally share the resulting product fee equally.

A producer that does not sign an operator contract bears the relevant product fee alone and at a higher rate. For the covered plastic bottles and metal cans, the official 2026 guidance distinguishes between PLN 1 per missing kilogram for participants and PLN 3 per missing kilogram for producers that have not contracted with an operator.

Because collection outside the recognised system cannot simply be counted towards the statutory target, remaining outside the system creates a significant financial and evidentiary risk.

The legal structure may therefore allow a producer to remain outside an operator arrangement, but it does not provide a commercially equivalent alternative.

Poland permits several deposit system operators

Poland has chosen a decentralised structure rather than appointing one national monopoly operator.

The Ministry of Climate and Environment has granted operating permits to several companies. Beverage producers can select an authorised operator whose permit covers the relevant packaging categories.

Joining an operator requires a written agreement. The contract must cover the entire mass of the selected packaging type or types placed on the market by the producer. A company should not divide one packaging category between participating and non-participating quantities without a legally supported structure.

The operator is generally required to accept a producer that applies to join its system. The contract determines matters such as:

• the producer’s financial contributions;
• payment terms;
• packaging and product-data submissions;
• deposit settlement;
• collection and logistics arrangements;
• reporting and reconciliation processes;
• treatment of returned packaging and materials.

Producer fees are not the only commercial consideration. The company should also assess the operator’s data systems, packaging approval process, national collection coverage, financial-security arrangements and procedures for managing product changes.

The operating agreement must be retained for five years after it ceases to apply.

The deposit mark is a legal part of the system

Covered packaging participating in the Polish system must display the official deposit mark and the applicable deposit value.

The marking must be:

• clear and visible;
• legible;
• durable;
• sufficiently contrasted against the background;
• placed on the product label.

Only packaging carrying the official mark belongs to the general Polish deposit system. A retailer may collect the statutory deposit only for properly marked packaging, and the consumer can recover the deposit only by returning packaging recognised by the system.

The mark is therefore not simply a general environmental symbol. It connects the individual packaging format to the financial, reporting and collection structure of the deposit system.

In practice, operators also need to identify and register the individual packaging variants supplied by their participating producers. A compliant symbol on an otherwise unknown or incorrectly registered packaging format may not be enough for automated return machines and operator reconciliation.

Companies should coordinate label approval, product codes and packaging registration with their selected operator before placing the product on the market.

Can the deposit mark be added with a sticker?

The legislation focuses on whether the required marking is visible, legible and durable and whether it appears on the label.

It does not make the printing technique the central legal test. An over-label or sticker may therefore be technically possible where it meets all applicable marking requirements and remains securely attached throughout distribution and use.

That does not mean that any sticker is automatically acceptable.

The packaging must still be correctly registered in the operator’s system, identifiable by the return infrastructure and linked to the applicable deposit. A temporary, removable or poorly positioned label can create problems even where the printed information is formally correct.

The producer should obtain confirmation from its operator before relying on over-labelling for imported stock, short production runs or packaging corrections. Operator specifications may address dimensions, barcode placement, print quality and the interaction between the deposit mark and the packaging identifier.

The operator’s operational approval does not replace the producer’s legal responsibility for the final packaging.

What happens to unmarked stock?

Products lawfully introduced before the end of the transition can continue to be sold until stocks are exhausted.

No statutory deposit is charged on these unmarked products, and consumers cannot return the packaging through the national system in exchange for a deposit.

This remaining stock should be distinguished from packaging newly introduced after the producer became subject to the full 2026 requirements.

The transition applies to products already placed on the market, not merely to empty labels, bottles or cans held in a manufacturer’s warehouse. A company cannot rely solely on the packaging production date without considering when the filled product entered commercial distribution in Poland.

Businesses should retain records that distinguish:

• transitional unmarked stock;
• marked domestic-market stock;
• products manufactured for export;
• products returned or relabelled;
• packaging formats introduced after an operator contract began.

Retailers can continue selling qualifying old stock, but they should not charge the statutory deposit where the packaging does not carry the official mark.

Export packaging must be separated from Polish-market packaging

Packaging intended for export is not treated as Polish deposit packaging.

Where a producer manufactures beverages for export, it should not apply the Polish deposit mark, collect the deposit from the wholesaler or route the deposit to a Polish operator.

The intended destination must therefore be established at the beginning of the supply chain.

A producer that declares packaging for export but subsequently places it on the Polish market can create labelling, deposit and reporting violations. Conversely, a distributor that purchases Polish marked stock and later exports it does not have a general statutory right to reverse the deposit through the supply chain.

The Ministry has emphasised that the deposit follows the packaging forward through the domestic distribution chain. The system does not provide a general retrospective reimbursement mechanism for marked products later exported by a downstream purchaser.

Companies using central European distribution centres should therefore decide which market a batch is intended for before marking and commercial release.

Who is the responsible producer?

The obligation generally applies to the business that introduces beverages in the covered packaging onto the Polish market.

Depending on the supply chain, this may be:

• a Polish beverage manufacturer;
• an importer;
• a company making an intra-EU acquisition;
• a private-label business;
• a brand company introducing the packaged beverage;
• another business first commercially supplying the product in Poland.

The physical manufacturer of the empty bottle or can is not automatically the responsible beverage producer.

The label owner is also not necessarily decisive. The assessment should identify which legal entity carries out the relevant market-introduction activity under Polish packaging law.

A producer can be responsible even if another company:

• manufactures the beverage;
• owns the trademark;
• fills the packaging;
• operates the warehouse;
• sells the product to the final consumer.

Commercial contracts can allocate packaging data, operator costs and deposit reconciliation. They cannot by themselves replace the statutory assessment of which company introduces the product.

Imported beverages require an entity-level assessment

Imported beverages are not excluded from the deposit return system.

Where a Polish company imports or makes an intra-EU acquisition of covered packaged drinks and introduces them onto the national market, that company can become the responsible producer.

The foreign supplier may own the brand and control the packaging design, but the Polish importer may still hold the national deposit, BDO and operator obligations.

This division often creates a data dependency.

The importer needs technical and commercial information such as:

• packaging type and capacity;
• unit and component weights;
• label and closure specifications;
• product codes;
• annual quantities supplied to Poland;
• packaging intended for export or other markets;
• confirmation of whether the format is reusable.

A foreign producer selling through a local importer should not assume that the importer can complete the assessment using only invoices and total shipment weights.

Where a foreign company supplies the Polish market directly, the BDO registration and legal representation structure must Polish market directly, the BDO registration and legal representation structure must be assessed separately. Foreign businesses without a Polish branch can interact with BDO, but the appropriacise activities and Polish legal presence.

Private-label and contract-filling structures

Private-label beverages can involve several companies:

• the retailer or brand owner;
• the contract filler;
• the packaging supplier;
• an importer;
• a distributor;
• the business selling the product in Poland.

The brand name alone does not determine responsibility.

A Polish retailer can be the responsible introducer for an imported private-label beverage even where the overseas manufacturer controls production. In another structure, a Polish filler may introduce the finished beverage before selling it to the brand owner.

The commercial flow, ownership, invoicing and first domestic supply should be reviewed together.

The operator contract should also identify which brands and packaging formats are included. A contract filler producing for several customers should not automatically report all packaging under its own operator account if another legal entity is the producer for a particular product line.

The same quantities must not be reported twice by the filler and brand owner, but they must not be omitted because each assumes that the other party is responsible.

What data must producers retain?

Producers must maintain records supporting the packaging placed on the market.

For covered beverage packaging, the records include more than annual mass. Polish law also requires information on the number and capacity of the packages, separated by the categories covered by the deposit system.

The producer must provide its operator with the data needed to perform the system obligations, including information on all covered packaging placed on the market during the year.

Failure to provide the operator with complete information can create a separate product-fee exposure for the undeclared packaging.

A reliable dataset should therefore connect:

• product identifier;
• packaging category;
• unit capacity;
• unit weight;
• number of units introduced;
• total packaging mass;
• deposit value;
• operator;
• Polish-market or export status;
• date of first introduction;
• reusable or single-use classification.

Labels and adhesives may also be relevant to the reported packaging mass where they are treated consistently in both market and collection calculations.

This level of detail is greater than the information available in many ordinary sales ledgers. Producerications and operator records.

Product fees remain a real compliance risk

Joining an operator does not guarantee that no product fee will arise.

The operator and its participating producers must achieve the statutory collection target. If the target is missed, the fee is calculated in relation to the shortfall.

For participating producers, the product-fee liability is generally divided equally between the producer and operator. This allocation gives the operator a direct financial interest in developing an effective national collection system.

A non-participating producer bears the liability independently and at the higher applicable rate.

The fee should not be confused with:

• the deposit collected from the customer;
• the producer’s contractual fee to the operator;
• general packaging EPR charges;
• BDO registration or administrative costs.

These are separate financial flows.

The producer should therefore assess not only the operator’s participation fee, but also the contractual allocation of data errors, target shortfalls, unregistered formats and deposit-accounting discrepancies.

Unclaimed deposits finance the system

Where the consumer does not return a marked package, the deposit becomes unclaimed.

Unclaimed deposit money is not ordinary profit for the producer or retailer. It is allocated to the operator and must be used to finance the operation and development of the deposit system.

This can include collection, logistics, administration and remuneration paid to retailers and collection points for handling returned packaging.

The system is therefore financed through a combination of:

• producer contributions;
• unclaimed deposits;
• revenue from recovered materials.

Deposit accounting must remain separate from ordinary beverage revenue. The deposit moves through the distribution chain with the marked product and is ultimately erred into the system’s financing structure.

Retailer obligations are separate from producer obligations

Retailers perform a different role from beverage producers.

Every retail outlet selling beverages in marked packaging must charge the applicable deposit, regardless of the size of the store.

The obligation to accept returns depends on the store and packaging category.

Stores with a sales area above 200 square metres must generally accept covered packaging and return the deposit. Smaller stores may participate voluntarily in the collection of plastic bottles and cans.

Small stores selling beverages in covered reusable glass bottles have broader participation requirements and must generally collect those bottles and return the deposit.

Retailers can use manual collection or reverse-vending machines. Consumers do not need to show a receipt, and a participating collection point must accept eligible marked packaging regardless of where the beverage was purchased.

The retailer’s obligation to charge and return deposits does not make it the responsible producer for the bevmust be assessed separately.

Participation does not replace BDO registration

The deposit system operates within Poland’s wider packaging and waste framework.

A contract with an operator does not automatically replace the producer’s BDO registration, product and packaging records or all annual reporting obligations.

BDO remains the national database used for registrations, records and reports relating to products, packaging and waste management.

The deposit operator performs defined collection, reconciliation and reporting functions for the packaging covered by its system. The producer must still ensure that:

• the correct legal entity is registered in BDO;
• the relevant beverage-packaging activity appears in its registration;
• its internal packaging records are complete;
• annual reports are submitted where required;
• non-deposit packaging is handled under the ordinary packaging rules;
• remaining recycling and public-education obligations are addressed;
• operator data agrees with the producer’s own records.

The exact division of reporting between the producer and operator should be mapped before the annual reporting cycle. A producer shopackaging obligation.

Other packaging remains outside the deposit system

The deposit system covers only the specified primary beverage containers.

A beverage producer may also place the following packaging on the Polish market:

• cardboard multipacks;
• shrink film;
• trays;
• transport cartons;
• pallets;
• stretch film;
• e-commerce shipping packaging;
• promotional packaging.

These materials are not automatically covered by the beverage deposit arrangement.

They may remain subject to ordinary Polish packaging EPR, BDO reporting, recycling obligations and packaging-related fees or compliance arrangements.

A beverage producer should therefore split its packaging portfolio into at least two groups:

1. beverage containers handled through the deposit system;
2. other packaging handled under the general packaging framework.

Using only the operator’s deposit packaging report will not provide a complete annual packaging dataset.

Operator selection is an ongoing compliance decision

The presence of several licensed operators gives producers a commercial choice, but it also creates the need for proper due diligence.

Relevant differences can include:

• packaging onboarding timelines;
• data submission formats;
• fee structure;
• collection network;
• return-machine compatibility;
• support for reusable glass;
• settlement cycles;
• retailer agreements;
• audit and correction procedures;
• financial guarantees;
• approach to target shortfalls.

Changing operators can also affect packaging registration, product codes, deposit reconciliation and data continuity.

The law requires participation to cover the complete mass of the selected packaging category. A producer should therefore ensure that the effective dates of old and new contracts do not create gaps or overlapping declarations.

The existence of an operating permit confirms that an operator is authorised. It does not remove the need to review whether the operator’s system covers the producer’s actual packaging portfolio and distribution structure.

The deposit system is not just a label change

For beverage companies, Poland’s deposit return system affects product design, contracting, logistics, accounting, data management and national packaging compliance.

The official deposit mark is the visible part of the system, but it is not the complete obligation.

Producers must determine the responsible entity, join an appropriate operator, register packaging formats, finance the system, maintain detailed packaging records and manage the relationship between deposit reporting and BDO.

The option to remain outside an operator system exists more in theory than as an equivalent compliance model. Higher product-fee exposure and the restriction that only system collections count towards the target make non-participation commercially difficult.

Companies introducing new beverages, changing import structures or using several fulfilment routes should complete the Polish assessment before packaging is printed and products enter distribution.

Viron Compliance supports beverage producers, importers and private-label businesses with Polish BDO registration, deposit-system assessments, operator coordination, packaging reporting and ongoing EPR compliance.