Deposit-refund system in Poland – postponed until October 2025

Deposit-refund system in Poland – postponed until October 2025
On December 18, 2024, President Andrzej Duda signed the long-awaited amendment to the Packaging and Waste Packaging Management Act. At the beginning of January 2025, the provisions came into force, officially postponing the start date of the deposit-refund system to 1 October 2025. While the system was originally expected to start at the beginning of this year, the amendment was necessary so that businesses, retailers, and those responsible for implementing the new regulations could prepare accordingly.

What is the deposit-refund system?

The deposit-refund system is designed to increase recycling rates and encourage the reuse of packaging. It is based on a simple mechanism: when purchasing a beverage in packaging covered by the system, a deposit will be added to the price, which the consumer can get back by returning the empty packaging. Importantly, no receipt will be required to receive the refund.

The system will cover three types of packaging:

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

Why was the deadline postponed?

Originally, the system was due to start on 1 January 2025, but many entities, including businesses and shops, reported the need to extend the preparation time. The amendment introduced a new date – 1 October 2025 – and a number of facilitating measures:

Packaging collection points in each municipality – at least one collection point must operate in each municipality to ensure the system is accessible to residents.
Exclusion of packaging for dairy products – for sanitary reasons, packaging for milk, yogurt, and other dairy beverages will not be included in the system.
Transition period for labeling – packaging without the new labelling will be allowed to be marketed until the end of 2025 so that businesses can use up their stocks and adjust production.

Changes in VAT regulations in Poland

Under the new rules, entities introducing beverages in packaging covered by the deposit-refund system will be required to calculate and pay VAT on unreturned packaging or packaging waste. The taxpayer will still be the trader placing the products on the market, but the entity representing the deposit-refund system will be the VAT payer.

For businesses, this may be a challenge, especially during the early stages of the system’s implementation.

Benefits of the deposit-refund system in Poland

The primary goal of the deposit system is to reduce municipal waste and increase recycling rates. This will result in more raw materials being reused, helping to protect the environment. The unclaimed deposit will contribute to the fund necessary to maintain the system, and the mandatory levels of selective collection of packaging (77% in 2025 and 90% in 2029) will allow Poland to meet EU environmental requirements.

Preparations for 2025

Work is underway to establish the infrastructure needed to ensure the smooth operation of the system by October 2025. A key element of this process is educating both consumers and businesses about the new requirements.

Support in adapting to the deposit-refund system and VAT settlements

The introduction of the deposit-refund system entails additional tax and reporting obligations for manufacturers, importers, distributors, and retailers. VAT settlement will extend to a new group of disposable packaging, and the process of collecting and returning the deposit will extend beyond the final stage of distribution. In addition, it will become crucial to properly distinguish between the roles of taxpayer and VAT payer in the new system.

If you need support in adapting your business to the changed regulations concerning the deposit-refund system, tax obligations, or reporting obligations, we invite you to contact us. Our specialists will help you understand the rules of the new system and provide support in correctly accounting for VAT in accordance with the current regulations.

If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.

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