compliance teamThe Polish deposit-return system for beverage sellers
Step 1
Identify covered beverage formats
Step 2
Check the deposit mark on artwork
Step 3
Contract a permitted operator
Step 4
Keep the packaging duties running alongside
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Live since October 2025, marked packaging since January 2026
The deposit system started on 1 October 2025 and, from 1 January 2026, producers inside it may place on the market only packaging carrying the deposit mark. The covered formats are single-use plastic beverage bottles up to three litres, metal cans up to one litre and reusable glass bottles up to one and a half litres; confirm the current scope against your exact format before relying on it.
It is an additional regime rather than a replacement. A beverage seller inside the deposit system is still a registered introducer with a report, an annual fee and a registry-number duty on its documents.
You must contract an operator, and it must accept you
An introducer of beverages in covered packaging has to contract a system operator. An operator is a Polish joint-stock company holding a permit from the Minister of Climate and Environment, and it is obliged to contract with any introducer that applies to it.
Failing to contract one is expensive by design: the rate for the selective-collection obligation is tripled, against a statutory ceiling of 25 zł per kilogram for that obligation. Separate penalties apply to the deposit regime itself.
Why we scope this rather than price it
The obligations are operator-specific, the deposit mark has physical consequences for artwork and packaging lines, and the reporting sits alongside the ordinary packaging duties rather than inside them.
For cross-border sellers this is a narrow but heavy vertical. We scope it in writing, per format and per operator, and we never fold it into a packaging estimate or into an automated quote.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. The marshal, the register, recovery organisations and marketplaces control their own procedures, timing and decisions.