Deposit return scheme for cans and bottles: what the PPWR requires
⏱ Updated: 2026-10-26 · source: Regulation (EU) 2025/40 + EC Guidance C(2026) 3702
The question “which packaging does the deposit cover” has two layers in the EU: the minimum in Art. 50 of the PPWR and national additions. Here are both, with the Commission's answers on exemptions, labels and producer registration.
In brief
- The PPWR requires 90 % separate collection for single-use plastic bottles and metal beverage containers from 2029; in practice that means a deposit-and-return system (DRS).
- Milk, wine and spirits containers are exempt from the DRS obligation but count towards the 90 % target; States may include them in a deposit.
- DRS labels are not harmonised: the label of the State where the product is made available applies (chapter VIII, Q3).
- The Polish deposit is a national obligation alongside the PPWR; the PPWR does not replace it.
What the European Commission says
Separate collection of single-use plastic and aluminium beverage packaging, referred to in Art. 50, means collection in a deposit-and-return system.
European Commission, PPWR questions and answers, chapter XIX, Q2
See how PPWRapka handles it
Requirements map — Step three: the requirements. Each article is a tile with its own status.
Full episode: PPWR #3 — Articles 5–12 and the lab report (PFAS, heavy metals) →
The PPWR minimum: what a deposit scheme must cover
Art. 50 of the PPWR sets 90 % separate-collection targets for two groups: single-use plastic beverage bottles and metal beverage containers (cans). They are two separate targets, applying from 2029 (chapter XX, Q1). Separate collection of these packaging items means collection through a deposit-and-return system (DRS), so the practical minimum for Member States is a DRS for plastic bottles and cans.
An exemption is possible but hard: a Member State that by 2026 collects more than 80 % of single-use plastic bottles or metal containers may apply for an exemption from the DRS obligation and must show how it will reach 90 % without a deposit. The exemption has to be obtained separately for each format.
Glass bottles and beverage cartons are outside the minimum, but the Commission encourages States to set up a DRS for them as well and for reusable packaging (chapter XX, Q2).
Exemptions and national additions
| Packaging | Status in the PPWR | Note |
|---|---|---|
| Single-use plastic beverage bottle | covered by the 90 % target | collected through a DRS |
| Metal beverage container (can) | covered by the 90 % target | collected through a DRS |
| Milk and dairy, wine, spirits | exempt from the DRS obligation | count towards the 90 % target; a State may include them in a deposit |
| Glass and carton for beverages | outside the minimum | a State may add them to its DRS |
Member States may adopt DRS rules going beyond the minimum in Art. 50 and Annex X, provided they respect the Treaty and the PPWR (chapter XX, Q2). Which packaging is covered by a deposit in Poland therefore follows from national law; the PPWR sets only the lower bound.
A DRS set up after 11 February 2025 for single-use plastic bottles and metal containers must be non-profit. For schemes that existed earlier the requirement applies only from 2035, and only if the collection targets are not reached at the first review (chapter XX, Q4).
What it means for a beverage producer
Labels: marking of packaging under a DRS is not harmonised. A bottle or can placed on another country's market must carry the DRS label of that country, and States may not forbid the DRS labels of other Member States (chapter VIII, Q3). An exporter therefore plans separate print versions.
Registration: a DRS for single-use packaging with arrangements comparable to a producer responsibility organisation may register and report on behalf of participating producers in the producer register (chapter XX, Q6).
A deposit does not replace the PPWR: bottles and cans still need technical documentation and a declaration of conformity (Art. 5–12). See also the deposit return system guide.
What PPWRapka does with it
PPWRapka covers the PPWR side of the deposit, not the settlement side: in the register you describe the bottle or can (material, mass, recyclability, recycled content for plastics) and the application builds the Declaration of Conformity regardless of whether the packaging is under a DRS. For an aluminium can, Art. 7 is immediately marked as not applicable.
The application does not register you in a deposit scheme and does not settle deposits or the product fee; those are separate national obligations. It does help you have the material data ready that both authorities and scheme operators ask for.
Check this on your own packaging
Describe a bottle or can in PPWRapka and prepare conformity documents regardless of the deposit.
The quotation comes from the European Commission document Packaging and Packaging Waste Regulation (PPWR) — questions and answers (chapter XIX, Q2), in the Polish version of the document, translated here. Commentary, practical conclusions and the description of the application are ours. Only the text of Regulation (EU) 2025/40 is binding.
Frequently asked questions
Does the deposit cover cans?
The PPWR requires 90 % separate collection of metal beverage containers, and that collection means a DRS. The exact scope in Poland follows from national law.
Are milk and wine covered by the deposit?
They do not have to be. They are exempt from the DRS obligation in Art. 50(4) but count towards the collection targets, and a State may include them in a deposit.
Is a deposit label from another country enough?
No. The DRS label of the State where the product is made available on the market applies.
Does the deposit replace the declaration of conformity?
No. A deposit is a separate collection system; the declaration and technical documentation under the PPWR apply independently.
Sources
ℹ️ This material is informational and educational and does not constitute legal advice. Only Regulation (EU) 2025/40 and national law are binding. PPWRapka is a commercial tool, not a public-administration service.