EU Deposit Return Systems for Packaging Under PPWR

Deposit Return Systems, commonly known as DRS, are becoming one of the most important packaging compliance topics under the EU Packaging and Packaging Waste Regulation, known as the PPWR.

For companies placing beverages and packaged products on the EU market, DRS compliance is not only a waste collection topic. It affects packaging design, product labelling, barcodes, deposit charging, retail return points, data reporting, EPR obligations, finance processes, consumer communication, and market access.

Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025 and generally applies from 12 August 2026. The regulation establishes rules for packaging across its life cycle, including production, use, waste management, labelling, reuse, recycling, and waste prevention.

Under Article 50 of the PPWR, Member States must take measures by 1 January 2029 to ensure the separate collection of at least 90% per year by weight of certain beverage packaging formats placed on the market for the first time in that Member State. These formats include single-use plastic beverage bottles with a capacity of up to three litres and single-use metal beverage containers with a capacity of up to three litres.

This means companies cannot treat DRS as a local recycling scheme only. DRS is becoming part of EU packaging compliance, and businesses should prepare early.

A Deposit Return System is a packaging collection system where a deposit is charged when a consumer buys a product in covered packaging. The deposit is refunded when the empty packaging is returned through an approved return channel.

In simple terms:

1- The consumer buys a beverage in covered packaging.

2- A deposit is charged at the point of sale.

3- The consumer returns the empty packaging.

4- The deposit is refunded.

5- The packaging is collected for recycling or reuse.

DRS is designed to increase collection rates, reduce litter, improve material quality, and support closed-loop recycling. The PPWR recognises that well-functioning deposit and return systems can deliver high collection rates and high-quality recycling, especially for beverage bottles and cans.

For businesses, this means DRS can affect much more than the packaging label. It may affect pricing, invoicing, retail operations, reverse logistics, consumer refunds, data systems, EPR records, and reporting.

DRS matters because it creates a direct link between packaging placed on the market and packaging collected after use.

For beverage packaging, this can be a critical compliance issue. If a company sells covered packaging in a Member State with a DRS, it may need to register with the system, apply the correct label or barcode, charge the correct deposit, report packaging quantities, and maintain data about packaging placed on the market.

DRS can affect:

The European Commission explains that packaging uses large quantities of primary raw materials and that increasing packaging waste, combined with low levels of reuse, collection, and recycling, is a barrier to a circular and resilient economy. DRS is one of the systems intended to improve collection and recycling performance.

DRS compliance is especially relevant for businesses involved in beverage packaging, but it can also affect retailers, distributors, online sellers, packaging suppliers, and marketplaces.

Businesses that should assess DRS obligations

A company should review DRS obligations if it sells beverages in plastic bottles, metal cans, or other packaging types included in national deposit systems.

The PPWR specifically requires Member States to ensure separate collection targets for two main packaging formats by 1 January 2029:

Member States must take the necessary measures to ensure DRS systems are set up for these packaging formats and that a deposit is charged at the point of sale.

However, companies should also remember that Member States may go beyond the minimum PPWR scope. The regulation allows Member States to include other packaging formats, other products, or packaging made from other materials in their DRS, provided they follow EU internal market rules.

Packaging that may need DRS review

The practical message is simple: companies should check both EU-level PPWR rules and the national DRS rules of each Member State where products are sold.

The main PPWR DRS milestone is 1 January 2029.

By this date, Member States must take measures to ensure at least 90% separate collection per year by weight for covered single-use plastic beverage bottles and single-use metal beverage containers. They must also set up deposit and return systems for the relevant formats unless an exemption applies.

DRS timeline for businesses

Companies should not wait until 2029 to prepare. DRS readiness may require national registration, packaging label changes, barcode updates, deposit accounting, retail and distributor coordination, stock transition planning, and reporting workflows.

The PPWR requires Member States to ensure the separate collection of at least 90% per year by weight of the covered packaging formats placed on the market for the first time in that Member State.

For companies, this target does not only matter at government level. It affects the systems that producers, retailers, distributors, and DRS operators must participate in.

What the 90% target means in practice

The EUR-Lex summary confirms that Member States must ensure DRS for single-use plastic or metal beverage containers by 2029 unless they already reach a high separate collection rate.

The PPWR allows a Member State to be exempt from setting up a DRS for the covered formats if specific conditions are met.

A Member State may be exempt if the separate collection rate for the relevant packaging format is 80% or more by weight in 2026, and if by 1 January 2028 the Member State notifies the Commission and submits an implementation plan showing how it will achieve the 90% separate collection rate.

Practical meaning for companies

Companies should not assume that exemption means no work is needed. Even if a Member State does not immediately set up a new DRS, businesses may still need to meet collection, reporting, labelling, EPR, or national packaging obligations.

Not every beverage packaging format is automatically subject to the mandatory DRS setup requirement under Article 50.

The PPWR excludes certain categories from the DRS setup obligation, including specific wine and aromatised wine products, products similar to wine products obtained from fruits or vegetables, spirit drinks, and milk and milk products. It also allows Member States to exempt single-use plastic beverage bottles and metal beverage containers with capacities lower than 0.1 litres where participation is not technically feasible.

Packaging categories to assess carefully

Businesses should assess DRS applicability by product category, packaging material, packaging capacity, country, and national system rules.

The PPWR includes a specific derogation for certain HORECA situations.

Member States may exempt economic operators in the HORECA sector from charging a deposit where the deposit-bearing packaging is opened on the premises, the product is consumed on the premises, and the empty deposit-bearing packaging is returned at the premises.

Practical HORECA scenarios

HORECA businesses should not assume they are always outside DRS. The conditions depend on how the beverage is served, where it is consumed, and how the empty packaging is returned.

Deposit-bearing packaging must be clearly identifiable.

The PPWR states that packaging subject to DRS under Article 50(1) must be marked with a clear and unambiguous label. It also allows a harmonised colour label in addition to national labels, depending on implementing acts and Member State requirements.

DRS label data companies should manage

Labelling is one of the highest-risk operational areas because a small artwork error can affect market access, return acceptance, retailer compliance, and consumer refunds.

The PPWR includes minimum requirements for DRS systems in Annex X.

These requirements cover governance, fair access, reporting, deposit levels, financial capacity, system operator independence, public awareness, return obligations, consumer refund rights, clear labels, and transparent fees.

Minimum DRS requirements under PPWR

For businesses, the minimum requirements show that DRS is not only a consumer refund system. It is a structured compliance infrastructure with governance, reporting, finance, and data obligations.

Retailers and final distributors may play a major role in DRS operation.

Under Annex X, final distributors must accept deposit-bearing packaging of the material and format they distribute and provide redeemed deposits when packaging is returned, unless consumers have equally accessible means to redeem the deposit through authorised collection channels. Final distributors must always accept the return of empty packaging of products they sell, subject to the relevant rules.

Retail readiness checklist

Retailers should treat DRS readiness as an operational project, not only a compliance memo.

Producers and importers may need to register with national DRS systems, report covered packaging, apply correct labels, and ensure deposit processes are in place.

Producer and importer readiness checklist

Companies selling the same beverage in several EU markets may need different labels, barcodes, deposit values, and reporting processes by country.

Online sellers should also assess DRS obligations. The product may be sold remotely, but the packaging still enters a national market and may be covered by a deposit return system.

Online sales DRS considerations

E-commerce businesses should coordinate compliance, finance, IT, fulfilment, and customer service teams when preparing for DRS.

DRS compliance is data-heavy. Companies need reliable data on packaging placed on the market, packaging returned, deposit values, labels, material types, and national systems.

DRS data checklist

The PPWR requires reporting on quantities by weight of separately collected single-use plastic beverage bottles up to three litres and single-use metal beverage containers up to three litres.

Companies should build DRS data into their packaging compliance system rather than managing it separately in finance, retail, or logistics systems.

DRS and EPR are connected but not identical.

EPR covers producer responsibility for packaging placed on the market. DRS is a specific collection mechanism for certain deposit-bearing packaging. A company may need to manage both at the same time.

Difference between EPR and DRS

The PPWR states that Member States must ensure extended producer responsibility schemes and deposit and return systems allocate a minimum share of their budget to financing reduction and prevention actions.

For companies, the practical challenge is to avoid duplicate, inconsistent, or disconnected data between EPR and DRS reporting.

DRS can support both single-use collection and reusable packaging return, but the requirements are not the same.

The PPWR recognises that single-use DRS and deposit-based reuse systems have different requirements. It also encourages Member States to establish and maintain DRS for single-use glass beverage bottles and beverage cartons, and to ensure return opportunities for reusable packaging are as convenient as those for single-use deposit-bearing packaging where technically and economically feasible.

Practical reuse considerations

Companies should not assume one DRS process covers both single-use and reusable packaging. The operational model and evidence requirements can differ.

DRS labels and identifiers are critical because they allow consumers, retailers, reverse vending machines, and system operators to recognize covered packaging.

Artwork control checklist

The PPWR requires deposit-bearing packaging to be clearly labelled so end users can identify the need to return it.

Deposit systems create both compliance and financial workflows. Companies may need to reconcile deposits charged, deposits refunded, units sold, units returned, system fees, and reporting data.

DRS financial and reporting data

Finance, compliance, sales, retail, and supply chain teams should work together to avoid mismatches between commercial data and DRS reporting.

Although PPWR sets EU-level requirements, DRS is still highly country-specific in practice.

Different Member States may have different:

• System operators
• Registration processes
• Deposit values
• Labels and logos
• Barcode rules
• Reporting portals
• Product categories
• Return point obligations
• Retailer responsibilities
• Exemption rules
• Transition periods
• Enforcement practices

The PPWR allows Member States to include additional packaging formats or other materials in DRS, and it also allows national systems to go beyond minimum requirements where compatible with EU rules.

Country-by-country DRS data to track

Companies selling beverages in multiple EU countries should not use one generic DRS checklist. They need a market-by-market compliance process.

DRS compliance gaps often happen when businesses treat deposit return as a local retail process instead of a packaging compliance obligation.

Common mistakes

A strong DRS compliance process should connect packaging design, labels, data, registration, finance, retail operations, and reporting.

Companies can use the following roadmap to prepare for Deposit Return Systems under PPWR.

Step 1: Identify beverage packaging in scope

List all beverage products sold in the EU and identify packaging material, format, capacity, and country placed on market.

Step 2: Classify packaging by DRS relevance

Determine whether each item is a single-use plastic beverage bottle up to 3 litres, a single-use metal beverage container up to 3 litres, or another packaging format included in a national DRS.

Step 3: Check product-category exemptions

Review whether the product falls into an excluded category such as wine, certain aromatised wine products, spirit drinks, milk or milk products, or other nationally exempt categories.

Step 4: Map national DRS systems

Identify the DRS operator, registration process, deposit value, label, barcode, reporting rules, and transition dates for each Member State.

Step 5: Prepare packaging labels and identifiers

Update artwork, DRS logos, barcodes, QR codes, deposit indications, and country-specific packaging files.

Step 6: Set up deposit charging and refund processes

Coordinate pricing, invoices, accounting, checkout systems, retailer settlement, and consumer refund processes.

Step 7: Build DRS data tracking

Track units placed on the market, packaging weight, deposit values, units returned, refunds, and system operator reports.

Step 8: Align DRS and EPR data

Ensure DRS data and EPR packaging data use consistent material, weight, product, and country classifications.

Step 9: Prepare evidence and audit records

Store registration confirmations, label approvals, system reports, financial reconciliations, and packaging data.

Step 10: Monitor PPWR and national updates

Track implementing acts, national DRS rules, label changes, deposit value updates, and DRS scope expansion.

This checklist can support beverage portfolio reviews, market launch approvals, artwork updates, EPR reporting, retailer onboarding, online sales readiness, and internal compliance audits.

DRS compliance under PPWR requires accurate packaging data, country-level obligation tracking, DRS registration records, label control, barcode management, EPR alignment, financial data, and audit-ready documentation.

ComplyMarket’s packaging compliance services describe packaging compliance as a controlled process involving packaging materials, labelling, recycling obligations, registration, reporting, documentation, recordkeeping, recyclability, eco-design expectations, and EPR compliance. ComplyMarket also highlights the need to identify packaging articles and components, map packaging to target markets, collect supplier data, review labels, assess registration and reporting duties, maintain documentation, monitor legal changes, and generate compliance reports.

ComplyMarket’s EPR management service explains that EPR affects market access, cost control, legal exposure, and operational readiness, especially where companies manage several countries, producer setups, registrations, reporting bases, and supporting evidence.

ComplyMarket can help companies prepare for DRS requirements by supporting:

• Packaging inventory and beverage packaging mapping
• Product-to-packaging and country-level DRS assessment
• Identification of DRS-covered packaging formats
• Packaging material, capacity, weight, and component data management
• DRS registration and system-operator record management
• Deposit value and country-specific requirement tracking
• DRS label, barcode, and artwork evidence control
• Supplier declaration and packaging specification collection
• DRS reporting data preparation
• Alignment between DRS and EPR data
• Marketplace and retailer evidence preparation
• Version control for packaging, label, and market changes
• Audit-ready records for internal and external compliance reviews
• Digital Product Passport and circular economy data readiness

For companies placing beverage packaging on the EU market, the challenge is not only understanding whether DRS applies. The real challenge is keeping product data, packaging data, labels, deposits, reporting, retail requirements, and evidence aligned across multiple countries.

ComplyMarket helps companies move from fragmented spreadsheets, manual label checks, supplier emails, and local system records to a structured, traceable, and audit-ready packaging compliance process.