Ireland Packaging EPR and Deposit Return Guide 2026

Ireland’s packaging compliance framework combines Extended Producer Responsibility, producer-funded recycling, packaging-data reporting, single-use-plastic obligations, and a nationwide Deposit Return Scheme for certain beverage containers.

Businesses placing packaging or packaged goods on the Irish market may need to:

• Determine whether they are a major producer
• Become a member of Repak
• Submit packaging statistics
• Pay packaging EPR membership fees
• Record packaging materials and weights
• Identify packaging handled at different stages of the supply chain
• Register with Re-turn when selling or distributing covered beverages
• Register individual beverage products
• Apply the Re-turn logo and approved barcode
• Charge and pass on the correct deposit
• Provide or support a consumer return service
• Maintain evidence supporting packaging and sales quantities
• Prepare for requirements under the EU Packaging and Packaging Waste Regulation

Ireland’s current packaging EPR system is primarily based on the European Union (Packaging) Regulations 2014, as amended. The 2022 amendment removed the former self-compliance option for major producers and made membership of an approved body mandatory. Repak is currently Ireland’s approved packaging compliance scheme and received a further ten-year operating approval in January 2026, extending its licence to 2035.

Ireland’s Deposit Return Scheme, operated by Re-turn, launched on 1 February 2024 and applies to eligible drinks sold in PET plastic bottles and aluminium or steel cans. Producers, distributors, retailers, online sellers, and hospitality businesses can all have responsibilities under the system.

These national systems now operate alongside Regulation (EU) 2025/40, known as the PPWR. The PPWR entered into force on 11 February 2025 and applies generally from 12 August 2026, although individual obligations have different application dates.

Packaging Extended Producer Responsibility requires businesses responsible for placing packaging on the Irish market to contribute to the collection, recovery, and recycling of that packaging after use.

For qualifying producers, compliance is delivered through Repak. Repak uses member contributions to fund household and commercial packaging recycling infrastructure and activities across Ireland. Regular membership fees are linked to the packaging a business places on the Irish market, while some qualifying retailers and hospitality businesses can use a scheduled membership structure based on their business category and turnover.

Packaging EPR may require a business to:

• Assess whether it crosses the major-producer thresholds
• Determine its role in the packaging supply chain
• Identify packaging supplied or handled in Ireland
• Calculate packaging quantities by material and weight
• Join Repak under the correct membership category
• Submit packaging statistics at the required frequency
• Pay the applicable membership fees
• Maintain evidence supporting packaging calculations
• Update data after packaging, supplier, or product changes
• Support recycling, waste prevention, and circular packaging objectives

A company should not treat EPR as an annual finance exercise. Reliable EPR reporting depends on packaging specifications, product sales, import data, supplier evidence, and controlled calculation methods.

A business is considered a major producer under the current Irish packaging framework when it:

• Has annual turnover of more than €1 million, and
• Places or supplies 10 tonnes or more of packaging on the Irish market annually

Major producers are required to become members of an approved body. Repak is currently the only approved packaging body operating in Ireland.

Major-producer test

Both criteria matter. A business exceeding only one threshold may not be classified as a major producer under the current national definition, but it should still assess Deposit Return Scheme, Single-Use Plastics, waste-segregation, and future PPWR obligations separately.

Packaging included in the tonnage assessment should not be limited to packaging carrying the company’s logo. Repak’s current training material indicates that Deposit Return Scheme tonnage, contract-packing activity, and consignment activity can contribute toward the ten-tonne threshold.

Threshold status should be reviewed every year and whenever the company:

• Introduces new products
• Begins importing packaged goods
• Acquires another business
• Changes its legal-entity structure
• Expands into retail or e-commerce
• Adds contract-packing operations
• Enters the drinks market
• Significantly increases Irish sales

Since 1 January 2023, a major producer must be a member of an approved packaging compliance body. The former option to register as a self-complier with a local authority was removed through the European Union (Packaging) (Amendment) Regulations 2022.

Repak’s role includes helping members fulfil their packaging recovery and recycling obligations and collecting the packaging data and fees needed to finance the Irish packaging-recycling system.

Practical Repak compliance steps

1. Assess the business against the turnover and packaging thresholds.
2. Identify the correct legal entity or entities.
3. Determine the business’s packaging supply-chain roles.
4. Build an initial packaging inventory.
5. Complete the Repak membership application.
6. Prepare initial packaging statistics.
7. Select the appropriate membership structure.
8. Submit ongoing statistical returns.
9. Pay invoices based on the approved data and fee structure.
10. Update Repak when the business or packaging portfolio changes.

Repak’s approval to operate Ireland’s packaging EPR scheme has been extended through 2035, providing continuity while Ireland transitions from the existing Packaging Regulations to the PPWR framework.

Repak currently provides regular and scheduled membership routes.

Regular membership

Regular membership is intended for major producers such as:

• Manufacturers
• Contract packers
• Brand holders
• Importers
• Distributors
• Large retailers

Fees are based on packaging statistics showing the packaging placed on the Irish market. Regular members provide packaging data twice a year through statistical returns.

Scheduled membership

Scheduled membership is intended for eligible businesses that retail directly to consumers and are not importers or brand holders.

Examples may include:

• Independent retailers
• Hospitality businesses
• Pubs
• Restaurants
• Pharmacies
• Certain electrical retailers
• Hardware retailers

Scheduled members normally pay a flat fee linked to their business category and turnover and do not submit the same detailed packaging statistics as regular members.

Membership comparison

The correct route should be confirmed with Repak because a retailer that imports or owns brands may need regular rather than scheduled membership.

Packaging responsibility can arise at several points in the Irish packaging chain.

Common producer roles

Repak’s fee and reporting structure recognises packaging handled at different stages of the supply chain, including materials manufacture, conversion, brand-holder or importer activity, and retail.

A business can perform more than one role. For example, a company may import packaged goods, add Irish e-commerce packaging, and then sell directly to consumers. Each activity should be reflected accurately in the packaging-data model.

Ireland’s Packaging Regulations recognise three principal packaging levels:

• Sales or primary packaging
• Grouped or secondary packaging
• Transport or tertiary packaging

The regulations also recognise packaging components and ancillary elements that perform a packaging function.

Packaging inventory examples

Businesses should also account for back-door waste, meaning secondary or tertiary packaging received by the producer but not subsequently used in supplying products. This can include transport cartons, pallets, wraps, and protective packaging removed at a warehouse or production site.

A common error is to report only consumer-facing packaging while excluding:

• Imported transport packaging
• Supplier cartons
• Pallet wrap
• Wooden pallets
• E-commerce packaging
• Labels and closures
• Contract-packing materials
• Packaging added by fulfilment centres

A reliable packaging dataset should connect packaging information to products, sales, suppliers, legal entities, and reporting periods.

Recommended packaging master data

Packaging data should be version-controlled. A bottle weight, label material, carton grade, or supplier change can alter the tonnage and fees reported.

A standard packaging calculation is:

Packaging weight per unit × number of units placed on the Irish market

Example

Each component should be assigned to the correct material and supply-chain category.

Suitable evidence sources

• Supplier packaging specifications
• Packaging bills of materials
• Technical drawings
• Sample-weighing records
• Packaging-converter declarations
• Production records
• Approved engineering calculations

Where estimates are used, the business should record:

• Why an estimate was necessary
• Which sample or specification was used
• Which components were included
• Which products use the estimate
• How the average was calculated
• How often the figure is reviewed

Small weight errors can create significant reporting differences when multiplied across high sales volumes.

Regular members provide packaging information to Repak twice each year. These returns support the calculation of membership fees and Ireland’s packaging-recycling obligations.

A statistical return may require information concerning:

• Packaging materials
• Packaging weights
• Packaging supply-chain stages
• Products placed on the Irish market
• Imports and exports
• Retail activity
• Back-door packaging waste
• DRS and non-DRS packaging distinctions
• Packaging handled under contract or consignment arrangements

Repak offers training to help regular members complete their packaging returns and supports members in building suitable calculation systems.

Recommended internal reporting cycle

The business should be able to explain how each submitted quantity was calculated.

Repak regular-member fees are calculated based on the quantity and type of packaging placed on the Irish market and the member’s position in the packaging chain. Repak publishes updated fee schedules annually, including a current 2026 schedule.

Fee exposure can be affected by:

• Packaging material
• Packaging weight
• Supply-chain activity
• Irish market volume
• Recyclability category
• DRS or non-DRS status
• Single-use-plastic obligations
• Membership route

Businesses should use the fee schedule for the relevant reporting year rather than relying on historic rates.

Cost-control opportunities

• Reduce unnecessary packaging weight
• Remove avoidable packaging components
• Improve recyclability
• Standardise packaging formats
• Validate sales and export deductions
• Prevent duplicate reporting
• Maintain accurate supplier weight data
• Separate DRS and non-DRS packaging correctly

Packaging optimisation can reduce material use, transport costs, and future EPR exposure.

Ireland’s packaging regulations include a progression toward 2030 recycling targets.

From 1 January 2026, importers of packaged products and packers or fillers must take steps toward achieving a minimum overall packaging-waste recycling rate of 70% by the end of 2030. The material-specific 2030 targets are set at 55% for plastic, 30% for wood, 80% for ferrous metals, 60% for aluminium, 75% for glass, and 85% for paper and cardboard.

Ireland’s 2030 packaging recycling targets

Repak members collectively support these targets through the approved EPR scheme, but individual businesses still need reliable packaging data and should review designs that are difficult to recycle.

Ireland’s Deposit Return Scheme is an industry-led EPR system operated by Re-turn.

The system launched on 1 February 2024. It uses a refundable deposit to encourage consumers to return eligible plastic bottles and metal cans for separate collection and recycling.

The scheme connects several parties:

The current scheme applies to:

• PET plastic beverage bottles
• Aluminium beverage cans
• Steel beverage cans
• Capacities from 150 ml to 3 litres
• Containers displaying the Re-turn logo

The current statutory scope excludes plastic beverage bottles that are not made from PET and metal containers that are not designed to contain a beverage.

DRS scope summary

Milk and other dairy-based drinks are excluded from the legal definition of covered beverages. Glass containers are also outside the current Irish DRS.

Two deposit values currently apply:

The deposit is added to the product price and refunded when an eligible empty and undamaged container is returned.

The deposit should remain separate from the underlying product price in the commercial and accounting process.

The DRS producer is generally the business first placing the in-scope product on the Irish market.

A producer may need to:

• Register with Re-turn
• Enter into the producer agreement
• Register each in-scope product
• Provide product and packaging information
• Use an approved barcode
• Apply the Re-turn logo
• Report units placed on the market
• Pay the producer fee
• Pay the deposit fee for each in-scope unit
• Maintain sales and packaging records
• Notify Re-turn of product or packaging changes

Re-turn states that the producer pays both a producer fee and the deposit fee for each in-scope drink placed on the market. The deposit is then passed through the distribution chain and recouped from the next purchaser.

Producer-registration process

1. Register the producer organisation.
2. Submit required company information.
3. Sign the producer agreement.
4. Receive approval.
5. Access the product-registration portal.
6. Register in-scope products and packaging formats.
7. Complete barcode and logo requirements.
8. Begin reporting market quantities.

A producer is approved to register products after its producer agreement has been completed and accepted.

Businesses should maintain a controlled record for every DRS product.

Recommended DRS product data

A new barcode, container capacity, material, or product format should trigger a registration and compliance review.

A distributor selling or supplying in-scope products to retailers, hospitality businesses, or other commercial customers must register with Re-turn and operate in accordance with the scheme’s requirements.

Distributor controls should include:

• Purchasing only registered in-scope products
• Checking that packaging carries the Re-turn logo
• Passing the deposit through the supply chain
• Maintaining product and customer data
• Separating deposits from product pricing
• Retaining invoices and transaction records
• Avoiding the distribution of unregistered stock
• Controlling returns and credits

Distributors should ensure that deposit amounts shown on purchase and sales documentation reconcile with the number of in-scope units supplied.

Any retailer selling in-scope drinks on premises, for take-away, or online must register with Re-turn. Unless the retailer has been granted a take-back exemption, it must provide a deposit-return service to consumers.

A retailer providing take-back can use:

• A reverse vending machine
• A manual return process

Retailer responsibilities

The consumer does not need to return the container to the same retailer from which it was purchased. Eligible containers can be returned through participating return points.

All retailers selling in-scope drinks must register, even where they intend to apply for a take-back exemption.

Re-turn’s exemption framework allows qualifying retailers with retail space of 250 square metres or less to apply for an exemption. Food-to-go businesses, hospitality premises, online retailers, and vending-machine operators may also have exemption routes subject to relevant conditions.

A retailer granted an exemption may need to:

• Display a take-back exemption notice
• Clearly identify a nearby return point
• Display a QR-code locator or Re-turn information
• Keep its Re-turn registration active
• Continue charging the correct deposit
• Update consumer information when return locations change

Exemption from operating a return point does not mean exemption from registration or deposit charging.

Online retailers selling in-scope drinks must register with Re-turn.

Online retailers may apply for a take-back exemption where it is not practical to collect empty containers at delivery. The exemption framework requires online sellers to provide customers with access to information identifying available return points, such as a QR code or Re-turn website information on receipts or sales documentation.

Online retailer controls

• Confirm that every in-scope SKU is registered
• Add the correct deposit at checkout
• Display deposit information before purchase
• Record deposits separately on invoices
• Maintain Irish delivery quantities
• Provide return-point information
• Apply for a take-back exemption where appropriate
• Retain exemption approval
• Update product pages after barcode or packaging changes

Online sellers should also ensure that fulfilment providers do not substitute unregistered packaging or stock intended for another market.

Hotels, restaurants, cafés, pubs, bars, and other hospitality operators selling in-scope drinks must register with Re-turn.

For drinks opened and consumed on the premises, hospitality businesses can use the available deposit-charging exemption arrangement, provided the containers remain on the premises and are managed within the hospitality system. The deposit obligation applies where products are sold for off-site consumption or take-away.

Hospitality businesses may also receive a take-back exemption but must meet the required consumer-information conditions.

Hospitality questions to assess

Consumers should generally return containers that are:

• Empty
• Undamaged
• Uncrushed
• Carrying a readable barcode
• Carrying the Re-turn logo
• Within the eligible material and capacity scope

Re-turn’s consumer guidance states that eligible containers must be empty and undamaged to receive the refund.

If a barcode or label is unreadable, the return system may not be able to confirm the container’s eligibility.

Repak and Re-turn are separate compliance systems, but their data should be aligned.

A company should avoid using one product quantity in its Re-turn report and a different sales figure in its packaging EPR calculations without documented justification.

Recommended reconciliation

1. Extract Irish beverage sales by SKU.
2. Confirm the product’s Re-turn registration status.
3. Apply the correct deposit value.
4. Reconcile Re-turn units with Irish sales.
5. Link each unit to its packaging weights.
6. Calculate packaging tonnage for Repak purposes.
7. Separate DRS and non-DRS packaging where required.
8. Review exports, returns, samples, and promotional stock.

Approve both datasets through the same governance process.

Ireland’s Single-Use Plastics regulations add obligations for certain packaging formats.

The Irish packaging EPR scheme is responsible for litter-clean-up costs associated with specified single-use-plastic packaging, including certain food containers, beverage containers, cups, packets and wrappers, and lightweight carrier bags. The rules also contain design, labelling, recycled-content, and separate-collection requirements for relevant products.

Businesses should identify whether their packaging includes:

• Single-use beverage containers
• Food containers
• Beverage cups
• Packets and wrappers
• Lightweight carrier bags
• Wet wipes or balloons subject to separate EPR schemes
• Tobacco products containing plastic

Single-use-plastic data should be connected to the main packaging inventory rather than managed in an unrelated spreadsheet.

The PPWR applies generally from 12 August 2026 and establishes EU-wide rules covering packaging sustainability and labelling across production, use, and waste management. It is intended to reduce unnecessary packaging and support reuse, refill, and recycling.

PPWR requirements include areas such as:

• Substances in packaging
• Recyclability
• Recycled content
• Compostable packaging
• Packaging minimisation
• Empty-space limitations
• Harmonised labels
• Restricted packaging formats
• Reuse and refill
• Technical documentation
• EU Declarations of Conformity
• Producer registration and EPR reporting
• Online marketplace checks

Repak membership and Re-turn registration do not automatically prove compliance with these design and documentation requirements.

Practical 2026 approach

Companies should:

1. Maintain current Repak membership and reporting.
2. Continue complying with Re-turn requirements.
3. Build a complete packaging bill of materials.
4. Identify the responsible PPWR manufacturer and producer.
5. Review technical-documentation requirements.
6. Assess recyclability and future recycled-content obligations.
7. Review packaging minimisation and e-commerce empty space.
8. Prepare for harmonised EU packaging labels.
9. Monitor Irish implementation and Repak guidance.
10. Maintain one controlled dataset supporting Irish and EU obligations.

Repak describes the PPWR as introducing updated responsibilities and reporting requirements for packaging placed on the market, with stricter design, labelling, reporting, and recycling expectations.

A business should maintain technical packaging evidence even where its immediate EPR requirement is primarily financial or data-based.

A packaging evidence file can include:

• Packaging description
• Packaging level
• Product and SKU mapping
• Bill of materials
• Component weights
• Supplier specifications
• Material declarations
• Substance evidence
• Recyclability assessment
• Recycled-content evidence
• Packaging-minimisation assessment
• Reusable-packaging documentation
• Artwork and label records
• Barcode and Re-turn registration
• Repak statistical-return evidence
• Change history

The Irish packaging framework also contains essential requirements covering packaging prevention, recovery, recycling, and reuse.

The PPWR further increases the importance of structured technical evidence and conformity assessment.

Step 1: Map the Irish supply chain

Identify:

• Manufacturers
• Packers and fillers
• Brand holders
• Importers
• Distributors
• Retailers
• Online sellers
• Beverage producers
• Hospitality businesses
• Fulfilment providers

Step 2: Assess major-producer status

Calculate annual turnover and the total weight of packaging placed or supplied on the Irish market.

Step 3: Determine the Repak membership route

Confirm whether the business requires regular or scheduled membership.

Step 4: Build a complete packaging inventory

Include primary, secondary, tertiary, e-commerce, service, reusable, and DRS packaging.

Step 5: Create a packaging bill of materials

Record every component, material, weight, supplier, and packaging version.

Step 6: Connect packaging to sales

Link approved packaging weights to Irish product quantities.

Step 7: Establish Repak reporting controls

Prepare the twice-yearly statistics and maintain supporting records.

Step 8: Assess Re-turn scope

Identify PET bottles and aluminium or steel cans between 150 ml and 3 litres.

Step 9: Register DRS participants

Register the producer, distributor, retailer, or other relevant organisation.

Step 10: Register products

Complete barcode, packaging, logo, and product registration before launch.

Step 11: Configure deposits

Apply €0.15 or €0.25 based on container capacity.

Step 12: Establish retailer take-back

Provide manual or automated return services or obtain the appropriate exemption.

Step 13: Reconcile Repak and Re-turn data

Use consistent Irish market quantities across both systems.

Step 14: Prepare for PPWR

Assess recyclability, recycled content, minimisation, labelling, documentation, and producer-registration requirements.

Step 15: Maintain change control

Reassess compliance whenever the business changes:

• Packaging material
• Packaging weight
• Supplier
• Barcode
• Container capacity
• Re-turn artwork
• Product formulation
• Legal entity
• Sales channel
• Irish market route

Ireland packaging compliance requires connected data across products, packaging components, suppliers, legal entities, Repak returns, Re-turn registrations, deposits, retailer obligations, and PPWR requirements.

ComplyMarket’s packaging compliance approach supports organisations managing different national rules, EPR obligations, labelling requirements, supplier data, technical documentation, and reporting deadlines within a structured compliance process.

ComplyMarket can help companies with:

• Ireland packaging EPR applicability assessments
• Major-producer threshold reviews
• Repak membership readiness
• Producer and supply-chain role mapping
• Packaging inventory development
• Packaging bill-of-materials management
• Material and component weight data
• Product-to-packaging mapping
• Supplier specifications and declarations
• Repak statistical-return inputs
• Packaging quantity calculations
• DRS product-scope assessments
• Re-turn producer, distributor, and retailer records
• Deposit-value management
• Barcode and artwork evidence
• Retailer exemption documentation
• Online and hospitality sales controls
• Repak and Re-turn data reconciliation
• Single-use-plastic data management
• PPWR readiness assessments
• Technical-documentation and change control
• Audit-ready compliance evidence

ComplyMarket’s EPR management framework also focuses on jurisdiction-level applicability control, producer master data, quantity reporting, evidence management, deadlines, and audit-ready records.

For companies managing many products, packaging formats, suppliers, and European markets, this creates one controlled packaging-data process rather than separate spreadsheets for Repak, Re-turn, supplier evidence, and PPWR assessments.