Deposit System vs. Hospitality: What to Expect After October 1, 2025?

Deposit-Return System vs Gastronomy: What to Expect After October 1, 2025

On October 1, 2025, the deposit-return system will come into force in Poland. In practice, this means that beverages sold in bottles and cans will include an added deposit, which must then be refundable to the customer. That’s the simplified version. It seems straightforward, but not entirely. For businesses in the gastronomy and retail sectors, this is a concrete challenge.

 

Do you run a restaurant, catering service, food truck, or sell drinks in bottles and cans? Sit back and read this blog. This text is for you.
We’re not going to go on about ecology here. We’re talking specifically about money, obligations, and the logistics that await you.

 

Do you have to pay a deposit for the 0.5L water your employees drink?

 

What about bottles from lemonade served on the spot?

 

Do you have to accept empty packaging?

 

We explain everything—clearly, in plain language, with the hospitality industry in mind. No legal jargon, no nonsense.

 

What exactly is this deposit system?

 

In a nutshell - you buy a drink somewhere, pay a deposit, drink it, return the bottle, and get your money back. That’s it.

 

A deposit is simply an additional fee added to the price of a drink in a plastic bottle, can, or reusable glass bottle. To be clear—it’s not a tax. The money doesn’t go to the state budget. It’s money that circulates and is meant to be returned to the customer if they return the empty packaging to a so-called collection point.

 

The most important thing! Remember, it’s not the customer’s job to figure out how this works. You, as the seller or introducer, have to do it for them.
You must collect the deposit if you are the introducer—properly label the product, settle accounts with the system, and (if required) accept returned packaging.

 

The deposit system is not optional—it’s an obligation for companies selling drinks in containers covered by the new regulations, starting from October 1, 2025.

 

Which containers will be subject to a deposit?

 

To t’s not the case that you’ll have to pay a deposit for everything with a cap or a lid.

 
The legislator has chosen a very specific group of drink containers that will be subject to the new regulations.

Here’s the list:

  • Single-use plastic bottles – up to 3 liters,

  • Metal cans – up to 1 liter,

  • Reusable glass bottles – up to 1.5 liters.

     

But beware—not only the container matters, but also what’s inside. The deposit applies only to containers with drinks such as:

  • water,

  • carbonated drinks (including still drinks),

  • juices,

  • nectars,

  • isotonic drinks,

  • energy drinks,

  • and other concoctions—if consumed cold.

And what is not subject to a deposit?

 

  • Cartons (e.g., Tetra Pak) – not yet,

  • Bottles for milk and dairy drinks (e.g., buttermilk, kefir, drinking yogurt, ayran) – these are excluded,

  • Bottles for soy sauce, oil, syrups, soups - in other words, anything that is not considered a “drink” under the regulations,

  • A traditional sushi bottle (including the fish-shaped one) can rest easy. No deposit will be charged for it.

 

How much is the deposit? And what about VAT?

 

Deposit amount per container:

 
Container Type Deposit (PLN) Deposit (EUR)
Single-use plastic bottle (up to 3 liters) 0.50 zł 0.12 €
Metal can (up to 1 liter) 0.50 zł 0.12 €
Reusable glass bottle (up to 1.5 liters) 1.00 zł 0.23 €
Rodzaj opakowania Kaucja
Plastikowa butelka jednorazowa (do 3 l) 0,50 zł
Puszka metalowa (do 1 l) 0,50 zł
Butelka szklana wielokrotnego użytku (do 1,5 l) 1,00 zł
 
 

The deposit is added to the price of the drink and refunded to the customer if they return the empty container at any collection point (no receipt needed, just the marking).

 

And what about VAT?

According to the interpretation of the Ministry of Finance and confirmation on gov.pl: 

The deposit is not subject to VAT if it is refundable and returned to the customer.”

 

In summary:

  • If you collect a deposit for a bottle/can, you do not add VAT to it,

  • But only if you can actually refund it to the customer later.

Note: the deposit must be recorded separately (e.g., on a receipt or invoice) – not as part of the drink’s price.

 

What does the marking look like?

The customer must know that when purchasing a given drink, they pay a deposit but can also get it back. How will they know? Every container subject to the deposit system must have the appropriate marking.

 

What does the marking on the container look like?

 

  1. The word “Deposit” (or “D”) – clearly visible, in a prominent place, not hidden or in fine print.

  1. Deposit amount – e.g. “Deposit: PLN 0.50”.

  1. System symbol – i.e. the graphic mark provided by the system operator. 

All these elements must be placed on the front or clearly on the side. We cannot play aesthetes here and hide these markings under the label or the cap.

 

If the packaging does not bear the marking:

  • you cannot sell the beverage within the deposit system,

  • the customer cannot return it and will not get the deposit back,

  • while you risk trouble (inspection, fines, suspension of sales).

Each system operator will provide templates that must be applied to labels or packaging in the appropriate place and format.

 

Is your food service business a “beverage introducer”? (do you need to worry about this)

 

This is one of those questions that initially feels scary, like an environmental driving test, but actually the answer is quite simple – it depends on what you do with the beverages.

 

 

According to Art. 8, point 21a of the Act of 13 June 2013 on Packaging and Packaging Waste (consolidated text: Journal of Laws 2024, item 927): “beverage packaging introducer” – means an entrepreneur who, in the course of their business activity, places products in beverage packaging on the market for the first time in the territory of the Republic of Poland, including free-of-charge

 

Now, something from real life:

- If you bottle beverages yourself (e.g., lemonade, juice, water) and sell them to a customer…

Yes. You are a beverage introducer and have obligations.

  • If you buy beverages in bottles or cans and resell them (e.g., through catering, for takeout delivery, in your company store, or wholesale)...

         -> You are not a beverage introducer – you do not produce or import beverages,

         -> But you are a seller and must collect the deposit at every stage of the chain – regardless of whether your customer is the end user or another business.

  • If the customer consumes the beverage “on-site” and the bottle/can remains with you…

         -> Then you are the end user, not the customer. You pay the deposit, but you can also reclaim it.

 

  • If you simply buy water for your employees (e.g., a case of water for the office) – No. You are not a beverage introducer. You don’t have to do anything. You pay the deposit where you purchased the beverage.

 

What do you need to do as a food service business?

 

Here you need to distinguish whether you are introducing beverages to the market or just reselling them to customers.

If you independently bottle or can beverages (e.g., lemonade, juice, water) and sell them, you are considered a beverage introducer.

Musisz: 

 

  • Register with the deposit system operator (here is the LIST).

  • Collect a deposit from the end customer,

  • Place a special deposit marking on the packaging,

  • Settle accounts with the operator and report in BDO.

     

Other than that, you don’t need to do anything – the system operator handles all the logistics.

 

 

If you buy ready-made beverages from Polish producers (e.g., water, juices, soft drinks) and sell them to your customers:

You are not an introducer, but you still must collect a deposit, regardless of whether your customer is the end user or not.

 

In practice:

  • You collect a deposit when selling a beverage in packaging covered by the system,

  • You allow the customer to return the packaging and get the deposit back, but this depends on the size of your sales area:

  • If your premises/store has a sales area of over 200 m²

    • You must allow the return of packaging and refund the deposit to the customer.

  • If your premises/store has a sales area of less than 200 m²

    • You are not required to accept returns of plastic bottles and cans.

    • Exception: if you sell reusable glass bottles – then you must accept their return.

What about online purchases?

 

Do you sell beverages exclusively online? The deposit system still applies to you, but without any unnecessary stress, because:

 

  • You must charge a deposit - just like any other seller.

  • You don’t need to operate your own collection point.

     

What are the consequences of inaction?

 

Do you think, “It’ll be fine” or “Maybe no one will notice”? You might get away with it, but unfortunately—if not, there are real consequences:

  • Product fee

It sounds harmless and almost painless, but it’s actually a financial penalty for not participating in the system.

Haven’t you reached the required collection rate (e.g., 77% in 2025 or 90% in 2029)? You pay—and it’s steep.

  • Official inspections

Everything can be checked—BDO records, settlements, cooperation with the operator.

 

Didn’t manage it? Get ready for a painful administrative decision.

  • Sales ban

Not in the system? Not labeling your packaging? You cannot legally sell beverages in bottles or cans subject to a deposit.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

FAQ – Frequently Asked Questions

Which packaging is subject to a deposit?

PET bottles up to 3 L, cans up to 1 L, and reusable glass bottles up to 1.5 L.

 

Do I have to accept empty containers in a small shop or kiosk?

If your shop is larger than 200 m², yes. If smaller—you can, but you don’t have to. 

 

Do storage areas, restrooms, or utility rooms count toward the 200 m²?

No. Don’t worry—it’s not about the entire premises, nor the backroom or storage areas.

Only the areas where customers can make purchasing decisions count: the sales floor, showroom, or the place where you actually sell beverages.  For example, if you have an 87 m² sales area and a 188 m² storage area—you don’t have to accept returns (because your sales area doesn’t exceed 200 m²).

 

What happens to a deposit that a customer doesn’t collect?

 It goes to the operator and will be used to develop the system.

 

What’s the point of this system in the first place?

To reduce plastic waste, improve recycling, and achieve the EU’s climate goals.

 

What does the labeling of containers covered by the system look like?

Containers covered by the deposit system will feature special markings. You can find the template here:

 

How can I reclaim the deposit?

You can reclaim the deposit at a collection point. This can be done at any store or retail outlet larger than 200 m². Smaller establishments charge the deposit but are not required to collect containers.

 

Do I need a receipt to reclaim the deposit?

The collection point will only verify whether the container is part of the deposit system. A receipt or any other proof of purchase is not required to reclaim the deposit.

 

Can I crush the bottle or can before returning it?

It’s better not to. The container must be empty and identifiable—not damaged or crushed, with the deposit marking clearly visible.

 

Can I return a container purchased before October 1, 2025, under the system?

No, such containers will not be accepted at collection points. Deposits can only be reclaimed for containers marked with the deposit system pictogram.