Packaging rule · European Union · Deposit return
PPWR: 90% separate collection of beverage containers (deposit systems)
Deposit return rule covering plastic, metal in the European Union, set by European Parliament and Council of the EU. Adopted; applies from 1 January 2029.
The rule
Recorded from the official source named below. Rates and dates are as the source states them on the date it was consulted.
- Jurisdiction
- European Union
- Authority
- European Parliament and Council of the EU
- Rule type
- Deposit return
- Materials
- Plastic, Metal
- Status
- Adopted, not yet applying Enacted
- Rate or target
- 90%Annual separate collection rate by weight, single-use plastic bottles and metal cans up to 3 litres.
- Adopted or published
- 19 December 2024
- Applies from
- 1 January 2029
From the source“By 1 January 2029 at the latest, Member States shall take the necessary measures to ensure the separate collection of at least 90%, per year, by weight of single-use metal and plastic beverage packaging”
Official source European Parliament Legislative Observatory: Regulation (EU) 2025/40 summaryOfficial (government or regulator) · consulted 13 October 2026
Key dates
Adopted or published 1 year and 9 months ago
Source consulted by the SPI team 2 days ago
Re-checked by a second SPI team member 2 days ago
Today
Applies from in 2 years and 2 months
What it means
SPI analysis Our reading of the official source above. Not legal advice; always rely on the official text.
SPI summary
By 1 January 2029 Member States must ensure separate collection of at least 90% by weight of single-use plastic and metal beverage containers up to three litres, in principle via deposit return systems.
In practice
By 1 January 2029 each Member State must separately collect at least 90% by weight per year of single-use plastic and metal beverage containers up to three litres, and where that cannot be reached by other means a deposit return system is to be set up. For fillers and brand owners of bottled and canned drinks this usually means joining a national deposit scheme, paying fees, and adding scheme labels to packs. Converters may see changes in specifications driven by deposit labelling and return-machine requirements.
Where the record is unclear
- The Legislative Observatory page does not mention deposit systems. The obligation to set up a system where the target is not met by other means is taken from the Commission facts page and recital 142; SPI has not yet checked Article 50 for this note.
- Exact conditions for the 80% exemption and for pre-existing systems are described only in recitals on the opened pages.
- The harmonised label for deposit packaging depends on an implementing act listed as due by 12 August 2026; its status is not given.
Where it sits in the tracker
- One of 18 packaging rules we track in the European Union, of which 1 are deposit return rules.
- In all, 7 deposit return rules are tracked across 6 jurisdictions. Compare them below
Company profiles that map to this rule
Companies whose SPI profile lists this rule in its regulatory exposure, based on where they report selling. Not company-reported.
Overview
Article 50 of Regulation (EU) 2025/40 turns beverage container collection into a result each Member State must deliver, with a fixed delivery mechanism. By 1 January 2029 at least 90% by weight per year of single-use plastic beverage bottles up to three litres, and of single-use metal beverage containers up to three litres, must be separately collected (Article 50(1)), and Member States must set up deposit and return systems that charge a deposit at the point of sale for those formats (Article 50(2))2. The only route out of the deposit obligation is performance based: a separate collection rate of 80% or more by weight for packaging first placed on the market in 2026, plus a notification and an implementation plan sent to the Commission by 1 January 2028 (Article 50(5))2.
The recitals give the policy reason. Well run deposit systems reach very high collection rates and cleaner recycling streams, and they support the 90% bottle collection target already written into Directive (EU) 2019/904 (recital 141)1. Article 50(11) and Annex X then add minimum design requirements for single-use deposit systems, so that schemes across the Union converge on consistent labelling, deposit handling and return points (recital 145)12. Member States keep room to go further, for example by adding single-use glass bottles or charging a deposit for drinks served in hospitality (recital 142)1.
Who must do what
Member States
- Reach at least 90% separate collection by weight per year for single-use plastic bottles and single-use metal beverage containers up to three litres by 1 January 2029 (Article 50(1)).
- Establish deposit and return systems for those formats and require a deposit at the point of sale, unless the Article 50(5) exemption applies (Article 50(2)).
- Bring every single-use deposit system into line with the Annex X minimum requirements by 1 January 2029 (Article 50(11)); a system that predates the Regulation is spared only if it reaches 90% by that date.
- Report the separate collection rate under Article 56(1)(c); the 2026 figure is the one the 80% exemption test relies on.
Final distributors of drinks
- Charge the deposit on in-scope containers in any Member State that runs a system, including to shoppers resident in another Member State; the Commission reads deposit charging and the system as cumulative (guidance section 28).
- Accept deposit-bearing packaging of the material and format sold and pay out redeemed deposits, unless end users have equally accessible authorised return points (Annex X, point (l)).
Beverage brand owners and fillers
- Carry the harmonised label for deposit packaging set by the implementing act under Article 12(6), which the Commission timeline lists as due by 12 August 20264.
- Operate inside the national deposit system wherever the Member State has not obtained an Article 50(5) exemption, since the deposit is levied on every in-scope container sold there2.
Are you in scope?
Work through each question. The answers are the SPI team's reading of the sources cited.
Is the container a single-use plastic beverage bottle holding up to three litres?
- If yes
- It counts toward the Article 50(1)(a) collection rate and falls inside the mandatory deposit system.
- If no
- Larger or reusable bottles sit outside Article 50(1), although a Member State may add other formats nationally (recital 142).
Is it a single-use metal beverage container, such as a can, of up to three litres?
- If yes
- It is covered by Article 50(1)(b), so metal joins plastic in the 90% rate.
- If no
- Single-use glass bottles are not mandatory, but Member States may choose to include them (recital 142).
Does the container hold wine, aromatised wine products, spirit drinks, or milk and milk products?
- If yes
- Recital 144 says a deposit system is not mandatory for these products, though a Member State may still cover them.
- If no
- The general Article 50 rule applies.
Did the Member State separately collect 80% or more of the format in 2026 without a deposit system?
- If yes
- It may notify the Commission and file a plan with measures and a timeline by 1 January 2028 to avoid setting up a system (Article 50(5)).
- If no
- A deposit system must be running by 1 January 2029.
Was the national system established before the Regulation entered into force on 11 February 2025?
- If yes
- It is exempt from Annex X only if it reaches 90% by 1 January 2029; otherwise Annex X applies by 1 January 2035 at the latest.
- If no
- The system must meet Annex X by 1 January 2029 (Article 50(11)).
Compliance checklist
Map in-scope containers by Member State
By NowSPI analysis of the official text. Not legal advice; confirm with the text or counsel. List each single-use plastic bottle and metal container of three litres or less sold in each Member State, and flag wine, spirits and dairy lines that recital 144 treats separately.
Evidence to keep SKU register with volume, material, product category and country of sale.
Watch for 80% exemption filings
By 2028-01-01Member States hoping to skip a deposit system must notify the Commission with an implementation plan by this date. The filings show where new schemes are, and are not, coming.
Evidence to keep Dated log of national notifications and scheme launch announcements per market.
Plan deposit label artwork
By When the Article 12(6) act appliesThe implementing act on harmonised labels for deposit packaging was listed as due by 12 August 2026; its adoption status was not shown on the timeline consulted. Budget an artwork cycle once the final design is published.
Evidence to keep Artwork change schedule linked to the act's reference and application date.
Set up deposit charging at checkout
By 2029-01-01Final distributors in a deposit Member State charge the deposit on every in-scope container, including sales to residents of neighbouring Member States, as the guidance reads Article 50(2).
Evidence to keep Till and webshop configuration records showing the deposit line per container.
Organise take-back and refunds
By 2029-01-01Annex X, point (l) expects final distributors to take back the material and format they sell and pay out deposits unless equally accessible authorised return points exist.
Evidence to keep Return point inventory, refund reconciliation and scheme membership contract.
Test an older national scheme against 90%
By 2029-01-01Where a scheme predates 11 February 2025 and misses 90% on this date, Annex X compliance follows by 1 January 2035, which can change return rules, deposit values and labels.
Evidence to keep Annual national collection rate reported under Article 56(1)(c).
Enforcement and penalties
- Who enforces
- Member States carry the Article 50 result; the European Commission receives their collection data and any Article 50(5) notification and implementation plan.
- Powers
- Each Member State writes the deposit rules that bind retailers, producers and system operators, including deposit levels and return duties within the Annex X minimums. The Commission assesses exemption notifications filed by 1 January 2028.
- Enforcement so far
- No Member State was shown as holding an Article 50(5) exemption on the Commission pages opened on 14 October 2026.
Article 50 places the 90% duty on Member States, so it fixes no fine for a company. Sanctions for a retailer that skips the deposit or refuses returns, or a producer that stays outside a scheme, come from the national law that creates each system. SPI has not yet confirmed the wording of the penalties article of Regulation (EU) 2025/40 against the official text, so it is not quoted here.
How it fits with other rules
- Directive (EU) 2019/904, Article 9 (separate collection of beverage bottles)
Article 9 of the SUP Directive already required 77% separate collection of Part F plastic bottles by 2025 and 90% by 2029, naming deposit refund schemes as one tool. Article 50 keeps the 90% figure for plastic bottles, adds metal containers and makes a deposit system the default rather than an option. - SUP Directive: recycled content in plastic beverage bottles PR-EU-016
Recital 141 credits deposit systems with higher quality recycling. That matters for the SUP Directive's 25% and 30% recycled content averages for bottles, which need a clean recycled PET stream to be met. - Ireland Deposit Return Scheme (Re-turn) PR-IE-001
Ireland's Re-turn system and Austria's scheme (PR-AT-001) were running by 2025. Whether a national system counts as established before 11 February 2025 decides whether it can avoid Annex X by hitting 90% in 2029 or must align with it by 2029 regardless. - Poland deposit return system PR-PL-001
Poland's system from October 2025 and Portugal's Volta (PR-PT-001) from April 2026 also cover reusable formats in part. Recital 142 asks Member States to extend single-use systems to reusable packaging where feasible, so these designs show how far beyond the Article 50 minimum a scheme can go. - PPWR: 2030 reuse targets for transport and grouped packaging PR-EU-006
The Article 29 reuse targets for beverages run alongside Article 50. Deposit systems for reusable formats are one of the measures recital 149 lists for meeting them, so one deposit infrastructure can serve both rules.
History of the rule
Directive (EU) 2019/904 published; Article 9 sets 77% by 2025 and 90% by 2029 separate collection for plastic beverage bottles.
Commission proposes the packaging regulation, COM(2022) 677.
European Parliament closes its first reading on the negotiated text (T9-0318/2024).
Council adopts the act; it is signed on 19 December 2024.
Official Journal publication of Regulation (EU) 2025/40, with entry into force twenty days later.
Reference year: the separate collection rate for packaging first placed on the market in 2026 decides eligibility for the 80% exemption.
Regulation applies; the implementing act on deposit labels under Article 12(6) was due by this date.
Today
Deadline for Member States to notify an Article 50(5) exemption with an implementation plan.
90% separate collection rate and Annex X minimum requirements apply.
Latest date for older schemes that missed 90% in 2029 to comply with Annex X.
Questions
Does every EU country need a bottle and can deposit system by 2029?
By default yes: Article 50(2) requires deposit and return systems for single-use plastic bottles and metal beverage containers up to three litres by 1 January 2029. A Member State can avoid one only if it separately collected 80% or more of the format in 2026 and notifies the Commission with a plan by 1 January 2028.
Are wine, spirits and milk containers covered by mandatory deposits?
Recital 144 of Regulation (EU) 2025/40 says deposit systems are not mandatory for wine, aromatised wine products, spirit drinks, and milk and milk products. A Member State may still include them in its 2029 system if it chooses.
Must a shop charge the deposit to a tourist from another EU country?
Yes, according to the Commission guidance published on 10 June 2026. It reads the deposit duty and the system as cumulative, so a final distributor in a deposit Member State charges the deposit on every in-scope container, whoever buys it.
Do existing deposit schemes have to change their rules?
A scheme that predates the Regulation is exempt from the Annex X minimum requirements only if it reaches 90% separate collection by 1 January 2029. If it misses that rate, it must comply with Annex X by 1 January 2035 at the latest.
Is a glass bottle part of the 90% target?
No. Article 50(1) names single-use plastic bottles and single-use metal containers of up to three litres only. Recital 142 lets a Member State add single-use glass bottles to its deposit system, which some may do before or after 2029.
Definitions
- deposit and return system
- A system under which a deposit is charged when the product is bought and redeemed when the packaging is returned through an authorised collection channel (Article 3(1), point (62)).2
- Packaging
- Defined in EU Packaging and Packaging Waste Regulation (PPWR) applies PR-EU-001
- Placing on the market
- Defined in EU Packaging and Packaging Waste Regulation (PPWR) applies PR-EU-001
- Making available on the market
- Defined in EU Packaging and Packaging Waste Regulation (PPWR) applies PR-EU-001
Sources for this analysis
- EUR-Lex: Regulation (EU) 2025/40, OJ L 22.1.2025 Official · Consulted 14 October 2026
- EUR-Lex: Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40, sections 28 to 30 Official · Consulted 14 October 2026
- European Parliament Legislative Observatory: Regulation (EU) 2025/40 summary Official · Consulted 14 October 2026
- European Commission Green Forum: PPWR implementation timeline Official · Consulted 14 October 2026
- EUR-Lex: Directive (EU) 2019/904, Article 9 Official · Consulted 14 October 2026
- European Parliament Legislative Observatory: procedure file 2022/0396(COD) Official · Consulted 14 October 2026
- European Commission (DG ENV): Facts about the new EU rules on packaging and packaging waste Consulted 13 October 2026
- European Commission (DG ENV): Packaging waste Consulted 13 October 2026
- EUR-Lex: Summaries of EU legislation, Packaging and packaging waste (from 2026), last updated 26.9.2025 Consulted 13 October 2026
Written by the SPI team on 14 October 2026. Sources checked as of 14 October 2026. SPI analysis, not legal advice; always rely on the official text.
Change history
Verified: a second SPI team member re-checked every fact above against the source on 13 October 2026. Any later change to the facts sends the rule back to Sourced and is logged here.
Verified by a second SPI team member
Added to the tracker
Spotted an error? Write to sales@strategicpackaginginsights.com quoting PR-EU-007 and the source. Corrections are logged in this history.
Deposit return rules elsewhere
The same type of rule for the same materials in other jurisdictions, by the date it applies.
| Rule | Where | Type | Materials | Status | Applies from |
|---|---|---|---|---|---|
| Ireland Deposit Return Scheme (Re-turn)PR-IE-001 | Ireland | Deposit return | Plastic, Metal | In force | 1 February 2024 |
| Austria deposit on single-use beverage containersPR-AT-001 | Austria | Deposit return | Plastic, Metal | In force | 1 January 2025 |
| Poland deposit return systemPR-PL-001 | Poland | Deposit return | Plastic, Metal, Glass | In force | 1 October 2025 |
| Portugal deposit and refund system (Volta)PR-PT-001 | Portugal | Deposit return | Plastic, Metal | In force | 10 April 2026 |
| Scotland deposit return scheme start moved to October 2027PR-GB-005 | Scotland, United Kingdom | Deposit return | Plastic, Metal | Adopted, not yet applying | 1 October 2027 |
| Deposit return scheme for drinks containers (England and Northern Ireland)PR-GB-004 | England, Northern Ireland, United Kingdom | Deposit return | Plastic, Metal | Adopted, not yet applying | 1 October 2027 |
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