Four deposit return schemes now run in the tracked EU markets, and the UK's four nations start together in October 2027

What the EU now requires

Under Article 50(1) of the PPWR, which has applied since 12 August 2026, each Member State must separately collect at least 90% by weight per year of single-use plastic beverage bottles and single-use metal beverage containers up to three litres by 1 January 2029. Article 50(2) then requires a deposit and return system that charges a deposit at the point of sale (Commission Notice C/2026/3084, section 28, which quotes the article).

The only route out is performance. Under Article 50(5), a Member State that separately collects 80% or more by weight for packaging first placed on the market in 2026 may notify the Commission, with an implementation plan, by 1 January 2028. Recital 144 says deposit systems need not cover wine, spirits and milk products, and recital 142 lets Member States add single-use glass or hospitality drinks.

Article 50(11) and Annex X add minimum design requirements, such as consistent labelling and deposit handling, which apply by 1 January 2029. A system that predates the Regulation is spared only if it reaches 90% by that date; otherwise it must align with Annex X by 1 January 2035 at the latest. No Member State was shown as holding an Article 50(5) exemption on the Commission pages consulted on 14 October 2026 (SPI rule note, PR-EU-007).

Packaging in a deposit system is also to carry a harmonised label under Article 12(6), with an implementing act listed for 12 August 2026 on the Commission’s timeline. SPI has not yet confirmed that the deposit label act has been adopted; the PPWR after 12 August 2026 piece tracks the act timetable.

Deposits and scope, scheme by scheme

Ireland

Ireland’s scheme went live on 1 February 2024 and now rests on the Separate Collection (Deposit Return Scheme) Regulations 2024, S.I. No. 33 of 2024, made on 31 January 2024. Regulation 25 revoked the 2021 Regulations, S.I. No. 599 of 2021, and S.I. No. 555 of 2024 later amended the distributor definition, exemption register, enforcement and deposit schedule (Irish Statute Book). The government set the deposit at 15 cent from 150 ml to 500 ml and 25 cent from 500 ml to 3 litres (gov.ie); Re-turn’s wholesaler FAQ places a 500 ml container in the 15 cent band.

Producers join Re-turn before placing products, register each product with barcode, dimensions and materials, report monthly, and pay the deposit plus a per-unit fee that varies by material but not by size (Re-turn producer page). Stores of 250 square metres or less may agree an exemption from take-back under Regulation 17, but still charge the deposit. At launch the government expected “more than 2,000 return points”.

Austria

Austria’s Pfandverordnung, BGBl. II Nr. 283/2023, has charged EUR 0.25 per container since 1 January 2025 on single-use plastic and metal beverage containers of 0.1 to 3 litres (PR-AT-001). First placers, including mail-order sellers without an Austrian seat, register each container type with the central body, pay a per-container producer contribution set at least yearly, and mark each container with a barcode and the deposit symbol. The central body, EWP Recycling Pfand Österreich gGmbH, keeps unclaimed deposits and material revenue to fund its tasks (section 11), and pays retailers a handling fee (section 12).

Poland

Poland built its system into the packaging act through Dz.U. 2023 poz. 1852 and started it on 1 October 2025, a date set by Dz.U. 2024 poz. 1911 (ministry reply to Sejm interpellation 6943). Unlike a single national operator, Poland licenses several operators, each a Polish joint-stock company with share capital of at least PLN 5,000,000 and a permit of up to 10 years. Shops over 200 m2 take back containers; smaller shops charge the deposit.

A further amendment, Dz.U. 2026 poz. 174, lets producers of reusable glass bottles stay outside the operators’ systems until 31 December 2028. Poland remains the only tracked scheme with a deposit on reusable glass, and that deposit is twice the single-use one (PLN 1 against PLN 0.50).

Portugal

Portugal’s Volta system launched on 10 April 2026 and is run by SDR Portugal, licensed as managing entity since 1 June 2024. The government’s launch note says “O consumidor recebe um depósito de 10 cêntimos por cada unidade devolvida” (the consumer receives a deposit of 10 cent per unit returned) and puts the investment at “cerca de 150 milhões de euros”, financed by producers and packers with no public funding (Government of Portugal, 13 April 2026). The transition ended on 9 August 2026. From 12 August 2026 the APA FAQ brings service packaging and plant-based drinks into scope and removes wine-sector products, spirits and dairy, citing PPWR Article 50.

England, Northern Ireland, Scotland and Wales

The England and Northern Ireland Regulations, SI 2025/67, bring the main duties into force on 1 October 2027 for single-use PET, steel and aluminium containers of 150 ml to 3 litres. Scotland’s SSI 2025/188 moved its start to the same day, removed glass and raised the size floor to 150 ml. The deposit is not in either set of regulations: regulation 59 of SI 2025/67 makes the operator set it, and Exchange for Change stated “a flat 20p deposit” on 24 April 2026. It cited research that “deposit levels below 15p are unlikely to provide sufficient incentive” to reach 90% within three years.

Wales starts the same day with glass included. The Welsh Government’s written statement of 20 August 2026 appointed Exchange for Change and said glass drinks containers “will be exempt from labelling requirements and carry a zero pence deposit” for a four-year transition. SPI has not yet added the Welsh regulations to the tracker. Exchange for Change opened phase 1 registration on 29 September 2026, and phase 2 opens in January 2027.

Four scheme archetypes

SPI’s framework groups the schemes by who controls the money and the deposit, because that decides what a producer negotiates, budgets and labels.

How the euro deposits compare

Four deposits are set in euro and can be compared directly. Poland’s złoty amounts and the UK’s pence are excluded.

Ireland is the only euro scheme with two bands; its larger deposit is 1.67 times the smaller (25 / 15). Austria applies one rate from 0.1 to 3 litres, so a 330 ml can and a 1.5 litre bottle carry the same 25 cent. Germany’s federal environment ministry states that the law requires “ein Pfand von 25 Eurocent pro Flasche” on single-use packaging such as thin-walled PET bottles and cans (BMUKN FAQ, 22 January 2025), carried forward in section 46 of the new VerpackDG (PR-DE-001).

SPI calculation within one currency: one million containers in Ireland’s larger band means EUR 250,000 paid to Re-turn ahead of consumer refunds (1,000,000 x 0.25); in Portugal the same volume is EUR 100,000. The money comes back as containers return, but the gap is working capital for a fast-growing drinks brand.

Collection targets: the road to 90%

The UK targets sit in regulation 81 of SI 2025/67, counted separately for England and for Northern Ireland, with a floor of 85% for PET and for other materials from 2030. Ireland’s Re-turn names 90% by 2029 as the Single-Use Plastics Directive bottle target it must meet (Re-turn producer page).

Time to show 90%

What the schemes report

By SPI’s calculation, Poland’s 5 billion over the 365 days from 1 October 2025 is about 13.7 million containers a day. Re-turn’s own figures put direct capture at over 76%, below the 90% the PPWR requires, although Re-turn reports a further 15% through mixed dry recycling. How Member States count deposit returns and other separate collection towards 90% will depend on the reporting rules under Article 56.

The cash flow scenario

Deposit money passes through producers and operators before it reaches consumers. Under regulation 22 of SI 2025/67, a UK producer pays the operator an amount equal to the deposit on every item, and regulation 62 makes the operator hold deposit money first to pay refunds. In Austria and Ireland, unredeemed deposits help fund the scheme (section 11 of the Austrian ordinance; Regulation 4 of the Irish regulations).

SPI calculation for the UK row: 10,000,000 x £0.20 = £2,000,000 paid in; at 70% returned, 30% or £600,000 is unredeemed; at 80%, £400,000; at 90%, £200,000. Portugal: 10,000,000 x EUR 0.10 = EUR 1,000,000; at its 2026 target of 40%, EUR 600,000 unredeemed, falling to EUR 100,000 at 90%.

SPI calculation for a UK producer placing 100 million containers a year, 40 million PET and 60 million cans: from January 2029, 40,000,000 x 2.3p = £920,000 plus 60,000,000 x 0.6p = £360,000, or £1.28 million a year, against £0 before. Deposit amounts passed to the operator would be 100,000,000 x 20p = £20 million a year, a cash flow rather than a cost. A low case holds fees at 0p if the May 2027 review keeps them there; SPI has no basis for a high case until the operator publishes revised figures.

What each scheme asks of the supply chain

The UK low-volume rule lets a product line under 6,250 containers in the first scheme year, and 5,000 in later years, skip fees, deposits and labelling, though it must still register and report (SI 2025/67, regulation 18). Exchange for Change asked industry to sell through drinks filled before 1 October 2027 by April 2028, a request rather than a legal deadline.

Converters meet deposit schemes through specifications: the deposit symbol and barcode in Austria, the Volta symbol and GTIN in Portugal, the Re-turn logo in Ireland, the KAUCJA mark in Poland and the scheme logo and return code in the UK. Return machines read those marks, so print quality and barcode placement become functional requirements.

Deposit schemes and packaging EPR: one container, two systems

Deposit schemes sit beside packaging EPR, not instead of it, and each market draws the line differently. In Germany, deposit-liable packaging is exempt from dual-system participation under section 11 of the VerpackDG (PR-DE-001). In Portugal, packers keep their SIGRE obligations with the existing schemes until the deposit system covers a product; once in Volta, that packaging leaves the yellow bin route, which changes the tonnage reported to those schemes (APA FAQ, via PR-PT-001).

In the UK, containers in the deposit scheme are handled through the operator’s fees rather than EPR disposal fees, so producers need to split drinks containers out of their EPR data from 1 October 2027 (Defra guidance, via PR-GB-004). Ireland deems Re-turn membership to meet certain single-use plastics and packaging duties under Regulation 13 of S.I. 33/2024. Austria’s packaging EPR tariff runs separately: the SPI EPR & Plastic Tax Calculator holds ARA’s 2026 household rates of EUR 1.04 per kg for plastic and EUR 0.48 per kg for aluminium, among 216 fee rows in 14 markets.

Material choices at the margin

Scope shapes material choices. Glass is out of the schemes in England, Northern Ireland, Scotland, Austria and Portugal; Poland covers it only when reusable, and Wales covers it at a zero pence deposit until 30 September 2031. Ireland covers PET but not other plastics, and the UK excludes HDPE.

There is also a supply benefit. Recital 141 of the PPWR credits deposit systems with cleaner recycling streams, and Austria’s ordinance gives first placers a right to buy sorted material at market price up to 90% of their share (sections 19 and 20). Poland requires records of recycled content in single-use plastic bottles (article 22 of its packaging act). For PET fillers facing recycled-content duties, the deposit stream is the main source of food-grade feedstock, and access terms differ by scheme.

What non-compliance costs

Start dates, 2024 to 2035