For an Irish drinks brand, Re-turn's per-container fees now outweigh the Repak bill on everything else many times over

Where Repak stops and Re-turn starts

The legal line is drawn by container, not by brand. Regulation 3 of S.I. 33/2024 covers PET beverage bottles and aluminium or steel beverage containers from 0.150 to 3 litres, with their component parts, where the deposit has been paid. It excludes plastic beverage bottles not made of PET and metal containers not designed to hold a beverage. Repak’s guidance adds that dairy drinks such as milk and yogurt drinks are not in the deposit scheme (Repak QF 509).

Repak’s guidance applies the same line to its own fees. From 1 February 2024, in-scope deposit material carries no Repak charge “for any stages of shared responsibility”, so the manufacturer, converter, brand holder and retailer shares all fall away together. The containers still appear on the Repak return, in the deposit material type fields, and caps, lids and labels on them are excluded from reporting (Repak QF 509). PET bottles and cans that are not in scope remain reportable and pay a fee.

The statute adds a deeming rule. Regulation 13(7) of S.I. 33/2024 treats a producer that is a member of an approved deposit body as having met specified duties under the Single Use Plastics (No. 2) Regulations 2021 and under Regulations 5 to 16 of S.I. 282/2014 for its in-scope products. Since S.I. 659/2022 revoked Regulations 12 to 16, the deeming now bites on Regulations 5 to 11 of the packaging rules for those products. SPI analysis of the official text, not legal advice; check with counsel where it applies.

Repak's 2026 fee table, line by line

Repak sets one per-tonne rate for each material line and splits it across the supply chain under its shared responsibility model. In 2026 the material manufacturer and the converter each pay EUR 1.00 per tonne, the retailer EUR 2.00, and the brand holder or importer the variable share (Exhibit 3). The fee sheet’s table header reads H1/H2 2026, while its introductory text still refers to H1 2024 and H2 2024, a drafting slip in the sheet itself.

Eco-modulation in Ireland works through one switch: whether a material is recycled in Ireland. A plastic or composite pack that is not recycled pays EUR 616.22 per tonne, 3.72 times the recycled rate of EUR 165.70, and 14.8 times the paper rate. The polymer, colour and format do not set separate lines, unlike the Belgian or Spanish tables in the EPR fees per tonne piece. Repak’s annual report says eco-modulated fees have applied to all reported packaging materials since January 2023, and that its net necessary cost model, introduced for plastics and composites in 2020, now covers every material (Repak Annual Report 2025).

The 2025 sheet shows how the deposit scheme sits in the table. It carries three rows for deposit material (in-scope aluminium cans, in-scope steel cans and in-scope PET bottles, each 150 ml to 3 litres) with no fee entered, beside the non-DRS lines for the same materials (Repak Regular fees 2025). The 2026 sheet keeps the non-DRS lines and drops the empty deposit rows.

Repak invoices twice a year, in January and July, each payable within 30 days, and bases each invoice on the same half of the previous year: H1 2026 fees rest on H1 2025 tonnages. Statistics for January to June are due by 21 August, and for July to December by 21 February of the following year. Members that file on time, pay within 30 days and register bank details on the portal qualify for a rebate, paid by SEPA transfer each half year depending on Repak’s financial performance (Repak QF 509).

Who must join, and the routes that remain

The obligation sits with the major producer. Regulation 4(3)(a) of S.I. 282/2014 makes a producer a major producer if the packaging it supplies “exceeds or may be expected to exceed 10 tonnes in a calendar year, and” its annual turnover is more than EUR 1 million. Both tests must be met. The 2014 Regulations revoked the Waste Management (Packaging) Regulations 2007 (S.I. No. 798 of 2007) from 21 June 2014 (regulation 36), so the 2007 title now has historical value only.

The self-compliance route is closed. The 2014 text let a major producer register with its local authority, pay EUR 15 per tonne (minimum EUR 500, maximum EUR 15,000 per premises), take back packaging waste and file quarterly reports. The Department consulted from 16 September to 28 October 2022 on removing that option, and S.I. No. 659 of 2022, made on 14 December 2022, inserted regulation 10(5), requiring every major producer to be a member of an approved body from 1 January 2023. It revoked Regulations 12 to 16 and Schedule 3, and narrowed the approved-body exemption in regulation 17(1) to regulations 10, 11 and 25. The Department’s release said Repak would provide switcher assistance to former self-compliers (gov.ie, 19 December 2022).

Below the thresholds there is no membership duty, but the general duties stay. Every producer must handle packaging waste arising on its premises under regulation 5, passing specified materials to a matching producer or segregating them for recovery, keep records for reusable packaging and supply weight data on request (S.I. 282/2014, regulations 5 to 8). For the PPWR, which applies from 12 August 2026, S.I. No. 541 of 2025, made on 6 November 2025, designates the EPA, the Minister and local authorities as competent authorities for different articles of Regulation (EU) 2025/40.

Scheduled membership matters to the drinks trade because pubs, restaurants and off licences pay it. The 2026 schedule charges EUR 402 a year, excluding VAT, for most sectors placing 10 to 25 tonnes, and EUR 986 for those over 25 tonnes. Off licences, all in the over 25 tonne class, pay by 16 turnover bands from EUR 986 to EUR 3,451 (Exhibit 6).

Re-turn's fees, deposits and registration

Re-turn finances itself from four sources set in Regulation 4 of S.I. 33/2024: registration and producer fees, unredeemed deposits, revenue from returned material and other income, and its fees must cover only its costs of operation. Producers join before placing in-scope drinks on the market, register each product with barcode, dimensions, weight and material data, report placed-on-market volumes monthly, and pay Re-turn the deposit and the producer fee (Re-turn producer page, modified 20 October 2026).

The deposit is 15 cent for containers up to and including 500 ml and 25 cent for those over 500 ml up to 3 litres (Re-turn producer page). The government’s launch release of 1 February 2024 gave the bands as 150 ml to 500 ml and 500 ml to 3 litres. S.I. No. 555 of 2024, made on 22 October 2024, replaced the deposit schedule, and Regulation 18(3) lets the Minister change the amounts once per financial year after consulting the approved body.

Two points are open. Re-turn’s 2023 fee document said fees would be reviewed annually from Q1 2025 and that litter clean-up costs would be factored in later. Re-turn’s 2025 report says the retailer handling fee review took place in 2025 and its outcome will be communicated in 2026. SPI has not yet confirmed any Re-turn producer fee table for 2026 that differs from the 2025 figures.

What the two schemes report

Re-turn’s second full year shows the scheme near its first target. It returned 1,434,857,656 containers in 2025, 749,128,937 cans and 685,728,719 plastic bottles, for 30,917 tonnes of material, and reports an overall return rate of 76.4%, against 66% for June to December 2024 (Re-turn 2025 Annual Report). Its 5 March 2026 release puts returns since launch at 2.5 billion and says about 76% of containers are captured through the deposit scheme and the rest through mixed dry recycling, giving an estimated overall recycling rate above 90%.

At the end of 2025 Re-turn had 301 registered producers, 9,607 active barcodes, 7,381 registered retailers and 2,624 return locations with 2,815 reverse vending machines and 555 manual return points. SPI calculation: EUR 31.5 million of handling fees over 1,434,857,656 containers returned is EUR 0.022 per container, in line with the published EUR 0.022 machine and EUR 0.026 manual rates.

Repak’s 2025 report shows the other side. Members placed 735,805 tonnes on the market, Repak recycled 847,412 tonnes and recovered 371,370 more, and members met 115% of their recycling targets. Members recycled 75% of their plastic placed on the market (98,769 of 131,457 tonnes). Aluminium recycled fell by 1,391 tonnes and PET bottles by about 2,300 tonnes, falls Repak links to the deposit scheme. SPI calculation: EUR 47,929,908 of fee income on 735,805 tonnes is EUR 65.14 per tonne gross, a scale check rather than a rate, since 59% of members pay scheduled fees.

Four kinds of drinks pack in Ireland

SPI groups a drinks brand’s packaging into four archetypes by which scheme charges it and what moves the charge (Exhibit 9). The device is drawn from the two fee tables and S.I. 33/2024, and it tells a packaging team where each design or sourcing decision lands.

Archetype A rewards fewer, larger units. A 1.5 litre PET bottle pays the same EUR 0.02 as a 500 ml one, so at SPI’s assumed weights its fee per tonne is EUR 571.43 against EUR 909.09. Lightweighting a can saves nothing in Re-turn fees, because the fee is per container.

Archetype B rewards recyclability and weight. A carton recycled in Ireland pays EUR 165.70 per tonne; one that is not pays EUR 616.22. Glass rose 158.3% for 2026, but at EUR 19.14 per tonne a 190 g bottle still costs the brand holder about EUR 0.0036.

Archetype C is the easiest to miss. A brand that adds a 5 litre PET water or a 100 ml shot falls back into Repak, on the non-DRS lines, and must report it there. A dairy drink in a PET bottle is in the same position, because Repak’s guidance places dairy drinks outside the deposit scheme.

Archetype D is often the largest Repak line for a drinks brand once the containers have left. Corrugated cases at EUR 41.60 per tonne and recyclable shrink film at EUR 165.70 are low rates, but a non-recyclable multipack film would pay EUR 616.22.

Worked example: one drinks brand, two schemes

SPI priced a hypothetical Irish soft drinks brand holder that places 11 million deposit containers and 180 tonnes of other packaging a year (Exhibit 10). Unit counts and weights are SPI assumptions for illustration, not industry averages; rates are the published 2026 Repak brand holder rates and the Re-turn 2025 table. Everything is in euros, excluding VAT.

SPI calculation: Re-turn fees are 6,000,000 x 0.0125 + 4,000,000 x 0.02 + 1,000,000 x 0.02 + 5 x 100 = EUR 175,500. The Repak bill is 95 x 19.14 + 9 x 165.70 + 60 x 41.60 + 15 x 165.70 + 1 x 64.76 = EUR 8,355.86. Combined, EUR 183,855.86 on 381 tonnes, of which Repak is 4.5%.

The deposit sits on top, as cash rather than cost. The brand pays Re-turn 6,000,000 x 0.15 + 4,000,000 x 0.15 + 1,000,000 x 0.25 = EUR 1,750,000 in deposits and recovers the same amount from its customers through the itemised deposit line on invoices that Regulations 13 and 14 require. The cost is the timing gap between paying Re-turn and collecting from the trade, which the deposit return piece sets out for Ireland and its neighbours.

Scenarios: how the bill moves

SPI ran two sensitivities, one on each table, in euros only (Exhibit 12). The Repak sensitivity uses Repak’s own 2025 and 2026 rates on the example’s 180 tonnes: low is the 2025 table, base is 2026, and the stress case repeats each line’s 2025 to 2026 step once more, an SPI assumption and not a forecast. The Re-turn sensitivity changes container weight, which moves the per-tonne equivalent but not the bill.

Glass drives the Repak stress case. At a repeated step glass would be EUR 49.44 per tonne, and the 95 tonnes of bottles would cost EUR 4,696.80 instead of EUR 1,818.30. For a brand whose Repak bill is mostly glass, Repak’s 2027 glass line is the number to find first in the new sheet.

On the Re-turn side, unit count is the only volume lever. Each extra million cans adds EUR 12,500 and each extra million PET bottles EUR 20,000, and crossing 1.5 million units a year brings in the EUR 100 per product registration charge. Switching a 330 ml line from PET to cans saves EUR 0.0075 per unit at the 2025 rates, or EUR 7,500 per million.

The calendar both schemes run on

The two schemes report on different clocks. Re-turn takes placed-on-market volumes every month under the producer membership agreement, while Repak takes statistics twice a year and invoices a year in arrears (Re-turn producer page; Repak QF 509). The dates that matter to a drinks brand over the next three years are set out in Exhibit 13, and most of the near ones belong to Repak.

The approval itself frames how Repak may set fees. The Department’s January 2026 release says the licence keeps fee modulation, with higher fees for materials that are harder to recycle, and requires an annual performance report to the Minister. Read with the deposit Regulations’ rule that Re-turn’s fees may cover only its operating costs, both schemes are cost recovery bodies, and a rise in either table usually reflects a rise in collection, sorting or handling cost rather than a margin.

The gaps in this view

Repak 2027. Repak publishes a 2027 Regular Membership Rates sheet (QF 628) on its membership page, but SPI has not yet confirmed its rates, so no 2027 Repak figure is used here.

Re-turn 2026. Re-turn’s producer page, updated on 20 October 2026, still points to the fee update of 29 September 2023, whose small-producer flat fees of EUR 500 and EUR 1,000 do not appear in the 2025 annual report table. SPI uses the 2025 report and has not yet confirmed a 2026 table.

Re-turn rates by material. Re-turn reports one return rate across all in-scope containers. SPI has not yet confirmed separate PET and metal return rates, which the PET bottle target will need.

Scope of the example. The portfolio, weights and SKU count are SPI assumptions. Repak’s chain shares, VAT, back fees for late joiners and Re-turn’s barcode surcharge are left out unless stated.