Deposit Return Systems under the PPWR: 90 % Collection of Plastic Bottles and Cans by 2029

Article 50 of the PPWR (Regulation (EU) 2025/40) requires every Member State to collect separately at least 90 % by weight of single-use plastic beverage bottles and single-use metal beverage containers of up to 3 litres by 1 January 2029, through a deposit return system. The 90 % is a separate collection rate per year, not a recycling rate, and a deposit is charged at the point of sale.

Deposit return systems are one of the waste duties of Member States under the EU Packaging and Packaging Waste Regulation (PPWR), in force since 11 February 2025 and applicable from 12 August 2026. A Member State that collected 80 % or more of a format separately in 2026 may ask to be exempted, and every system set up after 11 February 2025 must meet the fifteen minimum requirements of Annex X by 1 January 2029.

This page sets out the formats in scope, the exempt beverages, the exemption route for Member States, Annex X, the duties of producers and final distributors, the DRS label and the national systems already running.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; every value on this page is checked against EUR-Lex and Commission guidance, see our methodology and fact-checking.

The key facts of the PPWR deposit return rule are summarised in the table below.

What Does the PPWR Require for Deposit Return Systems?

The PPWR requires Member States to set up deposit return systems and charge a deposit at the point of sale for the two Art. 50(1) formats, so that at least 90 % of each format is collected separately every year from 1 January 2029. Art. 50(2) PPWR carries the system duty, and Art. 50(1) the 90 % separate collection target. Art. 50 has applied since 12 August 2026, but the target itself bites only from 1 January 2029.

The deposit and the system are cumulative duties. Commission Notice C/2026/3084 (OJ C, 10.6.2026), point 28, which is non-binding, reads Art. 50 so that a distributor is relieved from charging the deposit only where the Member State has granted an exemption, and border regions get no lighter treatment.

What is a deposit and return system under the PPWR?

A deposit and return system is, under Art. 3(1)(62) PPWR, a system in which a deposit is charged to the end user when purchasing a packaged or filled product covered by that system, and redeemed when the deposit bearing packaging is returned through one of the collection channels that are authorised for that purpose by the national authorities. The definition has three elements: a deposit paid by the end user, a refund on return, and collection channels authorised by national authorities. The German text uses "Pfand- und Rücknahmesystem", the French text "système de consigne". Article 50 and Annex X can be read in full in the PPWR legal text.

How is the 90 % separate collection rate calculated?

The 90 % is calculated per format, by weight, against the bottles or metal beverage containers made available on the market for the first time in that Member State in a calendar year. Art. 50(1) lets Member States use packaging waste generated, calculated under the implementing act of Art. 56(7)(a), as the alternative basis.

Beverages exempt under Art. 50(4) still count. The Commission's PPWR FAQ (non-binding), section XX, states that wine, spirits and milk containers stay in the 90 % calculation even where they sit outside the system. For comparison, under the Single-Use Plastics Directive, Member States separately collected 71 % of single-use plastic beverage bottles in 2022 (26 Member States reporting), and 6 Member States were already above 90 %, according to Commission report COM(2026) 160 of 16 April 2026.

Which Packaging Must Be in a Deposit Return System?

Two formats must be in a deposit return system under Art. 50(1) PPWR: single-use plastic beverage bottles and single-use metal beverage containers, each with a capacity of up to 3 litres. Single-use plastic beverage bottles are the beverage bottles of up to 3 litres listed in Part F of the Annex to Directive (EU) 2019/904, as set out in Art. 3(1)(54), one of the PPWR definitions.

The table below shows which packaging Art. 50 brings into a system, which it leaves to Member States and which it exempts.

Which beverages are exempt from the DRS duty?

Art. 50(4) PPWR exempts four groups of beverages from the DRS duty: grapevine and aromatised wine products, wine-like fermented beverages of CN code 2206 00, spirits of CN code 2208, and milk and milk products. The four groups are listed below with their legal references.

• Grapevine products of points 1, 3, 8, 9, 11, 12, 15, 16 and 17 of the list referred to in Art. 50(4), and aromatised wine products.
• Wine-like fermented beverages of CN code 2206 00.
• Spirit drinks of CN code 2208.
• Milk and milk products listed in Part XVI of Annex I to Regulation (EU) No 1308/2013.

The exemption removes the duty to include these containers in a system, but not their weight from the 90 % calculation. Art. 50(9) also lets a Member State bring the exempt beverages into its system. The other packaging rules for drinks producers are collected under PPWR for beverages.

Are glass bottles and beverage cartons included?

No: for single-use glass bottles and beverage cartons Art. 50(8) PPWR only asks Member States to endeavour to set up deposit return systems. Glass and cartons therefore carry no 90 % target and no binding DRS deadline. A Member State may still include them under Art. 50(9), and the national systems of Romania and Hungary already cover glass.

Can a Member State Avoid Setting Up a Deposit Return System?

Yes, under Art. 50(5) PPWR: a Member State that collected 80 % or more by weight of a format separately in calendar year 2026 may be exempted from the DRS duty for that format if it submits a request and an implementation plan by 1 January 2028. The threshold in the Regulation is "80 % or more"; the Commission's FAQ wording "more than 80 %" does not change the legal text. The four steps of the exemption are listed below.

1. Reach a separate collection rate of 80 % or more by weight in calendar year 2026, assessed separately for plastic bottles and for metal beverage containers (Art. 50(5)(a); Commission's PPWR FAQ, section XX).
2. Submit the exemption request together with an implementation plan to the Commission by 1 January 2028 (Art. 50(5)(b)).
3. Revise the plan within 3 months where the Commission asks for a revision, which it may do within 3 months of receiving it (Art. 50(6)).
4. Set up a DRS by 1 January of the second calendar year after the notification if the format stays below 90 % for three consecutive calendar years (Art. 50(7)).

The exemption can lapse under Art. 50(7), and step 4 ties it to the 90 % level of Art. 50(1). A Member State exempted for plastic bottles may still need a system for metal beverage containers, because each format is tested on its own 2026 figure.

What Are the Annex X Minimum Requirements for a Deposit Return System?

Annex X PPWR lists fifteen minimum requirements, points (a) to (o), that a deposit return system must meet, from a single or coordinated system operator and equal access for producers to take-back by final distributors, clear labelling and transparent fees. The fifteen points fall into the five groups listed below.

• Governance: a single system operator established or licensed, with coordination where there are several (a); a non-profit, independent operator (f) that performs only the roles set by the Regulation and DRS coordination (g) and coordinates the system (h); a written statute, evidence of funding and a statement of compliance (i).
• Access and money: equal access and fair conditions for economic operators (b); a minimum deposit level sufficient for the required collection rates (d); minimum financial capacity requirements (e); transparent fees (o).
• Control: control procedures and reporting systems (c); information from the operator to the competent authorities (k).
• Consumers: a sufficient share of annual turnover spent on public awareness campaigns (j); clear labelling of all deposit-bearing packaging (n).
• Retail: final distributors accept deposit-bearing packaging of the material and format they distribute and redeem the deposit, always for their own products (l); return is possible without buying goods (m).

Annex X also requires Member States with a high level of transboundary business to allow collection of other Member States' deposit packaging at designated points. Under Art. 50(12), Annex X does not apply in the outermost regions referred to in Art. 349 TFEU.

When must existing deposit return systems meet Annex X?

Deposit return systems set up after 11 February 2025 must meet Annex X by 1 January 2029, while older systems must meet it only if they miss 90 % by that date, and then by 1 January 2035. An older system that reaches 90 % by 1 January 2029 is exempt from Annex X under Art. 50(11). Notice C/2026/3084, point 29, reads "first reviewed" in Art. 50(11) as any regulative action established through legislation that imposes a substantial change to the system. By 1 January 2038 the Commission must assess the interoperability of national systems (Art. 50(11), third subparagraph). The 2029, 2035 and 2038 dates sit among the PPWR deadlines from 2025 to 2040.

Can a deposit return system operator make a profit?

No for systems set up after 11 February 2025: Annex X point (f) requires a non-profit, independent operator, and the Commission's PPWR FAQ (non-binding), section XX, reads this as binding older systems only from 1 January 2035 if they miss 90 % by 1 January 2029. The timing follows from Art. 50(11).

What Must Producers and Retailers Do in a Deposit Return System?

Producers must get equal access to the national deposit return system on fair conditions, and final distributors must take back the deposit-bearing packaging of the material and format they sell and refund the deposit. Art. 50 binds Member States, so these duties reach economic operators through the national system that Annex X shapes.

The five operator duties that follow from Art. 50 and Annex X are listed below.

• Deposit: a deposit is charged at the point of sale (Art. 50(2)); a distributor is relieved from charging it only under a Member State exemption, with no lighter rule for border regions (Notice C/2026/3084, point 28).
• Take-back: final distributors accept the material and format they distribute and redeem the deposit, and always take back their own products, even where the sales surface makes other returns impossible (Annex X point (l)).
• No purchase: the consumer may return packaging without buying goods (Annex X point (m)) and without proof of purchase (Notice C/2026/3084, point 30).
• HORECA: Member States may exempt hotels, restaurants and cafés from charging the deposit where the packaging is opened, consumed and returned on the premises (Art. 50(3)).
• Reusable packaging: return points for reusable packaging must be as convenient as those for single-use DRS packaging (Art. 50(10)).

Points (b) and (o) of Annex X set the terms producers meet in the system: equal access on fair conditions and transparent fees.

How must deposit return packaging be labelled?

Packaging in a deposit return system under Art. 50(1) PPWR must carry a clear and unambiguous label, and may also carry a harmonised colour label from the Art. 12(6) implementing act, which a Member State can make mandatory. The duty sits in the fourth subparagraph of Art. 12(1), and Annex X point (n) repeats it for all deposit-bearing packaging. DRS packaging is excluded from the harmonised material label that applies from 12 August 2028 at the earliest, and the Art. 12(6) implementing act has not been adopted as of 24 October 2026.

DRS labelling is the one part of Art. 12 that is not fully harmonised (Notice C/2026/3084, section 13). The Commission's PPWR FAQ (non-binding), section VIII, states that a bottle or can must carry the DRS label of the Member State where it is made available. For systems outside Art. 50(1) a national symbol is allowed, and Member States may not prohibit other Member States' DRS labels (Art. 12(10)). How the sorting and reuse labels differ from DRS labels in the PPWR labelling requirements is shown on the labelling page.

Can a deposit return system cover only part of a Member State?

Yes: Member States may run deposit return systems at subnational level, provided the systems together cover the whole territory (recital 148 PPWR and Notice C/2026/3084, point 33). A regional system that leaves part of the territory uncovered does not meet Art. 50.

How Does the PPWR Deposit Return Rule Fit with Other EU Packaging Waste Rules?

Art. 50 PPWR is one of three packaging waste duties of Member States in Chapter VIII, next to the mandatory collection objectives due by 1 January 2029 (Art. 49) and the recycling targets of 65 % by 31 December 2025 and 70 % by 31 December 2030 (Art. 52). Collection objectives and recycling targets are summarised under EU packaging waste targets under the PPWR.

The Single-Use Plastics Directive, Directive (EU) 2019/904 (OJ L 155, 12.6.2019, p. 1), already sets a separate collection target for the same bottles: 77 % by weight by 2025 and 90 % by 2029 for Part F bottles (Art. 9(1) SUPD). The PPWR amends the Directive under Art. 67 but does not repeal it, and Art. 50 adds metal beverage containers and the DRS duty.

The 2022 SUPD bottle data rest on Commission Implementing Decision (EU) 2021/1752 (OJ L 349, 4.10.2021, p. 19), which sets the calculation, verification and reporting of separate collection of waste single-use plastic beverage bottles. COM(2026) 160 also reports 2.54 million tonnes of these bottles placed on the market in 2022 and 10 Member States above 77 %.

Re-use is a separate rule. Final distributors face a 10 % beverage re-use target from 1 January 2030 under Art. 29(6), and the Art. 29(7) list of excluded beverages differs from the Art. 50(4) list: it covers grapevine points 1, 3 to 9, 11, 12, 15, 16 and 17 plus highly perishable beverages. How the two bottle rules interact is compared under PPWR vs the Single-Use Plastics Directive.

Which EU countries already run a deposit return system?

Germany, Latvia, Romania, Hungary, Ireland, Poland and Portugal already run deposit return systems under national law: Germany since 2003, Latvia since 1 February 2022, Romania since 30 November 2023, Hungary since 1 January 2024, Ireland since February 2024, Poland since October 2025 and Portugal since April 2026. Spain requires a system by law, and France has none at national level as of 24 October 2026. The table below gives one row per state; schemes in the United Kingdom are not covered, since this page covers the EU rule only.

Registers, PRO models and deposit systems in the 27 Member States are compared country by country.

Is Article 50 challenged before the EU courts?

Yes: in Case T-197/25, brought on 21 March 2025 and published in OJ C/2025/2903 of 2 June 2025, five Czech waste-sector applicants ask the General Court to annul Art. 50(1) to (7) and (9) to (12) PPWR. The action is brought against the European Commission and relies on five pleas.

The contested provisions cover the 90 % target, the exemption route and Annex X. Art. 50 has been part of Regulation (EU) 2025/40 since its entry into force on 11 February 2025.

Do the deposit return rules apply to imported beverages?

Yes: an imported bottle or can is covered once it is made available on the market in a Member State, while beverages brought in privately are not made available on the market (Commission's PPWR FAQ, section VIII). The importer is the person established in the Union who places packaging from a third country on the market (Art. 3(1)(17) PPWR). What else the importer must check is set out in the PPWR obligations of importers.