EU PPWR FAQs Updated August 2026 - Flipbook - Page 66
XX.
DEPOSIT AND RETURN SYSTEMS
1) Does the exemption from setting up a deposit and return systems (DRS) apply to the
two beverage packaging types separately?
The 90 % separate collection targets for single-use plastic beverage bottles and metal beverage
containers are two separate collection targets that apply by 1 January 2029. An exemption from the
requirement to be part of a DRS would therefore need to be obtained separately for each format.
Article 50(5) establishes that Member States which collect more than 80% of all single-use plastic
beverage bottles or metal beverage containers within the scope of the PPWR by 2026 may be
exempt from the obligation to set up a DRS. Member States would also have to show with concrete
measures how they will reach 90% separate collection targets by 2029 without setting up a DRS
when notifying the Commission about their request for an exemption.
2) Can a Member State set additional national requirements for DRS?
Pursuant to Article 50(9) PPWR, Member States may adopt provisions for DRS which go beyond
the minimum requirements set forth in Article 50 and in Annex X, while observing the Treaty on
the functioning of the EU and acting in accordance with the PPWR.
For example, Member States are encouraged to establish or maintain DRS for single-use glass
beverage bottles and beverage cartons and may include beverages which are not required to be part
of a DRS under Article 50(4), such as wine, spirits or milk-based products, as well as for other
products. They should, however, be mindful of the negative impact on the internal market of such
rules and should take account of the recommendations in the Communication from the Commission
4 Beverage packaging, deposit systems and free movement of goods (2009/C 107/01). Member
States should encourage DRS for reusable packaging, in particular for reusable glass beverage
bottles.
Member States must ensure that the return of packaging is convenient for end users and may
establish additional minimum requirements to ensure that the objectives of the Regulation are met
and to increase the purity of the collected packaging waste and reduce litter (Article 50(9) PPWR).
3) What is to be understood by 8high transboundary business9 in Annex X?
Annex X requires that Member States with regions with high transboundary business ensure that
the DRS allow for collection of packaging from other Member States9 DRS at designated collection
points and that they must endeavour to enable the possibility of return of a deposit that was charged
to the end user when purchasing the packaging.
Member States will need to assess if this requirement applies when ensuring compliance with the
minimum requirements in Annex X. The minimum requirements apply to DRS established after 11
February 2025, whereas for the existing DRS, Member States must only apply the requirements
from 1 January 2035 if the 90% separate collection targets are not reached by 1 January 2029
(Article 50(11) PPWR). Given that an increasing number of Member States is establishing DRS,
the need for transboundary collaboration between the DRS9 is likely to increase to ensure separate
collection of beverage packaging. The Commission must assess best practice of such measures by
2038 in collaboration with Member States to strengthen interoperability of DRS from different
Member States (Article 50(11) PPWR).
4) Do all DRS have to be non-profit?
A DRS for single-use beverage bottles of plastic and metal containers established after 11 February
2025 must be non-profit, as specified in the minimum criteria set out in Annex X, point f.
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