The deposit return system in Poland has moved from the design phase to the operational stage. Initial data from the transition period shows that the implementation includes not only large retail chains, but also the segment of small stores. According to information cited by franczyzawhandlu.pl, the Ministry of Climate and Environment summarized the first three months of the system’s operation in Q4 2025, indicating a clear increase in the number of deposit-packaged products in circulation and the active participation of stores under 200 m², which are not formally required to join the system.
First quarter of the deposit system operation
According to ministry data, in October 2025, 85,000 deposit-covered packages entered retail circulation. In November, this number increased to 2.5 million units. During the same period, consumers reclaimed deposits from approximately 500,000 packages. By November, nearly 60 million deposit-marked packages were already in circulation, with a clear dominance of cans.
The ministry emphasized that the first months of implementation were transitional, allowing producers to introduce into the market stock manufactured before the new labeling requirements. At the same time, some companies postponed joining the system until 2026, which is a natural consequence of major regulatory changes in the beverage industry.
Participation of small stores
The most surprising element of the summary is the activity of small stores. According to data cited by franczyzawhandlu.pl, around 20,000 stores with an area below 200 m² may have already joined the system. It should be noted that participation for this category of stores is voluntary. The ministry assumes that in the first quarter of 2026, the number of both introduced and returned packages will increase, among others due to the obligation to achieve a 77% collection rate and the product fee imposed for non-compliance.
Operational implications
The first months of system operation have shifted the focus from legislation to operations. Real return flows have appeared in stores, and deposit handling has begun to require logistical, technical, and reporting efforts. For some retail entities, this means the need to implement return support infrastructure and integration with system operators.
Integration as a key condition for system performance
Launching a collection point in the deposit system is not limited to installing a return device. It also requires integration with the operator, configuration of return reporting, and deposit settlement processes. At 4VS, we observe in practice that these are critical stages for the smooth operation of collection points. As a Polish manufacturer of reverse vending machines, we support implementations on the level of devices, integration, and processes, enabling collection points to operate in compliance with operator requirements.
Amendment for reusable glass bottles
At the same time, the process of clarifying regulations for reusable glass bottles is ongoing. As noted by franczyzawhandlu.pl, at the end of December 2025, a draft amendment to the Act on Packaging and Packaging Waste Management was submitted to the Polish Parliament. Its purpose is to allow the continued operation of market-based return systems for reusable glass bottles managed by producers. On January 9, 2026, the amendment was adopted and submitted to the President of Poland for signature. This topic has been further described, among others, by prawo.pl.
Summary
The first months of the deposit return system confirm that the implementation covers both large retail chains and small stores, and that the market has entered the stage of practical return handling. The last quarter of 2025 shows that not only legislation matters, but also logistics, infrastructure, and technical integration, which determine how the system operates in practice at collection points.
Sources:
franczyzawhandlu.pl
prawo.pl
Ministry of Climate and Environment