The deposit return system has come into force, and with it, the process of building return infrastructure in Poland has begun. In 2025, retailers, producers, and technology providers implemented procedures, signed agreements, and tested operational solutions. System operators are also part of this process — they are responsible for logistics, settlements, and deposit flows. In 2026, the market enters its first real test — retailers, operators, and producers verify whether procedures, collection, and settlements function at an operational scale. The legislator has introduced high financial penalties to enforce real participation in the system and the development of infrastructure necessary to achieve required collection targets.
Penalties for retailers and wholesalers
Retail units are responsible for collecting, refunding, and recording deposits, while stores above 200 m² are additionally required to operate a collection point for packaging. Failure to meet these obligations may result in administrative penalties, including:
- up to PLN 500,000 for not collecting or refunding deposits
- up to PLN 50,000 for not signing an agreement with an operator
- up to PLN 20,000 for failing to provide customer information
- up to PLN 1,000,000 for not maintaining required documentation
For many stores, the cost of penalties exceeds the cost of implementing system-compliant solutions. This is why larger stores are considering reverse vending machines — a technically simpler, scalable solution that reduces operational risk.
Penalties for producers and importers
The most severe mechanism applies to beverage producers and importers. From January 1, 2026, failure to join the system results in a triple product fee rate. This solution is intentionally designed as an economic incentive — staying outside the system is meant to be more expensive than participation.
Additionally, failure to properly label packaging (EAN code + deposit mark) may result in penalties of up to PLN 50,000 per batch of products introduced without proper marking.
Penalties for system operators
Operators are responsible for logistics, transport, deposit settlements, and achieving collection targets. Failure to meet these obligations may result in high administrative penalties of up to PLN 1,000,000 and, in extreme cases, withdrawal of authorization.
Who enforces compliance?
Supervision over the system is primarily carried out by the Regional Inspectorates for Environmental Protection (WIOŚ), which in 2026 will begin inspections of compliance with deposit system obligations — from deposit collection and refund processes, through the operation of collection points, to documentation and settlements. This is the first year in which the system will be assessed not at the level of declarations, but real operation in stores and by producers.
The Ministry of Climate and Environment is responsible for system-level oversight, while operators handle collection, transport, and settlements. This means that the entire chain — from producer, through retail, to sorting facilities — must operate consistently.
Reverse vending machines as a compliance tool for retail
In practice, RVM machines are becoming the simplest way for stores to:
- meet deposit system obligations
- reduce the risk of penalties
- speed up customer service
- streamline settlements with the system operator
- handle high return volumes without involving staff
This is particularly important for stores above 200 m², which are required to operate collection points, where manual handling of deposits is costly, slow, and prone to errors.
2026: implementation, production, and market scaling
The legislative phase has been formally completed, but the implementation phase is ongoing — and it is this phase that will shape the system in practice. In 2025–2026, the market is building return infrastructure: machines, software, collection logistics, sorting, settlements, and in-store operations. It is infrastructure, not just knowledge of regulations, that will determine whether the system works at scale.
For 4VS, this is a period of intensive production and delivery of RVM machines to new clients. Polish-made products and local manufacturing provide a time advantage over imported solutions — shortening implementation time, service response, and adaptation to system changes.
In 2026, 4VS machines become part of the deposit system infrastructure in Poland, and the market transitions from a “legislation phase” to a phase of real implementation and scaling, where execution, speed, and delivery capability matter most.
Frequently asked questions (FAQ)
Can a store choose not to participate in the system?
Stores below 200 m² are not required to operate collection points but must still collect deposits. If they sell beverages in reusable glass bottles, collection becomes mandatory.
Is a receipt required to return a deposit?
No. Deposits are refunded without a receipt, provided the packaging is marked with a deposit symbol and code.
Are machines mandatory?
No, but for stores with high sales volumes, they are a practical way to meet obligations and avoid penalties and operational queues.
Summary
The deposit return system does not end with regulations — it begins in stores, warehouses, at producers, and on production lines. Penalties for non-compliance are real and significant, and 2026 will be a year of market verification. For retail and the beverage industry, this means implementing infrastructure that enables deposit collection and refunds, and for producers — mandatory participation in the system and proper packaging labeling.