Understanding the VAT Implications of Poland’s New Deposit Refund Scheme

November 6, 2025 EU VAT Update

Poland’s Deposit Refund Scheme (DRS), which launched on October 1, 2025, marks a major shift in how beverage packaging is managed—and taxed. Designed to boost recycling and reduce waste, the scheme introduces a refundable deposit on certain beverage containers. But for businesses, it also brings new VAT obligations that require careful attention.

What Is the Deposit Refund Scheme?

The DRS will currently apply to single-use plastic bottles up to 3 litres, metal cans up to 1 litre and reusable glass bottles up to 1.5 litres (although the scheme may be extended at some point to additional products).

Consumers pay a deposit when purchasing beverages in these types of packaging, which is refunded upon return of same.

VAT Treatment: What You Need to Know

Deposits on DRS-covered containers are not subject to VAT when charged. They are excluded from the taxable base and should be shown separately on invoices or receipts.

If a container is not returned, the deposit becomes part of the taxable sale price. VAT must be applied at the same rate as the beverage which was sold in the container. (e.g., 5% for juice, 23% for soda).

By December 31st of each year, producers and importers must reconcile deposits collected and deposits refunded, and the VAT on the difference must be reported and paid in the first VAT return period of the following year.

System Operator’s Role

The DRS requires the selling business to appoint a System Operator as the party responsible for calculating and paying the VAT due to the Polish tax office. This structure is intended to simplify the process of paying the VAT due on deposits, and ensure that this obligation rests with the company that actually manages the funds from the deposit, and has the full information necessary to correctly calculate the tax due.

As the System Operator calculates and remits VAT on behalf of producers/importers, businesses must ensure contracts are in place and data is shared accurately.

Documentation & Reporting Requirements

Businesses must maintain electronic records of:

  • Containers placed on the market
  • Containers returned
  • Deposit values

These records must be integrated into Poland’s JPK_V7 (SAF-T) reporting system, which now includes fields for deposit-related data.

Special Cases: Dual VAT Regime

Not all packaging is covered by the DRS. For example, milk, yoghurt or other such dairy product packaging, which are excluded for sanitary reasons.

Businesses must manage a dual VAT regime, distinguishing between DRS-covered and non-DRS packaging.

Action Points for Businesses

To stay compliant with the DRS obligations, retailers/manufacturers of impacted packaging should:

  • Update invoicing systems to reflect VAT-exempt deposits
  • Appoint a system operator
  • Train staff on DRS and VAT procedures
  • Provide the data relevant for the annual reconciliation of packaging placed on the market vs returns to the system operator

Conclusion

Poland’s DRS is a positive step for sustainability, but it introduces complex VAT implications. Businesses must adapt their systems and processes to ensure compliance. With proper planning, the transition can be smooth, and also be beneficial for the environment.

If you wish to discuss any VAT related issues with respect to this change, please do not hesitate to contact Meridian Global VAT Services and we will be happy to assist you.

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