Poland’s New Deposit Return System (DRS): VAT rules in a nutshell

Poland is rolling out a nationwide deposit return system for beverage packaging (the “DRS”). The scheme will start no earlier than 1 October 2025. Under the DRS, a deposit is added to the price of a drink and is paid back when the consumer returns the empty packaging at any collection point- no receipt required.

What packaging is covered?

The DRS covers:

• PET bottles up to 3 litres,
• metal cans up to 1 litre, and
• reusable glass bottles up to 1.5 litres,
  each marked to show the deposit applies and the amount due.

How the VAT mechanics work (high level)

• Deposits are not taxed as you sell down the chain. Charging or refunding the deposit is outside the VAT base at each stage of trade.
• VAT arises only if the packaging isn’t returned. In that case, the introducer of beverages in DRS packaging (the “introducer”) increases the VAT base by the value of unreturned deposits, taxed at the same VAT rate as the drink that was sold in that package.
• All other traders in the chain (wholesalers/retailers) do not account for VAT on the deposit.

Who is who: taxpayer vs. remitter

• Taxpayer (introducer): The entity that places beverages in DRS packaging on the market is the taxpayer for VAT on unreturned deposits.
• Remitter (representative entity): The DRS representative entity (set up by or for introducers) is the VAT remitter. It calculates and pays the VAT due on unreturned deposits- because it holds the deposit funds and has the data to compute the tax.

Key obligations

For the taxpayer (introducer)

• Records: Keep electronic records of DRS packaging introduced (by type, quantity and deposit value) and returned (by type, quantity and refunded deposit).
• Annual VAT adjustment: After year-end, compute the difference between deposits charged and deposits tied to returns recorded by the representative entity. Increase your VAT base by the gross number of unreturned deposits and report it in the first VAT period of the following year (monthly: January return; quarterly: Q1 return; subject to transitional rules for first reporting period). Technical boxes in JPK_V7 will include dedicated lines (e.g., P_360/K_360) for this settlement.

For the remitter (representative entity)

• Hold and manage deposits: Introducers transfer collected deposits to the representative entity on two cycles each month (by the 7th and 21st).
• Pay the VAT: Compute VAT due on unreturned deposits for the year and pay it-without being summoned- by the last day of January of the following year to the introducer’s micro-account. Transitional rule for the first settlement: the payment for 2025 is due by 28 February 2026.

Taxpayer and the remitter will need to cooperate in order to ensure proper VAT reporting.

Practical takeaways

• The deposit itself is neutral for VAT during routine sales and returns; VAT only appears if a package never comes back.
• Introducers should map products to VAT rates (e.g., 23% drinks vs 5% juices) because unreturned deposits are taxed at the product’s rate.
• Both introducers and the representative entity must align contracts, data flows, and ledgers now so that post-year-end VAT computations and JPK reporting are straightforward.

If you produce, import or sell beverages in Poland- or plan to become a DRS representative- we can help you design contracts, records and JPK/VAT workflows that fit the new rules. Contact us– Dudkowiak Putyra sp.k. is ready to support your implementation and ongoing compliance.