Extending the deposit return system (DRS) in Poland to single-use glass and establishing an umbrella organisation could strengthen the current system model and close one of the key areas that currently remains outside its scope. The Ministry of Climate and Environment is analysing the possibility of legislative changes in this direction which, if introduced, would have significant consequences for the entire beverage market.

The deposit return system has been operating in Poland since 1 October 2025 and primarily covers single-use plastic bottles up to 3 litres and metal cans up to 1 litre. As regards refillable glass bottles (up to 1.5 litres), the regulations allow them to function either within the DRS or under separate return schemes operated by producers.

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At the same time, the system does not currently include single-use glass bottles. That may change. The Ministry of Climate and Environment is analysing the possibility of a broader amendment to the regulations, one of the main directions of which would be to extend the DRS to single-use glass.

Why might implementation be challenging?

Including single-use glass in the DRS would be a change felt across the entire beverage market value chain.

For retailers, it would mean handling a larger number of returns and an additional packaging fraction. This may be particularly significant for stores with limited storage space, which already need to organise space for packaging returned by consumers.

For DRS operators, the change would require planning efficient collection, transport and transfer of glass for further processing. For recyclers, a larger stream of single-use glass could be an opportunity for more predictable access to feedstock, but only if quality coordination and collection logistics are managed effectively.

Producers and entities placing beverages on the market in single-use glass packaging would need to prepare for new regulatory obligations, including in the areas of packaging labelling, deposit collection, cooperation with the system operator and reporting.

An umbrella organisation as the second pillar of change

A second direction under consideration is the creation of an umbrella organisation covering not only DRS operators, but also retailers and recyclers.

This is important because the practical functioning of the system depends not only on the regulations themselves, but also on effective cooperation among many market participants: producers, operators, stores, logistics providers and recyclers. Extending the system to single-use glass may further increase the complexity of these relationships.

Under such a model, the umbrella organisation could serve as a coordination platform, helping to identify operational issues, agree on cooperation standards and improve communication between system participants. It will be crucial, however, that it does not become merely an additional formal structure, but a real tool supporting the system’s day-to-day operation.

Scope of CRIDO support

CRIDO supports businesses in the area of the deposit return system, including the analysis of regulatory obligations, assessment of the impact of planned changes on operations, preparation for the implementation of new requirements and ongoing legal and regulatory advice related to packaging and waste management.