Deposit return schemes and EPR — what they mean for paper packaging

The phrase deposit return scheme packaging causes a fair amount of anxiety among companies that order printed boxes and bags — it sounds like another obligation, another cost and more paperwork to deal with. The good news is that in most cases it is not your cardboard packaging that goes into the deposit system. It is still worth understanding what is changing and why, because a second mechanism operates alongside the deposit — EPR — and that one affects you more than you might think.

One thing up front: this is a regulatory topic, and rules and deadlines can change. We write about the direction and the mechanism — as things stand in 2026 — while specific amounts, dates and requirements are always worth confirming in current official sources or with us. This is a practical overview to support a purchasing decision, not legal advice. We will calmly separate two ideas that are easy to confuse: the deposit return scheme and EPR (extended producer responsibility).

Deposit return scheme versus EPR — two different things

Let us start by sorting them out, because in conversation the two terms merge into one “new packaging rules”. In fact they are two separate mechanisms that touch your company in completely different ways:

• The deposit return scheme — a surcharge (deposit) added when buying a product in a specified type of packaging. The customer pays the deposit and gets it back when they return the empty packaging at a collection point. In Poland it covers primarily beverage packaging.
• EPR (extended producer responsibility) — the principle that a company placing a packed product on the market co-finances the later collection and recycling of that packaging. It covers a far wider scope, including paper and cardboard packaging.

Both mechanisms head in the same direction — less waste, more genuine recycling — but they do it differently. The deposit works through the consumer physically returning the packaging. EPR works through fees and responsibility on the side of whoever places the packaging on the market. For a company ordering boxes and bags that difference is crucial.

What the deposit scheme covers — and what it does not

The most important distinction in this whole topic: the deposit return scheme in Poland covers mainly beverage packaging — PET bottles, returnable glass and cans (within specific scopes set by the rules). That is the world of producers of drinks, water, beer or juice, not of companies ordering packaging for a product.

If you order cardboard boxes, printed paper bags, packaging for sushi, biscuits, cosmetics or supplements from us — as a rule they sit outside the deposit scheme. Nobody will add a deposit to them or collect them in reverse vending machines. There is no need to panic-redesign your packaging “because the deposit is coming”, because most often it is not. Below is a summary that quickly shows what applies to what (the descriptions are indicative — confirm the detailed scopes in current legislation):

In other words: the deposit is not your front. Your front is EPR — and the good news is that paper and board come out of that one rather well.

EPR — what really applies to your boxes and bags

EPR rests on a simple idea: whoever places packaging on the market takes co-responsibility for what happens to it after use. In practice that means fees and obligations tied to collection and recycling — spread across producers, importers and those placing packed products on the market.

What matters most for you is the direction in which those fees are evolving. They are moving increasingly towards so-called eco-modulation, meaning rates differentiated by how easy a given piece of packaging is to recycle. The mechanism is common sense:

• Packaging that is easy to recycle — mono-material paper and board — is simply more favourable in the settlement and consistent with the direction of the rules.
• Packaging that is hard to recover — complex laminates, paper permanently bonded to film or plastic — tends to be treated less kindly, because it returns to circulation with more difficulty.

This is exactly where paper boxes and bags come out ahead. A uniform cellulose material is widely collected and processed, so it naturally fits what EPR is pushing the whole market towards. We write more about the recovery process itself in the piece on recycling cardboard packaging, and more broadly about materials and an “eco for the purchasing decision” approach in the guide to eco packaging for business.

How this connects to PPWR

The deposit and EPR do not operate in a vacuum — they are elements of a bigger puzzle framed by the EU’s PPWR, the regulation on packaging and packaging waste. PPWR sets the direction: design for recycling, mono-materials, sensible labelling and cutting excess. The deposit scheme and EPR are concrete tools that pursue the same goal from the financial and organisational side.

For a company ordering packaging there is one coherent conclusion: the decisions you take for EPR are exactly the decisions that serve you under PPWR. You do not have to prepare separately “for the deposit”, “for EPR” and “for PPWR” — it is one direction. We lay out the full picture of the incoming rules in a separate article on PPWR 2026 — what changes for packaging. Here we focus on what follows practically for your box and your bag.

How to prepare the packaging — four decisions

Rather than worrying about rules in isolation from the product, it is worth reducing the topic to four concrete decisions you make anyway when ordering packaging. Made well, they do most of the work for you:

• Design for recycling. Right at the design stage it is worth assuming the packaging really will return to circulation. That means: a simple structure, fewer elements the consumer cannot separate, and avoiding solutions that make sorting harder.
• Mono-materials. One raw material — paper or board alone — instead of paper-and-film or paper-and-plastic mixes that are hard to separate. Mono-material is the simplest route to packaging consistent with the spirit of EPR and PPWR. We explain the difference between genuinely recyclable and merely biodegradable material in the piece biodegradable or recyclable.
• Proper labelling. Clear information about the material and how to sort it helps the packaging reach the right waste stream. It is a small element of the design that genuinely affects whether the board returns to circulation.
• Material choice. Paper with documented origin or with recycled content strengthens the packaging’s environmental profile. If confirming the origin of the raw material matters to you, it is worth asking about a certified version — we cover this in the article on the FSC certificate for packaging.

All four decisions share a common denominator: they lead towards simpler, paper-based, uniform packaging. That is no accident — it is exactly the direction the rules reward today.

What to do now — without panic

There is no need to run five years ahead or rework your whole warehouse overnight. A few sensible moves right now set you up well for the future:

• Calmly check what actually applies to you. If you pack your product in board and paper, the deposit most often passes you by and your area is EPR. That removes a lot of unnecessary stress.
• Choose mono-material where you can. Paper alone instead of laminates and film — easier recovery and a more favourable direction on fees.
• Do not oversize the packaging. A well-chosen size means less material, lower cost and alignment with the spirit of the rules all at once.
• Think about the eco profile from the design stage. It is easier to plan at the start than to rework a finished run — and we do that visualisation as part of the price anyway.
• Confirm details in current sources. Amounts, dates and scopes change — if in doubt we will point you to where to check, or how to choose packaging for the current requirements.

The most common doubts

Will my cardboard boxes go into the deposit scheme?
As a rule, no. The deposit return scheme in Poland covers primarily beverage packaging — PET bottles, glass and cans. Typical paper boxes and bags for a product sit outside the deposit. Detailed scopes are worth confirming in current legislation, but that is the direction.

How does EPR differ from the deposit in practice?
The deposit is money returned to the consumer for handing back beverage packaging. EPR is co-responsibility and fees on the side of the company placing the packaging on the market. Your paper packaging falls under the second mechanism — and that one rewards board that is easy to recycle.

Does paper packaging genuinely help with EPR?
Yes, because mono-material paper and board are widely collected and processed, and the direction of fees favours packaging that is easy to recover. A simple paper structure without unnecessary laminates is consistent with the spirit of the rules.

Do I have to change my packaging right now?
Usually not overnight. What is worth doing is making forward-looking material decisions with the next run — mono-material, sensible size, clear labelling. That is cheaper than redesigning under pressure later.

Will you help me choose packaging that complies with the new rules?
Yes. We will advise on material, sensible size and finish so that the packaging is consistent with the direction of EPR and PPWR while still looking good. We prepare the design and visualisation as part of the price, for approval before production.

Design packaging ready for the new rules

The simplest way to start is with specifics: give us the type of packaging, the material and an approximate run, and we will select a solution consistent with the direction of EPR and PPWR and prepare a visualisation with an initial quote. Design and visualisation are included, and we produce from 500 pcs:

→ Calculate the cost of packaging ready for the new rules

Look here too

Want the wider regulatory context? Start with PPWR 2026 — what changes for packaging, see how recycling cardboard packaging works, and get the materials topic straight in the guide to eco packaging for business. We select material and structure for the new requirements in-house — as a packaging manufacturer from Warsaw the design and visualisation are included, we produce from 500 pcs and ship across Poland and the EU.