Eneris Calls for Dialogue and Clarity on Deposit Return System Legislation
The Deposit Return System (DRS) has the potential to significantly boost recycling levels in Poland. Yet, just months before its planned launch, more questions than answers remain. That was the key takeaway from the recent session of the Parliamentary Subcommittee on Waste Management Monitoring, dedicated to the DRS rollout. ENERIS was represented at the meeting by Agata Jużyk and Przemysław Wojciechowski.
Our presence at the subcommittee session is part of ENERIS’ broader commitment to shaping the regulatory landscape. We actively participate in discussions and highlight the practical needs of the sector – so that Polish companies can contribute effectively to building a circular economy and meeting ambitious recycling targets.
Key Concerns Raised by Industry Stakeholders
Participants from across the value chain pointed to a range of regulatory gaps and ambiguities. The following issues stood out most clearly:
- Concerns from beverage producers using reusable containers, who fear the new law could dismantle the currently functioning return system for these types of packaging.
- Lack of clarity around the registration and identification of glass packaging separators – such as crates used in distribution.
- Unanswered questions about public education – how to inform consumers about the new rules, and whether they should start collecting bottles now to reclaim deposits after October 1, 2025.
- Concerns from smaller retail outlets, including those under 200 m², about their obligation to handle deposit reimbursements.
- Warnings from the alternative fuels sector, which sees a risk of limited access to waste-based fuel inputs under the new law.
- Potential for abuse in waste storage practices, due to vague or missing administrative requirements.
- A lack of realistic implementation timelines, with many stakeholders calling for either a delay or a longer transition period.
- Uncertainty around the role of non-food retail and e-commerce platforms – will they be required to participate in the system?
- No clear consensus on the level of the handling fee that retailers and system operators would receive.
- Lingering silence from the Ministry, which has not responded to industry questions submitted as early as March.
Still Waiting on the ROP Law
It’s also worth emphasizing that Poland still lacks a legislated Extended Producer Responsibility (EPR) framework – which should serve as the backbone of the country’s entire waste management system. Without this foundation, it’s difficult to build a coherent and efficient deposit return scheme.
Our Message
Together with other industry players, ENERIS calls for open dialogue, legislative precision, and meaningful support for all stakeholders involved in the DRS rollout. Only a well-designed deposit system, anchored in a fair and functional EPR law, can deliver real environmental benefits while supporting a healthy circular economy.