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On 29 August 2025, the Ministry of Finance published tax explanations on VAT settlement in connection with the deposit-return system. This is important for businesses placing drinks on the market in bottles or cans subject to deposits, retail chains and entities representing participants in the system.
The explanations aim to standardise legal practice and protect taxpayers: anyone following these rules will receive protection equivalent to that provided by tax interpretations.
What is the deposit-return system?
The system was introduced by the Packaging and Packaging Waste Management Act. From 1 October 2025, Poland will operate a mandatory mechanism covering, among other things:
PET bottles up to three litres,
Metal cans up to one litre,
Reusable glass bottles up to 1.5 litres.
Consumers buying drinks in such packaging pay a deposit, refunded when the packaging is returned at any collection point, without needing a receipt.
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Main VAT rules
The explanations clarify key VAT issues:
The deposit is not part of the price – at every trading stage, manufacturer, wholesaler or retailer, it remains tax-neutral. Only when packaging is not returned must the entity placing the drink on the market add it to the tax base.
Annual settlement – VAT on unreturned deposits will be settled once a year, in the return for the first settlement period of the following year.
The VAT rate depends on the product – an unreturned deposit uses the drink's VAT rate, such as 5% for juice and 23% for carbonated drinks.
The representing entity – acts as the VAT remitter in the system, transferring tax on unreturned deposits to the tax office using funds collected from entities placing drinks on the market.
Electronic records – both the placing entity and representing entity must keep detailed records of packaging, deposits and returns.
What about businesses and retailers?
Shops, wholesalers and other intermediaries selling drinks covered by the system will not settle deposit VAT: this responsibility rests solely with entities placing products on the market. For retailers, this simplifies matters: a deposit may appear in the receipt's non-fiscal section but does not increase VAT-taxable sales.
Why does this matter?
The system supports recycling and introduces clear tax rules. The explanations show companies how to document deposits, when tax obligations arise and what happens if packaging is not returned. This reduces tax disputes and helps prepare accounting processes.
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Summary
From autumn 2025, the deposit-return system will become a real part of Poland's drinks market, and from 2026 businesses will have full deposit-related VAT settlement obligations. The explanations set clear rules: VAT neutrality until a deposit is retained, responsibility of placing and representing entities, and detailed record-keeping.
Businesses should now adapt accounting processes and reporting systems to avoid problems in the first year.
To ensure your company is prepared and settles correctly, contact TaxCoach. We provide comprehensive accounting services and tax support, letting you focus on business while specialists handle formalities.
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