The deposit-return system in SAP

The deposit-return system is a mechanism designed to promote recycling and the reuse of packaging. It applies to companies that market beverages in packaging covered by the deposit-return system through a representative entity, as well as to retail stores offering such products.

Entrepreneurs that market beverages in packaging covered by the deposit-return system will be required to include labeling on the packaging, indicating that the packaging is covered by the deposit-return system and specifying the deposit amount. A template for this labeling has already been made available by the Ministry of Climate and Environment.

The deposit amount has also been set in a ministerial regulation.  It will be 50 groszy for PET bottles and cans and 1 zloty for glass bottles.

The foundation for implementing the deposit-return system in Poland was Directive 2019/904 of the European Parliament and Council of the European Union, aimed at reducing the environmental impact of certain plastic products (the so-called SUP Directive). This directive imposed an obligation on member states to ensure selective collection for recycling purposes.

The implementation of the deposit-return system in Poland was initially planned for early 2025. However, in late October 2024, Prime Minister Donald Tusk announced a new date: October 1, 2025. At the same time, he acknowledged that the system was not yet ready and that the additional months would allow both the Ministry and businesses and stores, as well as consumers, to better prepare for this complex operation.

A draft amendment to the law, containing significant changes proposed by the beverage industry and representatives of the retail sector, is currently awaiting consideration in the Sejm. The final version of the law is awaited by businesses and IT system producers to prepare and implement the necessary changes in business processes.

The anticipated benefits associated with the implementation of the deposit-return system primarily include a reduction in environmental pollution caused by packaging waste and an increase in the level of selective waste collection and recycling. Additionally, it will foster the development of positive habits related to waste sorting.

The deposit-return system obliges the entities introducing products to the market (manufacturers, importers, brand owners) to collect packaging and achieve minimum levels set by regulations. These levels are quite ambitious and include:

• 77% for 2025,
• 81% for 2026,
• 84% for 2027,
• 87% for 2028,
• 90% for 2029 and beyond.

The law stipulates that the system will be decentralized – each entrepreneur introducing products to the market can establish its own entity responsible for packaging collection. In practice, this means that there will be multiple deposit-return system operators functioning in the market. Currently, the Ministry of Environment is in the process of verifying entities that are applying to run the system. The first permits have already been issued.

Retail stores are obligated to collect and refund deposits, physically collect packaging from consumers, handle logistics, and collaborate with the deposit-return system operator(s).

Adapting companies, their logistics chains and IT systems to the new regulations is a demanding and time-consuming process. Experiences from other countries where similar systems are already operational show that proper implementation requires the right IT tools, technological solutions, and business processes, including effective communication with partners throughout the value chain.

With the upcoming legal changes regarding deposit packaging in Poland, businesses must adapt their systems to meet the new requirements. Implementing the appropriate tools in the SAP system becomes crucial, particularly in the areas of sales and distribution as well as finance (SD, FI). All for One Poland is developing a comprehensive solution that will support compliance with legal regulations and provide the necessary modifications to existing sales and accounting processes, ensuring their operational efficiency.

Our team will conduct a detailed analysis of the sales processes and accounting entries related to packaging covered by the deposit-return system. Based on this analysis, we will propose the necessary system modifications, including customizations of existing processes or the creation of new solutions. We will then collaboratively establish an implementation schedule. The main objectives of this phase include:

• Identifying necessary changes in operational processes,
• Defining changes in the accounting area,
• Estimating the impact of system modifications on current business mechanisms.

The primary task of the All for One solution will be to fulfill the legislator’s requirements regarding reporting, including:

• Keeping a record of packaging introduced to the market;
• Reporting sold goods, taking into account deposit packaging and the balance of packaging within a given period;
• Keeping a record of the packaging mass put into circulation;
• Declarations and reports to the authorities responsible for recycling and packaging management.

Our experience with implementing and developing SAP systems for the largest beverage producers in the market enables us to develop system and process changes that facilitate auditing and reporting. Key areas include:

• Tracking packaging in terms of quantity and value;
• Changes to the pricing procedure to ensure accurate deposit calculation and accounting allocation,
• Modifications in the invoicing area to ensure proper settlement of accounts with customers and tax reporting.

Tax settlements under the new regulations will occur periodically. The current version of the law still does not regulate many aspects of how settlements should be conducted, which withholds companies from making decisions regarding their final accounting and tax approach, an aspect that is critical from the regulator’s perspective.

Despite many uncertainties that should be clarified in the planned amendment to the law, companies can already begin preparations in collaboration with All for One Poland. The elements that can be developed now primarily concern analyzing systems and processes, as well as implementing changes in sales processes, which will enable the provision of appropriate data sources for reporting. This approach will shorten the implementation of the reporting part to be made by launching standardized reports for our clients as soon as the law is finalized.

Currently, we are analyzing the SAP systems of our clients, producers of beverages in all types of packaging covered by the deposit-return system, in terms of the deposit-return system implementation.

The solution is prepared for both SAP ECC and S/4HANA versions.