Poland VAT Deposit System 2025: Key Insights and Changes for Businesses

The beverage industry across Europe is familiar with deposit schemes designed to encourage consumers to return bottles, cans, and other packaging. But in Poland, major changes are coming with the launch of the Poland VAT deposit system 2025 on 1 October 2025. These updates are not only an environmental initiative – they carry significant VAT implications that businesses must be ready for.

On 3 July 2025, Poland’s Ministry of Finance published draft tax guidelines explaining how VAT will be applied under this new deposit framework. While much aligns with existing legislation, the guidance offers essential clarifications for beverage manufacturers, retailers, and supply chain players preparing for the rollout.

What Is the Poland VAT Deposit System 2025?

The Poland VAT deposit system 2025 – known locally as kaucyjny – requires certain beverages sold in single-use packaging to include a refundable deposit in the sale price. Consumers get their deposit back upon returning the empty packaging. This initiative supports Poland’s waste reduction strategy, with VAT rules adapted to ensure consistent treatment.

Who Bears VAT Responsibility?

The Ministry’s draft clarifies that VAT liability primarily falls on:

• Entities introducing packaged products to the market
• Representing entities acting for producers

This includes beverage manufacturers and companies placing packaged drinks on the Polish market. They must handle VAT for both the sale and deposit aspects.
Distributors and retailers have lighter VAT responsibilities but must still follow proper procedures when accepting returns and issuing documentation.

When Does VAT Apply?

The rule is straightforward: VAT applies only if the packaging is not returned.

• Packaging returned → No VAT on the deposit, whether refunded in cash, voucher, or store credit.
• Packaging not returned → Deposit becomes part of the sale price and is subject to VAT at the same rate as the product.

This approach ensures VAT applies to actual consumption rather than temporary refundable amounts.

Documentation and Return Methods

A significant clarification in the Poland VAT deposit system 2025 is that non-cash refunds – such as loyalty points, vouchers, or store credits – still qualify as valid packaging returns for VAT purposes. The key factor is that the packaging is returned, and the value is acknowledged, regardless of the refund method.

This flexibility benefits modern retail setups using digital refund processes or customer loyalty systems.

VAT Rate Follows the Product

The deposit VAT rate will always match the VAT rate of the related product.
Example: A soft drink taxed at 23% means the deposit, if VAT is triggered, will also be taxed at 23%.
This prevents mismatched rates and simplifies VAT reporting.

Handling Unidentified Returns

Sometimes packaging can’t be linked to its original sale. In such cases, businesses must use proportional VAT calculation based on sales structure – applying an average or weighted VAT rate across their product mix. This ensures fair, accurate VAT reporting even when tracking isn’t perfect.

Why It Matters for Your Business

For beverage producers, retailers, and packaging companies, the Poland VAT deposit system 2025 is both an environmental compliance requirement and a VAT management challenge. Key takeaways include:

• VAT applies only when deposits are not refunded.
• Non-cash refunds are fully compliant.
• VAT rates on deposits match the product’s VAT rate.
• Proportional VAT applies when tracking returns is not possible.

By updating invoicing, reporting, and refund systems ahead of the 1 October 2025 launch, businesses can avoid compliance risks and ensure smooth operations.