Commission’s interpretation:
According to the minimum requirements for DRS as set out in Annex X, final distributors must accept empty packaging of the products they sell and redeem the deposit. This obligation applies without proof of purchase. Furthermore, Member States must ensure that final distributors are obliged to accept all the deposit-bearing packaging of the same packaging material and format that they sell and pay out the deposit to the end user. The obligation to redeem the deposit does not apply where the sale surface area of the final distributor does not make it possible for the final distributor to accept the return the deposit-bearing packaging, or if end users have equally accessible means to redeem the deposit through another established and equally accessible collection channel for single use beverage packaging, authorised for that purpose. Member States must establish how these exemptions apply. The requirements specified in Annex X only apply to DRS established after 11 February 2025 or if a DRS does not achieve the 90 % separate collection targets by 1 January 2029. Consequently, DRS that must not fulfil the minimum requirements are not concerned by the take-back obligations set in PPWR.
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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.