Will the deposit scheme cover multi-material cartons?

The Ministry of Climate and Environment does not rule out extending the deposit system to further fractions, including multi-material packaging. The issue is currently under discussion between the ministry and the bottling industry. Possible changes can be expected no earlier than 2027.

MEP asks, MEP answers - discussion on multi-material packaging in the deposit system

The issue of including multi-material cartons in the deposit system was raised by MEP Grzegorz Matusiak in an interpellation addressed to the Minister for Climate and Environment. He pointed out that there is a current trend in the market to „escape” from the bail system - large beverage producers are switching from the mono-material packaging previously included in the system to alternative packaging that does not belong to the system. According to reports from the trade press the most common choice for producers in this situation is the difficult-to-recycle multi-material cardboard packaging, for which no deposit is charged.

In its response, the climate ministry confirmed that it recognises the phenomenon, but that it is, as indicated, of marginal scale, so does not require immediate action. However, the Ministry of the Environment is constantly analysing the industry's demands, including those regarding the inclusion of so-called tetraps in the deposit system, and still plans to decide on a possible legislative initiative in 2026.

Multi-material packaging is not a priority - take care of the fractions listed in the law first

The answer to the interpellation by the Undersecretary of State at the Ministry of Climate and Environment, Anita Sowinska, shows that at the moment the ministry is focusing on the development of infrastructure and reverse logistics those types of beverage packaging that have been part of the deposit system since its inception. Sowinska also pointed out that the imposition of a deposit on another fraction would result in a an additional burden on retail outlets and a reduction in the already greatly reduced waste stream going into the municipal system. In addition, it would require significant changes to the return infrastructure that has just been set up. One element of this is the bottle dispensers installed at collection points, which have not been adapted to collect waste from multi-material packaging.

Do exemptions to the bail system restrict competition?

In his interpellation, Grzegorz Matusiak also raised the problem of entire packaging segments being excluded from the deposit system. At first it was milk and dairy products, and after the launch of the system - beer and other beverages in reusable glass bottles. While the possibility to exclude beer packaging is only temporary (until the end of 2028) and the use of it has been made conditional by the Ministry of the Environment on the operation of an alternative collection system, for milk and dairy products there is no other collection system in place, nor is there a timetable set for their future inclusion in the central system. In the Member's view, such aim at restricting competition between marketers of packaged beverages, and the validity of their use should be reviewed by the IOC.

Read also: Glass bottles, however, outside the deposit system >>

As a restriction of competition in the market, the Member also points to the phenomenon of PET bottles and aluminium cans being replaced by multi-material cardboard packaging, which, due to the absence of a deposit and the need to return them, is a cheaper and more convenient alternative for consumers.

The Ministry did not directly address the issue of a potential restriction of competition. However, Minister Sowińska stressed that the purpose of the deposit system was not to promote the use of multi-material cardboard packaging, but to meet the high EU targets for separate collection levels of packaging waste. She added that the effectiveness of the system and its impact on the environment and the competitiveness of bottlers would only be able to be reliably assessed after an analysis of the reports for the first full year of operation of the deposit system.

Read also: Will there be an umbrella institution in the bail system?

Sources:

1. Interrogatory No. 16100 to the Minister for Climate and Environment on the deposit system and the types of beverage packaging covered, https://www.sejm.gov.pl/sejm10.nsf/InterpelacjaTresc.xsp?key=DSHE6Y
2. Reply to MEP Grzegorz Matusiak's interpellation on the deposit system and the types of beverage packaging covered, K10INT16100, https://sejm.gov.pl/INT10.nsf/klucz/ATTDSWJ5B/%24FILE/i16100-o1.pdf