Poland set to launch VAT Deposit System in October 2025: important features

Poland will introduce a new VAT deposit system (kaucyjny system) on 1 October 2025, requiring refundable deposits on single-use beverage packaging, with VAT applied only to unreturned deposits. The rules clarify VAT liability, allow refunds via cash or non-cash methods, and oblige businesses across the supply chain to update invoicing, reporting, and refund systems to avoid penalties.

Poland is preparing to roll out a transformative VAT deposit system on 1 October 2025. Known locally as the kaucyjny system, the initiative aims to reduce waste while introducing new VAT compliance requirements for businesses across the beverage supply chain.

On 3 July 2025, Poland’s Ministry of Finance published draft tax guidelines detailing how VAT will be applied under the new deposit framework. While the system builds on existing environmental legislation, the guidance introduces key clarifications for manufacturers, distributors, and retailers.

Under the new rules, certain beverages sold in single-use packaging must include a refundable deposit in the sale price. Consumers receive their deposit back when they return the empty packaging—whether in cash, store credit, or loyalty points.

The Ministry’s draft outlines who bears VAT liability:

• Returned Packaging: No VAT on the deposit.
• Unreturned Packaging: Deposit becomes part of the sale price and is taxed at the same rate as the product.

This ensures VAT is only applied to actual consumption, not temporary refundable amounts.

A major clarification is that non-cash refunds—such as vouchers or loyalty points—are fully compliant for VAT purposes, as long as the packaging is returned and the value is acknowledged.

The VAT rate on the deposit will always match the rate of the associated product. For example, a soft drink taxed at 23% will have its deposit taxed at 23% if not returned.

If packaging cannot be linked to a specific sale, businesses must apply a proportional VAT calculation based on their product mix. This ensures fair reporting even when tracking is imperfect.

With the launch date approaching, beverage producers, retailers, and packaging companies must:

• Update invoicing and reporting systems
• Ensure refund mechanisms support non-cash returns.
• Prepare for proportional VAT calculations

Failing to comply could result in audit risks and financial penalties.