Author: Krzysztof Wiśniewski, CEO of Eurocast
The concept was logical and aligned with the European direction of change. Extended Producer Responsibility was to cover the actual costs of managing packaging waste, while the deposit return scheme was to ensure high-quality collection of selected fractions. In theory, both mechanisms were meant to jointly close the loop of the Circular Economy. In practice in Poland, they are being developed as two separate projects, without clearly defined boundaries of responsibility, without a single decision-making centre and—most importantly—without a coherent financial model. The problem is not the deposit return scheme concept itself. The problem is the marginalisation of the role of EPR and an attempt to build the deposit system outside the producer responsibility framework, instead of within it.
EPR – a foundation, not an add-on
Extended Producer Responsibility should not be treated as another administrative obligation or a future “add-on” to the waste management system. It is the foundation of the entire waste management architecture, determining who bears the costs of operating the system, who manages those costs, and who is actually responsible for achieving the recycling levels required under EU law. In well-designed European systems, EPR clearly assigns financial responsibility to producers, stabilises material flows to recyclers, balances costs borne by municipalities, and the deposit return scheme is one of the tools used to deliver EPR objectives—not an autonomous, competing mechanism.
In Poland, however, this order has been reversed. The deposit return scheme is being designed as a separate, costly logistics and financial infrastructure, while EPR remains undefined both in terms of the scope of responsibility and financing mechanisms. As a result, a competency and financial chaos is emerging, with no clarity on who is responsible for specific waste streams, who reports them, and who bears the actual costs of their management. The consequences of this lack of coherence are already visible: uncertainty is increasing for producers, municipalities and recyclers, and instead of being managed rationally, system costs begin to accumulate and be passed along the value chain, ultimately burdening consumers.
Blurred responsibility = blurred costs
The lack of a clear division of roles between the deposit return scheme and Extended Producer Responsibility leads to a number of fundamental questions that still have no unambiguous answers. It is unclear who should report actual recycling rates, who truly bears the cost of managing specific waste fractions, who is entitled to count a given material stream towards meeting EU targets, and—most importantly—who pays when the system no longer balances. Such unclear competencies translate directly into financial uncertainty for all market participants.
From an economic perspective, this primarily means a real risk of double financing of the same waste streams. Producers already incur high costs related to building, operating and maintaining the deposit return scheme, while at the same time they are being prepared for the implementation of a full-scale EPR system, which will also require financing collection, sorting and recycling of packaging. Without coherently linking these mechanisms into a single logical system, these costs will not be reduced or optimised. Instead, they will gradually be pushed down the value chain—from producers, through retail and local governments, to consumers, who will ultimately pay for the lack of a coherent regulatory architecture through higher product prices and rising waste management fees.
Loss of value in the municipal system
From the perspective of recyclers and processors, one more aspect is important—the value of the material. PET, aluminium and glass have so far been the most valuable fractions in municipal systems. Their sale made it possible to partially offset the costs of managing problematic and low-quality fractions.
Moving these materials to the deposit return scheme:
- deprives municipalities of the most financially “liquid” materials,
- leaves them with fractions that are more expensive and harder to manage,
- reduces the quality of input material delivered to sorting plants.
Without a strong, central EPR that would compensate municipalities for the loss of material value, the municipal system becomes increasingly costly—even though, theoretically, there should be less waste. The result? Higher fees for residents and growing financial pressure on local governments.
Krzysztof Wiśniewski, CEO of Eurocast
Recyclers need stability, not uncertainty
For companies such as Eurocast, a stable, predictable material stream and clear rules of the game are crucial. Recycling investments are capital-intensive and long-term. Under regulatory uncertainty, risk is priced in, and some investments are put on hold.
The EPR system should be a tool for market stabilisation:
- ensure continuity of material streams,
- clearly define financial responsibility,
- enable planning investments in recycling capacity.
Without this, both recyclers and producers operate defensively, and the costs of the entire system increase.
One structure, not two parallel projects
Without a single decision-making centre and without coherent management of material and financial flows, both solutions—the deposit return scheme and Extended Producer Responsibility—lose effectiveness and cease to deliver the objectives for which they were established. Instead of complementing each other, they start to operate in parallel, generating additional costs, regulatory uncertainty and competency conflicts. If the aim is to achieve a real Circular Economy, rather than merely formal compliance with EU reporting requirements, EPR must be designed as the overarching, integrating system within which the deposit return scheme will be one of the tools for delivering environmental objectives. It is also crucial to clearly and unambiguously assign responsibilities and costs to individual market participants, and above all to eliminate the risk of double financing of the same waste streams.
Otherwise, the domino effect will be inevitable. System inconsistencies will translate into rising operating costs, a slowdown in recycling investments and further shifting of financial burdens down the value chain. Ultimately, the consequences of these errors will be felt not only by producers and local governments, but above all by consumers, who will pay for the lack of a coherent vision through higher product prices and rising waste management fees.
