Deposit Return System take-back obligation

A mandatory take-back obligation for retail outlets is one of the possible policy options for improving the collection of deposit-return packaging. This report analyses the potential effects of four variants of a take-back obligation to support the policy-making process. We qualitatively assess the implications for collection rates, feasibility, consumer convenience, and the practical consequences for different types of retail outlets. The different variants are compared with the current situation, in which no mandatory take-back obligation exists.

A take-back obligation can be introduced either with or without exemptions. This study explores four variants; additional exemptions or combinations of exemptions may also be considered during the subsequent policy development process.

1. Take-back obligation without exemptions: Every retail outlet selling deposit-return packaging is required to accept returned deposit-return packaging and reimburse consumers for the deposit.
2. Take-back obligation with an exemption based on floor space: Retail outlets selling deposit-return packaging that are smaller than a specified floor area threshold (m²) are not required to accept returned deposit-return packaging.
3. Take-back obligation with exemptions for specific sectors: Hospitality businesses where beverages are consumed on the premises, online deliveries made via parcel services, and standalone beverage vending machines that are not associated with a staffed retail outlet are not required to accept returned deposit-return packaging.
4. Take-back obligation with an exemption where specific conditions are met: An exemption applies where several nearby retail outlets selling deposit-return packaging jointly provide a single return point under binding agreements.

Based on the findings, we make the following recommendations:

• Define any exemptions on the basis of their impact on effectiveness and efficiency. Exemptions may be justified where collection is already effective or where disproportionately high costs would be incurred to achieve only limited additional collection. It is important that exemptions minimise any reduction in the overall effectiveness of the system.
• Conduct a legal assessment to determine the feasibility of any proposed exemptions and to establish an appropriate legal framework for their implementation.
• Explicitly stipulate in legislation that a take-back obligation constitutes a genuine obligation to accept returns. For example, where a reverse vending machine (RVM) is out of service, the collection point should still be required to accept deposit-return packaging manually.
• Where a take-back obligation includes only limited exemptions, these should be administered through an active application process. Such a system appears to be less susceptible to fraud and may encourage collection by exempted retail outlets. Where the scope of the take-back obligation is very limited, passive exemptions may be more appropriate.
• When considering exemptions, also consider imposing conditions on collection rather than fully exempting certain types of collection points. Examples include setting a maximum number of items that may be returned, specifying the method of reimbursement (cash or digital), or limiting the obligation to particular types of packaging.

The report was submitted to the House of Representatives on 26 June 2026 together with the accompanying ministerial letter (only available in Dutch). The Minister will present a proposal at a later stage to increase the number of collection points.