The Deposit and Return System (SDR) is based on the application of a deposit fee charged to consumers at the point of purchase, which will subsequently be reimbursed upon the return of the empty packaging at an authorised collection point.
The deposit amount has been set at €0.10 per package, regardless of its volume or material. This amount is refundable and, as such, is not included in the price of the product and is not subject to VAT.
The system applies to non-reusable primary beverage packaging with a capacity of less than 3 litres, including water, soft drinks, juices, energy drinks and beer, provided that they are duly identified with the “Volta” symbol.
This symbol constitutes a key element of the system, as only packaging bearing it will be subject to the deposit and eligible for return and reimbursement.
It is also important to note that, between 10 April and 9 August 2026, a transitional period will apply during which packaging with and without the “Volta” symbol may coexist on the market, allowing for stock clearance and a gradual adaptation by economic operators to the new rules.
From a legal perspective, producers and importers of beverages will be required to ensure their registration with the system’s managing entity, SDR Portugal, as well as to carry out prior registration of packaging and ensure its correct identification with the “Volta” symbol and the corresponding EAN code.
Retail establishments will, in turn, be subject to different levels of take-back obligations depending on their size. This obligation will be mandatory for establishments with a surface area of 400 m² or more and, with certain nuances, for those with an area between 50 m² and 400 m².
The reimbursement of the deposit to consumers will be carried out upon return of the packaging at collection points and may take the form of cash, vouchers or digital solutions, with no requirement to present a purchase receipt.
For the return to be accepted, the packaging must be empty, not deformed and must display a legible barcode; otherwise, it may be rejected.
The legal framework governing the SDR is set out in the Unified Regime for Specific Waste Streams (UNILEX), approved by Decree-Law no. 152-D/2017, as amended by Decree-Law no. 24/2024, reflecting the legislator’s increasing focus on environmental sustainability and the circular economy.
The SDR will require companies to adapt:
- invoicing systems and price communication.
- product labelling and packaging.
- compliance with new operational and reporting obligations.
- the adoption of a structured and preventive compliance approach.
The Commercial and Corporate Law Department of Belzuz Abogados, S.L.P. remains at your disposal to provide all necessary clarifications and to support companies in analysing the applicable legal framework, adapting their operational models and ensuring compliance with the obligations arising from this new regime.
Belzuz Abogados, S.L.P. – Portuguese Branch is an international law firm, headquartered in Madrid, with offices in Lisbon and Oporto, providing legal advice to national and international clients, including in regulatory and environmental matters.