10 August 2026 marks an important change for producers, importers, distributors, commercial establishments and consumers.
Since 10 April, the date on which the Deposit Return Scheme came into operation, a transitional period has been in force allowing packaging bearing the Volta symbol to coexist with packaging without that symbol. The purpose of this period was to allow economic operators to sell through their existing stock and adapt their commercial, logistical and accounting procedures.
This period ends on 9 August. Accordingly, from 10 August onwards, beverage packaging covered by the scheme that has not been duly registered, identified with the Volta symbol and made subject to the deposit will no longer be permitted to be sold in Portugal.
The scheme applies, in particular, to single-use plastic bottles and metal or aluminium cans with a capacity of less than three litres, without prejudice to any exclusions provided by law.
How does the 10-cent deposit work?
When purchasing a beverage covered by the scheme, the consumer pays an additional deposit of EUR 0.10 per container, irrespective of its material or capacity.
This amount does not represent a permanent increase in the price of the beverage. It is a refundable amount, which is returned when the empty container is delivered to an authorised collection point. The deposit must be passed on throughout the entire distribution chain and shown separately on invoices and on any medium used to display the price.
The deposit may be refunded in cash, through shopping vouchers, digital solutions or by way of a donation to charitable organisations. The option to receive the refund in cash may not be removed or made subject to conditions.
Retailers purchasing beverages from a supplier established in Portugal
Where a retailer purchases cans or bottles from a producer, importer or distributor established in Portugal, the products must be supplied already duly incorporated into the Volta scheme.
In principle, the Portuguese supplier responsible for first placing the beverages on the national market will be required to ensure the registration of the packaging, its correct marking, the payment of the relevant financial contributions and the initial charging of the deposit.
The retailer therefore purchases each product with the EUR 0.10 deposit already reflected in the commercial transaction. When selling the beverage to the final consumer, the retailer must charge the same amount and display it separately on the invoice, receipt and price information.
In this situation, the retailer should verify that:
- the packaging bears the Volta symbol and an eligible barcode;
- the deposit is duly itemised on the supplier’s invoice;
- the amount is passed on to the final consumer without any adjustment;
- stock without the required marking is withdrawn from sale before the end of the transitional period.
Retailers purchasing beverages directly from another European Union Member State
The position is more demanding where a Portuguese retailer purchases beverages directly from a supplier established in another Member State and places them on the Portuguese market for the first time.
In these circumstances, the Portuguese operator carrying out the intra-Community acquisition will, as a rule, be regarded as the packer or importer responsible for first placing the products on the national market. For environmental purposes, the operator is the producer of the product and is subject to the principle of extended producer responsibility.
This responsibility may not fall upon the Portuguese distributor where the foreign supplier has appointed an authorised representative in Portugal who validly assumes those obligations.
In the absence of an authorised representative, the retailer-importer will be required, among other obligations, to register and be classified as a producer or packer in SILiAmb; join the management entity responsible for the Deposit Return Scheme; register each packaging reference in advance; ensure that the Volta symbol and an eligible EAN code are affixed; pay the applicable financial contributions and deposits; submit declarations regarding the quantities placed on the market; and maintain up-to-date records of the transactions carried out.
The legislation also provides that packers must join the scheme and register each packaging reference at least 30 days before it is placed on the market.
Accordingly, a retailer directly importing beverages cannot simply affix a Volta label to the packaging. The relevant reference must first have been registered and approved by the management entity, and all environmental, financial, technical and reporting obligations associated with first placing the product on the Portuguese market must be complied with.
What happens to stock without the Volta symbol?
Until 9 August, retail establishments and HORECA-sector operators may continue to sell and exhaust their stock of beverages covered by the scheme whose packaging does not yet bear the Volta symbol. In such cases, the EUR 0.10 deposit may not be charged to the consumer.
From 10 August onwards, these products may no longer be sold to final consumers. The prohibition is not limited to sales made in physical establishments but also applies to e-commerce and other forms of distance selling.
Operators should therefore identify any remaining stock in advance, suspend its sale and assess, in accordance with the guidelines issued by the Portuguese Environment Agency, the legally permissible destination for such packaging.
Failure to comply with the obligations relating to marking, registration, application of the deposit or sale of the packaging may constitute an administrative offence and result in the imposition of penalties by the competent authorities.
Are all establishments required to accept returned containers?
Collection obligations vary according to the size and characteristics of each establishment.
Establishments with a continuous display and sales area of 400 m² or more must accept all packaging included in the scheme.
Establishments with an area exceeding 50 m² but below 400 m² must, as a general rule, accept packaging for the beverages they sell. However, they may be exempted where they demonstrate that they do not have suitable conditions for accepting returns and where there is a sufficient density of collection points in the relevant area.
Establishments with an area of 50 m² or less, as well as those in which the sale of food products represents less than 10% of total turnover, are exempt from the collection obligation, although they may join the scheme voluntarily.
It is therefore incorrect to state that all establishments with an area below 400 m² are automatically exempt from accepting returned containers.
Belzuz Abogados, S.L.P. – Portuguese Branch is an Iternational law firm, with its head office in Madrid and offices in Lisbon and Porto, which advises national and international companies on adapting to the new requirements of the Deposit Return Scheme, particularly in relation to extended producer responsibility and compliance with registration, declaration and reporting obligations.