The Deposit Map: Which Member States Run, Build or Debate DRS
The station's reference table in prose: operating systems, legislated launches, derogation candidates and open debates - and how a producer keeps the map current as the 2029 deadline reorganises it.
The short answer
Three populations divide the map. Operating systems - the Nordics, Germany, the Netherlands, Croatia, Slovakia, Romania, Hungary, the Baltic states, Ireland (whose Re-turn scheme launched in 2024) and others - run deposit today, each with its operator, scope and level in the DRS station's terms. Building systems - states that have legislated or are constructing toward the deadline, Poland and Spain's framework among them - are launches in progress, where producer registration windows and recognition queues are forming now. And the deciding states - those weighing the derogation evidence or final scope choices, Czechia the most visible - where the producer's duty is to prepare for the system while contributing data to the decision.
This guide is the map's legend and its maintenance discipline; the map itself lives in the portfolio's matrix, refreshed quarterly.
The operating population: what 'running' demands of you
In operating markets the producer's duties are steady-state: container registration maintained, deposits cleared, scope watched for extensions (several operators have widened material or category scope since launch, and each extension is a mini-launch for the affected SKUs). Ireland's experience is the freshest template for a launch inside a common travel area - its differential with Northern Ireland (outside the EU system) made border retail and marking discipline first-order issues from day one, the cross-border guide's analysis in live form. Operating-market vigilance is therefore not passive: subscribe to the operator's producer communications as a compliance feed, with the same seriousness as a regulator's newsletter.
The building population: the queue is the message
In building markets the scarce resources are the operator's onboarding capacity and the recognition laboratories - queues form in the launch year and punish late registrants with delayed listings. The producer programme for a building market starts at legislation, not at launch: scope mapping of the portfolio, data assembly in registration grade, sample logistics planned, and the commercial terms (deposit in pricing, retail communication) built into the annual cycle preceding launch. The systems' own communications will understate the queue; the operators' producer desks, asked directly, rarely do. Ask directly.
The derogation watch: reading a deciding state
For deciding states, the indicators are the derogation guide's: published collection-rate methodology and results, the plan's milestones if a request is filed, and the Commission's response. A producer's posture in a deciding state is dual-track preparation - the data discipline a derogation requires (register-grade placement and collection numbers) is the same discipline a launch requires, so preparation is never wasted whichever way the decision falls. Record the state's position in the matrix with its evidence date; a derogation debate is a moving position, and last year's summary is this year's incident.
The map's half-life
A deposit map decays faster than any other document in this station: decisions land monthly in the run to 2029, and a map six months old is a historical source. The quarterly review in this guide is a maximum interval, not a rhythm to relax into - the event triggers (a decision, a launch date, a derogation filing) override the calendar whenever they fire. Assign the map an owner who reads operator news the way traders read wires; in the launch years, deposit intelligence is a competitive input, not a compliance chore.
Reading the map for one range review
A drinks range review run off the map, in five lines per market reduced to one: Germany - operating, maintain registrations, scope steady. Poland - building, registration window open, samples submitted, launch-staffed. Czechia - deciding, dual-track data ready, decision trigger diarised. Spain - framework pending, watch the collection-evidence trigger. Italy - no deposit, EPR position only, content and marks reviewed. Five sentences that took a quarter's intelligence work to earn, and that priced the range's next two years of packaging administration in a single meeting. That compression - from system knowledge to decision line - is the map's entire purpose.
Primary sources on the record
- Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste, Official Journal text on EUR-Lex.
- European Commission, packaging waste topic page - guidance and act progress.
- Directive 2008/98/EC of 19 November 2008 on waste (the Waste Framework Directive), text on EUR-Lex - the EPR minimum requirements and waste definitions behind the PPWR.
- EWP Recycling Pfand Oesterreich, recycling-pfand.at - the operator of the Austrian one-way deposit system.
Legal status: Article 50 of Regulation (EU) 2025/40 in national execution. Application position for this topic: Map current at verification date; systems due by 1 January 2029.