The implementation of the deposit return system ("DRS") for bottled water, soft drinks, beer, cider, wine and spirits ("DRS products") in disposable plastic, glass or metal packaging of between 0.1l and 3l, will kick-off on 30 November 2023. As of that date, Romanians will be able to return the packaging of these beverages to the reverse vending machines provided by retailers or producers, as per the legal provisions.
Background
As detailed in this article, in 2021 Romania adopted its new legislative framework introducing a DRS applicable to non-refillable primary packaging made of glass, plastic or metal with volumes between 0.1l and 3l, containing water, juice or alcoholic beverages.
In 2023, the initial legislative act introducing the DRS was amended (as detailed in this article). A new set of obligations were introduced for producers, importers and traders of relevant products, and the application of DRS was postponed from 1 October 2022 to 30 November 2023.
New guidelines
The DRS administrator is taking steps to ensure that the system becomes operational on time. Among others, it has recently released Guidelines regulating prerequisites for reverse vending machines ("RVMs") employed for DRS packaging.
The Guidelines (available in Romanian on the administrator's website here) detail technical requirements and specifications for RVMs to be used by operators to ensure the effective functioning of the DRS.
These rules set a transitional period of six months from the implementation date of the DRS (30 November 2023), during which RVMs that have already been ordered or placed on the market should be updated to comply with the standards set forth in the Guidelines.
Also available on the administrator's website are the requirements for the barcode and the logo to be applied on the packaging in order to ascertain that it is a DRS packaging.
What do producers and retailers need to do?
Since DRS packaging requirements apply to products manufactured in Romania and to products imported or acquired from the EU, producers and retailers should already take steps to ensure that they will comply with these requirements.
By Oana Constantinescu, Partner, Schoenherr
