Deposit Return Scheme Rules for Online Sellers

Re-turn published its annual report at the end of July, and the figure that drew the coverage was the €60.1 million left unclaimed in deposits across 2025, down from roughly €67 million the year before. If you ship drinks from your own website, a much smaller number matters more: fifteen cent, and exactly where it appears on the order.

Most online shops I have looked at have the Deposit Return Scheme roughly right in the stockroom and wrong on the page. The cans are correctly labelled. Deposits have been paid up the chain. And then the website quietly folds the whole thing into the product price, because that was the fastest way to make the maths come out, and nobody went back to check what the regulations actually ask for.

They ask for something quite specific. Not a total that happens to be correct. A separate line.

The deposit is not part of your price, and the regulations say so in as many words

The Separate Collection (Deposit Return Scheme) Regulations 2024, which replaced the original 2021 instrument, define the scheme as one where the consumer at the point of sale pays an amount that is, in the drafter's words, not part of the sales transaction. That phrase is doing real work. The deposit travels alongside your price. It is not a component of it.

Revenue takes the same view for tax. Its guidance on the scheme states that the deposit amount is regarded as nil while a drink product is moving through the supply chain, so businesses have no VAT liability relating to the deposit and the consumer is not charged VAT on it. VAT on the drink itself applies in the normal way.

Now put those two together and look at what a baked-in price does. Fold fifteen cent into a product line that your shop is taxing at the standard rate, and you have just charged VAT on something Revenue treats as carrying none. Every order. Quietly. The customer overpays by a few cent, your VAT return overstates, and the receipt in their inbox shows no deposit at all, which is the one thing the regulations were most concerned about. It is the mirror image of the surcharge you are not allowed to add at your checkout: one line is forbidden, this one is compulsory, and both of them get decided by a settings field somebody configured once.

What is in scope, and what the deposit actually comes to

The scheme covers beverage bottles made from PET and beverage containers made from aluminium or steel, in both cases with a capacity between 0.150 litres and 3 litres. Glass is not in scope. Neither is a carton, a pouch, or a keg.

The First Schedule to the regulations fixes the deposit at €0.15 for in-scope products of half a litre or less, and €0.25 for anything larger. Per container. Not per pack, not per order.

That distinction is where the arithmetic starts to bite for anyone selling by the case. Consider a coffee roaster in Roscommon shipping cold brew in 250ml cans, sold as a twelve-pack. The deposit on that single order is €1.80, which is more than the margin on a bag of beans, and it is not revenue. It never was. That money passes straight through. If it has been absorbed into the case price for eighteen months because the product was set up before anyone read the instrument, that is eighteen months of a number sitting in the wrong column of the business.

The deposit travels with the sale rather than inside it, which is why the regulations ask for a line of its own.

The four documents that have to carry the line

Regulation 14 puts three duties on a retailer where a deposit applies: make sure the product is labelled as the scheme requires, charge the deposit to the customer, and itemise that deposit as a separate line item. Regulation 18 repeats the itemisation duty in its own right. Both name the same four documents.

Document	Where it lives in a typical online shop	What has to be on it
Invoice	Trade and B2B orders, accounts software	Deposit as its own line, outside the taxable amount
Receipt	The order confirmation email the customer keeps	Deposit shown separately from the product total
Credit note	Refunds, cancellations, returned orders	The deposit credited back on its own line
Dispatch and delivery docket	The packing slip printed into the box	Deposit itemised against the containers shipped

The invoice and the receipt are the two most shops get partly right, because they are generated by the same order object and a fee line usually carries through to both. Worth verifying rather than assuming, though, because plenty of receipt templates are configured to print a simplified total.

The credit note is where it tends to fall apart. A customer returns two cases, your shop processes a partial refund, and the refund is calculated against the product line only. Now you have kept a deposit on containers you never delivered, and there is no document showing what happened to it.

The delivery docket is the one almost nobody has looked at. That packing slip is generated by a print plugin, often with its own template, and that template was written to show products and quantities. A fee added at cart level does not always survive the trip into it. Print one. Read it. That single sheet of paper is named in the regulations as plainly as the invoice is, and it is the only one of the four that leaves your building physically.

You are not outside the scheme, you are exempted from one part of it

This is the misreading that does the most damage, and I have made a version of it myself.

Re-turn's own guidance for retailers is unambiguous: if you sell in-scope drinks containers on your premises, for take away, or online, you must register. Selling only through a website does not put you outside the scheme. It puts you inside it with one obligation adjusted.

The adjustment sits in Regulation 17. A retailer may, subject to agreement with the approved body, be exempted from the take-back obligations where an in-scope product is purchased through online sales. Read the qualifier. The exemption is not automatic and it is not self-certified. It is agreed. And Regulation 14 then adds a condition that rides along with it: where such an exemption has been agreed, the retailer must display the location of the closest return point that accepts returns from customers, in a manner agreed with the approved body.

So the online seller who correctly concludes that nobody has to post empty cans back to them still ends up with something to publish. A line telling the customer where their containers go. On the page, in the confirmation email, or on the docket in the box, depending on what has been agreed.

My own version of getting this wrong was reading a trade summary instead of the instrument when the scheme launched, and carrying around the assumption for months that distance sellers were simply out of scope. They are not. The summary was not wrong so much as compressed, and compression is where compliance detail goes to die. I read the statutory instrument now, every time, and it takes twenty minutes.

Where this gets awkward, honestly

Three things are genuinely untidy, and it is better to know them before a customer asks.

The first is that the same can can be in scope and out of scope in one business. Regulation 17 exempts a retailer from charging the deposit where the product is purchased and intended to be consumed on the premises. Serve the can at a table, no deposit. Sell the identical can for takeaway, or ship it, and the deposit applies. If you run a room and a website, your two channels follow different rules for the same SKU, and a shared product record will not know the difference.

The second is a shop-software problem rather than a legal one. Deposits are usually implemented as a fee, and fees are the part of a cart most likely to behave oddly when something else recalculates. Apply a percentage discount code and check whether it has just discounted the deposit. Change a tax class and check the fee did not inherit it. Cart totals are not proof; the receipt and the docket are.

The third is the question everyone asks second, and the honest answer is that it follows from the definition rather than from a rule written for it. If the deposit is not part of the sales transaction, then the safe reading is that it should not count towards a free delivery threshold and a discount should not be applied to it. That reasoning is sound, but it is reasoning, not a published determination, so it is worth a short conversation with your accountant and with Re-turn before you set the threshold logic. The same care is worth taking with how the delivery charge itself is presented on the page, which is governed by an entirely different set of rules.

Four documents, one line, and only one of them leaves the building in a box.

Five passes over your shop before the next order goes out

Register. If in-scope containers leave your building, you are a retailer under the scheme, and registration with Re-turn comes before anything you change on the site.

Separate. Pull the deposit out of every product price and configure it as its own amount, at €0.15 or €0.25 per container, with no VAT applied to it.

Verify. Place a real test order, refund half of it, and read all four documents that come out the other end, including the packing slip you print rather than the one you assume.

Signpost. Agree your take-back position with Re-turn and publish whatever return point information that agreement requires, in the place it was agreed to appear.

Deploy. Push the change to production the day you make it, then watch the first live orders rather than waiting for a customer to notice the difference.

What being able to make this edit yourself is actually worth

None of the above is difficult. Every part of it is small. The problem is that "small" and "quick" are not the same thing when you do not hold the keys to your own product settings, and a two-line change becomes a change request, a quote, and a fortnight.

I will give the other side its due. If your catalogue is a handful of in-scope lines and nothing else, a premium hosted shop platform with a native container-deposit field will genuinely do this in a couple of clicks, and that is a fair reason to be on one. The trade comes later, when the next scheme arrives and the field you need is not one the platform has decided to build.

Full WordPress does not have that ceiling, which is most of why we run it. On Web60's €60 a year all-inclusive platform the site, the hosting, the SSL, the nightly backups and the staging environment come in one price, so the change costs you the twenty minutes it takes rather than an invoice. Test the deposit line on staging, read the docket, push it. That is the whole job.

Regulations are not usually the interesting part of running a shop. But a scheme that moved roughly 1.4 billion containers in a single year, at a return rate Re-turn puts at 76.4% on its own measure with the balance of in-scope containers still reaching the ordinary dry recycling stream, is not a pilot any more. It is ordinary trading infrastructure, and the paperwork it generates has settled into a shape your website is expected to match.

Conclusion

The Deposit Return Scheme asks for less from an online seller than most owners fear and something more precise than most have configured. Charge it. Show it on its own line. Put it on all four documents, including the one that goes in the box. Agree your take-back position rather than assuming it.

An hour with your product settings and a test order will tell you where you stand, and if the answer is that the deposit has been hiding inside your prices since 2024, that is a fixable afternoon rather than a crisis.

Frequently Asked Questions

Do I have to register with Re-turn if I only sell drinks through my website?

Yes. Re-turn's retailer guidance states that if you sell in-scope drinks containers on your premises, for take away, or online, you must register. Selling exclusively at a distance does not put you outside the scheme. It changes which obligations apply to you, principally the take-back obligation, which can be adjusted by agreement.

Can I just include the deposit in my product price to keep it simple?

No. The 2024 regulations require the deposit to be itemised as a separate line item on any invoice, receipt, credit note, dispatch or delivery docket that carries the price of an in-scope product. There is also a tax consequence: Revenue treats the deposit as carrying no VAT, so folding it into a taxable product price charges VAT on an amount that should not bear any.

How much is the deposit and is it per container or per pack?

Per container. The First Schedule sets €0.15 for in-scope products of 0.5 litres or less and €0.25 for those above 0.5 litres. A twelve-pack of 250ml cans therefore carries €1.80 in deposits, shown separately from the price of the pack.

Do customers post empty containers back to me?

Generally no. Regulation 17 allows a retailer to be exempted from the take-back obligations for products purchased through online sales, but that exemption is subject to agreement with the approved body rather than being automatic. Where it is agreed, you are required to display the location of the nearest return point in a manner agreed with Re-turn.

Which containers are actually in scope?

PET beverage bottles and aluminium or steel beverage containers with a capacity between 0.150 litres and 3 litres, carrying the Re-turn logo. Glass bottles, cartons and pouches are not currently in scope in Ireland. If a container in your catalogue does not carry the logo, it is not an in-scope product and no deposit applies to it.

What happens if my shop has been getting this wrong since 2024?

Correct it, document when you corrected it, and reconcile the deposits you have collected with what you have paid up the chain. Enforcement of the regulations sits with local authorities, and an authorised person's first interest is normally whether the business has registered and is charging and itemising correctly now. Getting the configuration right and being able to show when you changed it is a considerably better position than an unexplained discrepancy.

The Deposit Return Scheme Rule That Lands on Your Product Page