Q & A
As an economic operator selling beverages in primary non-refillable packaging, you have an important role in the implementation of the DRS in Romania and a decisive contribution to reach the national collection and recycling targets.
We want to provide support to all retailers who play a key role in the implementation of this system and in this regard, we have developed a list of questions and answers to help you understand the legal obligations set out in HG 1074/2021 and to guide you through the process of registering in the system's database.
Category of economic operators who are obliged to register in the DRS.
There is an obligation to register in DRS to all retailers, legal persons authorised to market to consumers or end-users products packaged in non-refillable primary packaging made of glass, plastic or metal, with volumes between 0.1 l and 3 l, used for beer, beer mixes, mixes of alcoholic beverages, cider, other fermented beverages, juices, nectars, soft drinks, mineral waters and drinking waters of any kind, wines and spirits, which will bear the DRS mark. This category includes HORECA retailers, legal entities in the hospitality and food service industry, in particular establishments organising events, preparing and serving food and beverages, as well as retailers who make products packaged in DRS packaging available on the national market exclusively via online platforms or exclusively via vending machines. It is compulsory for the above retailers to be registered in the DRS, irrespective of whether their activity is permanent or seasonal.
What is a return point?
A return point is a place organized and managed by one or more retailers, respectively in partnership with a local administrative unit or an inter-community development association, where primary non-refillable drinks packaging is returned by consumers or end-users for the refund of the deposit.
Are all retailers obliged to organize collection points?
Only HORECA retailers or those who sell products exclusively online or exclusively via vending machines are not legally obliged to organise collection points. Otherwise, all retailers selling products for the purpose of DRS, regardless of the size of the sales area, are legally obliged to organize collection points for DRS packaging.
What options do retailers have for organising collection points?
There are different ways for retailers to fulfil their legal obligation to organize collection points, depending on the size of the sales structure.
Retailers who have a sales structure area larger than 200 sqm are obliged to organize their own collection points.
Retailers with a sales structure area of less than 200 square meters may, in addition to organizing their own collection points, opt to fulfil the legal obligation to organize collection points by association with other retailers with sales structures of less than 200 square meters, or by partnership agreement with local administrative units or inter-community development associations.
In the case of retailers who do not organize their own collection points, the distance to the established return point may not be more than 150 m from each sales structure of the trader in the partnership agreement, for sales structures in cities, and 500 m for sales structures in rural areas. Retailers may opt, within the sales structures they operate, for manual takeover or takeover using RVMs (automated takeover systems).
What other obligations do retailers have regarding collection points?
According to Government Decision 1074/2021, at collection points retailers must accept all DRS packaging returned by consumers or end-users, regardless of where the packaged product was purchased and without making the acceptance of the DRS packaging conditional on the presentation of the receipt.
They are required to keep the returned DRS packaging separate from waste or other non-DRS packaging for collection by the DRS manager. They are also obliged to allow only the DRS manager to take back the DRS packaging from the collection points at the request of the DRS manager or his designated representative.
For all collection points, including those organized outside the sales area, the operators of the collection points will ensure their monitoring and security, based on their own regulations that ensure the integrity of the return point, its equipment and the returned packaging.
What obligations do retailers have after the DRS becomes operational in Romania?
In addition to the obligations related to the collection points mentioned in the previous question, retailers will have the following legal obligations after the entry into operation of the Deposit-Return System: received from consumers or end-users, the DRS manager, and the other economic operators within the DRS with whom the retailer has concluded contracts.
To clearly indicate the value of the deposit on the shelf and on the fiscal documents related to the DRS packaged product
To pay the value of the deposit to the economic operators from whom they purchase DRS packaged products
To collect from their customers the deposit related to DRS packaged products
To not market DRS packaged products purchased from producers not registered with the DRS administrator or distributors of such producers
To not market products packaged in DRS packaging that are not marked in accordance with the law
To display information to consumers or end-users at points of sale about their obligations and rights under the DRS.
To use the software provided online by the DRS manager to report on DRS packaging and the associated deposits.
To use, for the reporting of DRS packaging and related deposits, the software made available online by the DRS administrator.
To keep track of the total number of DRS packaged products sold, broken down by product, for each sales structure and/or online shop they operate, the total number of DRS packaging returned to the retailer by consumers or end-users, broken down by type of material and volume, as well as the deposit paid, collected on the sale of products and returned to consumers at the collection point.
To enable the competent authorities to carry out checks and to provide them with documents, correct and complete information on how the retailer has fulfilled his obligations, as well as supporting documents received from consumers or end-users, the DRS manager, and the other economic operators within the DRS with whom the retailer has concluded contracts.
To provide in writing, within a maximum of 10 working days, clarifications and information requested by the DRS manager in relation to the fulfilment of the obligations arising from this decision.
I opt to organize a manually operated return point. What does this entail?
All retailers who organize a collection point with manual return will check whether the returned packaging meets the conditions laid down by law. They will only take back packaging that is returned in one piece, without being degraded or deformed, is completely emptied of its contents and has the marking indicating that it belongs to the DRS visibly and legibly applied.
Retailers will use the computer system provided online by the DRS manager to report DRS packaging and the associated deposits.
In order to cover the costs of managing packaging at the collection points, there will be a management fee to be paid to the operators of the collection points for the packaging taken over by the DRS manager, which will be set by the DRS manager in accordance with the methodology for calculating the management fee to be approved by order of the Minister for the Environment, Water and Forests. The amount and frequency of payment of the management fee will be set transparently by the DRS administrator, based on the methodology developed by the central public authority for environmental protection.
I opt for organizing a collection point using an RVM. What does this entail?
In the case of a decision to take back packaging via RVMs, RetuRO's recommendation is to make a prior analysis from an efficiency point of view, in the sense that the installation of the RVM should be justified in terms of the number of DRS packaging expected to be returned to that collection point organized and operated by the retailer. It should be noted that all initial purchase costs of the RVM will be paid by the trader.
In order to cover the costs of managing the packaging at the collection points, a management fee will be paid by the DRS manager to the operators of the collection points for each package taken over by the DRS manager, and will be set by the DRS manager in accordance with the methodology for calculating the management fee to be approved by order of the Minister for the Environment, Water and Forests. The amount and frequency of payment of the management fee will be set transparently by the RMS administrator, based on the methodology developed by the central public authority for environmental protection.
How do I register in the Deposit-Refund System database?
Registration is done online at portal.returosgr.ro and before registering you can consult the registration procedure available here: www.returosgr.ro/info-comercianti.
The registration procedure is simple:
A user account will be created by entering the company's identification data and the contact data of the person designated in relation to the DRS administrator.
After activating the account, the person designated in relation to the DRS administrator will fill in all the required information, in accordance with the legal provisions.
After entering this data, the Standard DRS Registration Form will be generated - automatically filled in with the data already entered. The form must be signed by the legal representative, using a simple or qualified electronic signature, also through the RetuRO portal.
If I own a restaurant and run promotions where I offer a free juice with every dish/menu, am I obliged to register on the platform? Business operators such as restaurants (irrespective of whether the food is delivered to your door) fall under the category of HoReCa retailers and are therefore subject to registration on the DRS platform and are still obliged to participate in the operation of the DRS.
The registration is deemed as completed when the trader has correctly and completely submitted the information and documentation required in Article 5(5). (2) of Decision No 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging.
The call-center operators can guide you in filling in the forms and give you further instructions in the event of any uncertainties, but it is up to the trader alone to fill in the forms and to provide information in accordance with the actual situation.
An important clarification for HoReCa retailers: there is no obligation for HoReCa retailers to organize collection points, but they are obliged to charge the deposit to end consumers for products in DRS packaging consumed outside the sales structure. Juices offered as part of offers are subject to the reporting obligation.
The quantities of products in DRS packaging that an economic operator has in stock on 30.11.2023, can be marketed until 31.12.2024, the operator not being registered in DRS? Or only until 30.11.2023?
All economic operators who will have products in DRS packaging in stock on 30.11.2023 should have registered in advance on the DRS platform, according to the legal obligations in force.
In the event of failure to comply with the obligation to register, in addition to the penalty of a fine, an additional penalty of temporary suspension of the economic operator's activity may be applied until compliance with this obligation.
Products which are in the stock of producers or retailers on 30.11.2023 may be marketed until 31.12.2024 at the latest.
In the case of a fitness club network that has a code for one of its outlets and a code for selling drinks in primary non-refillable packaging and is currently not selling anything, is it still necessary to register on the platform?
According to the provisions of Decision No 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging, "retailer" means the legal person authorized to carry out marketing of products in DRS packaging to consumers or end-users.
Thus, subject to the above, the mere fact that marketing activities are authorized entails the obligation to register in the DRS, regardless of whether or not these activities are actually carried out.
The information provided at the time of registration in the DRS must reflect the actual situation. Therefore, we consider that the point of work for which marketing of products in DRS packaging is authorized should be registered, and that the information requested on the number of products in DRS packaging marketed in the previous year, i.e. the number of products in DRS packaging expected to be marketed in 2023, should be submitted as 0, if this statement corresponds to the actual situation.
If I own a trading company that is currently out of business, do I have to register it on the DRS platform?
According to the provisions of the Decision no. 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging, "retailer" means the legal person authorized to carry out activities of marketing products in DRS packaging to consumers or end-users.
As long as companies have not been struck off the Commercial Register and marketing activities are authorized which can be carried out through them, there is an obligation to register in the DRS, regardless of whether or not these activities are actually carried out.
The procedure for the withdrawal of economic operators from the DRS will be regulated promptly and in detail at a later stage, including in relation to the contract to be signed between the parties.
If a company has HORECA as its main activity and the restaurant has been rented out in the last 2 years, is it still necessary to register in the DRS platform?
Each economic operator should make its own analysis of the applicable legal framework to determine the exact obligations imposed on it by law. The comments below are not intended as a substitute for this analysis and do not in any way constitute legal advice, nor can they in any other way engage the liability of the DRS manager.
Subject to the above, as long as the restaurant's authorized activities include the marketing of products in DRS packaging, there is an obligation to register with the DRS platform.
In the case of a hotel that offers juice in dispensers for breakfast and the minibar in the room is free of charge, without selling drinks in any way in various packages, is it still necessary to register this point of business on the DRS platform?
With regard to juices offered on tap, as long as DRS packaging is not used to make them available to customers, they do not fall within the scope of Government Decision No 1074/2021 on the establishment of the deposit-refund system for non-refillable primary packaging.
In regards to the minibar drinks, to the extent that they are, in fact, integrated into the price of accommodation as part of an offer, they would be subject to the reporting obligation.
It should also be kept in mind that there is no obligation for HoReCa retailers to organize collection points and they are only obliged to charge the deposit to end consumers for products in DRS packaging consumed outside the sales structure. The information required for registration in the DRS must correspond to that registered with the Trade Register. Specifically, the DRS platform should provide information on the point of business where the activity under which beverages in DRS packaging are sold is authorized.
What is the procedure for registering an administrative-territorial unit (municipality) on the RetuRO DRS platform in order to organize a DRS packaging return point.
Only economic operators who are retailers or producers, as defined in Decision No 1.074/2021 on the establishment of the deposit-return system for primary non-refillable packaging ("Decision No 1.074/2021"), may register on the DRS platform. Therefore, administrative-territorial units may not register on the DRS platform.
Instead, the deliberative authorities at the level of the administrative-territorial units may, under the conditions set out in Decision No 1.074/2021, (i) approve the conclusion of partnership agreements with retailers with sales structures of less than 200 sqm, at their request, for the organization and operation of collection points and (ii) organize DRS packaging collection points within the administrative-territorial radius of the respective administrative-territorial unit, in collaboration and under the coordination of the DRS administrator.
Does a company with no current activity have to register, or can it register after starting activity?
According to the provisions of Decision No 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging, "retailer" means the legal person authorized to carry out activities of marketing products in DRS packaging to consumers or end-users.
Thus, the mere fact that marketing activities are authorized entails the obligation to register in the DRS, regardless of whether these activities are actually carried out. If the company is not yet so authorized, the retailer is not obliged to register in the DRS.
We are planning to open a branch in the coming months. The company already exists and we have activated the account in the DRS platform. Please let us know what the next steps are.
Full registration in DRS involves, in addition to creating a user account, entering all the data specified in the registration procedure available on the website, signing the appropriate DRS Registration Form and uploading it to your user account. The next step will be to sign the contract with RetuRO when it becomes available.
To complete the registration procedure, the total number of DRS packages corresponding to the calendar year 2022 (can be 0 if there was no activity) and 2023 (forecast) must be provided to RetuRO.
If I own a business that will close in the next few months, is it still mandatory to register in the DRS system?
Yes, the obligation to register in the DRS platform exists even if the trader intends to cease trading. Failure to do so will result in a fine and may also result in the additional sanction of temporary suspension of activity until the obligation is fulfilled.
The obligation to register on the DRS platform exists for every trader authorized to market products in non-refillable primary packaging made of glass, plastic or metal, with volumes between 0.1 l and 3 l inclusive, used to make available on the national market beer, beer mixes, mixes of alcoholic beverages, cider, other fermented beverages, juices, nectars, soft drinks, mineral waters and drinking waters of any kind, wines and spirits.
What is a return point?
A return point is a place organized and managed by one or more retailers, respectively in partnership with a local administrative unit or an inter-community development association, where primary non-refillable drinks packaging is returned by consumers or end-users for the refund of the deposit.
Are all retailers obliged to organize collection points?
Only HORECA retailers or those who sell products exclusively online or exclusively via vending machines are not legally obliged to organise collection points. Otherwise, all retailers selling products for the purpose of DRS, regardless of the size of the sales area, are legally obliged to organize collection points for DRS packaging.
What options do retailers have for organising collection points?
There are different ways for retailers to fulfil their legal obligation to organize collection points, depending on the size of the sales structure.
Retailers who have a sales structure area larger than 200 sqm are obliged to organize their own collection points.
Retailers with a sales structure area of less than 200 square meters may, in addition to organizing their own collection points, opt to fulfil the legal obligation to organize collection points by association with other retailers with sales structures of less than 200 square meters, or by partnership agreement with local administrative units or inter-community development associations.
In the case of retailers who do not organize their own collection points, the distance to the established return point may not be more than 150 m from each sales structure of the trader in the partnership agreement, for sales structures in cities, and 500 m for sales structures in rural areas. Retailers may opt, within the sales structures they operate, for manual takeover or takeover using RVMs (automated takeover systems).
What other obligations do retailers have regarding collection points?
According to Government Decision 1074/2021, at collection points retailers must accept all DRS packaging returned by consumers or end-users, regardless of where the packaged product was purchased and without making the acceptance of the DRS packaging conditional on the presentation of the receipt.
They are required to keep the returned DRS packaging separate from waste or other non-DRS packaging for collection by the DRS manager. They are also obliged to allow only the DRS manager to take back the DRS packaging from the collection points at the request of the DRS manager or his designated representative.
For all collection points, including those organized outside the sales area, the operators of the collection points will ensure their monitoring and security, based on their own regulations that ensure the integrity of the return point, its equipment and the returned packaging.
What obligations do retailers have after the DRS becomes operational in Romania?
In addition to the obligations related to the collection points mentioned in the previous question, retailers will have the following legal obligations after the entry into operation of the Deposit-Return System: received from consumers or end-users, the DRS manager, and the other economic operators within the DRS with whom the retailer has concluded contracts.
To clearly indicate the value of the deposit on the shelf and on the fiscal documents related to the DRS packaged product
To pay the value of the deposit to the economic operators from whom they purchase DRS packaged products
To collect from their customers the deposit related to DRS packaged products
To not market DRS packaged products purchased from producers not registered with the DRS administrator or distributors of such producers
To not market products packaged in DRS packaging that are not marked in accordance with the law
To display information to consumers or end-users at points of sale about their obligations and rights under the DRS.
To use the software provided online by the DRS manager to report on DRS packaging and the associated deposits.
To use, for the reporting of DRS packaging and related deposits, the software made available online by the DRS administrator.
To keep track of the total number of DRS packaged products sold, broken down by product, for each sales structure and/or online shop they operate, the total number of DRS packaging returned to the retailer by consumers or end-users, broken down by type of material and volume, as well as the deposit paid, collected on the sale of products and returned to consumers at the collection point.
To enable the competent authorities to carry out checks and to provide them with documents, correct and complete information on how the retailer has fulfilled his obligations, as well as supporting documents received from consumers or end-users, the DRS manager, and the other economic operators within the DRS with whom the retailer has concluded contracts.
To provide in writing, within a maximum of 10 working days, clarifications and information requested by the DRS manager in relation to the fulfilment of the obligations arising from this decision.
I opt to organize a manually operated return point. What does this entail?
All retailers who organize a collection point with manual return will check whether the returned packaging meets the conditions laid down by law. They will only take back packaging that is returned in one piece, without being degraded or deformed, is completely emptied of its contents and has the marking indicating that it belongs to the DRS visibly and legibly applied.
Retailers will use the computer system provided online by the DRS manager to report DRS packaging and the associated deposits.
In order to cover the costs of managing packaging at the collection points, there will be a management fee to be paid to the operators of the collection points for the packaging taken over by the DRS manager, which will be set by the DRS manager in accordance with the methodology for calculating the management fee to be approved by order of the Minister for the Environment, Water and Forests. The amount and frequency of payment of the management fee will be set transparently by the DRS administrator, based on the methodology developed by the central public authority for environmental protection.
I opt for organizing a collection point using an RVM. What does this entail?
In the case of a decision to take back packaging via RVMs, RetuRO's recommendation is to make a prior analysis from an efficiency point of view, in the sense that the installation of the RVM should be justified in terms of the number of DRS packaging expected to be returned to that collection point organized and operated by the retailer. It should be noted that all initial purchase costs of the RVM will be paid by the trader.
In order to cover the costs of managing the packaging at the collection points, a management fee will be paid by the DRS manager to the operators of the collection points for each package taken over by the DRS manager, and will be set by the DRS manager in accordance with the methodology for calculating the management fee to be approved by order of the Minister for the Environment, Water and Forests. The amount and frequency of payment of the management fee will be set transparently by the RMS administrator, based on the methodology developed by the central public authority for environmental protection.
How do I register in the Deposit-Refund System database?
Registration is done online at portal.returosgr.ro and before registering you can consult the registration procedure available here: www.returosgr.ro/info-comercianti.
The registration procedure is simple:
A user account will be created by entering the company's identification data and the contact data of the person designated in relation to the DRS administrator.
After activating the account, the person designated in relation to the DRS administrator will fill in all the required information, in accordance with the legal provisions.
After entering this data, the Standard DRS Registration Form will be generated - automatically filled in with the data already entered. The form must be signed by the legal representative, using a simple or qualified electronic signature, also through the RetuRO portal.
If I own a restaurant and run promotions where I offer a free juice with every dish/menu, am I obliged to register on the platform? Business operators such as restaurants (irrespective of whether the food is delivered to your door) fall under the category of HoReCa retailers and are therefore subject to registration on the DRS platform and are still obliged to participate in the operation of the DRS.
The registration is deemed as completed when the trader has correctly and completely submitted the information and documentation required in Article 5(5). (2) of Decision No 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging.
The call-center operators can guide you in filling in the forms and give you further instructions in the event of any uncertainties, but it is up to the trader alone to fill in the forms and to provide information in accordance with the actual situation.
An important clarification for HoReCa retailers: there is no obligation for HoReCa retailers to organize collection points, but they are obliged to charge the deposit to end consumers for products in DRS packaging consumed outside the sales structure. Juices offered as part of offers are subject to the reporting obligation.
The quantities of products in DRS packaging that an economic operator has in stock on 30.11.2023, can be marketed until 31.12.2024, the operator not being registered in DRS? Or only until 30.11.2023?
All economic operators who will have products in DRS packaging in stock on 30.11.2023 should have registered in advance on the DRS platform, according to the legal obligations in force.
In the event of failure to comply with the obligation to register, in addition to the penalty of a fine, an additional penalty of temporary suspension of the economic operator's activity may be applied until compliance with this obligation.
Products which are in the stock of producers or retailers on 30.11.2023 may be marketed until 31.12.2024 at the latest.
In the case of a fitness club network that has a code for one of its outlets and a code for selling drinks in primary non-refillable packaging and is currently not selling anything, is it still necessary to register on the platform?
According to the provisions of Decision No 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging, "retailer" means the legal person authorized to carry out marketing of products in DRS packaging to consumers or end-users.
Thus, subject to the above, the mere fact that marketing activities are authorized entails the obligation to register in the DRS, regardless of whether or not these activities are actually carried out.
The information provided at the time of registration in the DRS must reflect the actual situation. Therefore, we consider that the point of work for which marketing of products in DRS packaging is authorized should be registered, and that the information requested on the number of products in DRS packaging marketed in the previous year, i.e. the number of products in DRS packaging expected to be marketed in 2023, should be submitted as 0, if this statement corresponds to the actual situation.
If I own a trading company that is currently out of business, do I have to register it on the DRS platform?
According to the provisions of the Decision no. 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging, "retailer" means the legal person authorized to carry out activities of marketing products in DRS packaging to consumers or end-users.
As long as companies have not been struck off the Commercial Register and marketing activities are authorized which can be carried out through them, there is an obligation to register in the DRS, regardless of whether or not these activities are actually carried out.
The procedure for the withdrawal of economic operators from the DRS will be regulated promptly and in detail at a later stage, including in relation to the contract to be signed between the parties.
If a company has HORECA as its main activity and the restaurant has been rented out in the last 2 years, is it still necessary to register in the DRS platform?
Each economic operator should make its own analysis of the applicable legal framework to determine the exact obligations imposed on it by law. The comments below are not intended as a substitute for this analysis and do not in any way constitute legal advice, nor can they in any other way engage the liability of the DRS manager.
Subject to the above, as long as the restaurant's authorized activities include the marketing of products in DRS packaging, there is an obligation to register with the DRS platform.
In the case of a hotel that offers juice in dispensers for breakfast and the minibar in the room is free of charge, without selling drinks in any way in various packages, is it still necessary to register this point of business on the DRS platform?
With regard to juices offered on tap, as long as DRS packaging is not used to make them available to customers, they do not fall within the scope of Government Decision No 1074/2021 on the establishment of the deposit-refund system for non-refillable primary packaging.
In regards to the minibar drinks, to the extent that they are, in fact, integrated into the price of accommodation as part of an offer, they would be subject to the reporting obligation.
It should also be kept in mind that there is no obligation for HoReCa retailers to organize collection points and they are only obliged to charge the deposit to end consumers for products in DRS packaging consumed outside the sales structure. The information required for registration in the DRS must correspond to that registered with the Trade Register. Specifically, the DRS platform should provide information on the point of business where the activity under which beverages in DRS packaging are sold is authorized.
What is the procedure for registering an administrative-territorial unit (municipality) on the RetuRO DRS platform in order to organize a DRS packaging return point.
Only economic operators who are retailers or producers, as defined in Decision No 1.074/2021 on the establishment of the deposit-return system for primary non-refillable packaging ("Decision No 1.074/2021"), may register on the DRS platform. Therefore, administrative-territorial units may not register on the DRS platform.
Instead, the deliberative authorities at the level of the administrative-territorial units may, under the conditions set out in Decision No 1.074/2021, (i) approve the conclusion of partnership agreements with retailers with sales structures of less than 200 sqm, at their request, for the organization and operation of collection points and (ii) organize DRS packaging collection points within the administrative-territorial radius of the respective administrative-territorial unit, in collaboration and under the coordination of the DRS administrator.
Does a company with no current activity have to register, or can it register after starting activity?
According to the provisions of Decision No 1.074/2021 on the establishment of the deposit-refund system for primary non-refillable packaging, "retailer" means the legal person authorized to carry out activities of marketing products in DRS packaging to consumers or end-users.
Thus, the mere fact that marketing activities are authorized entails the obligation to register in the DRS, regardless of whether these activities are actually carried out. If the company is not yet so authorized, the retailer is not obliged to register in the DRS.
We are planning to open a branch in the coming months. The company already exists and we have activated the account in the DRS platform. Please let us know what the next steps are.
Full registration in DRS involves, in addition to creating a user account, entering all the data specified in the registration procedure available on the website, signing the appropriate DRS Registration Form and uploading it to your user account. The next step will be to sign the contract with RetuRO when it becomes available.
To complete the registration procedure, the total number of DRS packages corresponding to the calendar year 2022 (can be 0 if there was no activity) and 2023 (forecast) must be provided to RetuRO.
If I own a business that will close in the next few months, is it still mandatory to register in the DRS system?
Yes, the obligation to register in the DRS platform exists even if the trader intends to cease trading. Failure to do so will result in a fine and may also result in the additional sanction of temporary suspension of activity until the obligation is fulfilled.
The obligation to register on the DRS platform exists for every trader authorized to market products in non-refillable primary packaging made of glass, plastic or metal, with volumes between 0.1 l and 3 l inclusive, used to make available on the national market beer, beer mixes, mixes of alcoholic beverages, cider, other fermented beverages, juices, nectars, soft drinks, mineral waters and drinking waters of any kind, wines and spirits.