Walk into a supermarket in Berlin or Oslo today and you’ll see the same ritual: shoppers feeding empty bottles into a reverse vending machine, listening for the reassuring clunk and waiting for their refund ticket. Deposit return schemes (DRS) are no longer experiments; they’re mainstream, and governments are rolling them out at record pace to fight packaging waste.
But here’s the question most industry headlines skip: while DRS are rightly celebrated for their environmental wins, do they introduce a blind spot for food safety and regulatory compliance? For professionals in food safety, QA, and regulatory affairs, this is more than a theoretical worry. Bringing sticky, used beverage containers back into food retail settings is not a risk-free exercise.
The model is simple: consumers pay a small deposit when purchasing a beverage, then reclaim it by returning the empty container. The incentive works remarkably well. High-performing schemes in Germany, Norway, and Lithuania routinely recover over 90% of bottles and cans. That level of capture doesn’t just reduce litter – it also secures a steady stream of high-quality, food-grade recyclate. In fact, PET from deposit systems is so clean that it commands a premium on the recycling market and is the preferred source for food-contact recycled plastics.
It’s worth remembering that this isn’t new. The first national deposit scheme started in Denmark in 1922, originally designed for reusing glass bottles. What’s new is the regulatory pressure: the EU Packaging Regulation now mandates that by 2029, 90% of single-use plastic and metal beverage containers must be separately collected. For many countries, DRS is the only practical way to get there.
Now consider the operational reality: thousands of returned containers, many with residues of soda, juice, or milk, moving through retail stores every week. Food safety teams instinctively see red flags:
Residue and microbial growth: A returned chocolate milk bottle can be a perfect breeding ground for microbes if it sits too long.
Pests and odors: Sticky, sugary bottles attract insects and rodents – not ideal in a grocery environment.
Cross-contamination: Staff handling dirty returns before stocking fresh produce risks a hygiene breach.
Physical hazards: Broken glass or leaking liquid in a backroom that also stores food is a regulatory headache waiting to happen.
These aren’t hypothetical. When Scotland consulted retailers on its planned DRS, many flagged the hygiene risks of handling dairy containers. The UK’s Association of Convenience Stores publicly argued that milk bottles should be excluded entirely because of the contamination potential.
And yet, Germany just expanded its DRS to include dairy-based drinks in 2024. How? The Federal Institute for Risk Assessment (BfR) assessed the risks and concluded that with modern reverse vending machines and regular cleaning, no significant health risk to consumers is expected. That’s a striking contrast to the caution voiced elsewhere – and it highlights how much hinges on technology and implementation.
Here’s where regulatory nuance matters. Some systems build in exemptions: Scottish rules allow retailers to refuse soiled or contaminated returns, and even to apply for exemption from acting as a return point if it would compromise food safety. Others exclude certain products (like milk) at the outset and revisit later. In all cases, food hygiene law remains the higher authority – if a DRS requirement conflicts with HACCP or retail hygiene codes, safety must win.
Another tool regulators use is infrastructure design. Large supermarkets install automated reverse vending machines, keeping returns sealed and away from food areas. Smaller shops, which may lack space or equipment, are often compensated through handling fees or allowed manual collection under strict hygiene protocols. In practice, the key is rapid removal: sealed bags of collected containers should leave the food premises quickly to avoid turning a sustainability measure into a sanitation liability.
As DRS expands globally, what should food safety and regulatory professionals anticipate?
Scope creep: Expect more product categories to be added – not just soda and beer, but juices, dairy drinks, even nutritional supplements. Each new category comes with new residue profiles and new hygiene challenges.
Digital and smart systems: Pilot projects in Europe are testing app-based DRS and smart packaging, potentially reducing the need for physical handling in stores.
Producer responsibility pressures: As regulators raise recycled content targets, the industry will lean more heavily on deposit systems for safe, food-grade materials.
Unintended behaviors: From “professional recyclers” rummaging through bins, to consumers buying more single-use drinks because they feel good about recycling, DRS will continue to generate side effects regulators must anticipate.
Deposit return schemes are not a zero-sum choice between environmental sustainability and food safety. They are clearly effective in cutting litter and supplying high-quality recycled materials for food packaging. At the same time, they introduce real – though manageable – hygiene challenges. The frontier is not deciding whether to implement DRS, but how to design them so that food safety is safeguarded.
For the industry, this means being at the table as DRS policies evolve: pushing for evidence-based exclusions where necessary, ensuring machine and logistics standards meet hygiene expectations, and embedding food safety considerations into the sustainability narrative. The balance is achievable – but only if professionals in food safety and regulatory compliance continue to ask the hard questions.