In manual collection, the retailer hands over DRS packaging in sealed bags, and RetuRO issues the self-billed invoice on the retailer's behalf based on the quantities validated at counting. When the invoiced quantities differ from the retailer's own records - bags, seals, handover documents - the difference can only be recovered through a documented dispute.
From 8 October 2026 this process moves into the RetuRO platform: the dispute is created from the retailer's account, in the "Complaints" section, and goes through statuses visible in real time - "Open", "In progress", then "Approved" or "Rejected". If approved, the quantities are adjusted and the corrected invoices appear under "Manual collection invoicing documents > Invoices". A resolved dispute cannot be re-filed for the same quantities, so the file must be complete from the first submission.
The central rule of the guide is the deadline: 5 working days from the date RetuRO sent the invoice to the retailer. Whoever checks self-billed invoices once a month simply loses the right to dispute. Checking invoices in the platform has to become a routine - ideally weekly, and in high-volume periods at every issue.
The second condition is evidence. The guide requires supporting documents attached to the dispute: the record of returned products, proof of the seals handed over and the CMR or other transport documents. In other words, the dispute is prepared before it is needed: if the record of sealed bags and the documents of every pickup are not kept in order from the start, the 5-day deadline leaves no time for reconstruction.
At Circulad'OR we support retailers and producers with all DRS obligations - from organising collection records and checking self-billed invoices to preparing documented disputes and the day-to-day relationship with RetuRO. If the figures in your self-billed invoices do not match your own records, write to us before the 5 days run out.
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