Until now, GD no. 1074/2021 neither defined unclaimed deposits - the money paid for packaging that never comes back into the system - nor said how they are calculated. The decision adopted on 30 October fills exactly this gap: the annual value is determined as the difference between deposits collected and deposits refunded in the calendar year, minus the estimated value of refund obligations that may still fall due, plus the deposits on vouchers that expired unused.
The estimate of refund obligations follows a procedure drawn up by the SGR administrator, based on aggregated historical data on market placements, actual return behaviour and seasonality. The administrator must keep the result of the calculation and the supporting documentation for 5 years. And the consumer's right to recover the deposit for packaging returned after the annual calculation date remains untouched.
Producers placing products in SGR packaging on the market pay the administrator, every month, the value of the related deposits and, separately, the administration fee. With a collection rate of 85% in the first nine months of 2026, part of the deposits paid remains unclaimed year after year - significant amounts, with over 4.1 billion containers returned in this interval alone. Until now the calculation of this money was a grey area; from now on, the figure becomes documented and verifiable. The Government stated explicitly that the decision does not change the deposit value and introduces no new obligations for consumers, retailers or producers.
Also on 30 October, the Government dropped the draft article that would have allowed return points with reverse vending machines in schools, universities and public institutions, based on partnerships with retailers. Returns therefore stay on the existing channels.
The annual calculation rests on aggregated market-placement and return data - that is, upstream, on producers' monthly reports to the SGR administrator. Make sure these are accurate and reconciled with your internal records, the self-billing invoices you receive and your Environment Fund returns. And when you analyse how the administration fee and your SGR costs for 2027 are substantiated, the newly documented unclaimed-deposit figure is a reference you can request and verify. If you were considering collection projects in partnership with schools or public institutions, they no longer have a legal basis in the adopted text.
Circulad'OR can help you check these reconciliations - market placements, self-billing invoices, Environment Fund returns - and analyse your SGR costs before budgeting for 2027. And if you are preparing your packaging for the PPWR requirements, Yvora keeps compliance records at packaging level - the same data, put to work twice.
The first conversation is free: you find out what applies to you, by when, and who does it - you, us, or the application.