Although the legislature has not expressly determined whether online shops must join the deposit return scheme, many will probably choose to do so if they sell beverages in covered packaging: plastic bottles up to 3 litres, aluminium cans up to 1 litre and, from 2026, returnable glass bottles up to 1.5 litres.
The participation obligation applies to shops — more precisely, retail establishments — with a specified sales area which offer beverages in covered packaging. Their duties depend on the outlet’s size: different rules apply to shops with a sales area of no more than 200 m² and those exceeding that threshold.
“Sales area” means the space where goods are sold directly. Online shops generally have no such space, which might suggest that the scheme should not cover them.
Increasingly, however, the interpretation adopted is that an online shop has a sales area of 0 m². It therefore falls within the category of shops not exceeding 200 m² and should participate to the extent required of small retail establishments.
In practice, online shops offering beverages in covered packaging would then have to:
- contract with at least one scheme operator and charge deposits on all covered packaging;
- accept returns of reusable glass bottles;
- refund deposits to customers.
