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Environment Minister Zuhal Demir (N-VA) took the initiative to introduce a deposit when the monitoring of litter of OVAM  showed that 18,171 tonnes of litter still need to be cleaned up every year in Flanders.

The Flemish government gave permission in late December to test the Belgian packaging industry’s proposal for a digital deposit system through pilot projects. Under the digital deposit system, two codes have to be scanned before you can throw a packaging in the blue bag at home or in ‘public blue bins’. The minister asked that the evaluation of this system be done in 2023.

The final goal is to introduce deposits on bottles and cans by 2025 with a system that is technically feasible and accessible to all. Obviously, this system should also effectively contribute to drastically reducing litter and promoting the circularity of high-value materials.

Environment minister Zuhal Demir (N-VA) explained that if the digital system is not superior to a classic deposit system, she will go ahead with the introduction of the classic system. With this known system, people get money back when they return empty cans and bottles at points of sale. OVAM confirmed her announcement  in a call to companies willing to play a role in setting up the system.

Digital Deposit Return System

A digital deposit system has not yet been implemented anywhere in the world. There is no practical example of whether and how it would work. Besides, there are no empirical data available and it is unsure whether the same results can be achieved with this system as with the classic system. There are only a few studies on the matter, including the study “Every Packaging Counts – DDRS Blueprint” that the Belgian packaging industry commissioned from PricewaterhouseCoopers (PwC).

PwC’s study was delivered to the packaging industry at the end of September 2022. The industry didn’t publish the study for a few months. Only after the government decision of introducing a deposit and under the pressure of the opposition and media did minister Demir decided to make the study public. That was on 13 January 2023, three weeks after the Flemish government’s decision.

Study commissioned by the industry

We analysed this blueprint on digital DRS from PwC. The objective of this study is clear: the packaging industry commissioned PwC to produce a report that could “serve as a clear, figure-based argument as to why this approach is better than the traditional deposit system“. That is why we also take a critical look at the study, pointing out its limitations and the questions that remain to be answered.

Our analysis presents both systems, including their respective costs and timeline for implementation. We look at whether the digital system is as effective as the conventional one in terms of waste reduction, return rate of high-value materials and potential for reuse.

The PwC study does not prove that introducing a digital deposit by 2025 is feasible, quite the contrary. Nor does the PwC study show that a digital DRS would be effective in reducing litter – something the traditional deposit has proven and is still proving to do in neighbouring countries.

Our analysis highlights the many risks for consumers: exclusion of people who do not have access to the internet or a bank account. Only half of the Belgian population has the necessary digital skills. The need to share personal data and the risks of fraud or abuse of the system are also problematic for users. These obstacles jeopardise the use of the system and thus its success.

Our analysis shows that digital DRS would not meet the objectives of improving the quality of recycling or aligning with European standards on recycling. This is highly problematic as Europe plans a rapid transition to a more circular economy at the European level. The effect on litter has also not been demonstrated. This is concerning as fighting litter was the very reason why minister Zuhal Demir announced the introduction of a deposit system.

The PwC study shows that a digital system would require a significant contribution from the Belgian municipalities. Be it the installation of more than 136,000 additional public bins or the possible management of home scanners for households.

Many elements have yet to be clarified in the study: the cost-benefit analysis lacks data and contains incorrect calculations. The governance layer of the study is missing.


Our analysis shows that the feasibility of the digital system is far from proven. Consequently, it is unrealistic that digital deposits can be launched by the 2025 deadline. More worryingly, the study fails to show whether the digital system would achieve the intended goals: reducing litter and increasing recycling quality. Why to set up a system that is not proven to work? Especially when the traditional system works and is being set up in an increasing amount of European countries. Finally, this system would not be accessible to all consumers, and places an unnecessary budgetary and organisational burden on municipalities.

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