Backup packaging

How are deposit-bearing returnable packages shown in e-invoice?

Short answer

Electronic invoicing under § 85o of the VAT Act does not change how deposit-bearing packages are assessed or reported. If a deposit for a reusable returnable package is currently shown as a separate invoice item that is excluded from the taxable amount under § 22 ods. 3 of the VAT Act, the same treatment is used in e-invoice.

No change

Same logic as today

e-invoice does not change the method of reporting backup packaging.

Section 22(3)

Outside the tax base

The deposit for reusable packaging is not included in the tax base.

The first in the chain

Who pays the tax

Tax liability for packaging arises from the person who first puts it on the market.

Separate item

Normal practice continues

The deposit can still be shown on the e-invoice as a separate item without VAT.

Detailed explanation

Section 19(10) of the VAT Act sets out a special tax regime for returnable packaging — the tax liability on packaging placed on the market arises for the taxable person who is the first in the supply chain to place it on the Slovak market together with the goods. Suppliers who are not the first in the chain do not include the deposit in the tax base, but at the same time are not obliged to pay tax on packaging that the customer has not returned to them. This division of responsibility remains unchanged with e-invoicing — only the form of the document changes, not the accounting or tax logic of returnable packaging.

As set out in the law and the FAQs

This follows from the official methodological and information materials of the Slovak Financial Administration on e-invoicing and from Act No. 222/2004 Coll. on VAT, Section 19(10) (special tax regime for returnable packaging) and Section 22(3) (exclusion of the deposit on reusable packaging from the tax base).

Practical examples

As the first party in the supply chain, the beverage manufacturer places the packaging on the market and pays tax on it in accordance with Section 19(10).
Further down the supply chain, the retailer lists the deposit on the e-invoice as a separate item excluding VAT, just as they have done to date on paper invoices.
Packaging that does not meet the definition of reusable beverage packaging is invoiced under the standard regime as other goods.

Most common mistakes

“The e-invoice requires a new method of reporting deposit-bearing packaging.” No, the introduction of e-invoicing does not change the way packaging is reported.
“The deposit on packaging is always included in the tax base.” No, in the case of reusable packaging, it is not included in the tax base under Section 22(3).
“Every supplier in the supply chain pays tax on packaging.” No, the tax liability arises only for the party who first places the packaging on the market.

Conclusion

Backed-up reusable packaging is indicated in the e-invoice in the same way as before — the electronic form does not change the substantive legal regulation according to Section 19 and Section 22(3) of the VAT Act.

Legal basis

Official methodological and information materials Financial Administration of the Slovak Republic k e-invoice
Act No. 222/2004 Coll. on VAT, Section 19(10) and Section 22(3)

Official cases from the Slovak Financial Administration’s FAQs

The following questions and answers are taken from the current July FAQ from the Financial Administration and have been assigned to this topic. Grouping the cases prevents the creation of duplicate pages, whilst retaining the full answer and the exact wording of the question.

Example No. 21: e-invoice – reporting of returnable packaging: Under Section 19(10) of the VAT Act, a special taxation regime applies to returnable packaging when it is supplied between domestic suppliers and customers. The tax liability on returnable packaging supplied to the market together with goods arises for those VAT payers (suppliers) who are the first in the supply chain to place the goods, together with the returnable packaging, on the Slovak market. This provision also sets out the calculation of the tax base and the tax. At the same time, under the VAT Act (Section 22(3)), “where goods are supplied in returnable packaging, the tax base under paragraph 1 shall not include the deposit on the returnable packaging supplied together with the goods. Where a drink is supplied in returnable single-use beverage packaging6abd), the deposit on such packaging shall not be included in the tax base under paragraph 1’. Similarly, suppliers who are not the first in the supply chain to place returnable packaging on the market also do not include the deposit for returnable packaging in the tax base, but are not obliged to pay tax on packaging that has not been returned to them by the customer. In practice, businesses list returnable (reusable) packaging on invoices as a separate item that is exempt from VAT. Is it correct, when invoicing such returnable packaging, to apply the same logic in the case of an electronic invoice under Section 85o of the VAT Act – i.e. should we list returnable reusable packaging as a separate item? Note: Packaging that does not meet the definition of reusable beverage packaging is not considered returnable packaging for the purposes of the VAT Act, and the standard tax regime applicable to the supply of goods applies to its supply and return. If so, what VAT category should then be correctly assigned to this item? If not, we assume that returnable packaging should be reported in a specific element within the BIS 3 structure. Which element ID should be used? Alternatively, how should data on returnable reusable packaging be correctly reported in the BIS 3 format?

The introduction of electronic invoicing under Section 85o of the VAT Act does not alter the way in which returnable packaging is treated or reported for the purposes of the VAT Act. If the deposit for returnable packaging is currently shown on the invoice as a separate item which, under Section 22(3) of the VAT Act, is not included in the tax base, the same procedure may be followed for electronic invoices. Electronic invoicing therefore does not alter the existing method of accounting for or invoicing these items, which remains the same.

Primary source: Financial Administration of the Slovak Republic, FAQ 9/VAT/2025/IM k e-invoice, July 2026 update. Processed and checked on 13 July 2026.