Spain's bottle deposit scheme (SDDR) is due on November 22nd. Nobody has yet said how a store with no staff complies.

Nobody knows yet. Spanish law requires that from November 22nd, 2026, plastic bottles up to 3 litres, cans and beverage cartons carry a deposit of at least 10 cents, including when they are sold from a vending machine. How a store with nobody inside takes the empty container back is something no rule spells out.

Who’s who in what follows: at Bonobo Services OÜ we build uNobo Connect, the operating system for 24h unattended retail. In Spain it is run by uRetail, our Country Partner, under two brands: Flappers, the 24h store with no staff, and 1Self, connected machines installed inside a client’s own business.

What the law says, with a date and a reason

The deposit isn’t a sudden idea. It follows from a missed target: according to the Ministry for Ecological Transition’s report, Spain separately collected 41.3% of the single-use plastic bottles placed on the market in 2023, when Article 59 of Law 7/2022 required 70%. The same article says that if the target is missed, a deposit, return and refund system must be in place within two years, and Article 47 of Royal Decree 1055/2022 sets its scope: single-use plastic bottles up to 3 litres of water, juices, soft drinks and the other beverages it lists, plus cans and cartons of those same products. The amount is set by whichever system runs the scheme, at a minimum of 10 cents per container, and the customer gets it back when returning the empty. The two-year window closes on November 22nd, 2026.

What the law does say about vending machines

The law didn’t forget vending. Its seventeenth additional provision states that the deposit applies whatever the sales channel, explicitly including distance selling and vending machines. It also requires the seller to tell customers, clearly and visibly, how much the deposit is, separately from the product price, and how to return the container. In a store with no staff there is nobody to explain it out loud: the screen, the receipt or a sign has to say it.

What the law doesn’t solve is the way back. The customer recovers the deposit by returning the container at the point of sale or at other points that may be set up, and if it comes back to the point of sale, the shop is obliged to accept it and pay out. A 24h store sells at three in the morning with nobody inside. Who takes the bottle there, where is it stored, and who hands back the 10 cents?

What still isn’t settled

The royal decree leaves the practical side to whichever system runs the deposit. That system defines the return points, which can be shops, containers, dedicated centres or any other return system, and it agrees with retailers how they take part, with room for specific conditions for shops with 120 m² or less of sales floor. That threshold is the one that matters most to a small store with no staff. But those conditions don’t exist yet, because the system doesn’t either: as of September 25th, the applications to run it were still being processed by the Madrid regional government, with no known decision date, and the Asociación SDDR para España, one of the applicants, considers it practically impossible for the scheme to start working in November.

Why a reverse vending machine isn’t the answer for these formats

The obvious way out is a reverse vending machine. It takes floor space, needs maintenance and someone to empty it, and it is more than a box that swallows bottles: it has to validate every container, connect to the scheme, handle the deposit and prevent fraud. In a hypermarket, that makes sense. In a Flappers store, the space is designed around the machines that sell. At a 1Self point, the machine lives inside a client’s business, a pharmacy, a gym or an office, where there is no spare room for another unit. Putting a full reverse vending machine there isn’t an upgrade: it adds exactly the kind of hardware the model is built not to depend on.

Where we think the refund should live

uNobo Connect already supports a digital relationship with anyone who buys through the web app: their account, their purchase history and their loyalty points. We think the deposit should be refunded there, as balance on that account, not as coins inside a machine. But crediting 10 cents on the strength of an on-screen confirmation would open the door to fraud, and the rules ask for more: containers are marked to work as an anti-fraud mechanism, and the scheme only pays the deposit back to the retailer once the count has been validated. The missing piece is exactly that: checking that the returned container is real, for example by reading its code at a small collection point inside the store, before crediting anything, and without the bulk of a full reverse vending machine. We don’t have it. And it doesn’t depend on us alone: it will have to fit the technical criteria set by whoever runs the scheme, which hasn’t been authorised yet.

Why we’re saying this now, in the open

We could wait until the scheme is authorised and its conditions are published, and react then. We’d rather say now, with the date set and the gap still open, what doesn’t fit and where we think the answer lies. It’s the same reason uNobo Connect was designed not to depend on a single hardware manufacturer or a single payment gateway: flexibility is built before the rules demand it, not after.

Nor is this only a Spanish question. Other European countries already charge deposits on their containers and others are putting them in place, and wherever the rule repeats, so will the question of how a staff-free point of sale fits in.

If you run unattended retail in a market that has a deposit scheme, or is about to, and you want to work on the missing piece with us, write to info@bonoboservices.com. We’d rather solve it with the people who will need it than wait for someone else to design it.

Román Suárez, Founder of Bonobo Services OÜ