The changes affect single-use plastic bottles for milk drinks with a volume between 0.1 and 3.0 litres. The following milk drink packaging will be subject to deposit starting 1 January 2024:

• milk and dairy drinks with at least 50 percent milk content or
• other drinkable dairy products as set out in section 2 of the Milk and Margarine Act (MilchMargG), especially yoghurt and kefir.

Read on to learn more. 

 

System participation requirement until 31 December 2021
Until 31 December 2023, you are required without exception to participate the packaging for milk drinks that will be subject to deposit from 1 January 2024 with a system in order to finance the recycling of this packaging. After 2023 ends, you must also report the specific packaging volumes of milk drinks bottles participated with the systems in 2023 to the LUCID Packaging Register (data reporting).
Breaching the system participation requirement will automatically lead to a distribution ban on your packaged goods, and may attract fines of up to €200,000.

Registration amendments in the LUCID Packaging Register as per 1 January 2024
Because the changeover means that the packaging for your milk drinks will be subject to deposit, you are required to review and adjust your registration in the LUCID Packaging Register (registration amendment). This concerns details about packaging types as well as brand names.
Packaging subject to deposit is packaging not subject to system participation. For single-use plastic bottles that you have switched to being subject to deposit, you need to update the information about the packaging in the LUCID Packaging Register as follows: you must tick ‘Packaging not subject to system participation’ and, in the next step, adjust the packaging category for the existing brand name.
If you place further milk drinks in packaging subject to system participation (that are not subject to deposit, such as milk in a Tetra Pak) on the German market, you must state that you are doing so in the LUCID Packaging Register by entering the brand names of these products under ‘Packaging subject to system participation’ and continue to fulfil all of your other obligations, such as system participation. 

Participating in DPG’s deposit scheme
Single-use plastic beverage bottles of the relevant milk drinks must participate in the DPG’s deposit scheme (DPG Deutsche Pfandsystem GmbH). Companies must charge a deposit of €0.25 for each of these bottles. There is no statutory transition period. Companies are not allowed to sell single-use plastic bottles filled with milk drinks to the final consumer with a deposit before 1 January 2024.
For further information about the implementation of the deposit obligation and about how to handle remaining stocks, please refer to the DPG website. 
The DPG has published an overview of beverage packaging subject to deposit here.

For beverages from the mentioned product areas, the first stage of the ‘extended deposit obligation for single-use beverage packaging’ entered into force on 1 January 2022. Since 1 January 2022, this included beverage cans filled with 

• milk and dairy drinks as well as other drinkable dairy products and
• dietary beverages for infants or young children.

To find out about which single-use beverage packaging is affected in what product areas, as well as about the relevant obligations, please click here.