The law surrounding the deposit obligation for single-use beverage packaging

Single-use beverage packaging is generally subject to deposit. Typical examples include beverage cans and single-use bottles made of plastic, glass or PET, e.g. for water, soft drinks, juices, beer or mixed beverages containing alcohol. 

In Germany, it is the initial distributor who is under obligation to label single-use beverage packaging as being subject to deposit. The deposit must be charged on all retail levels, up to the point that packaging is handed over to the end user.

No matter what type of packaging you use to distribute your goods, you have to be registered with the LUCID Packaging Register and indicate which packaging types are distributed under what brand names. That also applies to single-use beverage packaging subject to deposit.

Heads up

Grouped packaging for single-use beverage packaging can be subject to system participation. This includes films for bundling beverage bottles, trays, cartons and bottle crates/bottle carriers.

Exemptions from the deposit obligation

Certain single-use beverage packaging …

  • is expressly exempt from the deposit obligation due to its volume. The exemption applies to packaging with a volume of less than 0.1 and more than 3.0 litres.

  • is expressly exempt from the deposit obligation due to its design or material combination. Exemptions apply exhaustively to square, gable-top or cylindrical beverage cartons, or tubular bags for beverages made from polyethylene, or foil stand-up pouches.

  • is exempt from the deposit obligation due to its contents (cf. section 46 (4) no. 7 VerpackDG (Packaging Law Implementation Act): 

    • sparkling wines, sparkling wine-based cocktails with a sparkling wine content of at least 50 percent and sparkling drinks made of alcohol-free or low-alcohol wine; 
    • wine and wine-based cocktails with a wine content of at least 50 percent and alcohol-free or low-alcohol wine; 
    • (processed) beverages and mixed beverages similar to wine, including non-alcoholic or low-alcohol beverages, with a content of wine-like products of at least 50 percent; 
    • alcohol products subject to alcohol tax pursuant to section 1 (1) AlkStG (Alcohol Duty Act), unless these products are subject to alcopop tax pursuant to section 1 (2) AlkopopStG (Alcopop Duty Act);
    • other mixed beverages containing alcohol with an alcohol content of at least 15 percent; 
    • milk and dairy drinks with at least 50 percent milk content; 
    • other drinkable dairy products as set out in section 3 (1) no. 6 MilchPQV (Milk Product Quality Ordinance), especially yoghurt and kefir, if the other drinkable dairy products do not contain a substance listed in Appendix 8 FrSaftErfrischGetrV (Ordinance on Fruit Juices and Soft Drinks); 
    • fruit juices within the meaning of the FrSaftErfrischGetrV and vegetable juices; 
    • non-carbonated fruit nectars within the meaning of the FrSaftErfrischGetrV and non-carbonated vegetable nectars; 
    • food for special medical purposes within the meaning of Article 2 (2) (g) Regulation (EU) No 609/2013; 
    • beverages with an alcohol content of 1.2 percent by volume or less which are placed on the market as alcohol-free or low-alcohol alternatives to beverages listed under heading 2208 of the Combined Nomenclature within the meaning of section 1 (2) no. 1 (a) in conjunction with section 4 AlkStG and whose descriptive label and design indicate such a beverage. 

These exemptions do not apply to beverage cans and single-use plastic beverage bottles.

Heads up

In addition, single-use beverage packaging that is generally subject to deposit is not subject to deposit if it is proven that this packaging is not intended to be passed on to end users in Germany.

System participation requirement catalogue

Is your single-use beverage packaging subject to system participation? The catalogue not only contains details about the system participation requirement, but also about the deposit obligation. 

Classification decision

One of the ZSVR's duties is to decide, upon application, whether beverage packaging is to be classified as reusable packaging or single-use beverage packaging subject to deposit.

Participating your single-use beverage packaging in the German deposit scheme ('DPG')