Deposit Obligation 2024 for Milk Beverage Bottles

Since 2022, the deposit obligation applies to most single-use plastic beverage bottles in Germany. The same applies to beverage cans. However, this has previously excluded bottles containing 0.1 to 3 liters of milk, milk-based drinks, and dairy products. With the 2024 deposit obligation, this has changed with immediate effect from January 1, 2024. If regular milk, milk-based drinks containing at least 50 percent milk, and dairy products such as yogurt are packaged in single-use plastic bottles, a deposit of at least 25 cents must be charged.

According to current statistics, around 5 billion liters of milk are produced, of which 10 percent are packaged in plastic bottles. This amounts to approximately 455 million liters of milk affected by the 2024 deposit obligation. Beverage cartons containing milk will still remain exempt from the deposit.

Since January 1, 2024, the deposit obligation also applies to single-use plastic bottles containing milk, milk-based drinks, and other dairy products. A deposit of at least 25 cents must be charged and clearly marked. This regulation aims to increase the return of single-use packaging into the recycling cycle and reduce plastic waste. Manufacturers, importers, and retailers are required to join the DPG deposit system and properly register their products. For unmarked stock, a temporary “reasonable enforcement” policy will be in place. Violations of the deposit obligation will be penalized with high fines. 

What does the 2024 deposit obligation mean for manufacturers?

The transition period for the deposit obligation on plastic bottles containing milk and dairy products in Germany ended in 2024. This means that the regulation must now be officially implemented. Why was the 2024 deposit obligation delayed for so long? Due to hygiene concerns, several hurdles had to be overcome, which resulted in a longer preparation period.

With the 2024 deposit obligation, the return of single-use beverage bottles containing milk or dairy products must take place via reverse vending machines. Previously, proper disposal was carried out through the Yellow Bag or Yellow Bin, which was then managed by dual systems.

According to the Packaging Act, manufacturers must charge a deposit of at least €0.25 on milk in single-use beverage packaging. VAT is already included. The deposit is passed on to the end consumer throughout the entire distribution chain. To ensure this is transparently communicated, single-use beverage bottles must be marked as deposit-bearing.

Additionally, manufacturers or first distributors must participate in the unified deposit system in Germany (DPG Deutsche Pfandsystem GmbH and system partners). This system handles the processing of deposit refunds in Germany.

For milk beverages, the following deposit amounts apply: 

What are the goals of the 2024 deposit obligation on single-use plastic bottles for milk, milk-based drinks, and other drinkable dairy products?

With the new deposit regulation in Germany, the goal is to return single-use plastic beverage bottles with milk and dairy products into the sustainable raw material cycle. The aim is to reduce plastic waste, promote recycling, protect the environment, and raise awareness for sustainable consumption.

How is labeling handled under the 2024 deposit obligation?

The Packaging Act does not provide for any further transition arrangements. Packaging that falls under the 2024 deposit obligation may only be sold with the DPG deposit mark. Since March 2023, early registration in the DPG database has been possible, allowing companies sufficient time for the transition. Due to the absence of a nationwide transition arrangement, the authorities have announced “reasonable enforcement” for early 2024 via the Federal/State Working Group on Waste (LAGA). The sale of unmarked remaining stock will be temporarily tolerated for an undefined period.

How do you know if you are subject to the packaging act, and what else should you consider regarding the deposit obligation in Germany?

Companies that commercially distribute beverages in Germany are considered “first distributors” because they make the first step to the end consumer, whether the beverages are produced locally or imported. According to the German Packaging Act, all first distributors have been required to register properly in the LUCID packaging register of the Central Packaging Register Foundation (ZSVR) since July 1, 2022.

Our Packaging Law Consulting supports you comprehensively with all matters concerning packaging licensing, return, and recycling of your packaging – efficiently, thoroughly, and legally compliant. Packaging is considered a valuable resource that must be collected, sorted, and recycled, including sales packaging such as yogurt cups, cartons, or plastic bags. In accordance with the extended producer responsibility under the EU directive, manufacturers, retailers, and importers are required to comply with the legal regulations.

Not only within the EU but also internationally – in countries such as Macedonia, Israel, China, and Japan – comparable packaging laws are increasingly being enforced. Keeping track of the country-specific requirements is a challenge for many companies. This is where our packaging law consulting comes in: As an experienced partner, we help you correctly license, register, and dispose of packaging in compliance with national and international regulations. We are also at your side regarding the 2024 deposit obligation.

With years of expertise, we provide clarity and practical solutions. Starting with a detailed needs analysis, we handle all quantity reporting, filings, and settlements for you. Furthermore, we assist you in selecting suitable return systems and recycling all packaging put into circulation.

Our Services at a Glance:

• Legal monitoring and legal analysis for optimal cost efficiency
• Detailed consultations on national and international packaging licenses
• EU and worldwide analysis of obligations by packaging type
• Determination and implementation of recycling and recovery obligations
• Quantity reporting and international reporting
• Representation in foreign countries
• Evaluation of disposal and return systems from technical and financial perspectives
• Provision of suitable containers and annual statistics for documentation

What sanctions are imposed for non-compliance with the 2024 deposit obligation?

If dairy products are circulated without a deposit according to the 2024 deposit obligation, high fines will be imposed. Therefore, do not compromise and meet the requirements. We would be happy to review your environmental compliance.