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Austria: a deposit mark, not a general sorting label
Austria does not require a general consumer sorting label on ordinary packaging. What it does require, from 1 January 2025, is the Austrian deposit symbol and a registered barcode on covered single-use plastic or metal beverage containers. Material identification numbers and abbreviations are permitted by the Packaging Ordinance; they are not a universal duty. Harmonised Union labels under the Packaging and Packaging Waste Regulation have been adopted in law and are not yet the operative Austrian artwork.
The question this report answers
Austria is easy to misread from a European distance. It is a Member State. The Packaging and Packaging Waste Regulation applies. It operates a national deposit-return system for single-use drinks. None of those facts produces a Triman-style sorting panel on every household pack. The labelling landscape is three systems that must be kept apart: a product-specific deposit mark that is already mandatory; a national material-coding list that remains voluntary; and Union composition and reuse labels that are law, but that apply on later, implementing-act-dependent dates.
The central national instruments are the Packaging Ordinance 2014, which governs packaging design, collection and producer-responsibility arrangements, and the Deposit Ordinance for Single-Use Beverage Packaging 2023 (BGBl. II No. 283/2023), which creates the on-pack duty for covered drinks. Regulation (EU) 2025/40 became generally applicable on 12 August 2026. That date is not the date on which the future harmonised sorting artwork had to appear. Article 12 of the Regulation uses later triggers for material-composition and reusable-packaging labels. This report therefore does not treat 12 August 2026 as an Austrian labelling cut-over.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Austrian deposit symbol and barcode | mandatory | Covered single-use plastic or metal beverage containers must be marked visibly, recognisably and durably under section 6 of the 2023 Deposit Ordinance. |
| National material codes | voluntary | Annex 1 to the Packaging Ordinance permits listed EU-derived numbers and abbreviations. If they are used, competing identifiers for the same material are not allowed. |
| General national sorting label | none | Austria has no universal on-pack waste-fraction instruction for ordinary packaging. Collection guidance is not a statutory package mark. |
| PPWR harmonised labels | adopted; not yet applied | The Regulation is generally applicable. Its material-composition and reusable-packaging labels apply only on the later Article 12 timetables. |
The deposit mark that is already in force
The Deposit Ordinance covers a defined category of single-use beverage packaging made from plastic or metal and placed on the Austrian market. Section 6 assigns the marking duty to the Erstinverkehrsetzer — the first person placing the container on the market. Covered containers must carry both a barcode registered for the system and the deposit word-and-device mark reproduced in the Ordinance’s annex. The mark must be visible, recognisable and durable. The Ordinance does not state a millimetre minimum in the provisions cited for this report. Scheme manuals specify artwork, print and registration practice; the legal foundation remains the Ordinance.
The mark identifies participation in Austria’s deposit-and-return system. It is not a statement that the container is recyclable, and it is not a general sorting instruction for the rest of the pack. The system began on 1 January 2025. A transitional sell-through for older containers without the deposit logo ran through 31 December 2025. Current packs should not be read as if that launch transition were still open. Recycling Pfand Österreich administers registration and scheme documentation.
Material identification that remains a choice
Annex 1 to the Packaging Ordinance uses permissive language. Packaging may be marked with the listed numbers or abbreviations to identify materials. The list follows the familiar Decision 97/129 conventions: PET 1, HDPE 2, PAP 20–22, FE 40, ALU 41, and related composite forms. Where a business chooses to identify a material in this way, other numbers or abbreviations for the same material are not permitted, and abbreviations are written in capital letters.
The list therefore controls the form of an optional material code. It does not turn the code into a duty to mark every pack. A resin or paper identifier describes composition. A disposal direction represents acceptance in a collection and processing system. Those are different propositions, and the Austrian ordinance does not collapse them into one consumer panel. Collection guidance issued by municipalities or recovery organisations is not, without more, a statutory on-pack instruction.
Who the deposit duty binds
For the deposit mark, the obligated party is the first placer on the Austrian market. The definition reaches domestic first marketers and can capture distance sellers supplying Austria. A brand owner may control the artwork while a local importer is the first market placer. Those roles are not interchangeable, and they are not the same as the producer definition used for extended producer responsibility under the Packaging Ordinance or under the PPWR.
Under the broader packaging regime, producers and importers participate in collection and recovery systems according to packaging category and sales channel. Austrian waste authorities enforce the Waste Management Act and its ordinances. The deposit system’s central body controls registration and scheme artwork. Non-compliance may trigger administrative measures and penalties under the Waste Management Act. Misleading environmental claims may be reached separately through consumer or unfair-competition law.
Claims, and the Union labels that have not yet arrived
An optional material code should not be enlarged into an unsupported recyclability claim. General consumer and unfair-competition law applies to environmental representations. PPWR Article 14 adds a packaging-specific rule for claims about properties regulated by that Regulation: such a claim may concern performance exceeding the applicable minimum, and it must identify whether it relates to the packaging unit, part of the unit, or the operator’s packaging portfolio.
PPWR Article 12 also prohibits labels or symbols likely to mislead or confuse users about sustainability characteristics or waste-management options for which harmonised labelling has been established. That prohibition becomes especially important during the transition, when additional Austrian or private artwork must not imitate, contradict or obscure the future harmonised system. It is not a reason to treat the future system as if it were already the mark on an Austrian pack.
The PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. Its material-composition label applies from the later of 12 August 2028 and 24 months after the relevant implementing act enters into force. The reusable-packaging label follows the later of 12 February 2029 and 30 months after the implementing act. From 12 February 2027, Article 12(9) confines identification of EPR participation to a symbol in a QR code or other standardised open digital marking. Those dates are Union law. They do not, of themselves, create an Austrian waste-fraction pictogram in 2026.
Primary sources and verification
Republic of Austria. Packaging Ordinance 2014, Annex 1, consolidated text. RIS
Republic of Austria. Deposit Ordinance for Single-Use Beverage Packaging, BGBl. II No. 283/2023, section 6 and Annex. RIS
Recycling Pfand Oesterreich. Producer manual and system information. Scheme manual
European Union. Regulation (EU) 2025/40, especially Articles 12–15. EUR-Lex
German-language legal text controls. Last verified: 21 August 2026.