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Germany: a deposit identifier, not a national sorting label
Germany does not require a general consumer sorting label. Covered one-way drinks packaging must be durably marked as deposit-bearing before it is made available. Retailers must display EINWEG and MEHRWEG at the point of sale. LUCID registration and the ZSVR recyclability standard are not on-pack duties. The Green Dot has not been a legal requirement since 1 January 2009. From 12 August 2026 the Packaging Act is replaced by the VerpackDG around the directly applicable Packaging and Packaging Waste Regulation.
Marks are shown for identification, research and commentary. The Green Dot is not a German sorting instruction and is not proof of LUCID registration.
The question this report answers
Germany combines one of Europe’s stricter packaging producer-responsibility systems with almost no mandatory consumer sorting mark. There is no German equivalent of Triman, Info-tri or Spain’s fraction panel. The Packaging Law Adaptation Act (BGBl. 2026 I Nr. 207, 17 July 2026) replaced the Verpackungsgesetz with the Verpackungsrecht-Durchführungsgesetz (VerpackDG) from 12 August 2026, the same day Regulation (EU) 2025/40 generally applies. The new Act does not transpose the PPWR — a regulation is directly applicable — and does not create a national sorting label. It keeps the €0.25 one-way deposit, the LUCID register and dual-system participation, and fills Member-State discretion around the Union rules.
The only general on-pack consumer mark is the duty, now in VerpackDG § 46(1), to mark filled one-way drinks packaging as deposit-bearing, durably, clearly legibly and in a well-visible place, before it is made available in Germany. EINWEG and MEHRWEG, now in § 47, are point-of-sale notices for the final distributor, including distance selling. They are not pack marks. Material-identification numbers in § 4 remain voluntary. The ZSVR recyclability minimum standard modulates system-participation fees. It is not a licence to print “recyclable”.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Universal German sorting label | none | Neither VerpackG nor VerpackDG requires a general on-pack recycling or waste-fraction panel. |
| One-way deposit identifier | mandatory | The first placer must mark covered one-way drinks packaging as pfandpflichtig before making it available. In practice this is the DPG logo and barcode. |
| EINWEG / MEHRWEG | mandatory at point of sale | Final distributors must identify one-way and reusable drinks in the immediate vicinity of the goods, or equivalently in distance selling. Not a pack duty. |
| Material numbers (Anlage 2) | voluntary | § 4: packaging may carry the numbers and abbreviations in Anlage 2 (the Decision 97/129 set). Other numbering for the same materials is not allowed. |
| LUCID registration | mandatory; off-pack | § 6: register with ZSVR before first making available. The LUCID number is not printed on the pack. Foreign distance sellers need an authorised representative from 12 August 2026. |
| ZSVR recyclability minimum standard | fee method | Governs ecological modulation of system-participation fees. It does not authorise an unqualified consumer recyclability claim. |
| Green Dot | not required | Private trademark. The former legal duty ended on 1 January 2009. From 12 February 2027 PPWR Article 12(9) confines EPR identification to digital form. |
| PPWR harmonised label | adopted; not yet applied | When Article 12 applies, Germany will have a Union sorting pictogram for the first time. Until then there is no general German sorting mark to remove. |
The deposit identifier that is already on the bottle
VerpackDG § 46(1) requires the first placer of filled one-way drinks packaging to collect a deposit of at least €0.25 including VAT, to participate in a nationwide uniform deposit system, and to mark the packaging as deposit-bearing before making it available in Germany. The statutory words are “als pfandpflichtig”. The Act does not prescribe a logo. The operating system is Deutsche Pfandsystem GmbH. DPG specifies the identifier and the machine-readable code. A foreign deposit mark or a copied barcode does not establish German participation.
§ 46(4) carves out fill volumes below 0.1 litre or above 3.0 litres, listed cartons and pouches, and named beverage categories — including wine, spirits, milk of at least 50 per cent, and juices — unless those drinks are in one-way plastic bottles or cans, which remain in the deposit. Product category, volume, material and the statutory exclusions have to be read together. The mark communicates participation in the return route. It does not establish that every component is recyclable, or that the container is reusable.
EINWEG and MEHRWEG are shelf notices
VerpackDG § 47 is the successor of VerpackG § 32. Final distributors of one-way drinks packaging subject to the § 46 deposit must display information boards or signs with the characters “EINWEG”, making clear that the packaging will not be reused after return. Reusable drinks packaging must be identified with “MEHRWEG”, with exclusions for fill volumes above 3.0 litres and the beverage categories in § 46(4) no. 7. In distance selling the equivalent information must appear in the media used. Form and type size must at least match unit-price labelling. Retailers exempt from unit-price indication under PAngV § 4(3) nos. 3–5 are exempt. These notices sit on the shelf or the web page, not on the bottle, unless a retailer chooses to duplicate them.
What is not an on-pack duty
§ 4 allows material identification using only Anlage 2 numbers. The provision is “können”, not “müssen”. Using a rival numbering system for those materials is prohibited. LUCID registration under § 6 is a precondition of making packaging available. It is not a printed mark. The ZSVR minimum standard is a fee-modulation methodology. Printing “recyclable according to ZSVR” as a consumer claim converts a fee tool into an environmental representation that must still be true under unfair-competition and PPWR claims rules.
Der Grüne Punkt has not been a legal condition of market placement since 1 January 2009 (fifth amendment of the former Verpackungsverordnung). Later Acts did not re-impose it. Displaying it is a trademark-licence decision. From 12 February 2027 PPWR Article 12(9) requires EPR identification, if used, to sit inside a digital carrier rather than as a physical EPR mark.
The deposit on-pack mark is borne by the Erstinverkehrbringer of filled one-way drinks packaging. EINWEG/MEHRWEG signs are borne by the Endvertreiber. LUCID registration is borne by the manufacturer as defined through PPWR Article 3. Conformity documentation under the PPWR is a manufacturer duty; the declaration of conformity may be in German or English (§ 62). Fines can reach €200,000 under § 66. A brand owner who is not the first placer can still be the person making environmental claims to German consumers. Dual-system participation does not, of itself, substantiate those claims.
The 2026 Act, and the Union label that is not yet German law on the pack
For events on or after 12 August 2026 the citation is VerpackDG, not VerpackG. Former VerpackG § 31 (deposit) is now § 46; former § 32 (EINWEG/MEHRWEG) is now § 47; former LUCID § 9 is now § 6. The Adaptation Act is the national chassis around the PPWR, not a labelling statute. Harmonised Union sorting artwork remains on the Article 12 timetable: 12 August 2028 or 24 months after the implementing act, whichever is later. Commission Notice C/2026/3084 will matter for Germany mainly as the moment a general sorting label first appears, not as a command to remove an existing national panel. Until Article 12 applies, there is no general German sorting mark to take off.
Primary sources and verification
Germany. Gesetz zur Anpassung des Verpackungsrechts … an die Verordnung (EU) 2025/40, BGBl. 2026 I Nr. 207. BGBl.
Germany. VerpackDG, table of contents. gesetze-im-internet
Germany. VerpackDG § 46 (deposit marking). § 46
Germany. VerpackDG § 47 (EINWEG / MEHRWEG). § 47
Germany. VerpackDG § 4 (material identification). § 4
Germany. VerpackDG § 6 (LUCID). § 6
ZSVR. Changes from 12 August 2026. Packaging Register
Federal Environment Ministry. Deposit and reusable bottles. BMUV
European Union. Regulation (EU) 2025/40. EUR-Lex
German-language legislation controls. For events before 12 August 2026 the predecessor VerpackG numbering still appears in older files. Last verified: 21 August 2026.