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Iceland: coding that became a choice, and a deposit system without a proven logo duty
Iceland permits standardised material identification but no longer requires it on every package. Nordic sorting pictograms are voluntary. The national beverage-container deposit system, operated by Endurvinnslan, is operational. The sources reviewed for this report do not establish that every covered container must display a national deposit logo. PPWR obligations depend on incorporation into the EEA framework and Icelandic implementation.
The question this report answers
Iceland’s material-identification rule is often overstated because older official material described plastic coding as compulsory. Regulation No. 609/1996 was amended in 2018. The current provision permits packaging to be identified by material and requires the Annex II system where that choice is made. It does not impose a general duty to mark every package. Any code that is used must be visible, readily legible and durable, and competing material-identification systems are not permitted.
Iceland also participates in the common Nordic waste-symbol system. Those pictograms can support consistent sorting communication across participating countries, but their use on packaging is voluntary and governed by the system’s design and licensing conditions. Endurvinnslan has operated Iceland’s deposit-return scheme for beverage containers since 1989. The scheme itself is mandatory for covered products. The primary sources reviewed for this report do not support claiming that every container must display a national deposit logo. Future PPWR requirements must be assessed through the EEA incorporation process. An EU application date does not, of itself, make a Union regulation Icelandic law.
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Packaging material identification | voluntary | Since the 2018 amendment, packaging may be identified using the prescribed Annex II system. Alternative systems are prohibited where identification is used. |
| Nordic waste symbols | voluntary | Iceland participates in the common Nordic pictogram system, which can be used according to its licence and design rules. |
| Beverage deposit system | mandatory system | Covered containers participate in the national return system. The reviewed sources do not establish a universal mandatory on-pack deposit logo. |
| PPWR labels | pending EEA incorporation | Regulation (EU) 2025/40 does not automatically apply in Iceland without the relevant EEA and national steps. |
The 2018 amendment that changed the coding story
The current regulation uses permissive language for packaging material identification. If a producer chooses to identify composition, the code must follow Annex II, which reflects the European numbering and abbreviation system for packaging materials. The mark must remain visible and legible after the package is opened and should be applied to the component it describes. A material code is not a sorting instruction or a recyclability claim. Multi-material structures are especially difficult to communicate accurately, because the code may identify the predominant material rather than describe the practical collection route. An obsolete statement that all plastic packaging must be coded in Iceland is not the 2018 text.
Nordic pictograms, and a deposit scheme whose logo is not proven as a statute
The Nordic pictogram system provides a common visual vocabulary for household waste fractions and is used by municipalities and waste operators in several participating countries. Icelandic organisations can use the symbols under the programme’s terms, and matching on-pack and bin imagery may reduce consumer search effort. The system nevertheless remains voluntary on packaging unless a contract or sector-specific condition incorporates it. When used, the symbol should correspond to the waste fraction that accepts the package in the relevant Icelandic collection system. A voluntary pictogram is still a representation. It should not be accompanied by an unqualified assertion that the item will be recycled unless evidence supports that broader claim.
Endurvinnslan’s return system has operated since 1989. Covered beverage containers attract a deposit that is returned to the consumer through collection points. Producers and importers must account for covered products under the national system. Retailers and return operators have roles established by the governing legislation and scheme arrangements. The existence of the scheme should not be converted into an unsupported artwork requirement. Current operator instructions, product registration and barcode requirements are the sources for any logo that does appear. A voluntary logo authorised by the operator may be operationally useful without being mandated by regulation. This report records that distinction rather than inventing a logo duty the reviewed sources do not establish.
Why the PPWR is not automatically Icelandic
Regulation (EU) 2025/40 is relevant to Iceland as an EEA state, but EU regulations do not become directly applicable there solely because their EU application date has arrived. The measure must be incorporated into the EEA Agreement and implemented through the applicable Icelandic process. Until that occurs, the future harmonised labels should be recorded as pending EEA incorporation rather than current Icelandic duties. The Environment and Energy Agency and other competent Icelandic bodies administer packaging and waste legislation. Endurvinnslan administers the deposit system. Enforcement and scheme consequences depend on the breached obligation. Claims remain subject to marketing and consumer law even when the symbol itself is voluntary.
Primary sources and verification
Iceland. Regulation No. 609/1996 on packaging and packaging waste, consolidated text. Government regulations
Iceland. 2018 amendment to Regulation No. 609/1996. Amending regulation
Endurvinnslan. Icelandic deposit-return system. System operator
Nordic Waste Group. Iceland participation and packaging pictogram guidance. EUPicto
Icelandic legislation controls. EEA incorporation must be verified separately from EU adoption. Last verified: 21 August 2026.