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Latvia: a deposit sign that is fined, and a material alphabet that is not
Latvia requires in-scope beverage packaging to carry the deposit sign and a registered barcode. If a material identification mark is used, Cabinet Regulation No. 140 requires the authorised EU alphabet. The Packaging Law states that packaging is marked, but Article 22 does not make omission of that code an administrative offence. The small-pack exemptions that once appeared in the regulation were deleted in 2005.
The question this report answers
Two instruments are routinely collapsed. Cabinet Regulation No. 140 of 2 April 2002 sets how packaging is classified and marked. Point 3, in the 25 October 2005 redraft (MK No. 805), is written “Ja iepakotājs marķē iepakojumu, tad…” — if the packer marks the packaging, the pack or label shall indicate the material type by the Annex 2 number or abbreviation, and the graphical symbol that the material is recoverable and/or recyclable according to Annex 3. Point 4 requires the marking to be clearly visible, easily readable and durable after opening. Point 6 makes the packer liable for correctness. Packaging Law Article 10(1) is more imperative: packaging is classified by material and marked. Article 22, however, after the 25 November 2021 deletion of paragraph (1), fines only misuse of the deposit-system special sign, not omission of the Annex 2 code.
The operational on-pack duty that an inspector can match to a penalty is the deposit regime. Packaging Law Article 18.³ requires the deposit packer to place the special indications of the deposit system on the packaging or label. Cabinet Regulation No. 519, in force for the system from 1 February 2022 and last amended on 22 December 2025 (in force 24 December 2025), requires the Annex 2 special sign — separate single-use and reusable versions; reusable marked AU — and a barcode. A QR code is accepted at return. Putting that sign on a pack that is not registered as deposit packaging is the conduct Article 22(2) actually fines (140–280 penalty units on a legal person).
Legal status at a glance
| Requirement | Status | What it is |
|---|---|---|
| Deposit sign and barcode (Reg. 519) | mandatory on covered drinks | Special sign from Annex 2 of Regulation 519 on the pack or label, plus a unique barcode. QR accepted at return. System from 1 February 2022. Wine in glass is out; PET and cans of all alcoholic drinks are in, 0.1 L to under 3 L. |
| DRS sign on non-DRS packaging | prohibited; fined | Packaging Law Article 22(2). |
| Material type (Reg. 140, Annex 2) | authorised alphabet | If a mark is applied, it must be Annex 2 (number or abbreviation). No millimetre rule. No Article 22 fine for omission located. |
| Processing graphic (Reg. 140, Annex 3) | if marked, this graphic | Möbius family with code inside and/or abbreviation below. “Recycled n %” is a separate Annex 3 option, not a general recycled-content duty. |
| B2B accompanying documents | documents permitted | Point 5: where the end user is a manufacturer or service provider using the goods as input, information may appear in accompanying documents only. |
| Small-pack exemptions | not in current MK 140 | Points 7–9 were deleted in 2005. The 20 cm², 100 ml, 50 g and unprinted-wrap carve-outs are not Latvian law. |
| PPWR harmonised label | adopted; not yet applied | Ministry page updated 20 August 2026: mandatory PPWR marking from 12 August 2028 or 24 months after the implementing act. National DRS signs are preserved under Article 12(10). |
The deposit sign that is already a market-entry condition
A deposit packer is the service provider, producer or distributor who places beverages in deposit packaging on the Latvian market, under contract with the operator. Annex 1 of Regulation 519, as replaced in 2022 and 2025, covers PET bottles and cans from 0.1 L to under 3 L for carbonated and still non-alcoholic drinks, syrups and all alcoholic drinks, and glass bottles in a narrower drink list that excludes wine, sparkling wine, fruit wine, mulled wine, aromatised wine, bitters and liqueurs. A 3.0 L bottle is out. Packs that cannot be reverse-vended because of shape may be excluded case-by-case with State Environmental Service agreement.
Point 3 requires the special sign on the pack or label, and only on the drink types in Annex 1. Point 4, in the 22 December 2025 wording, requires a barcode containing the information for that deposit unit. The operator, agreeing with packers representing at least 51 per cent of units placed on the market, may introduce other digital and visual authentication elements with at least a six-month transition. Point 24.1 accepts the empty pack if it bears the Annex 2 sign and a barcode or QR code. Millimetre lock-ups, colours and exclusion zones are not in MK 519; they live in the operator handbook and are contractual, not statute. An Estonian, Lithuanian or German deposit mark is not the Latvian sign. The Latvian sign on an unregistered pack is the conduct Article 22(2) fines.
What Regulation 140 actually says
Annex 2 is the Decision 97/129 family: PET 1 through composites 80–98, with C/ plus the predominant material for composites. Point 3.1 allows the number or the abbreviation. Annex 3 authorises a general or simplified recycling graphic, with the number inside and/or the abbreviation below, and optionally “Recycled n %” for recyclate content. No Latvian sorting sentence (“yellow bin”) is prescribed. The Climate and Energy Ministry packaging page, updated 20 August 2026, still lists Regulation 140 as in force.
The trap is citing small-pack, gasket and unprinted-label exemptions as Latvian law. They are typical of other Member States and of the pre-2005 points 7–9. They are not in the current text. The only written carve-out is B2B documents-only (point 5). MK No. 1281 (2009) is a separate bioplastic/oxo marking regime. It is not an exemption from Regulation 140, and it is not the PPWR compostable label. The packer (iepakotājs) is the goods producer, service provider, seller or distributor who places a packed product on the Latvian market, or who adds packaging that reaches the service recipient after the service. Correctness of any Regulation 140 mark is the packer’s. Informing the public of the meaning of packaging marks is a Packaging Law Article 16 information duty, not an extra on-pack pictogram.
The Union labels, and what survives 2028
The Climate and Energy Ministry’s packaging page, updated 20 August 2026, records mandatory PPWR marking from 12 August 2028 or 24 months after the implementing act. National DRS signs are preserved under PPWR Article 12(10). From 12 February 2027, Article 12(9) confines identification of EPR participation to a digital carrier. That digital-carrier rule is about EPR identification, not about the Latvian deposit sign. The 97/129 alphabet that Regulation 140 authorises is the layer that sunsets with the Decision. English pages on likumi.lv are marked as not including the 2022 and 2025 DRS amendments. The Latvian consolidations control.
Primary sources and verification
Latvia. Cabinet Regulation No. 140 (consolidated). likumi.lv
Latvia. 2005 amendment MK No. 805 (deleted points 7–9). likumi.lv
Latvia. Packaging Law. likumi.lv
Latvia. Cabinet Regulation No. 519. likumi.lv
Latvia. MK No. 809 of 22 December 2025. likumi.lv
Climate and Energy Ministry. Packaging page (updated 20 August 2026). kem.gov.lv
European Union. Regulation (EU) 2025/40. EUR-Lex
Latvian-language consolidations control. Deleted small-pack exemptions are not current law. Last verified: 21 August 2026.