The deposit requirement on single-use beverage containers
With a few exceptions, beverage containers are subject to a deposit in Germany. This is regulated in Section 31 of the German Packaging Act (VerpackG). Manufacturers of the relevant products must participate in a system for processing deposit refund claims. DPG Deutsche Pfandsystem GmbH is the only system of this kind in Germany. The reason for this is, of course, consumer protection: disposable deposit containers must be able to be returned wherever they are sold. A clearing system is therefore necessary to ensure that retailers who pay out a deposit amount that they have not collected themselves are also reimbursed.
Your partner for deposit accounts and settlement
GreenDot supports you with deposit settlement – as a DPG-approved service provider, we take care of deposit accounting and check refund claims. Find out here whether you are affected and how we can help you.
From obligation to settlement – everything at a glance
Am I affected?
Answer our simple questions and find out whether your disposable beverage packaging is subject to mandatory deposit. If you answer ‘Yes’ to a question, move on to the next one. If the answer is ‘No’, your packaging is probably subject to system participation. You can then easily obtain a quote for participation in our dual system.
Question 1: Is your packaging single-use packaging for beverages?
Is the answer ‘YES’? --> Then move on to the next question!
Is the answer ‘NO’? --> Then your packaging is probably subject to system participation.
Question 2: Is your packaging NOT a beverage carton, polyethylene tubular bag packaging or a foil stand-up pouch?
Is the answer ‘YES’? --> Then move on to the next question!
Is the answer ‘NO’? --> Then your packaging is probably subject to system participation.
Question 3: Is the filling volume of your packaging between 0.1 and 3.0 litres?
Is the answer ‘YES’? --> Then move on to the next question!
Is the answer ‘NO’? --> Then your packaging is probably subject to system participation.
Question 4: Is the bottled product included in the DPG beverage overview list?
Is the answer ‘YES’? --> Then your packaging is probably subject to a deposit and you should take a closer look at our services!
Is the answer ‘NO’? --> Then your packaging is probably subject to system participation.
What we do for you
As the distributor (manufacturer, importer), you collect a deposit of 25 pence per container each time you sell your product. This is why you are referred to as the deposit account manager. As your deposit account service provider, we take care of all claims from collectors for the payment of these deposits. We refer to ‘external clearing’ when we mean the relationship between you and the returner (claimant), and ‘internal clearing’ when we mean the services we provide directly to you.
DPG clearing (external clearing)
The DPG sets out rules governing how deposit claims must be made. We provide the relevant communication procedures, accept the deposit refund claims reported by the returners, check and validate them, and finally archive them in a certified document management system. Such a valid deposit statement is referred to as ‘accepted’.
Settlement of claims (internal clearing)
The accepted pledge claims must now be settled by you. To this end, we compile the due pledge claims in payment runs and prepare the payment of the pledge funds for you. Payment is always made directly by you as the pledge account manager to the retaker (claimant) and thus in accordance with the pledge invoice. There is no need to go through trust or third-party accounts. We will provide you with all booking-relevant information and, of course, copies of the pledge statements. This allows you to easily claim the input tax contained in the pledge invoice. All data can be transmitted by email and/or secure sFTP data transfer.
X.400 Business Mail-Box
Provision of the default communication method required by the DPG, including any necessary forwarding.
Migration services
Takeover or handover of document archives in the event of a change of service provider and/or transfer of items (GTIN change).
Document archive
GreenDot transfers the deposit statements (receipts and performance records) to its document management system in accordance with GoBD* and ensures that they are stored for the legally required periods.
*The GoBD is an administrative regulation issued by the German Federal Ministry of Finance that sets out rules for digital accounting and the archiving of tax-relevant documents.
Consulting and evaluations
We provide support with DPG registration and maintaining your product data in the master database, and we create reports on returns and claimants – personally and tailored to your needs.
GreenDot – also at your side with disposable deposits
Would you like a quote for deposit account management? Please feel free to contact us using our contact form.
Whether before registration, during active sales or in the follow-up phase: as an approved deposit account service provider, GreenDot is at your side, supporting you in every phase with experience, system expertise and legal certainty.
The preparatory phase
Unlike with the system participation for sales packaging, the deposit agreement (deposit account service) is required before you register with the DPG. Only then can you apply for DPG membership. Once you have been approved by the DPG, you become a participant, can register your items (GTIN/EAN) in the central DPG master database and start distribution.
Are you already a DPG member and would like to change your service provider? We will take care of transferring your deposit archive and assist you with the necessary changes in the DPG master database.
The distribution phase (active phase)
You collect the disposable deposit on each sale of your products and manage it yourself. The consumer returns your empty packaging to a participating retailer and receives the deposit back from them. The retailer wants to be reimbursed for the deposit money paid out and will issue a deposit invoice for this purpose. We take care of the deposit settlements resulting from the return and support you with the deposit reimbursement (deposit clearing).
This allows you to concentrate fully on the distribution of your products.
The follow-up phase
Would you like to discontinue the distribution of your products and leave the DPG system? We will, of course, also support you during the so-called settlement phase (follow-up). During this period, which usually lasts three years*, you will no longer be a DPG member, but you will still have to pay out legitimate deposit claims.
If you wish to switch to another service provider, we will be at your side during the transition phase and transfer your deposit archive to the new service provider.
* beginning at the end of the year in which you leave the DPG
Regulations on the statutory deposit requirement for single-use beverage containers
Disposable beverage containers are generally subject to a deposit requirement. The obligations are linked to the date on which the filled disposable beverage container was first placed on the market in Germany or imported into Germany.
Since January 2022, the deposit requirement has been gradually expanded. This affects, for example, various milk drinks, alcoholic beverages such as sparkling wine and wine, alcoholic mixed drinks, fruit and vegetable juices, and non-carbonated nectars in disposable plastic beverage bottles or beverage cans.
Regardless of the packaging in which you sell your goods, you must be registered in the LUCID packaging register and specify the types of packaging and brand names under which you sell your products. This also applies to goods in disposable beverage packaging subject to a deposit.
Important! Outer packaging for single-use beverage packaging may also be subject to system participation. This includes films for bundling beverage bottles, trays, cartons and beverage crates/bottle carriers.
Milk and milk-based beverages, as well as other drinkable milk products
Since 1 January 2024, disposable plastic beverage bottles containing the following milk drinks with a filling volume of 0.1 to 3 litres have been subject to a deposit:
Milk and milk-based drinks with a milk content of at least 50 per cent or
other drinkable milk products in accordance with Section 2 of the Milk and Margarine Act (primarily yoghurt and kefir).
Sparkling wine, wine, sparkling wine and wine mixed drinks, wine-like drinks and mixed drinks, alcoholic products and other alcoholic mixed drinks, fruit and vegetable juices, non-carbonated fruit and vegetable nectars
With effect from 1 January 2022, the first stage of the extended deposit requirement for single-use beverage containers for beverages from the aforementioned product areas came into force. Certain single-use beverage containers for these beverages have been subject to a deposit since then. The first stage also applied to beverage cans filled with
milk and milk-based beverages and other drinkable milk products, as well as
dietary beverages for infants or young children.
Exceptions to the deposit requirement
Certain single-use beverage containers ...
are expressly exempt from the deposit requirement due to their filling volume. These are containers with a filling volume of less than 0.1 and more than 3.0 litres.
are expressly exempt from the deposit requirement due to their design. Exceptions apply conclusively to beverage cartons in block, gable or cylinder form, or polyethylene beverage tubular bags or stand-up foil bags.
are expressly exempt from the deposit requirement due to their contents (cf. Section 31 (4) sentence 1 no. 7 VerpackG), whereby beverage cans are always subject to a deposit regardless of their contents. The same applies, with a few exceptions, to single-use plastic beverage bottles.
Containers that are demonstrably intended to be sold to end consumers abroad (export) are also exempt from the deposit requirement.
We are here for you!
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