For Companies
How does the new deposit cycle work?
- The producers always sell the beverages to their retail partners inclusive of the 25-cent deposit.
- For all products sold, the producers must pay the collected deposit to Recycling Pfand Österreich on a regular basis.
- Recycling Pfand Österreich is responsible for carrying out the credit procedure of the deposit amount with the collectors, and collecting and sorting the empty, returned plastic bottles and aluminium cans.
- The producers can buy back the same proportion of material put into circulation by them and then collected.
- The repurchased material is commissioned by the producers for recycling and can then be reused to manufacture new bottles or cans.
What do I have to consider as a producer/importer before the deposit system is introduced?
- All producers and importers of single-use drinks containers who sell their products in Austria must register themselves via the login platform of Recycling Pfand Österreich.
- Each drink item (=SKU) in a single-use plastic bottle or aluminium can must be registered with Recycling Pfand Österreich so that it can subsequently participate in the deposit cycle and be identified either by the reverse vending machine and or by manual collectors.
- From 2025, the sale of unregistered products in Austria will basically be prohibited. However, the Regulation specifies a transitional period for products bottled/canned before a certain date.
- The deposit logo must be placed on containers subject to deposit so that consumers can clearly identify that the product is part of the deposit cycle.
- Full information and precise specifications is available in the producer manual
What rights and obligations do initial distributors have:
Obligations: Initial distributors (= drinks producers, drinks importers) must register as initial distributors in the EWP portal and also register their products. Furthermore, initial distributors must pay contributions to the producers.
Rights: In return, initial distributors have the right of access to the recycled material of their containers.
I’m a producer/importer and don’t have an office in Austria. How can I register myself or my products?
Foreign companies also have to appoint an Austrian authorised representative to fulfil the obligations of the Deposit Regulation on behalf of the companies.
Are there transitional periods for producers?
Products may be sold until 31 December 2025 without the deposit being charged, if they were bottled/canned before 1 April 2025.
How does the deposit system work for sponsored goods?
For each drink sold in single-use deposit bottles from 1 January 2025, the corresponding deposit of 25 cents must be paid to Recycling Pfand Österreich. That also includes sponsored goods, test samples, samples, giveaways and home brew.
What is meant by “place on the market” – Are free items and giveaways also covered?
The following are deemed to have been put into circulation and must therefore be reported to Recycling Pfand:
- Samples & sponsoring
- In-house & own consumption
- Specimen goods
- Expired goods that are donated to food banks or employees
The following are deemed NOT to have been put into circulation and must therefore not be reported to Recycling Pfand:
- Laboratory prototypes that are not put into circulation
- Expired goods that have been demonstrably destroyed
- Products with production faults that have demonstrably not been put into circulation (and not donated either)
Special case recalls:
- Containers have already been reported as put into circulation and are recalled by the initial circulator due to a reason for complaint (e.g. quality, best before date).
- The initial circulator amends the initially circulated quantities in the next quantity report.
- The goods are demonstrably destroyed and the confirmation of destruction is is being kept.
As a producer, do I also have to pay the 25-cent deposit to Recycling Pfand Österreich for giveaways?
Yes. The corresponding deposit of 25 cents must be paid to Recycling Pfand Österreich for each drink. This also applies to giveaways, as the collectors will also reimburse the 25-cent deposit on these bottles and cans when they are returned.
What do I have to note with regard to the distribution of giveaways / samples?
Even if drinks subject to a deposit are distributed for free / as samples, there is an obligation to collect the containers.
The following collection options are available:
1) become a manual collector
2) indicate an alternative collection point, if distribution takes place at a highly frequented place
- This must be in the immediate vicinity
- An agreement has to be made with this collection point
- The consumer must be informed about this
We provide our employees with free drinks in our company. Does the deposit have to be paid to Recycling Pfand Österreich for these drinks?
Yes. The corresponding deposit of 25 cents must be paid to Recycling Pfand Österreich for each drink. This also applies to giveaways, as the collectors will also reimburse the 25-cent deposit on these bottles and cans when they are returned.
How will billing take place for companies during the transitional period?
During the transitional period provided for in the Regulation, companies only have to report those containers that are part of the single-use deposit system (new EAN codes, deposit logo). Billing takes place for these container only.
Who needs to register?
All producers and importers of single-use drinks containers who sell their products in Austria must register via Recycling Pfand Österreich.
Registration is a prerequisite for the approval of the drink item or its container and is required for the levying of the statutory producer contributions and for the payment of the deposit amounts.
Why do I need to register?
Registration is required for the levying of the statutory producer contributions and for the payment of the deposit amounts.
- Each producer and importer that sells drinks in plastic bottles and cans as the first placer on the market has to register with EWP Recycling Pfand Österreich.
- Each drink item (=SKU) in a single-use plastic bottle or aluminium can must be registered with Recycling Pfand Österreich so that it can participate in the deposit system.
By when do I need to register my company and my products?
The product has to be registered and approved before being sold in Austria. Important: Please note the lead times for registration.
- Each drink in a single-use deposit bottle must be registered and must display the deposit logo so that consumers can clearly identify that the product is involved in the deposit cycle.
Can single-use deposit bottles that have not been registered also be sold in Austria?
No. Upon expiry of the transitional period on 31 December 2025, all products sold in Austria that are subject to the deposit on single-use containers must be registered without exception.
How do I register?
Registration will be possible via the login area of the Recycling Pfand Österreich website.
Is the sale of unregistered products an offence?
Yes. § 79 of the Waste Management Act (AWG 2002) contains penalty clauses for violations of the Deposit Regulation, which was enacted in accordance with § 14c AWG. Violations therefore constitute an administrative offence and the penalty can amount to up to 8,400 euros.
How is the producer fee calculated?
The producer fee is invoiced together with the deposit amount for each item sold and on the basis of the sales reports. The calculation is specified in the Regulation under §10.
What does the registration fee cover and when is it due?
The provisions calculating the registration costs are laid out in §22 (3) of the Regulation. Producers will be charged these costs after registering. The fee must be paid before the respective product and its container (SKU) can finally be included in the database registry of the deposit system.
Does a release fee also have to be paid for single-use drinks containers from 1 January 2025 in addition to the producer fee?
No. For single-use drinks containers subject to a deposit which are sold with a new barcode and the Austrian deposit logo from 1 January 2025, and on which the deposit is levied, the release fee is no longer required, but instead the producer fee is to be paid.
The release fee no longer has to be paid for which parts of the single-use drinks containers?
There is no fee to pay for the container, labels, seals and caps.
Is it essential to create new GTIN codes (formerly EAN codes) for each container unit and by when do these need to be notified at the latest?
Yes. The deposit logo may only be used in combination with a new GTIN code, as that is the only way to differentiate the product from those already on the market.
For international EAN codes, there are exceptions, but these also require higher fees.
How do the products need to be labelled?
Each product must display the deposit logo so that it is clearly visible to consumers. Full information can be found in the producer manual.
From what date do the products need to display the deposit logo?
Sales of products displaying the deposit logo may commence on 1 January 2025. The regulation allows for products to be bottled/canned without the deposit logo until 31 March 2025 and thereafter sold with the levying of a deposit until 31 December 2025 (transitional period). From 1 January 2026, only registered products displaying the deposit logo may be sold.
How is the deposit charged on imported goods and how are they labelled?
By definition, all products that are subject to the deposit and sold in Austria must visibly display the deposit logo. The logo can be applied to the container by means of a sticker, including for very small quantities. Therefore, international and imported products must also be registered without exception.
International GTIN codes are permitted.
How is the deposit charged on smaller batches of cans or bottles and how are they labelled?
For products in small batches and imported goods, there is the possibility to place stickers from Recycling Pfand Österreich on the products. Details can be found in the producer manual.
I will still have products in stock in January 2025 that don’t display the deposit logo. Am I allowed to continue selling them?
Yes. There is a transitional period until the end of 2025. No deposit may be levied on products without the deposit logo and the container may also not be collected as a single-use deposit container. These items will continue to be collected via conventional collection systems (e.g. yellow bag). All products bottled/canned from 1 April 2025 must be registered and labelled accordingly.
From 2026, all products sold in Austria must be registered and display the deposit logo.
Does the label adhesive have to meet certain requirements?
Full information can be found in the producer manual.
In the case of trademarks, who is responsible for registering the product and applying the logo?
Answer: In accordance with the deposit regulation, the clients, i.e. the brand owners, have the obligation to register the respective products and arrange for them to be labelled with the deposit logo in the case of contract bottling.
In the case of trademarks, who is responsible for registering the product and applying the deposit logo?
In accordance with the deposit regulation, these obligations fall on the clients (i.e. the brand owner) of the contract bottlers for these instances of contract bottling. They must therefore register the respective products and arrange for them to be labelled with the deposit logo.
I am a drinks dealer and supply companies and events (often on commission). Who is responsible for return, refunding the deposit and collection?
If your company acts solely as a dispenser in the value chain and does not pass drinks directly to end consumers, you are not obligated to collect the empty containers or disburse the deposit. These obligations essentially fall on the final distributor. It also makes no difference whether the goods were handed over to final distributors as part of, for example, a commission-based transaction or by means of reservation of title.
However, you are free to make special arrangements with the final distributors and to pick up the collected drinks containers yourself. In this case, collection is performed by Recycling Pfand Österreich or delivery partners at one of your specified business locations.
How is the settlement of the deposit to be assessed for VAT by the retailer or producer?
The deposit is collected by the retailer or producer on behalf of and on account of EWP Recycling Pfand Österreich gGmbH (§4(1) Deposit Return Scheme for Single-Use Drinks Containers, Federal Gazette II No. 283/2023). For retailers and producers, the deposit therefore represents a transitory item that is not subject to value added tax (§4(3) Value Added Tax Act (UStG)). If the cash register and document reporting obligation or invoicing obligation applies, the deposit must be shown on the till receipt / invoice on its own line with a value added tax rate of 0%. The remark “Settlement on behalf of and on account of EWP Recycling Pfand Österreich gGmbH” can also be indicated.
Conversely, the deposit is reimbursed by collectors on behalf of and on account of EWP Recycling Pfand Österreich gGmbH. The reimbursement must also be posted without value added tax; the credit amount must be shown on the invoice / till receipt on its own line with a value added tax rate of 0%.
This regulation is subject to change, as the final approval of the authorities is still outstanding.
How do I get the deposit logo?
The deposit logo is a warranty mark whose use is strictly regulated. It may only be used on registered products to identify the product or to identify registered collection points. The logo may only be used to identify collection points via the data package provided by EWP.
To obtain the logo, register in the EWP portal as an initial distributor. This will give you access to the licence agreement. A print quality copy of the logo will be supplied only once the agreement has been signed and uploaded. If the signing of the contract has not yet been activated in the system, we will be happy to send you the contract for signing after you have registered as an initial distributor. Use of the logo is permitted solely with a signed licence agreement.
Can I identify my single-use deposit products by noting the deposit as “Einwegpfand € 0,25” on the label?
Yes, you can add this information anywhere on the label. Austrian authorities neither require nor recommend adding such information on the label for containers that are part of the deposit-refund system. However, containers that fall under the deposit-refund system must carry the official Austrian deposit-refund logo. In addition, such a note is permitted if the product carries an Austrian Global Trade Item Number (GTIN), as opposed to an international GTIN.
When can I register as an exporter, report my exported volumes on the portal and get the deposit amount back?
Registration is already possible in the EWP portal under the role of exporter.