Austria's deposit fees cost a drinks brand about what ARA's household rates would, so the real change is in cash flow and reporting

Where ARA stops and the deposit starts

The legal line is drawn by container and deposit, not by brand. Under the Pfandverordnung, a single-use plastic or metal beverage container of 0.1 to 3.0 litres carries a EUR 0.25 deposit (§ 4(1)), milk and dairy products are excluded (§ 4(3)), and § 3 takes glass or metal bottles with plastic closures, beverage cartons and bottles for infant food or special medical purposes out of the definition altogether (BGBl. II Nr. 283/2023, via PR-AT-001). The ministry’s one-year review confirms that the deposit has applied “Seit 1. Jänner 2025” to single-use bottles and cans (BMLUK).

The packaging ordinance applies the same line to the licence fee. § 6a, inserted by BGBl. II Nr. 284/2023, opens with the words “Für bepfandete Einweggetränkeverpackungen aus Kunststoff oder Metall gemäß einer Verordnung nach § 14c AWG 2002” and switches off a list of duties for those containers, including § 6, §§ 8 to 16 and the reporting annexes (VerpackVO 2014, consolidated text of 8 April 2024). ARA’s general terms follow suit: section II.2.a excludes deposit-bearing single-use beverage packaging under § 6a from what ARA counts as packaging (ARA AGB, 29 November 2024).

ARA’s own guidance spells out the practical result. Deposit containers are no longer reported to ARA, their single-use plastic reports and anti-litter contributions move to the central body, and labels, caps and lids on in-scope bottles and cans are part of the deposit container (ARA Infoblatt, 6 June 2024). Secondary and transport packaging used with deposit containers, such as tray film, displays and cardboard, stays in ARA reporting, and so do reusable items such as Euro pallets in the extended quantity report.

The changeover also had a tail. ARA’s sheet notes that plastic and metal beverage containers placed on the market during the transition under § 4(2) of the ordinance, without a deposit, stayed in ARA reporting. The ministry describes 2025 as a transition year: drinks could be filled into containers without the deposit logo until the end of March and sold until the end of the year (BMLUK). Recycling Pfand Österreich adds that unregistered products may not be sold in Austria from 2026. SPI analysis: 2026 is therefore the first full year in which a drinks brand’s ARA return should carry no in-scope bottles or cans at all, which may be why the scheme is often dated to 2026.

ARA's tariff, line by line

ARA publishes one tariff sheet a year in euro per kg, excluding VAT, with household codes (1.xx) and commercial codes (2.xx). The 2026 sheet, version of 29 September 2025, prints 2025 and 2026 side by side, and the 2027 sheet, version of 28 September 2026, prints 2026 and 2027 (Exhibit 3). The English sheets refer readers to “Article 13h WMA 2013” for the household and commercial definitions; the provision is § 13h of the AWG 2002.

The sheet is not modulated by recyclability grade in the way the Belgian or Italian tables in the EPR fees per tonne piece are. The spread comes from the material code and the stream. The ordinance requires uniform tariffs per category, published, cost-based and without discounts (§ 13(2) VerpackVO 2014), and ARA’s general terms let it change tariffs at the start of any month, ideally with a month’s notice, with a right for the licence partner to terminate within three weeks of a published increase (AGB VII.3, VII.8 and XXIII.6.b).

The classification follows the destination. § 13h AWG 2002 separates household packaging from commercial packaging that arises at sites not comparable to households, and ARA’s sheet points to it for the definitions. For drinks, ARA’s information sheet places secondary and transport packaging in the product group “AT 03 Getränke” of the Verpackungsabgrenzungsverordnung, which sets the household and commercial split for that group. SPI analysis: a corrugated tray declared as household paper costs EUR 0.208 per kg instead of EUR 0.07, so 300 tonnes of trays move from EUR 21,000 to EUR 62,400 on a classification alone.

Reporting follows the expected annual fee. ARA’s terms require monthly reports above EUR 20,000 a year, quarterly reports from EUR 1,500 to EUR 20,000 and an annual report below EUR 1,500, the same thresholds as § 9(2) Z 4 of the ordinance (AGB IX.1). Monthly and quarterly reports are due on the 15th of the month after the period and payable on the 15th of the month after that; the annual report is due on 15 January and payable on 15 February (AGB VIII.5). A partner placing no more than 1,500 kg of household and 1,500 kg of commercial packaging a year can pay the EUR 150 flat fee instead (AGB XVII.1). Under-reporting found in an audit above the 5% thresholds draws a contractual penalty of 20% of the shortfall, from EUR 50 for periods from 1 January 2024 (AGB XIII.7).

Who must join, and the systems on offer

The obligation sits with the Primärverpflichteter. § 8(1) of the Verpackungsverordnung requires a party placing household packaging on the market to join an approved household system and sign the contract within two months, and § 8(2) lets an upstream stage take over the duty if it gives a binding declaration that is kept for at least seven years (VerpackVO 2014). The ministry’s PPWR note of 10 June 2026 says the § 13g participation duty is unchanged for now, treats the filler or packer as the usual producer of sales packaging, and lets a supplier in Austria take the role for a micro-enterprise client under Article 3(1)(14)(b) of Regulation (EU) 2025/40 (BMLUK Merkblatt).

ARA is not the only choice. The ministry’s list names six systems licensed for household packaging and five for commercial packaging (Exhibit 5). Systems compete for contracts, and collected household material is split among them by market share. The Verpackungskoordinierungsstelle (VKS) coordinates and audits them: in its 2025 report it selected about 1,085 participants for checks of their 2024 quantity reports, about 59% of them on site, and received EUR 227,299.92 in penalties transferred by the systems (VKS Leistungsbericht 2025).

ARA’s 2026 sheet still prints a household glass code at EUR 0.108 per kg, while the ministry list licenses household glass to AGR. SPI has not yet confirmed the contract route by which ARA customers’ glass reaches AGR, so this piece uses ARA’s published rate as the price a licence partner pays.

PPWR adds one change to scope from 12 August 2026: single-portion coffee and tea units count as packaging, and the ministry requires system participation for them from 1 October 2026, with aluminium capsules under aluminium household and plastic capsules under 95% plastic by weight under composites, pending a separate tariff category in a planned AWG amendment (BMLUK Merkblatt). Austria’s tracker entry for the deposit is PR-AT-001; the PPWR itself is PR-EU-001.

The deposit system's fees, deposit and rules

Recycling Pfand Österreich charges first placers, the fillers and importers that first place a filled container on the Austrian market, including mail-order sellers without an Austrian seat (PR-AT-001). They register themselves and each container type in the EWP portal, mark each container with the deposit logo and a readable barcode, report quantities monthly, and pay the deposit and the producer contribution (Für Unternehmen; Produzenten-Handbuch v5).

The fee is set by material, at least once a year, and may not be negative. Its calculation nets registration fees, material revenue and unredeemed deposits against handling fees for retailers, collection, sorting, counting and transport, and the central body’s own costs, and it takes account of international barcodes and recyclability (Infoblatt Produzentenbeitrag 2026). For 2026 the sheet states that the contribution “bleibt unverändert zum Produzentenbeitrag 2025”.

SPI calculation: the machine handling fee on a returned can, EUR 0.0341, is 3.2 times the producer contribution on that can, and on a plastic bottle EUR 0.0365 is 1.5 times. The gap is closed by unredeemed deposits and material sales, which § 11 of the ordinance leaves with the central body. As return rates climb toward 90%, unredeemed deposits shrink, and producer contributions will have to carry more of the cost; SPI has not seen a Recycling Pfand Österreich forecast of that shift.

The handbook sets two further charges. The international barcode fee is EUR 0.03 per container, paid by the importer for containers sold in Austria or by an Austrian producer for containers sold in the foreign market concerned, and the handbook gives a maximum annual quantity of 500,000 units per international GTIN (Produzenten-Handbuch v5). The second is eco-modulation, which works as a percentage surcharge on the producer contribution by recyclability class (Exhibit 7).

Money flows on a short clock. Recycling Pfand Österreich bills monthly on the first-placing report, which is due in the first five days of the following month, with late reports accepted until the 9th. Its sample invoice shows payment by SEPA direct debit ten days after issue, with the deposit shown as not taxable because it is not payment for a service (Produzenten-Handbuch v5; Infoblatt Verrechnung). For sticker products, deposit and producer fee have been charged after the monthly report since 1 January 2026.

What the two systems report

The deposit system’s first year met the statutory floor. Recycling Pfand Österreich reports a collection rate of 81.5% for 2025, weighted for container weights and an average of 51 days between first sale and return, against the 80% target for 2025; about 2 billion containers were placed on the market and about 1.4 billion returned by 31 December 2025, 51% plastic bottles and 49% cans (Jahresbilanz 2025; press release, 28 January 2026). The ordinance’s next step is 90% by weight from 2027, separately for plastic and metal, two years ahead of the EU’s 2029 date in PR-EU-007.

SPI calculation: about 2 billion containers placed and about 1.4 billion returned in calendar 2025 leave about 0.6 billion containers, or about EUR 150 million at 25 cent, not refunded by year end. Part of that comes back in 2026, given the 51-day average lag, so it is an upper bound on unredeemed deposits rather than the operator’s figure, which SPI has not yet confirmed.

ARA’s year shows the other side. Its General Assembly handout of 17 June 2026 lists the “Verlust von Lizenzeinnahmen durch Entfall der pfandpflichtigen GetränkeVP” among its 2026 challenges, and its May 2026 release says collection in the yellow bag and bin rose 7% in 2025 for packaging outside the deposit and that ARA provided 607,000 tonnes of secondary raw materials, 103,000 tonnes of them light packaging and metals. The release’s dateline reads 18 May 2025, while its file name and its 2025 results date it to May 2026.

Four kinds of drinks pack in Austria

SPI groups a drinks brand’s packaging into four archetypes by which system charges it and what moves the charge (Exhibit 9). The device is drawn from the two fee tables, the deposit ordinance and § 6a of the packaging ordinance, and it tells a packaging team where each design or sourcing decision lands.

Archetype A rewards fewer, larger and more recyclable units. A 1.5 litre PET bottle pays the same EUR 0.0245 as a 500 ml one, so at SPI’s assumed weights its fee per kg is EUR 0.64 against EUR 1.02. Lightweighting a can saves nothing in deposit fees; moving a bottle from a 60% surcharge class to class A saves EUR 0.0147 per unit.

Archetype B rewards weight reduction. A 200 g glass bottle costs EUR 0.0216 in ARA household glass fees, close to the EUR 0.0245 deposit fee on a PET bottle, while a 30 g carton at EUR 1.02 per kg costs EUR 0.0306.

Archetype C is the easiest to miss. A brand that adds a dairy drink in PET or a 5 litre water bottle falls back into ARA on the household plastic line and must report it there, at EUR 1.04 per kg.

Archetype D is where classification money sits. Shrink film on a six-pack that goes home with the shopper is household plastic at EUR 1.04 per kg; the stretch foil on the pallet is commercial foil at EUR 0.18.

Worked example: one drinks brand, two systems

SPI priced a hypothetical Austrian soft drinks filler that places 40 million deposit containers and 896 tonnes of other packaging a year (Exhibit 10). Unit counts and weights are SPI assumptions for illustration, not industry averages; rates are ARA’s published 2026 rates and Recycling Pfand Österreich’s 2026 producer contributions, with all containers in surcharge-free classes and on Austrian barcodes. Everything is in euros.

SPI calculation: deposit fees are 20,000,000 x 0.0107 + 15,000,000 x 0.0245 + 5,000,000 x 0.0245 = EUR 704,000. The ARA bill is 400,000 x 0.108 + 90,000 x 1.02 + 4,000 x 0.45 + 2,000 x 0.208 + 60,000 x 1.04 + 300,000 x 0.07 + 40,000 x 0.18 = EUR 227,816, in kg. Combined, EUR 931,816 on 1,706 tonnes, of which ARA is 24.4%. Household lines are EUR 199,616, or 87.6% of the ARA bill, on 556 of its 896 tonnes. On ARA’s 2025 rates the ARA bill would have been EUR 217,880, so the 2026 step adds 4.6%; on the 2027 sheet it is unchanged.

The deposit sits on top, as cash rather than cost. The brand charges its trade customers 40,000,000 x 0.25 = EUR 10,000,000 a year in deposits and passes the same amount to the central body on its monthly invoice. The cost is the timing gap between paying the central body ten days after the invoice and collecting from retailers on their own terms. The deposit return piece sets that cash flow out for Austria and its neighbours, and the Germany piece covers the German single-use deposit next door.

Scenarios: how the bill moves

SPI ran four cases on the example, in euros only (Exhibit 12). ARA moves only between 2025 and 2026 rates, since the 2027 sheet holds every rate. On the deposit side, the levers are the recyclability surcharge and the international barcode fee; the producer contribution itself is held at the 2026 level, because SPI has not yet confirmed any 2027 figure.

Recyclability drives the high case. A 30% surcharge on 20 million PET bottles adds EUR 147,000, a 10% surcharge on 20 million cans adds EUR 21,400, and 2 million units on international barcodes add EUR 60,000. With 99.5% of deposit packaging rated recyclable in March 2026, the stress case is unlikely for the market as a whole, but a single brand with sleeves or problem closures can sit in it.

On the ARA side, glass and cartons are the lines to watch. At EUR 0.108 per kg the 400 tonnes of glass cost EUR 43,200; each further 0.006 step, the size of the 2026 rise, would add EUR 2,400. Cartons are the largest ARA line at EUR 91,800, and a 5% step like 2026’s would add about EUR 4,600.

The calendar both systems run on

The two systems report on different clocks. The central body takes first-placing reports every month within five days, while ARA takes monthly, quarterly or annual reports by fee size, due on the 15th (Produzenten-Handbuch v5; ARA AGB VIII.5). The dates that matter to a drinks brand are set out in Exhibit 13.

The gaps in this view

Deposit 2027. Recycling Pfand Österreich has published no 2027 producer contribution that SPI has seen, so 2026 rates are carried forward in the scenarios.

Registration fees. The central body’s invoicing sheet lists a registration fee among its charges, but SPI has not yet confirmed its amount.

ARA’s market share. ARA states 73.4% for 2025; its own tonnage chart, which shows 805,653 and 1,126,267 tonnes, gives 71.5% on SPI’s reading of the labels. SPI has not yet confirmed the basis of the stated share.

Penalties. Breaches of the deposit ordinance are administrative offences under § 79 AWG 2002. SPI has not yet confirmed the current euro ranges.

Scope of the example. The portfolio, weights and classifications are SPI assumptions. VAT, the anti-litter contributions and the barcode audit costs are left out unless stated.