Compliance
Packaging tax: cost per machine explained
Term from the vending glossary
Packaging tax is a municipal levy on single-use containers for food and beverages for takeaway that individual German cities have independently collected since 2022. The operator who first places the single-use container in circulation is liable for tax; reusable containers are explicitly exempt in all ordinances enacted to date.
Who pays, who is exempt?
The party liable for tax is whoever first places the single-use container in circulation: for a hot-beverage machine, that is the operator, not the end user. Reusable cups and containers are explicitly exempt in all ordinances enacted to date.
What is the cost per machine?
In Tübingen, the first German city with a municipal packaging tax (ordinance effective 1 January 2022), the levy is €0.50 per single-use cup (Manufacturer statement, Tübingen ordinance). At 50 vends per day and 250 working days per year, this amounts to €6,250 additional cost per machine per year. At many sites, this exceeds the annual service fee and therefore represents a significant line item in operating cost calculations.
Legal classification
The Federal Administrative Court confirmed in April 2023 (case no. 9 CN 2.22) that municipal packaging taxes are compatible with the German Constitution provided they do not conflict with the federal Packaging Act (VerpackG). The ruling is considered precedential; additional municipalities have since reviewed or enacted their own ordinances.
Options for operators
Three approaches reduce or eliminate the tax liability:
- Introduce a reusable container system (e.g. ReCup or recircle): issuing a deposit cup is not subject to tax.
- Configure a bring-your-own-cup discount: users who do not take a single-use cup incur no tax liability.
- Site selection: the tax applies exclusively within the municipal territory of the collecting city.
Operators who pursue none of these options either incorporate the levy into the vend price or itemise it separately. Both approaches require adjustment of the price tables in the machine management system.