BottD - Council Directive 75/107/EEC

What BottD is and why it matters

The Bottles Directive (BottD) — formally Council Directive 75/107/EEC on the approximation of the laws of the Member States relating to bottles used as measuring containers — is the EU rule that lets a glass bottle do double duty as a measuring instrument. Instead of measuring a liquid into a separate measuring vessel and then pouring it into the bottle, a producer can fill the bottle directly to a marked level or up to its brim, because the bottle itself has been made and verified to hold a known, accurate volume. For anyone packing wine, spirits, juice, oils or similar liquids in glass, BottD is the rule that makes that filling method lawful across the whole Union.

BottD matters because it harmonises what would otherwise be twenty-seven different national metrology rules for these bottles. A bottle that meets the Directive carries a distinctive mark — the reverse, or inverted, epsilon resembling a “3” — and that single mark certifies metrological accuracy in every Member State. The practical effect is that a verified measuring-container bottle can move freely across borders without being re-checked, and a filler can rely on the bottle’s geometry rather than measuring each fill.

📄 Official text: Council Directive 75/107/EEC on bottles used as measuring containers — on EUR-Lex →

Who BottD applies to

BottD is aimed primarily at the people who make and place these bottles on the market, but it also matters to everyone who relies on them downstream:

Bottle manufacturers — glassworks and producers who make bottles intended to be used as measuring containers. They carry the core obligations: building bottles to the required accuracy, applying their identification mark, and applying the certifying mark when the conditions are met.
Importers — businesses bringing measuring-container bottles into the EU market, who need to ensure the bottles they place on the market meet the Directive’s requirements and bear the correct marks.
Fillers and packagers — producers of prepackaged liquids who use these bottles as the measuring step in their filling line. They depend on the bottle being a true measuring container, and they operate alongside the EU’s prepackaging rules when they fill and label the product.
Distributors and retailers — those further down the chain who handle the finished prepackaged goods and rely on the marks being present and correct.

The Directive is specifically about bottles used as measuring containers: closed or closable, made of glass or other material with the rigidity and stability giving the same metrological guarantees, and intended to hold, transport or deliver liquids.

Key requirements

BottD defines a measuring-container bottle by the function it performs and the accuracy it guarantees, and then sets out how that accuracy must be built in and marked. The requirements cluster around capacity, tolerance, and marking.

Nominal and brimful capacity

A measuring-container bottle is characterised by two capacities. The nominal capacity is the volume marked on the bottle — the quantity it is intended to contain when filled under the conditions of use it is designed for. The brimful capacity is the volume the bottle holds when filled right up to the level of the top edge. The Directive works with the relationship between these two, because the gap between them — the headspace, or “expansion volume” — together with the bottle’s geometry determines how accurately the bottle measures when filled to a given level or to its brim.

Permitted volume tolerances

Because no bottle is made perfectly, BottD allows the actual capacity to vary from the nominal capacity only within defined maximum permissible errors (tolerances). The tolerance depends on the bottle’s nominal capacity and on how it is intended to be filled — to a fixed mark, or up to the brim. The Directive sets these limits so that the spread of real bottles around the marked value stays small enough for the bottle to serve as a reliable measuring step. Manufacturers must control their production so that the bottles they make stay within those limits, on average and individually, as the Directive prescribes.

Marking and the certifying “3” mark

Every measuring-container bottle covered by BottD carries a defined set of markings, applied so they are legible, indelible and visible under normal conditions:

The nominal capacity and, where required, the brimful capacity, expressed in the prescribed units and form.
The manufacturer’s identification mark — a sign that identifies who made the bottle, registered with and accepted by the competent authorities, so a given bottle can be traced back to its maker.
The reverse epsilon mark — the distinctive sign resembling a “3” (an inverted Greek epsilon, “Ɛ”). This is the mark by which the manufacturer certifies that the bottle satisfies the Directive’s requirements for a measuring container. It is the metrological counterpart to the marks used elsewhere in EU metrology law, and it is what signals to authorities and fillers that the bottle may be used as a measuring container.

How it works alongside the prepackaging rules

BottD does not stand alone. It is designed to operate together with the EU’s prepackaging legislation, which governs the nominal quantities and the permitted shortfalls of the liquid product actually sold to the consumer. A measuring-container bottle gives the filler an accurate vessel; the prepackaging rules govern the quantity of liquid put into it and how that quantity is declared. In practice a filler relies on a BottD-compliant bottle as the measuring instrument and then meets the prepackaging requirements for the finished, filled, labelled product.

Enforcement

BottD is a directive, so each Member State has transposed it into national law and assigns its national metrology and market surveillance authorities to enforce it. Those authorities oversee manufacturers’ identification marks, check that bottles placed on the market meet the capacity and tolerance requirements, and verify that the certifying marks are correctly applied. Bottles found not to conform — wrong capacity, out-of-tolerance, or improperly marked — can be challenged on the market, and the right to use the certifying mark depends on continuing to meet the Directive’s conditions.

In Denmark, the Danish Safety Technology Authority (Sikkerhedsstyrelsen) is the national authority responsible for legal metrology, including measuring instruments and measuring containers. Because the certifying mark is recognised across the Union, a problem identified by one Member State’s authority is relevant to the bottle’s free movement everywhere.

Getting compliant

Confirm whether your bottles are intended to be used as measuring containers, which brings them within BottD’s scope.
Design and produce bottles so their actual capacity stays within the Directive’s permitted tolerances for the relevant nominal capacity and filling method.
Establish and register your manufacturer’s identification mark with the competent authority.
Mark each bottle with its nominal capacity (and brimful capacity where required) in the prescribed form and units.
Apply the reverse epsilon “3” mark only where the bottle genuinely meets the Directive’s requirements.
Coordinate with the prepackaging rules when the bottles are filled, so the finished prepackaged liquid is also compliant.
Keep your production controls and records so you can show conformity to authorities on request.

How Conphora helps

Conphora monitors BottD and maps your bottles against its requirements, flagging gaps in capacity, tolerances, the manufacturer’s identification mark and the certifying “3” mark before they become enforcement problems. The platform helps you generate and keep the right documentation, connects the measuring-container rules to the prepackaging obligations that apply when the bottles are filled, and alerts you when the rules change so your compliance stays current.

See how Conphora works · Start free with Conphora

Sources and further reading

This guide is for general information and is not legal advice.

Last updated: 12 June 2026