Just looking at the raw numbers from a German PoV, that is in line with our minimum vacation days (4 weeks * 5 workdays/week + 9 to 12 holidays depending on state, if a public holiday falls on a weekend, it is not not "made up later"). So for me that sounds fair and at the lower end, especially if you have negotiation potential. I am stating this to make my bias clear.
I found your reply coming across fairly harsh. I think this is because we might have different interpretations of what PTO is. For me PTO is part of the compensation for doing my work. In essence, I am not getting paid to do nothing. I get paid less raw money for working, in exchange for more flexibility and less time at work. PTO is reducing my average work hours per week, just taken in bigger chunks at once rather than working a little bit less each day. I think you can also express more PTO as an increase in hourly compensation, but of course with additional implications.
Whether the mandated minimums or any amount of PTO are fitting or not is a different discussion. I think having time you can plan yourself is important. Overall, I think we should strive to work to live and not live to work. At what amount of PTO, compensation, work hours and working conditions you draw your personal line is, in my opinion, very subjective and not necessarily related to job dissatisfaction.
P.S. One extreme example for time/money trade-off I have seen, is someone who works 100%, but gets paid 2/3. In exchange he takes an entire year off every 2 years while maintaining his salary during that time. It works out, roughly, to the same hourly wage, but with more flexibility.