compliance teamEPR in Austria: a practical guide for foreign sellers
Step 1
Map the entity and delivery country
Step 2
Prepare the representative appointment
Step 3
Allocate packaging and contract a system
Step 4
Maintain data, invoices and the annual report
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Start with the entity and the delivery country
Austrian packaging duty is not decided by a brand, a warehouse or a storefront. Record the selling entity, its establishment, the customer and the route by which the packaged goods reach an Austrian address.
There is no separate Austrian marketplace storefront, so a seller can be fully in scope while never having seen an Austrian domain. The delivery address is the trigger.
The appointment comes before the licence
A distance seller without an Austrian seat or establishment has to appoint one authorised representative established in Austria for packaging placed on the market from 1 January 2023, and cannot carry out the licensing itself.
That sequencing matters. The register data and the collection and recovery system contract both run through the appointed representative, so a file that starts with a system enquiry usually has to restart.
Two identifiers, from two different bodies
The register entry produces a Global Location Number. The contract with an approved collection and recovery system produces a separate participant number assigned by the coordination body.
Keep them apart in your records and in anything you upload to a platform. Neither identifier covers electrical equipment or batteries, which are separate registrations entirely.
Allocate the packaging, then report once a year
Every packaging item is split between household and commercial using a size criterion and binding product-group shares before any tariff applies. Declaring everything as household is both incorrect and usually more expensive.
The annual data set is due by 15 March for the preceding calendar year, and the reporting class follows the expected annual licence fee rather than tonnage. Records are kept for at least seven years.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. The ministry, the coordination body, collection and recovery systems and marketplaces control their own procedures, timing and decisions.