compliance teamThe 1,500 kg flat tariff is not an exemption
Step 1
Allocate to get the household mass
Step 2
Test the flat-tariff ceiling
Step 3
Price minimum, tariff and flat options
Step 4
Record the basis chosen
| 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 |
There is no de-minimis threshold
The earlier small-quantity regime expired on 31 December 2022. Since then there is no volume below which the Austrian registration, appointment and reporting duties fall away.
Anything that describes a tonnage as making a seller exempt is describing a regime that no longer exists. Volume changes the price, not the duty.
What the flat tariff actually is
Where no more than 1,500 kg of household packaging is placed on the market in a calendar year, a collection and recovery system may offer a flat annual solution, priced at €150 on both reviewed cards, and it replaces the detailed annual quantity report.
A separately worded allowance exists for commercial packaging on the same 1,500 kg basis. Whether one flat charge covers both buckets or each is charged separately is not settled in the public wording, so a conservative reading is the safer basis for a quote.
It is not automatically the cheapest
One reviewed system bills tariff-based volumes against an annual minimum of €90. Below roughly 433 kg of household paper the minimum is cheaper than the €150 flat tariff; between roughly 433 and 721 kg plain tariff billing sits between the two; above roughly 721 kg the flat tariff wins until the 1,500 kg ceiling.
Above the ceiling the flat tariff is unavailable and per-kilogram billing resumes. All three should be priced rather than defaulting to the flat option because it sounds simpler.
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.