compliance teamHow Austria splits household and commercial packaging
Step 1
Inventory both packaging layers
Step 2
Apply the size criterion
Step 3
Assign the product groups
Step 4
Apply the binding shares
| 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 |
Step one: the size criterion
Packaging is household packaging where it has a surface of up to 1.5 m², a nominal volume of up to 5 litres, or is expanded polystyrene of up to 0.15 kg per sales unit, and typically arises in households or comparable collection points such as restaurants, hotels, offices or sports facilities.
Service packaging, carrier bags, refuse sacks, glass and beverage carton packaging are household packaging regardless of size. Commercial packaging covers the remainder, together with paper and cardboard transport packaging, pallets, strapping and adhesive tapes.
Step two: 47 binding product groups
Each item is then assigned to one of 47 product groups, and the group fixes the percentage shares between household and commercial per material. Those shares are binding for every company.
An individual distribution-channel analysis instead of the fixed shares is expressly not permitted. A seller supplying only private consumers therefore does not declare everything as household packaging.
The distance-selling product group
Packaging that a distance seller adds for despatch — cartons, films, bags, cushioning, tapes and other packing means — sits in the distance-selling product group. The packaging of the goods themselves, including their original transport packaging, always stays in the product group of those goods.
So a complete file inventories two layers. In the distance-selling group, corrugated transport cartons split 92% household paper and 8% commercial paper; plastic bags and cushioning that meet the size criterion split 93% household plastic and 7% commercial film; composite air-cushion mailers split 96% and 4%; plastic adhesive tape splits 91% and 9%.
Why applying it properly matters
Commercial tariffs are several times lower than household tariffs, so the shares change the bill materially. Applying them is not optimisation; it is the required method.
It also changes whether a low-volume flat tariff is available at all, because the 1,500 kg test is measured on the household mass after allocation rather than on gross tonnage.
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.