compliance teamWho needs an Austrian authorised representative?
Step 1
Record entity and establishment
Step 2
Separate each sales channel
Step 3
Apply the duty per flow
Step 4
Document exclusions and carve-outs
| 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 |
Distance selling to private consumers
A seller without an Austrian seat or establishment that hands packaged goods to private consumers in Austria through distance selling is the party first placing that packaging on the market, and has to appoint an authorised representative.
The duty is written around the absence of an Austrian establishment rather than the seller's country of origin, so sellers based outside the EU are addressed on the same basis. Confirm the position for your entity rather than assuming it.
Supply to Austrian business customers
Where an Austrian business imports or buys the packaged goods and resells or distributes them as supplied, the duty normally sits with that Austrian party rather than with the foreign supplier.
A voluntary appointment is available to a foreign seller supplying business customers, which can be useful where customers ask for a declaration covering the packaging you supply. That is an option, not an obligation.
Mixed channels and carve-outs
A mixed file is judged flow by flow. A consumer share triggers the duty regardless of how small it is, because Austria has no de-minimis threshold.
Deposit-bearing single-use beverage containers are carved out of several packaging duties and run through the separate deposit system, while the rest of the packaging around them is unaffected. Treat that as a scoping question rather than an exemption.
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.