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FAQs

Austrian EPR, explained carefully.

Common questions from non-resident businesses about Austrian Extended Producer Responsibility, answered with sources and clear limits.

What is packaging EPR in Austria?

Austrian packaging EPR allocates responsibility for packaging placed on the Austrian market. A foreign distance seller normally needs an Austrian authorised representative, an entry in the national register, a contract with an approved collection and recovery system, and annual quantity reporting that matches the responsible legal entity and sales channel.

Who is responsible when a foreign seller supplies Austria?

It depends on the entity, establishment, customer and route. A distance seller shipping to Austrian private consumers is treated as the party first placing the packaging on the market. Where an Austrian business imports the goods for resale as supplied, the duty normally sits with that Austrian party instead. Mixed channels require a flow-by-flow review.

Does my German packaging registration cover Austria?

No. Austria maintains its own register, its own approved systems and its own representative requirement. A German registration is not read across the border, and the duty follows the customer’s delivery country rather than the marketplace domain you sell on.

Do I have to appoint an Austrian authorised representative?

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. The representative assumes the seller’s packaging obligations. Confirm the position for your entity before relying on any general statement.

Can I register and license myself instead?

Since 2023 a distance seller without an Austrian seat is not able to carry out the licensing itself. The register data and the system contract run through the appointed representative.

Is this the same as a fiscal or VAT representative?

No. This is a waste-law appointment under the packaging rules. It is not a fiscal or tax representative and does not by itself create an Austrian VAT position for the seller.

What does the appointment require?

The representative must be established in Austria with a domestic delivery address and must be answerable under Austrian administrative law. The appointment is made by an authenticated power of attorney in German or English that states the scope, the representative’s express consent to assume the obligations and the right to conclude binding contracts.

Does the signature have to be notarised?

The signature on the power of attorney has to be authenticated, by a notary or a competent sealing authority. Only the signature is authenticated rather than the whole document, and the certification must be in German or English. No apostille requirement was identified in the sources reviewed; practice outside the EEA should be confirmed for your jurisdiction.

When does an appointment take effect?

An appointment, a change or a termination can only take effect at the end of a calendar quarter. If a mandate lapses within a quarter, the seller has to ensure the obligations continue without a gap through a new representative.

Which Austrian numbers exist for packaging?

Two identifiers with different origins. The register entry produces a Global Location Number, and the contract with a collection and recovery system produces a separate participant number assigned by the coordination body. Neither is created by epraustria.com, and neither should be presented as an electrical equipment or battery registration.

How many collection and recovery systems can I choose from?

Six systems are approved for packaging. Their published household tariffs differ materially, so the choice is a calculation on your own material mix. This site compares the systems whose 2026 tariff sheets are published in a machine-readable form and names which ones were reviewed.

Is there a small-seller exemption in Austria?

No. Austria has no de-minimis threshold, and the earlier small-quantity regime expired on 31 December 2022. Where household packaging stays at or below 1,500 kg per calendar year a system may offer a flat annual tariff, but that is a tariff a system offers and not a legal exemption. Registration, appointment and reporting duties remain.

Is the flat annual tariff always the cheapest option?

No. One reviewed system bills tariff-based volumes against an annual minimum that is lower than the flat tariff, so at very small volumes the minimum can be cheaper and at larger volumes the flat tariff wins until the 1,500 kg ceiling. All three should be compared rather than assumed.

Why is some of my packaging classed as commercial?

Austrian law sets the household and commercial split by ordinance across 47 product groups, applied after a size criterion. The shares are binding for every company and an individual distribution-channel analysis is expressly not permitted, so a pure consumer seller does not declare everything as household packaging.

How is shipping packaging classified?

Cartons, films, bags, cushioning and tapes added for despatch fall in the distance-selling product group, while the packaging of the goods themselves stays in the product group of those goods. A complete file therefore inventories two layers rather than one.

When is packaging data reported?

The reporting class follows the expected annual licence fee across all tariff categories: annual up to €1,500, quarterly between €1,500 and €20,000 and monthly above that. The annual data set is due by 15 March for the preceding calendar year. Records are kept for at least seven years.

What is a system participant check?

The Austrian coordination body can check participants on the completeness and accuracy of their quantity reports, in practice through an external auditor comparing declared masses against actual deliveries. Reported figures should therefore be reconcilable to despatch data.

What happens if earlier years were never licensed?

Earlier quantities can normally be declared and settled with a system, and doing so before a check begins is usually less costly than afterwards. An appointment takes effect prospectively and does not by itself resolve the past. We scope remediation explicitly rather than folding it into a current-year file.

What are the penalties?

Breaches of the packaging rules carry administrative fines of €450 to €8,400, and purely procedural reporting breaches up to €3,400. On a final penalty the authority additionally claims the cost of the inspection and, except for pure reporting breaches, up to double the licensing cost avoided. Figures circulating elsewhere that quote much higher packaging fines were not supported by the statutory text reviewed.

Can a marketplace remove my listings?

Operators of electronic marketplaces are obliged to ensure that the sellers they host meet the applicable duties and to exclude those they cannot verify. Fulfilment providers face an equivalent duty to stop the service. The decision and its timing remain with the platform or provider.

Does Austria require environmental labelling on packaging?

Material marking is optional, though where the codes are used no alternative numbering is permitted. Separate marking duties do apply to listed single-use plastic products and to deposit-bearing beverage containers.

I sell beverages in cans or plastic bottles. What changes?

Single-use plastic and metal beverage containers between 0.1 and 3 litres fall under the Austrian deposit system, which has its own registration and reporting through the central body. Deposit-bearing containers are carved out of certain packaging duties, while your other packaging is unaffected. This is reviewed individually rather than assumed.

What about electrical equipment and batteries?

They are separate registrations with their own coordination body, system participation and representative requirements. No packaging identifier should be presented as covering them, and nothing in a packaging tariff table is used to price them.

What role can epraustria.com perform?

This site is a public information service with indicative calculations and a free scope review. A separately contracted service may prepare the appointment file, coordinate the register data and the system contract, and support recurring reporting. It is not a collection and recovery system, creates no Austrian tax position and is not affiliated with any Austrian body.

Can you guarantee registration, timing or marketplace acceptance?

No. The ministry, the coordination body, each system and each marketplace make their own decisions on their own timelines, and an appointment takes effect only at the end of a calendar quarter.

Where these answers come from. The answers draw on Austrian waste and packaging legislation, ministry and coordination-body guidance, published 2026 system tariffs and applicable EU regulations. They are general information, not legal advice or a third-party decision. Last reviewed: 14 August 2026.