Identify the producer
Map the selling entity, establishment, contract, marketplace and importer for each sales flow.
Regulation (EU) 2025/40 · applies now
Connect the staged EU rules to Austria’s operative national route.
Regulation (EU) 2025/40 has applied in stages since 12 August 2026. In Austria the national duties remain the operative ones: a distance seller without an Austrian seat appoints one authorised representative, is entered in the national register and licenses through an approved collection and recovery system.
Rules in force · indicative scope only · no authority or marketplace outcome guaranteed
Whether the statutory appointment applies turns on the absence of an Austrian seat or establishment rather than on the seller’s country of origin. A company outside the EU is addressed on the same basis, and the position should be confirmed for the entity rather than assumed.
Keep mandate, membership, declarations and labels distinct.
Document the PPWR mandate
The written mandate is for EPR representation. It is not fiscal representation and does not make the service provider a PRO.
Register, appoint and license
The register data, the system contract, the allocation applied and the annual report each need their own evidence trail.
Check the packaging
Material marking is optional in Austria, while single-use plastic marking and deposit obligations are assessed separately from licensing and marketplace checks.
Route matrix
“B2B” is not enough information.
An Austrian file separates the delivery country, the sales route and the recipient before drawing a conclusion. Each row below leads to a different review, not to a different marketing label.
Marketplace sale into Austria
Marketplace operators must ensure the sellers they host comply and exclude those they cannot verify. The storefront does not decide the duty; the Austrian delivery address does.
Own webshop — direct sale
An own web store carries the same Austrian appointment and licensing duty, with no platform prompt and the same two-month participation deadline.
Direct Austrian business end user
Do not label this automatically as an importer or reseller sale. A professional buyer that uses rather than resells the goods leaves the allocation open and needs review.
Austrian importer or reseller
Distinguish this route from a direct sale to an end user. Where the Austrian buyer places the goods on the market as supplied, that buyer generally carries the duty; a voluntary appointment can still be reviewed.
Austrian establishment
The entity registers and licenses itself and cannot use the distance-selling appointment route.
Mixed channels
Separate every flow. A reseller share can move responsibility to Austrian buyers while direct and marketplace shares follow different routes.
What to prepare now
Build one evidence chain per selling entity and route.
- 01
Confirm the seller
Legal entity, establishment, contracts and importer of record.
- 02
Map each route
Marketplace, own webshop, end-user and reseller flows kept separate.
- 03
Classify packaging
Annual grams by item, product-group assignment and the binding household and commercial shares.
- 04
Choose procedure
Ordinary or an eligible simplified import procedure for the calendar year.
- 05
Keep evidence current
Mandate, register identifier, participant number, reports and system invoices reconciled.
Indicative packaging service references
Marketplace Starter €399 first year / €299 renewal · Standard €474/year + €150 setup
Licence tariffs, notary or authority fees, VAT and third-party costs remain separate. Starter eligibility and every service scope require a written human review.
Establishment, not origin
Keep the establishment fact and the sales route as separate reviews.
The Austrian appointment duty is written around the absence of an Austrian seat or establishment rather than the seller’s country of origin, so a company outside the EU is addressed on the same basis. Confirm the establishment position for the entity before relying on any general statement.
Questions about PPWR and the Austrian route
Did PPWR replace the Austrian packaging route?
No. The Austrian national duties remain operative during the transition, and the ministry has announced further amendments rather than a replacement.
Does PPWR replace the appointment or the system contract?
No. The Austrian appointment, register entry, system contract and annual report continue to be assessed on their own terms.
Is the duty different for an own web store?
No. The appointment and licensing duties apply to distance selling regardless of whether the order came through a marketplace or your own store.
Does the duty depend on my country of origin?
The Austrian duty is written around the absence of an Austrian seat or establishment rather than the seller’s country of origin. Confirm the position for your entity.
Is every business sale an Austrian importer route?
No. A purchase by an Austrian importer or reseller that places the goods on the market as supplied is distinguished from a direct sale to a business end user.
Does a low tariff estimate remove every obligation?
No. Austria has no de-minimis threshold. A low volume can qualify for a flat annual system tariff, but the register entry, the appointment and the annual report remain due.
Can you guarantee a marketplace result?
No. We can prepare evidence for an agreed scope; Amazon and other marketplaces apply their own current fields, review and account decisions.
Primary sources · reviewed August 2026
- Regulation (EU) 2025/40 — EUR-Lex
- Austrian Waste Management Act 2002 — RIS
- Packaging Ordinance 2014 — RIS
- BMLUK — factsheet on the EU Packaging Regulation
- USP — authorised representatives for packaging
General information only, not legal advice or an authority decision. Product, contract, marketplace and procedural facts require individual review.
Map the Austrian route before presenting evidence to a marketplace.
One scope first; any work, price and timeline confirmed separately in writing.