Who must register for packaging EPR in Austria, and how

Checked against the AWG 2002 and the Verpackungsverordnung 2014 on 29 September 2026. This is general information about Regulation (EU) 2025/40 and Austria's national EPR scheme, not legal advice. Thresholds, fees, penalty amounts and go-live dates come from national law and PRO schedules that change: treat every figure as needing a fresh check, and confirm anything you act on with the national authority or qualified counsel.

The register and what it involves

Packaging EPR sits under the Abfallwirtschaftsgesetz 2002 (AWG 2002, § 13g) and the Verpackungsverordnung 2014 (VVO, §§ 16a to 16e). Producers register and report through the federal EDM (Elektronisches Datenmanagement) portal operated by the Umweltbundesamt; VKS GmbH (Verpackungskoordinierungsstelle) is the packaging coordination body. Note a common error: the packaging register is not run by the EAK, which handles WEEE and batteries under a separate regime.

A producer must join a Sammel- und Verwertungssystem (collection-and-recovery system), e.g. ARA, Interzero or Reclay, sign a licence agreement and pay a licence fee by packaging type and quantity; the system uploads participant data to the register.

The Authorised Representative: mandatory for distance sellers to consumers

Since 1 January 2023, a distance seller with no seat or establishment in Austria that sells packaged goods to private consumers must appoint an Austrian-established Authorised Representative, by certified power of attorney in German or English, to carry out its EPR duties. There is no volume exemption: it applies from the first unit.

A seller established in another EU member state that supplies business customers in Austria may appoint one: § 16a VVO 2014 says "können" (may). Since 12 August 2026, though, Art. 45(3) of Regulation (EU) 2025/40 requires an Authorised Representative from any producer not established in Austria that supplies Austrian end users directly, and that now covers professional end users too. Supplying Austrian distributors who resell your goods unchanged does not make you the producer there under the PPWR. A proposal to suspend Art. 45(3) has stalled since the Council ended negotiations on it in April 2026 and left it out of its 24 June 2026 mandate.

De-minimis: none (1,500 kg flat-rate relief)

There is no exemption. Systems offer a flat-rate contract, with simplified reporting, to a producer placing no more than 1,500 kg of household packaging and no more than 1,500 kg of commercial packaging a year. That is a relief, not an exemption: you still take part in a system, and a distance seller to Austrian consumers still needs its Authorised Representative.

Reporting and penalties

The statutory annual deadline is 15 March for the previous calendar year; reporting to a system can run annually, quarterly or monthly depending on the fee level. Reporting is by weight and tariff category, split household versus commercial. Breaches are administrative offences under § 79 AWG 2002, fined per offence: check the current bands in the statute before relying on any figure. A single-use deposit of €0.25 on plastic and metal drinks containers has run since 1 January 2025, separately from packaging licensing.

How onerous is it?

Moderate. A domestic producer joins one system (ARA or another) and files one annual report. A seller shipping to Austrian consumers from abroad has an extra step before the first sale: an Austrian-established Authorised Representative, appointed by certified power of attorney, with no volume exemption. Since 12 August 2026, direct supply to Austrian business end users needs one too, under Art. 45(3).

Frequently asked questions