Who must register for packaging EPR in Romania, and how
Producers register in the National Register of Producers held by the AFM (Environmental Fund Administration) and, in practice, transfer responsibility to a licensed OIREP / PRO such as Eco-Rom Ambalaje. There is no de-minimis — every producer, importer and distance seller is obliged regardless of volume. Non-Romanian companies must appoint a Romanian representative / fiscal agent. A 2 lei/kg Environmental Fund contribution applies on any target shortfall.
This is general information about Regulation (EU) 2025/40 and Romania'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.
| Register / authority | National Register of Producers, held by AFM (Environmental Fund Administration) |
|---|---|
| PRO / compliance scheme | An OIREP / PRO (e.g. Eco-Rom Ambalaje) |
| Authorised Representative | Yes Required for non-established producers |
| De-minimis threshold | None — obliged regardless of volume |
| National instrument | GEO 196/2005 on the Environmental Fund (as amended) |
The register and what it involves
Producers register in the National Register of Producers held by the Administrația Fondului pentru Mediu (AFM — Environmental Fund Administration). The governing law is GEO 196/2005 on the Environmental Fund, as amended (notably GEO 125/2022).
You register with AFM, submit baseline packaging data, and either comply individually or (in practice, almost always) transfer responsibility to a licensed OIREP / PRO (e.g. Eco-Rom Ambalaje). The eco-contribution (Green Dot) is paid to the PRO; residual obligations settle with AFM.
The Authorised Representative rule
Non-Romanian companies must appoint a Romanian representative / fiscal agent — a local legal entity legally accountable for reporting and payments, typically the entity signing the PRO contract.
De-minimis: none
There is no de-minimis — every producer, importer and distance seller is obliged regardless of volume; there is no minimum-tonnage exemption.
Reporting, penalties and the 2 lei/kg contribution
Reporting is monthly or quarterly (packaging introduced by material and recovery achieved via the PRO), plus an annual statement by February. The Environmental Fund penalty is a well-attested 2 lei/kg on the shortfall between the recovery target (a 60% global objective) and the amount actually achieved, paid to AFM. Late or missing declarations are reported at 1,000–5,000 lei (single-source).
How onerous is it?
High. No de-minimis, a mandatory local representative, frequent (monthly/quarterly) reporting, plus a hard financial contribution if recovery targets are missed.
Get Romania mapped alongside every other market you sell into
The report takes your packaging profile and returns the obligations that apply to you under Regulation (EU) 2025/40 — the EU-wide product duties plus the per-country EPR registration, PRO and Authorised-Representative steps — each cited to its article, with the deadline.
Get my full PPWR obligations report →Frequently asked questions
Does Romania have a small-volume exemption?
No. There is no de-minimis — every producer, importer and distance seller is obliged regardless of volume, with no minimum-tonnage exemption.
What is the 2 lei/kg contribution?
It is the Environmental Fund penalty contribution: 2 lei per kilogram on the shortfall between the recovery target (a 60% global objective) and the amount actually achieved, paid to AFM. It is a well-attested figure, distinct from the eco-contribution paid to your PRO.
Do foreign companies need a representative in Romania?
Yes — non-Romanian companies must appoint a Romanian representative / fiscal agent, a local legal entity legally accountable for reporting and payments, typically the entity that signs the PRO contract.
Sources
- Romania EPR — AFM register, the OIREP/PRO route and the 2 lei/kg contribution — https://vatcompliance.co/guides/epr/romania/
- Romania packaging EPR — no de-minimis, all producers obliged — https://www.complymarket.com/en/services/romania-packaging-epr
- Regulation (EU) 2025/40 — Authorised Representative from 12 August 2026 (Art. 45) — https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng