Who must register for packaging EPR in Romania, and how

Brought up to date against Romanian law on 29 September 2026. 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.

The register and what it involves

The packaging rules sit in Law 249/2015 on packaging; Environmental Fund contributions are set by Government Emergency Ordinance (OUG) 196/2005. You register with the Administrația Fondului pentru Mediu (AFM, Environmental Fund Administration) by filing your first declaration, and you report annually to the territorial environmental protection agency (APM).

You can meet the recovery obligations yourself or transfer them to a licensed OIREP (e.g. Eco-Rom Ambalaje), which you pay to arrange collection and recycling on your behalf. How often you file Environmental Fund declarations depends on your situation, so confirm the cadence with AFM before your first filing.

The Authorised Representative rule

Art. 16 of Law 249/2015 names the operators with packaging obligations and contains no requirement to appoint a Romanian representative that we could locate. Whether another provision requires one from distance sellers is unconfirmed, so check with AFM before you rely on going without. Some guides tell every foreign firm to appoint a Romanian representative or fiscal agent; we could not tie that to the law.

EU law is the firmer trigger. Since 12 August 2026, Article 45(3) of Regulation (EU) 2025/40 has required a producer that makes packaging available directly to end users in a member state where it is not established to appoint an authorised representative for EPR there, and that includes EU-based producers selling cross-border into Romania. If you supply Romanian resellers who pass the goods on unchanged, you are not the producer in Romania and Article 45(3) does not catch you. A proposal to suspend Article 45(3) until 2035, COM(2025) 982, stalled when the Council ended negotiations on it in April 2026 and left it out of its 24 June 2026 mandate; the rule applies now.

De-minimis: none found

Art. 16 of Law 249/2015 sets no volume floor that we could find, so plan on being obliged from your first shipment, and confirm with AFM if your quantities are very small.

Reporting and the 2 lei/kg contribution

You report annually to the territorial APM; confirm with AFM how often you must file Environmental Fund declarations. Under OUG 196/2005, a contribution of 2 lei/kg is paid to the Environmental Fund on the shortfall between the annual recovery targets and the quantity actually recovered.

How onerous is it?

High. There is no volume floor, a 2 lei/kg contribution falls due on any shortfall against the recovery targets, and the declaration cadence has to be settled with AFM before your first filing. The representative question is lighter than often described: Romanian law adds no mandate that we could locate, and Article 45(3) reaches you only if you sell direct to Romanian end users.

Frequently asked questions