Austria — packaging EPR

Does it apply to me?

Austria's packaging obligations attach to whoever first places packaging on the Austrian market. For a distance seller that means: if an Austrian consumer orders from you and a parcel crosses the border with your packaging around it, you placed that packaging on the Austrian market.

You sell to Austrian private consumers, no Austrian seat

Yes — and you must appoint a representative. Mandatory since 1 January 2023.

You sell only to Austrian businesses (B2B)

Different regime. Appointing a representative is optional for sellers established in the EU/EEA supplying non-private end users.

You have an Austrian seat or branch

You register and license yourself, in the normal way. No representative needed.

You sell only through a marketplace

Check the marketplace's terms before assuming you're covered. Since 12 August 2026 Art. 45(6) PPWR requires the platform to obtain your registration number and a self-certification before letting you sell — so it will ask you for one rather than supply it. A platform may pay your EPR fees under written mandate (Art. 45(4)), but it cannot do your registration or reporting unless you appoint it as your representative.

The representative — the thing that surprises people

In Germany, registration is a strictly personal duty and nobody may do it for you. Austria took the opposite route: a foreign distance seller cannot discharge these duties alone, and cannot sign up to an Austrian scheme directly for consumer sales. You appoint a Bevollmächtigter — an authorised representative — and they carry the obligations.

Legal basis

§§ 16a–16e Verpackungsverordnung 2014 together with the AWG 2002. The duty to appoint sits at § 12b Abs. 1 AWG 2002. Since 12 August 2026 the same duty also arrives directly from Art. 45(3) PPWR, which needs no national implementation to bite.

In force since

1 January 2023 under Austrian law — three and a half years before the PPWR. Austria did not wait, which is why nothing changed here on 12 August while Germany's world turned over.

Who can be one

A natural or legal person with a seat in Austria and a domestic delivery address.

What they take on

All of your obligations under the AWG and the Packaging Ordinance — licensing, the mass notifications, and dealing with the authorities.

Form of appointment

A notarially certified power of attorney, in German or English, stating the scope, your explicit consent, and their authority to contract on your behalf.

Can you do it yourself instead?

No — not for sales to private consumers without an Austrian establishment.

Why this matters for a buying group. Where the law forces every foreign seller through a representative, the representative's fee is a genuine common cost — the same service, bought a hundred times over at retail. That is exactly the kind of line KontorBund exists to negotiate once.

How you actually get registered

You don't touch most of this yourself — your representative does. It's here so you can tell whether a provider is doing the job properly.

Household or commercial — the split that decides your bill

Austria separates Haushaltsverpackung (packaging that ends up with households) from Gewerbeverpackung (packaging that ends up at businesses), and treats them differently. Getting the split wrong is the most common and most expensive mistake on this file.

Household packaging

Must be licensed with an approved collection and recovery system. This is where the fees are.

Commercial packaging

Not licensed the same way — obligations run instead to taking it back free of charge.

Who decides which is which

The Abgrenzungsverordnung — the delimitation ordinance — sets the criteria. Sending to consumers puts you squarely in household.

Do you have to print anything on the box?

Short answer for a small distance seller: no, not yet — with one exception that catches people who brand their own packaging.

The harmonised sorting label

The pictogram label telling the customer which bin the material goes in. Art. 12(1) PPWR applies it from 12 August 2028 at the earliest — later still if the implementing acts slip, because the trigger is 24 months from their entry into force, whichever is later. Nothing to do on 12 August 2026.

An Austrian national symbol

There isn't one for ordinary household shipping packaging. Austria's rules here are about licensing, reporting and the representative, not about printing a mark.

The one that does apply now

If your name or logo is on the packaging you are likely its manufacturer, and Art. 15(5) and 15(6) require an identifier plus your name and a postal address on it — from 12 August 2026. That is an EU-wide conformity duty, not an Austrian one. See manufacturer or producer?

Separately

Deposit-return and single-use-plastic marking rules are their own regimes and can apply to specific product types regardless of the above.

Thresholds and small quantities

The old de minimis rule — roughly €730,000 of turnover or 300 kg of paper — was abolished on 1 January 2023. If you are still working from a guide that mentions it, that guide is out of date. There is no general exemption for being small.

What survives is lighter administration, not exemption. A Kleinabgeber can settle the licensing duty with a flat payment and skip the volume reporting entirely. The flat-rate arrangements the systems offer run to 1,500 kg of household packaging and 1,500 kg of commercial packaging a year — two separate limbs, not one combined figure. This page previously quoted only the household limb.

The approved systems

Six collection and recovery systems are approved under § 29 AWG 2002. Your representative signs you up to one; you are not obliged to take whichever one they happen to prefer.

ARA

Altstoff Recycling Austria AG — the largest and oldest

Austria Glas Recycling

Austria Glas Recycling GmbH

Bonus

Bonus Holsystem für Verpackungen GmbH & Co. KG

ERP Austria

European Recycling Platform (ERP) Austria GmbH

Interzero

Interzero Circular Solutions Europe GmbH

Reclay

Reclay Systems GmbH

How often you report

Reporting frequency scales with the size of your expected licence fee, not with your turnover. Small sellers land in the top row, and Kleinabgeber on a flat rate report not at all.

What it costs

These are provider list prices we found published, not quotes we've negotiated, and not a recommendation. They are here to give you an order of magnitude — and to be replaced by real member quotes as they come in. Rechecked 14 August 2026: the ERP figure on this page was previously given as ~€169 and has been corrected.

What happens if you don't

Breaches are administrative offences under § 79 AWG 2002. Failing to appoint a representative falls in the mid band.

Enforcement is not only ministerial. The Verpackungskoordinierungsstelle (VKS) runs audits on behalf of the systems, typically on a three-to-five-year cycle. The practical risk for a small seller is less the headline fine than the back-payment plus audit costs, which routinely exceed what the licence would have cost in the first place.

GPSR is a separate problem

Packaging EPR and product safety are different regimes with different representatives, and solving one does not solve the other. The General Product Safety Regulation requires an EU-based Responsible Person for consumer products, with no exemption for small or low-volume sellers. If you are outside the EU and shipping to consumers, you cannot be your own Responsible Person without an establishment in the Union.

An Austrian packaging representative is not automatically your GPSR Responsible Person. Check what you're actually buying before assuming you're covered.

"It's been suspended"

You will be told this, usually by someone selling you something, and it is worth answering once.

Until something is adopted and enters into force, Art. 45(3) applies as written, and it has applied since 12 August 2026. We think the proposal is worth watching and worth arguing about — see our note on it — and we do not think it is worth planning around.

Known traps

Sources

Primary law first, then the official portals, then the secondary summaries we cross-checked against. Where a claim on this page rests only on a secondary source, we've said so above.

1. AWG 2002 § 79 — administrative penalties Statutory fine ranges, consolidated text
2. Verpackungsverordnung 2014 — consolidated text (RIS) Official legal information system of the Republic of Austria; §§ 16a–16e cover representatives
3. USP.gv.at — Authorised representatives for packaging and single-use plastics Official government business portal: who must appoint, the EDM route, certified power of attorney, ZAReg
4. BMLUK — Collection and recovery systems Ministry page and official list of approved systems under § 29 AWG 2002
5. EDM — Elektronisches Datenmanagement Umwelt The registration portal itself
6. IT-Recht Kanzlei — FAQ on packaging licensing in Austria Secondary. Source for the 1,500 kg Kleinabgeber rule and the reporting-frequency bands
7. IT-Recht Kanzlei — Representatives for foreign online traders Secondary. Source for the self-registration prohibition and notarial certification
8. VKS — Verpackungskoordinierungsstelle The body that runs the audits
9. ARA — PPWR guide, English edition Maps the PPWR role definitions onto the Austrian system. ARA is an industry body and one of the six approved systems — secondary material, and not a neutral source
10. Regulation (EU) 2025/40 (PPWR) — EUR-Lex Read in full, 14 August 2026. Source for Art. 44(3) on delegating registration, Art. 44(8) on the 10-tonne reporting threshold, Art. 45(3) on the representative, Art. 45(4) and (6) on marketplaces, Art. 12(1) on the 2028 label, Art. 62 on formal non-compliance and Art. 68 on the February 2027 penalties deadline
11. European Commission — PPWR Frequently Asked Questions, 2nd edition DG ENV Unit B01, August 2026 (KH-01-26-068-EN-N). Read in full, 14 August 2026 — this page previously said we hadn't. Source for the enforcement approach from 12 August and the confirmation that there is no general micro-enterprise exemption from EPR
12. European Commission — PPWR guidance (Commission Notice), 30 March 2026 The guidance document, distinct from the FAQ above and complemented by it. Still not read in full by us — where a claim rests on it, we have said so
13. WKO — EU-Verpackungsverordnung: PPWR-Pflichten ab 2026 Secondary, but the Austrian chamber of commerce. Source for what applies in Austria from 12 August, and for the statement that Austrian national implementing legislation is still outstanding

Help us finish this desk

This draft was assembled from public sources on 14 August 2026. It has not been checked by an Austrian lawyer and it has no keeper yet. If you ship to Austria, you can improve it faster than we can.

Updated 14 August 2026. The supplier-establishment question this desk used to point at is now answered — there are three micro-enterprise carve-outs with two different geographic tests, and the sources that appeared to disagree were describing different articles. The packaging edge cases around decorative ribbon and gift stickers are still open, but the search has narrowed: the Commission's August FAQ has been read in full and does not address them, so only the Commission Notice of 30 March 2026 is left.

What this desk most needs now is someone who has actually been through the EDM process as a foreign seller — how long the ministry took, what the notary charged, and whether the quarter-end rule bit. None of that is published anywhere, and one member who has done it knows more than this page.