Austria
Extended liability for packaging manufacturers (EPR) in Austria
Austria transposed the EU Packaging Directive through the Packaging Ordinance 2014 (BGBl II 184/2014), which — together with the Waste Management Act — sets up EPR Austria rules that make producers finance collection, sorting and recycling of all household and commercial packaging placed on the market. The ordinance is overseen by the Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology (BMK), while the non-profit VKS Verpackungskoordinierungsstelle coordinates systems’ market shares and audits.
Major amendments that took effect on 1 January 2023 tightened controls, extended obligations to commercial packaging and introduced the mandatory authorised-representative model for foreign sellers.
Who must register for packaging EPR in Austria
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Packers / manufacturers established in Austria that fill or import packaged goods.
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Importers of packaged goods (including own-brand imports) at the time of import.
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E-commerce merchants without an Austrian establishment selling B2C into Austria (must act via an authorised representative).
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Service-packaging producers (e.g., takeaway food packaging) with a place of business in Austria.
Extended producer responsibility for EEE in Austria
Austria implements the EU WEEE Directive through the Elektroaltgeräteverordnung (EAG-VO 2005, last amended 2024) and the Waste Management Act (AWG 2002). These rules oblige producers to finance collection, treatment and recovery of e-waste and are enforced by the Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology (BMK), with day-to-day coordination handled by Elektroaltgeräte Koordinierungsstelle Austria (EAK). Compliance with EPR Austria for electronics is therefore a legal pre-condition for selling electrical goods on the Austrian market.What the package includes
The regime covers household and commercial packaging of every material (paper, glass, plastics, metals, composites), plus certain single-use plastic items listed in Annex 6 of the ordinance. Reusable packaging and transport packaging are also in scope when first placed on the marketThreshold
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No de-minimis exemption: every company that places any amount of packaging on the Austrian market must comply with EPR registration Austria.
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Flat-rate option for small quantities: if you introduce ≤ 1 500 kg of household and ≤ 1 500 kg of commercial packaging per calendar year, you may pay a simplified annual lump sum (≈ €130-200) instead of material-specific tariffs.
EPR registration procedure in Austria
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Choose and contract a licensed collection & recovery system (PRO) such as ARA, ERP, Interzero, Reclay, etc. This contract simultaneously fulfils the licensing requirement — there is no separate public packaging register.
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Provide yearly packaging weight forecasts (or accept the flat-rate) and pay the calculated fee.
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The PRO uploads participant data to the VKS register and issues a licence number needed by marketplaces like Amazon.
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If you place un-licensed packaging (rare), you must open an EDM (Electronic Data Management) account and file quantities electronically
Authorized representative
Since 1 January 2023, any non-Austrian business that sells packaged goods directly to Austrian end-users must appoint an authorised representative established in Austria to fulfil all EPR packaging Austria duties (licensing, reporting, fee payment) on its behalf.The appointment must be in writing and uploaded to the EDM “Bevollmächtigten-Register
Reporting Deadline
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System participants: quantity reports are due monthly, quarterly or annually depending on volume, plus a consolidated annual statement no later than 15 March of the following year.
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Direct EDM filers (non-licensed packaging): electronic annual report via EDM by 31 March.
Who Assumes Responsibility?
| Actor | Primary liability? | When? |
|---|---|---|
| Austrian packer / manufacturer | Yes | First domestic placing on the market |
| Importer (B2B or B2C) | Yes if packaging not already licensed upstream | At import |
| Foreign distance seller | Via authorised representative | Direct B2C sales into Austria |
| PRO (e.g., ARA) | Operational | Collection, recycling & data transfer |
| BMK & VKS | Enforcement / coordination | Market surveillance & audits |
Duties of Each Group Who Is Responsible
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Producers / importers: join a PRO, keep weight records, pay tariffs, submit timely data, and display the licence declaration (if requested by customers)
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Authorised representative: sign PRO contract, register in EDM, file reports, maintain evidence for five years, act as local contact for the BMK.
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PROs: finance nationwide collection infrastructure, meet material-specific recycling targets, transmit participant lists to VKS, and support audits.
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BMK/VKS: approve PROs, set tariffs & quotas, perform plausibility checks and impose fines (up to € 50 000 for non-compliance).
Who must register for EPR in Austria
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Austrian manufacturers or brand-owners that put electrical and electronic equipment (EEE) on the market
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Importers bringing EEE into Austria on a professional basis
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Distance sellers without an Austrian establishment that ship EEE directly to Austrian consumers (must act via an authorised representative)
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Retailers placing own-brand EEE on the market.
What the equipment includes
The EAG-VO covers every item that needs electric current ≤ 1 000 V AC/1 500 V DC and falls into these categories:
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Temperature-exchange equipment (e.g., fridges, heat pumps)
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Screens and monitors ≥ 100 cm²
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Lamps
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Large equipment (> 50 cm)
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Small equipment (≤ 50 cm)
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Small IT & telecoms devices (≤ 50 cm)
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Photovoltaic modules (treated as large equipment)
All household and commercial devices are in scope, whether new or re-manufactured, once placed on the Austrian market.
Threshold
There is no de-minimis exemption for EEE: a single device obliges the producer to comply with EPR registration Austria requirements.
EPR registration procedure in Austria
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Open an EDM account on edm.gv.at and register the business and relevant device categories with EAK
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Conclude a compliance contract with an approved WEEE collection & recovery system (e.g., ARA ERA, Interzero, ERP Austria, UFH).
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Submit an annual quantity forecast (or continuous weight reports) and pay eco-fees set by the system.
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Receive your Austrian WEEE Registration number from EAK - marketplaces must verify it before listings go live
Authorized representative
Every foreign company that sells EEE directly to Austrian B2C customers must appoint an authorised representative established in Austria. The representative assumes all producer duties under the AWG 2002 and EAG-VO and must be recorded in the BMK’s Bevollmächtigten-Register within one month of appointment.Reporting Deadline
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Producers inside a WEEE system: the system files quarterly reports within seven weeks after each quarter end and a consolidated return by 10 April for the previous year (this fulfils the producer’s duty)
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Producers not covered by a system (rare/B2B gear): must submit the same quarterly data themselves and the annual mass balance to EAK by 10 April.
Who Assumes Responsibility?
| Actor | Primary liability | Moment of liability |
|---|---|---|
| Austrian manufacturer / brand-owner | Full | First placing on market |
| Importer | Full (if no upstream licence) | Import |
| Foreign distance seller | Via authorised representative | Direct sale to consumer |
| WEEE system (e.g., ERA, Interzero) | Operational | Collection & recycling |
| BMK EPR / EAK | Enforcement & registry | Oversight, audits, fines |
Duties of Each Group Who Is Responsible
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Producers / importers: register in EDM, mark products with the crossed-out wheeled-bin symbol, finance take-back, keep weight records for five years, and update category data promptly (EPR EEE Austria duty)
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Authorised representative: maintain local address, sign system contract, file quarterly/annual data, and receive official correspondence.
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WEEE systems: meet material-specific recycling quotas, operate nationwide collection points, audit member data, and forward reports to BMK/EAK.
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BMK/EAK: approve systems, manage the register, publish compliance lists, and levy fines up to €50 000 for non-compliance.