Austria Packaging EPR and Licensing Guide for 2026

Austria’s packaging Extended Producer Responsibility framework requires obligated businesses to take responsibility for packaging they place on the Austrian market.

In practice, this normally means identifying the responsible business, classifying the packaging, determining its material and weight, participating in an approved collection and recovery system, paying licensing fees, maintaining supporting records, and completing any applicable reporting or authorised-representative requirements.

The principal national framework includes Austria’s Waste Management Act, known as the Abfallwirtschaftsgesetz 2002, and the Packaging Ordinance 2014, or Verpackungsverordnung 2014. The Packaging Ordinance regulates the prevention and recovery of packaging waste and certain product residues.

Austria’s packaging rules also operate alongside the EU Packaging and Packaging Waste Regulation, or PPWR. Regulation (EU) 2025/40 entered into force on 11 February 2025 and applies from 12 August 2026, introducing EU-wide requirements for packaging sustainability, composition, recyclability, recycled content, labelling, minimisation, reuse, and waste management.

For businesses selling in Austria, packaging compliance therefore requires two connected workstreams:

Participation in an Austrian collection and recovery system does not by itself demonstrate compliance with every PPWR design or documentation requirement. Companies need a broader packaging compliance process.

Packaging EPR is a system under which the businesses responsible for placing packaging on the Austrian market contribute to its collection and recovery after use.

Obligated businesses generally need to:

• Determine whether they are a primary obligated party
• Identify all packaging placed on the Austrian market
• Classify packaging as household or commercial packaging
• Classify packaging by material and tariff category
• Calculate packaging quantities by weight
• Participate in an approved collection and recovery system
• Pay licensing fees based on packaging type and weight
• Provide confirmation of system participation to customers
• Appoint an authorised representative where required
• Maintain records supporting submitted quantities
• Complete applicable EDM or system reporting
• Monitor separate deposit requirements for beverage packaging

Austria’s official business portal states that companies placing household and/or commercial packaging on the market must participate in an approved collection and recovery system. It also confirms that licensing fees depend on the type and weight of the packaging.

Austria identifies several types of primary obligated parties for packaging. Responsibility depends on the business activity, establishment location, supply chain, and method of sale.

Main primary obligated parties

The Austrian business portal confirms that the rules apply regardless of the distribution method, including distance selling. It identifies domestic service-packaging manufacturers and importers, packers, importers, own importers, and foreign distance sellers supplying private Austrian consumers as primary obligated parties.

Responsibility questions companies should answer

1- Which legal entity first places the packaging or packaged goods on the Austrian market?

2- Is the product packed or filled in Austria?

3- Is the product imported into Austria?

4- Is the packaging supplied directly to a private consumer?

5- Is the seller established in Austria?

6- Is the packaging service, sales, grouped, transport or e-commerce packaging?

7- Is a local importer taking responsibility?

8- Does an authorised representative act for a foreign company?

9- Is the packaging already licensed at an earlier supply-chain level?

10- Can this allocation of responsibility be demonstrated?

Responsibility should be confirmed before products are launched or shipped to Austria.

Austria’s packaging rules are broad. Packaging can include packaging materials, packaging aids, pallets, and certain pre-products used directly to create packaging or packaging aids.

Official Austrian guidance describes:

• Sales packaging as packaging offered to the final consumer as a sales unit
• Transport packaging as packaging that facilitates the handling and transport of several sales units or grouped packages and protects against contact or transport damage
• Packaging generally as including packaging means, packaging aids, pallets and certain packaging pre-products

Packaging levels businesses should include

Companies frequently underreport packaging when they record only the main consumer-facing package and exclude labels, lids, cartons, pallets, films or shipping materials.

Packaging intended for export is generally subject to the requirements of the destination country rather than Austria’s domestic packaging obligations.

Correct classification between household and commercial packaging is central to Austrian packaging licensing and reporting.

Household packaging criteria

Austrian guidance describes household packaging as packaging that meets applicable size criteria and normally becomes waste in private households or comparable places.

The relevant size criteria include:

• Surface area of up to and including 1.5 square metres
• For hollow bodies, nominal filling volume of up to and including 5 litres
• For expanded polystyrene packaging, up to and including 0.15 kilograms per sales unit

The packaging must also typically arise in private households or comparable establishments, such as restaurants, hotels, canteens, offices, hospitals, educational institutions, cinemas, sports facilities and other similar locations.

Practical classification considerations

The customer being a business does not automatically make all packaging commercial. The packaging’s characteristics and usual point of waste generation must also be considered.

Companies should record the reasoning supporting each classification, particularly where the same packaging is supplied through both consumer and business channels.

Businesses placing household or commercial packaging on the Austrian market generally need to participate in an approved collection and recovery system, known in German as a Sammel- und Verwertungssystem.

This participation is commonly described as packaging licensing.

The collection and recovery system assumes relevant collection and recovery responsibilities based on the packaging quantities reported by the participating company. Official Austrian guidance confirms that participation fees are based on packaging type and weight.

Information usually needed for system participation

• Responsible legal entity
• Austrian market role
• Packaging materials
• Tariff categories
• Household or commercial classification
• Packaging weights
• Quantity placed on the Austrian market
• Reporting period
• Product or business category
• Supplier and packaging specifications
• Reusable or single-use status
• Any applicable exclusions or special routes

Common packaging material categories

Reporting categories depend on the selected system and applicable tariff structure, but businesses commonly need reliable data for materials such as:

• Paper and cardboard
• Glass
• Ferrous metals
• Aluminium
• Plastics
• Wood
• Composite materials
• Other packaging materials

The system contract and tariff catalogue should be reviewed before building the reporting file because reporting categories may be more detailed than the company’s internal material list.

Packaging licensing fees depend primarily on the packaging material, tariff category and mass placed on the Austrian market.

Factors that can influence EPR cost

Companies should not calculate licensing costs from product units alone. Each unit must be connected to an approved packaging weight and material structure.

Businesses participating in a collection and recovery system must provide customers with legally binding confirmation of that participation, for example through delivery documentation or invoices. Official guidance provides an example identifying the collection system and licence number.

This confirmation helps prevent uncertainty over whether packaging has already been licensed at an earlier supply-chain level.

Recommended supply-chain evidence

• System participation contract
• Licence or customer number
• Reporting confirmations
• Quantity declarations
• Supplier licensing statements
• Invoice or delivery-note declarations
• Customer responsibility agreements
• Packaging specifications
• Records showing which packaging is covered
• Period and market to which the declaration applies

A general statement that “packaging is compliant” may not be sufficient. The evidence should clarify which packaging, business entity, market and reporting period are covered.

Foreign distance sellers have a specific responsibility in Austria.

Since the beginning of 2023, foreign distance sellers without an Austrian establishment that supply packaging or packaged products directly to private final consumers in Austria must appoint an authorised representative. Foreign EU or EEA businesses supplying parties other than private final consumers may be able to appoint a representative voluntarily, depending on their circumstances.

Who generally requires an authorised representative?

A mandatory appointment applies particularly where a foreign seller:

• Has no registered office or establishment in Austria
• Uses distance-selling channels
• Supplies packaged goods to Austrian private consumers
• Places the relevant packaging on the Austrian market

Responsibilities of the authorised representative

The representative can assume the foreign company’s relevant duties under the Austrian Waste Management Act and Packaging Ordinance, including reporting the packaging quantities placed on the market.

The arrangement should cover:

• Scope of authority
• Packaging EPR responsibilities
• System participation
• Packaging quantity reporting
• Access to supporting data and documents
• Authority communication
• Record maintenance
• Financial resources required to fulfil obligations
• Notification of changes

EDM registration

The authorised representative must register in Austria’s Electronic Data Management system and submit the relevant power of attorney for review. The mandate and any changes must be managed through the EDM process.

Foreign sellers should complete this process before beginning consumer sales into Austria, rather than waiting for the first reporting period.

Foreign companies should distinguish carefully between business-to-consumer and business-to-business sales.

Contracts should clearly identify who assumes Austrian packaging licensing, reporting and data responsibilities. The actual supply flow should match the contractual allocation.

Austria uses different reporting routes depending on the operator and the packaging arrangement.

Standard obligated businesses generally report their licensed packaging quantities to their selected collection and recovery system according to the system contract and reporting frequency.

Separate direct EDM reporting applies to specific groups, including:

• Own importers
• Large-scale packaging waste generation points
• Certain fillers of reusable packaging
• Approved collection and recovery systems

The EDM eVerpackung application supports these statutory packaging reports.

Key direct EDM deadlines

EDM states that Annex 3 quantities must be recorded by packaging material in a traceable way and reported in kilograms.

Not every ordinary licensed company files the same report directly through EDM. Businesses should determine whether reporting is completed through their system provider, directly in EDM, or through both routes for different packaging flows.

Austria has a special category for large-scale commercial packaging waste generation points.

The official thresholds include annual commercial packaging waste quantities of at least:

Qualifying locations must be entered in the relevant register and may have specific reporting and waste-management arrangements.

Companies operating manufacturing sites, distribution centres or major commercial facilities should assess these thresholds separately from their standard packaging placed-on-market obligations.

An own importer is generally a final user that purchases packaged goods from abroad for its own Austrian business and generates the packaging waste within that business.

Examples can include:

• Manufacturing components imported for internal production
• Machinery delivered in transport packaging
• Office supplies imported directly
• Raw materials delivered in drums, bags or bulk packaging
• Equipment delivered on pallets and wrapped in film

Own importers may have direct reporting obligations where the packaging is not covered by participation in a collection and recovery system. The relevant packaging quantities and the waste-management route should be recorded accurately.

Austria packaging EPR compliance depends on accurate product and packaging data.

Recommended packaging master data

Packaging quantity calculation

A standard calculation is:

Packaging weight per product unit × number of units placed on the Austrian market

The calculation should be completed separately for each packaging component and material category.

Example

Each figure should be traceable to an approved source.

Packaging weights may come from:

• Supplier specifications
• Technical drawings
• Packaging bills of materials
• Controlled sample weighing
• Production records
• Converter declarations
• Laboratory measurements
• Approved engineering calculations

Where estimated values are used, companies should document:

• Why estimation was necessary
• The packaging samples used
• The number of samples weighed
• Whether labels, closures and adhesives were included
• How the average was calculated
• Which products use the estimate
• How frequently it is reviewed

Small weight errors can create significant reporting differences when multiplied across large sales volumes.

Supplier evidence should be linked to the exact packaging item and version.

Information to request from packaging suppliers

• Packaging specification
• Material composition
• Component structure
• Net packaging weight
• Recycled content where applicable
• Substance declarations
• Recyclability information
• Food-contact evidence where relevant
• Technical drawings
• Manufacturing site
• Effective date
• Change-notification commitment

Changes requiring reassessment

• New packaging supplier
• New production site
• Material-grade change
• Film-thickness change
• New label or sleeve
• Closure redesign
• Coating or adhesive change
• Recycled-content change
• Packaging dimension change
• Change from single-use to reusable
• New Austrian sales channel

A supplier change can affect licensing mass, tariff classification, recyclability, PPWR conformity and deposit registration simultaneously.

Austria introduced a national deposit system for covered single-use beverage containers on 1 January 2025.

A deposit of €0.25 per container applies to sealed PET beverage bottles and metal beverage cans with a filling volume from 0.1 to 3 litres. Covered containers must display the Austrian deposit logo. Certain milk and milk-heavy beverage products are excluded.

Deposit compliance areas

The transition period ended in 2025. From 1 January 2026, only registered covered products displaying the deposit logo may be sold.

Return conditions

Consumers normally receive the refund when the container is returned empty, uncrushed, and with a complete and readable label so the system can identify it. Covered containers are collected through participating sales outlets, manual collection points or reverse vending machines.

Foreign companies placing covered deposit containers on the Austrian market may need additional arrangements.

A foreign company can operate through:

• Its own Austrian company
• An Austrian importer or distributor
• An authorised representative, where legally available

A foreign company supplying private Austrian consumers directly must appoint a domestic authorised representative for participation in the Austrian single-use deposit system. The representative’s tasks can include product registration, notification of first market placement, deposit and producer-contribution payments, and master-data maintenance.

The packaging EPR and deposit arrangements should be reviewed together so that the same company, representative and product data are used consistently.

Standard Austrian packaging EPR participation should not be confused with a general requirement to place a specific licensing symbol on all packaging.

Businesses should assess labelling requirements based on:

• Packaging material
• Product category
• Deposit status
• Consumer disposal instructions
• Food-contact requirements
• Hazardous product requirements
• PPWR requirements and application dates
• Voluntary recycling or environmental claims

Any label or claim should be supported by reliable evidence. A deposit product must use the official Austrian deposit marking, while other packaging may have separate legal or voluntary identification requirements.

Labels should not imply that packaging is recyclable, reusable, compostable or made with recycled material unless the company can substantiate the claim.

Austria’s Packaging Ordinance does more than establish EPR licensing. Its essential requirements include limiting packaging volume and weight to the minimum needed to maintain the necessary safety and hygiene of the packaged product and consumer acceptance. Packaging should also be designed to support reuse or recovery, including recycling, in line with the waste hierarchy.

These national requirements increasingly connect with PPWR obligations concerning:

• Packaging minimisation
• Recyclability
• Recycled content
• Restricted packaging formats
• Reuse and refill
• Harmonised labelling
• Technical documentation
• Environmental claims

PPWR sets sustainability and labelling requirements throughout the packaging life cycle and aims to prevent unnecessary packaging while promoting reuse, refill and recycling.

Companies should therefore use the same controlled packaging dataset for Austrian EPR reporting and PPWR readiness.

The general PPWR application date does not eliminate the need to comply with Austria’s current collection, recovery and reporting infrastructure.

A practical 2026 approach is to:

1- Continue Austrian system participation and licensing.

2- Maintain authorised-representative arrangements where required.

3- Report packaging quantities according to current Austrian rules.

4- Register deposit products and use the correct logo.

5- Build complete product-level packaging data.

6- Assess upcoming PPWR design and documentation requirements.

7- Monitor Austrian legal and system updates resulting from PPWR.

8- Avoid assuming that EPR licensing proves full PPWR compliance.

This parallel approach reduces the risk of meeting one requirement while overlooking another.

Failure to participate adequately in a collection and recovery system can lead to enforcement and administrative consequences.

Austria’s Waste Management Act provides that where a primary obligated party has not participated, or has participated insufficiently, and this results in a final penalty, the party must participate retrospectively in a collection and recovery system and demonstrate that participation to the competent ministry.

Potential business consequences can include:

• Administrative penalties
• Retrospective system participation
• Additional licensing costs
• Corrections to reported quantities
• Customer or retailer disputes
• Product launch delays
• Marketplace restrictions
• Deposit-system non-compliance
• Reputational damage
• Increased audit activity

The strongest defence is a traceable packaging dataset supported by specifications, calculations, contracts and reporting evidence.

Step 1: Map the supply chain

Identify:

• Austrian legal entities
• Importers
• Packers and fillers
• Foreign distance sellers
• Retailers and distributors
• Packaging suppliers
• Fulfilment providers
• Private and business customers

Step 2: Determine the primary obligated party

Assign responsibility for each sales and import flow. Document the legal and commercial reasoning.

Step 3: Build a complete packaging inventory

Include primary, secondary, transport, e-commerce, service and reusable packaging.

Step 4: Create a packaging bill of materials

Record every material and component, including labels, closures, films, adhesives and pallets.

Step 5: Classify household and commercial packaging

Apply Austrian criteria and retain evidence for the decision.

Step 6: Select the collection and recovery system

Confirm the accepted materials, tariff categories, reporting frequency, contract terms and licensing evidence.

Step 7: Appoint an authorised representative where required

Foreign distance sellers should complete the mandate and EDM process before beginning Austrian consumer sales.

Step 8: Prepare packaging quantity calculations

Connect approved packaging weights to Austrian units placed on the market.

Step 9: Confirm the reporting route

Determine what is reported:

• To the collection and recovery system
• Directly through EDM
• Through the authorised representative
• Through the Austrian deposit-system portal

Step 10: Assess deposit obligations

Identify covered beverage packaging, complete registration, approve artwork and configure the deposit process.

Step 11: Prepare PPWR readiness data

Use the packaging inventory to assess recyclability, substances, recycled content, minimisation and labelling.

Step 12: Maintain change control

Reassess obligations when packaging, suppliers, entities, systems or market routes change.

Austria packaging EPR requires connected information across legal entities, packaging items, materials, suppliers, sales quantities, collection systems, authorised representatives, deposit products, and reporting periods.

ComplyMarket’s packaging compliance approach supports companies in identifying applicable packaging rules, connecting requirements to packaging items and products, collecting supplier evidence, controlling records, and preparing jurisdiction-specific reporting information.

ComplyMarket can support businesses with:

• Austria packaging EPR applicability assessments
• Primary-obligated-party determination
• Austrian importer and distance-seller analysis
• Authorised-representative readiness
• Packaging inventory and bill-of-materials creation
• Household and commercial packaging classification
• Packaging material and weight data management
• Supplier specification and declaration collection
• Collection-and-recovery system onboarding records
• Licence and customer-confirmation management
• Quantity calculation and reporting workflows
• EDM reporting-data preparation where applicable
• Austrian deposit-system product data
• Deposit label and packaging artwork records
• Packaging change and version control
• PPWR readiness assessments
• Audit-ready documentation and reporting evidence

ComplyMarket’s EPR management services also focus on jurisdiction-level obligation control, producer master data, quantity and category management, standardised data collection, and evidence-backed audit trails.

For companies managing several products, suppliers and European markets, this provides one structured process rather than separate spreadsheets for every country and reporting scheme.