Registering for packaging EPR in Austria yourself — why a distance seller must appoint a Bevollmächtigter, and what EDM registration involves

Does this apply to you

Austrian packaging obligations sit in the Verpackungsverordnung under the Waste Management Act (AWG). The federal business service portal (USP), whose content on this subject is published under the responsibility of the environment ministry BMLUK and was last updated on 1 January 2026, sets out who is caught, in two separate categories that are worth reading side by side.

• “Foreign persons” — persons whose seat is in another EU Member State or an EEA state and who distribute packaging in Austria to other than private end consumers. Since the start of 2023 these can appoint a representative to discharge their obligations.
• “Foreign mail-order / distance sellers” — sellers “who have no seat and no establishment in Austria and who hand over packaging, or goods or products in packaging, in Austria to private end consumers by distance selling”. These, the portal says in the same paragraph, are obliged to appoint a representative.

Two things follow that matter for a cross-border seller. First, the trigger is your customer, not your customs status: shipping to Austrian consumers puts you in the second category whether the parcel starts in Hamburg or in Shenzhen. Second, the second category's wording does not restrict itself to EU or EEA seats the way the first one does — a difference visible on the page itself, where the EU/EEA qualifier appears in every other bullet and not in this one.

Austrian exporters get the mirror image: where another Member State imposes a representative obligation on foreign exporters, Austrian exporters of packaging must appoint a representative in that state.

The steps

Austria's sequence is slow rather than difficult. Two of the four steps have waiting time built into them, so start with the calendar in mind.

1 · If you sell into Austria by distance selling: a Bevollmächtigter is compulsory

The Bevollmächtigte/r takes over all of the foreign seller's obligations under the Waste Management Act and the Verpackungsverordnung, and must report the quantities of packaging and single-use plastic products that you placed on the market.

The conditions for who can act are published, and they are narrow enough to check a candidate against before you pay anyone:

• a natural or legal person with a seat in Austria;
• an Austrian delivery address;
• responsibility for compliance with Austrian administrative rules;
• appointed by a certified power of attorney, in German or English, showing the scope of the authorisation — in particular the relevant collection and treatment category — the representative's express consent to take on the producer's obligations, and a contractual assurance that the representative is granted the right to conclude contracts binding the producer and is provided with all documents and means needed to do the job.

The procedure runs through the environment ministry, not through a system operator. The person who wants to act as representative first registers on edm.gv.at with the waste-specific activity profile “Hersteller/sonstige Meldepflicht”, then submits the power of attorney to BMLUK through the same portal. If the check is positive and the representative is registered in ZAReg, the register of installation and person master data, the ministry marks them as authorised representative there. BMLUK then passes your master data to the Umweltbundesamt, which registers you in ZAReg and issues the representative sub-user credentials giving access to your data. The competent unit is BMLUK Division V/2 (waste and contaminated sites law), Stubenring 1, 1010 Vienna, v2@bmluk.gv.at. There are, in the portal's words, no particular deadlines to observe for the appointment itself — which is not the same as saying you can trade first and appoint later, because the underlying obligations start when you place packaging on the market.

One useful detail if you also sell electricals or batteries: the same person can be appointed for packaging, for electrical and electronic equipment and for batteries, but you need either separate powers of attorney or one that states the exact scope of each. If authorisations already exist for waste electricals or batteries, quoting the existing GLN registration number in the new power of attorney simplifies the procedure.

2 · Register in EDM — allow two to three weeks, the password arrives by post

Reporting parties register in eRAS, the electronic register of installation and person master data, and must state in the master data that a reporting obligation under the Verpackungsverordnung exists. Then comes the sentence to plan around: “After your online registration you will receive your password by post. Please note that registration can take approximately 2–3 weeks.”

That is the real lead time on an Austrian launch. If you have a distance-selling representative under step 1, they go through this registration themselves and then receive sub-user credentials for your account; if you are established in Austria you do it directly.

3 · Contract with a licensed collection and recovery system

Austria does not run a single national scheme. Licensed collection and recovery systems (Sammel- und Verwertungssysteme) take over, for a fee, the obligations that would otherwise fall on manufacturers, importers, packers and mail-order sellers. They compete on price, so the choice is a commercial one — see Choosing a licensed system for the official list of who is licensed and for what.

4 · Report your volumes by 31 March

Quantity reports under Annex 3 to the Verpackungsverordnung 2014 (BGBl. II No. 184/2014) for a calendar year must be submitted electronically by 31 March of the following year, through edm.gv.at once you are registered.

One mechanical trap the ministry flags: entering and saving data in the forms is not filing. “Only with the active release of the data by the reporting party (submit report) is the report deemed to have been legally submitted.” A saved draft on 31 March is a missed deadline.

Choosing a licensed system

The ministry publishes the list of currently licensed systems under section 29(4), last sentence, of the Waste Management Act 2002, and states that the list is only updated when the set of licensed systems changes. Reproduced from that publication, with the collection categories each is licensed for:

Household packaging — six licensed systems:

• ARA Altstoff Recycling Austria AG, Vienna — paper, metals, light packaging
• AGR Austria Glas Recycling GmbH, Vienna — glass
• Bonus Holsystem Gesellschaft m.b.H. & Co KG, Kufstein — all categories
• European Recycling Platform (ERP) Austria GmbH, Vienna — all categories
• Interzero Circular Solutions Europe GmbH, Vienna — all categories
• Reclay Systems GmbH, Vienna — all categories

Commercial packaging — five licensed systems: the same list without AGR, each licensed for paper, metals, plastics, EPS, other composite materials, ceramics, wood, textiles and biogenic packaging materials.

Two consequences. If your packaging includes glass and you want a single contract, the four all-category systems can take it; AGR is glass-only and ARA's household licence covers paper, metals and light packaging rather than glass. And because these are competing private systems, the tariff is a quoted price, not a published statutory rate — see What it costs.

The checks worth doing before signing are the ordinary contract ones the ministry will not do for you: minimum term, whether it renews automatically, notice period and deadline, any minimum annual charge or minimum volume, how long a quote stays valid, and how the system settles a declared volume that turns out too high or too low.

Reporting: what you file and when

• To the ministry, through EDM: the Annex 3 quantity report for the calendar year, by 31 March of the following year, electronically, and only counted once actively released.
• To your system: the volumes it invoices on, on the system's own cycle. That is a contract obligation, and its calendar will not match 31 March.
• Master data upkeep in ZAReg: your record is created there by the Umweltbundesamt when a representative is appointed; keeping it current is part of the representative's job, and the ministry notes that the activity-profile entry for a representative is made for all possible authorisation areas — electricals, batteries, packaging — not only the one applied for.

When you actually need a provider

Austria is the clearest case in this set of a country where a foreign distance seller has to buy something. Being precise about what is where the money is.

• You do need a Bevollmächtigter if you sell to Austrian private consumers by distance selling and have no seat or establishment in Austria. This is not negotiable and not substitutable by joining a system.
• But the representative does not have to be a compliance company. The published conditions are a seat in Austria, an Austrian delivery address, acceptance of responsibility for compliance and a certified power of attorney. A subsidiary, a group company, or an Austrian business partner willing to take on the obligations can qualify. Companies that already have an Austrian entity often buy a service they did not need.
• You do not need a provider to choose a system. The list is published by the ministry, linked below, and the systems quote directly.
• You do not need one to make the annual report if you can access EDM — but note that in the distance-selling case the representative holds the credentials and the reporting duty anyway.
• Judgement calls worth paying for: classifying packaging into the collection categories the systems price on, and separating household from commercial packaging where you sell to both.

One thing to check in any quote: whether the price bundles the representative role with system membership. If it does, ask which system and compare against that system's own quote, because you are otherwise paying a margin on a tariff you could contract directly.

We have no commercial relationship with any licensed system or representative named or linked on this page, and we take no referral fees.

What it costs

Austria is a market-price country, not a tariff country, and that shapes what you can know in advance.

• Licence fees to a system — quoted per system, per collection category, per kilogram. The figures we publish on the Austria page are one licensed operator's published price list, not a statutory rate, and the page says so on every row: the paper row, the plastic row and the glass row are the three most sellers need. Use them to sanity-check a quote, not as the price you will pay.
• Authorised representative — a commercial fee, quoted per provider; unavoidable for a foreign distance seller, but see the note above about who is allowed to be one.
• Registration and reporting — the ministry publishes no fee for EDM registration or for the annual report. The cost there is the two to three weeks of waiting.

For the contrast, a country in the same market-price family but with ten competing systems and no representative obligation on the registration step itself is covered in our German registration guide; a country where the whole schedule is published in advance is in our Dutch guide.