Selling to Austria: Is the German packaging licence enough?

Why the German packaging licence is not enough

No. A German packaging licence only covers packaging you place on the market in Germany. For shipments to private end customers in Austria, you need a separate solution under Austrian law. The Austrian Packaging Ordinance 2014 expressly also covers packaging that a distance seller without a seat or branch in Austria hands over to private end consumers by distance selling. The obligation to appoint an authorised representative for this has applied since early 2023. It is not a new obligation of 2026. (As of: September 2026)

Your German system participation remains important nonetheless. It covers the packaging volumes arising in Germany and presupposes that you are registered in LUCID, license a dual system and report volumes. Across the border, it has no effect. A German system agreement does not release any packaging placed on the market in Austria from its obligations.

Appointment of an authorised representative with a seat in Austria
System participation through an Austrian collection and recovery system
Reporting of the packaging volumes placed on the market
Evidence you can present in the event of an inspection

Whether and in what form these obligations apply to your shop depends on your role and your delivery route. For online retailers selling into several countries, a clear classification is worthwhile before the first parcel heads to Austria. Check which shipments go to private customers in Austria and which packaging volumes they account for.

When you count as a foreign distance seller

The Austrian rules apply three criteria to packaging. All three must come together for you to count as a foreign distance seller and for the appointment of an authorised representative to become mandatory:

You have neither a registered office nor a branch in Austria.
The sale takes place by distance selling, i.e. via your own webshop or a marketplace.
You hand over packaging or packaged goods to private end consumers in Austria.

You can check all three criteria against your own business. Which delivery address appears at checkout, a private household or a company address? Do you sell via your own platform or via a marketplace? Who takes ownership of the goods before the border? These questions determine which role you take on in Austria.

One counter-case for clarification: if an independent Austrian retailer or wholesaler already delivers in Germany and takes the goods to Austria itself, you are not a foreign distance seller for those consignments. The retailer takes the goods into its own responsibility and needs its own role assessment. A B2B delivery to an Austrian reseller is also not a blanket exemption from all packaging obligations. It is classified separately: under the Austrian ordinance, an authorised representative is possible but not mandatory for foreign persons who distribute packaging to parties other than private end consumers. Article 45 of the PPWR has its own representation rule for producers not established in the member state, so check that route as well.

Assess authorised representation and system participation separately

Two steps, two proofs. One does not evidence the other. For registration as an authorised representative, the Austrian business service portal names four requirements:^[1]

The authorised representative is a natural or legal person with a registered office in Austria.
A domestic delivery address is available.
Responsibility for compliance with Austrian administrative regulations is in place.
The appointment is made by a certified power of attorney in German or English.

The power of attorney must show the scope of the authorisation, the authorised representative's express consent, and the contractual assurance that they may conclude contracts and receive the necessary documents and resources. The procedure runs via edm.gv.at: the authorised representative registers there and submits the power of attorney to the BMLUK. After a positive review and registration in ZAReg, the designation as authorised representative follows. Changes to the authorisation appear in the EDM system only after the end of a calendar quarter. However, the authorised representative may act as soon as the appointment takes effect under civil law.

System participation is a separate contract with an approved collection and recovery system. Each system sets its contributions on the basis of the packaging; promises on prices or processing times do not belong in your planning. Participation must be confirmed to customers as legally binding. Assess both separately: an entry as an authorised representative is not proof of a system contract, and a system contract does not replace a power of attorney.

Which documents should be ready before shipping

Put together your evidence package before the first consignment goes to an Austrian private customer. It includes:

the certified power of attorney for the Austrian authorised representative
proof of registration in ZAReg or in the EDM
the system contract with the Austrian collection and recovery system, including the licence number
records of material and quantity per packaging

A clarification on the term EDM: EDM is the administrative environment in which registration and reporting take place. The term is not a synonym for paying a system contribution. Anyone who merely holds an EDM account has not yet paid for system participation.

The authorised representative must report the quantities of packaging placed on the market by the principal.^[1] Do not confuse that duty with the annual packaging report in the EDM: the Austrian business service portal names a deadline of three months after the end of the calendar year for it, but that report is addressed to large waste generators and direct importers, not to a distance seller's representative.^[2] Keep your quantity records so that they can support whichever report applies to you. Do not rely on second-hand portal instructions; rely on the evidence named above.

Austrian obligations under the PPWR

Regulation (EU) 2025/40, the PPWR^[3], entered into force on 11 February 2025 and has applied generally since 12 August 2026^[4]. The Austrian representation obligation for foreign distance sellers existed before that, since the start of 2023^[1]. The PPWR did not introduce it, but it now sits alongside it.

Settled: since 12 August 2026, Article 44 of the PPWR requires registration in the producer register of every member state in which you first make packaging available, and Article 45 requires a producer that is not established in that member state to appoint an authorised representative for extended producer responsibility there.
Still open: The national implementation and reporting forms in Austria are still being worked out.
Still open: Concrete future contributions or procedures have not been fixed.

Even under the PPWR, a German registration does not become an Austrian one. Which role you hold and which obligations route applies is decided by your individual combination of product, role, sales channel and target country. These distinctions cannot reliably be resolved through a general checklist alone. Bring your product and delivery data to a consultation with ClearoSystems to determine the applicable route for your company.

Frequently asked questions about shipping to Austria

The three questions we receive most often on this topic. Our EPR FAQ brings together further context.

Does my German system contract also cover shipments to Austria?

No. The German contract licenses only packaging placed on the market in Germany. For shipments to private customers in Austria, you need system participation under Austrian law.

When do I need an authorised representative in Austria?

When you have no seat or establishment in Austria and hand over packaged goods sold by distance to private end consumers there. This obligation has applied since early 2023. For deliveries to parties other than private end consumers, appointing a representative is not mandatory under the Austrian ordinance, but Article 45 of the PPWR has applied since 12 August 2026 and carries its own representation rule; in every case, the role must be classified separately.

Which documents should I have ready before the first shipment?

The certified power of attorney, proof of registration in ZAReg or in the EDM, the system contract with the Austrian system including the licence number, and records of material and quantity per packaging unit.

Whether your situation triggers the distance-seller role depends on your products, your role in the supply chain and your sales channel. A general classification cannot replace these facts. To clarify which requirements apply in your case, request a consultation with ClearoSystems. Bring the relevant product and supply chain documents with you. We will classify your situation, support the implementation and keep track of how the legal situation develops for you.

Frequently asked questions

Does my German system contract also cover shipments to Austria?: No. A German system contract covers only packaging placed on the market in Germany. Under § 2 of the Austrian Packaging Ordinance 2014, packaging delivered to Austria by a distance seller without a seat in Austria is also subject to the Austrian ordinance. For these quantities, you need your own system participation in Austria.
When do I need an authorised representative in Austria?: Appointment is mandatory if you have no seat or establishment in Austria and hand over packaging or packaged goods sold by distance to private end consumers in Austria. This obligation has applied since early 2023. If you deliver to parties other than private end consumers, for example an independent reseller, appointment is not mandatory under the Austrian ordinance, but Article 45 of the PPWR carries its own representation rule since 12 August 2026, and the role must be examined separately.
Which documents should I have ready before the first shipment?: The certified power of attorney in German or English, proof of registration in the EDM or ZAReg, the system contract with the approved collection and recovery system including the licence number, and records of material and quantity per packaging unit. Note that the EDM is the administrative environment for registration and reporting, not proof of payment of a system contribution.