Packaging 📦 - to be compliant by 01.01.2023
You are obliged to register if you are distributing packaging that accumulates at the Austrian end consumer.
To be compliant with packaging in Austria you must follow these steps:
If you are not based in Austria - appointment of an AR
If you do not have a branch in Austria, you must first appoint an authorized representative. Most PROs operate as AR. Find a link list below.
💡 As from 01.01.2023 foreign producers have to appoint an authorized representative (AR). Most PROs also operate as AR. Find a list of PROs below. The AR will register for you.
If you are based in AT - Sign a license agreement with a recycling system (fee-based)
If you have an authorised representative in place, he/she will conclude the necessary contracts for you. Otherwise:
Choose one or more of the available recycling systems to sign an agreement or choose from a PRO below.
Determine packaging quantities by material type (paper, carton, cardboard/ plastics/ aluminium etc.) and report data.
Estimated costs 💸
Calculate your costs with the recycling systems. You can grasp an estimation with Reclay Systems here.
EEE 📱 - to be compliant by 01.01.2023
Electrical equipment may only be sold in Austria if you are have joined a recycling scheme.
💡 Austria differs the following equipment (appendix 3) here.
The only exception: If you sell equipment from other manufacturers/brands in Austria, of which you have sufficient proof that the manufacturer/supplier already reported your products to a recycling scheme (PRO).
Steps to be compliant with EEE:
Appoint foreign authorized representative (only if you have no entity in AT)
💡 The authorized representative (AR) takes over all registrations and declarations to official agencies on behalf of you.
Any business located in the concerning member state can be an authorized representative and most PROs can be appointed as AR. Find an official list of AR here.
Join a recycling scheme via a PRO
If you don’t have a branch in Austria, you need an authorized representative for this registration, otherwise you can voluntarily appoint an AR.
Receive the GLN Number, done by the PRO
The PRO does the registration for you.
Meet information and labeling requirements
Labeling: manufacturer/brand, serial number, symbol of crossed out trash can : if with sticker it must comply with DIN EN 50419 requirements
Indication of WEEE registration number: on all invoices & delivery notes
Information for consumers: Customers must be informed about the following topics:
Meaning of the crossed out trash can symbol (disposal only at collection points).
Information about collection and return points can be found.
End users are responsible for the deletion of their data (data protection).
System Participation
Principally, you must collect full containers of electronic waste from collection points at irregular intervals and dispose of them properly. This is done by the PRO/authorized representative who arrange the collection and treatment of WEEE.
Batteries🔋 - to be compliant by 01.01.2023
Portable batteries are all encapsulated batteries that can be easily held in the hand by the average person, including those contained in cell phones and must be registered separately from EEE.
Batteries in e-bikes are to be classified under the category "industrial batteries”.
Exception: If you make batteries available, of which you have sufficient proof that the manufacturer/supplier already reported the used batteries to the edm or if the batteries are demonstrably exported from Austria again.
💡 Producers or importers of portable batteries have to report for each calendar quarter on the masses of portable batteries placed and on the collected, recycled and exported waste batteries. As a rule, the reporting obligations are transferred to a collection and recovery system, therefore it is also essential to conclude with a PRO who takes over these obligations for you!
Producer of batteries?
A producer is anyone who commercially distributes
portable/industrial batteries
directly to end consumers in Austria
by means of distance communication technology and
is established in another Member State or in a third country.
💡 If you are based in Austria and distribute batteries to an Austrian end consumer, you are not considered a producer, unless the batteries have not been registered yet. On the contrary, if you are not based in Austria and sell batteries to an Austrian end consumer, you are considered a producer and must register these batteries.
This makes sense considering, that the battery is likely to be put to waste in Austria and since this generates waste-costs, anyone who distributes the battery for the first time in another state, is (extended) responsible for these costs.
You must follow these steps:
Appoint foreign authorized representative (only if you have no entity in AT).
💡 The authorized representative (AR) takes over all registrations and declarations to official agencies on behalf of you.
Any business located in the concerning member state can be an authorized representative and most PROs can be appointed as AR. Find an official list of AR here.
System Participation
You must participate to a collection center for batteries. This is done by the PRO/authorized representative who arrange the collection and treatment of batteries.
Get a GLN Number, done by the PRO.