ARA Austria: Registering and Declaring Packaging Under Austrian Packaging Law

Austria has one of the longest-running packaging EPR systems in Europe. The Altstoff Recycling Austria AG, known as ARA, was founded in 1993 — predating the EU Packaging Directive itself by a year. In the three decades since, ARA has built a comprehensive household packaging collection system and a detailed compliance infrastructure that any company placing packaging on the Austrian market must engage with.

Austria is also one of the EU countries where Amazon has most actively enforced EPR registration requirements. If you sell on Amazon.de and ship to Austrian addresses, Amazon will ask for your Austrian registration number. If you cannot provide it, your listings face restriction. Austrian compliance is not optional for any brand taking the DACH region seriously.

The Austrian Packaging Legal Framework

Austrian packaging EPR is governed by the Verpackungsverordnung (the Packaging Ordinance), most recently amended in 2021 to align with the revised EU Packaging Directive and to introduce stricter reporting requirements. The ordinance requires all companies that place packaging on the Austrian market to participate in a licensed collection and recovery system.

ARA is the dominant licensed PRO in Austria. It is licensed by the Austrian Federal Ministry for Climate Action (BMK) and operates the yellow sack/bin and collection point network across Austrian municipalities. Alternative licensed PROs exist — including Reclay UFH, Interzero, Bonus, and ERP Austria — but ARA holds the largest market share and is the most commonly used system for packaging declarations.

Critically, Austria also maintains a separate national producer registration: the EDM portal (Elektronisches Datenmanagement, edm.gv.at), operated under the federal ministry and typically accessed via the USP (Unternehmensserviceportal). EDM registration sits alongside your ARA participation and is used for official compliance reporting to Austrian authorities. This two-step structure — national register plus PRO — is similar to Portugal's SILiAmb + SPV approach.

Who Must Register

The obligation falls on the "Letztvertreiber" (final distributor) or "Inverkehrbringer" (company placing products on the market) of packaged goods sold in Austria. For e-commerce, this means:

• Any company selling packaged goods directly to Austrian consumers, regardless of the company's country of incorporation
• Importers bringing packaged goods into Austria from within or outside the EU
• Companies using fulfillment centers in Austria to ship packaged products
• Marketplace sellers on Amazon.de or Amazon.at shipping to Austrian addresses

Austria has a small-producer route: the Kleinmengenregelung under §9 VerpackVO allows flat-rate licensing for companies placing up to 1,500 kg of household packaging (plus up to 1,500 kg of commercial packaging) on the Austrian market per year. Under ARA's 2026 Tarifblatt, the flat-rate Pauschalentgelt is €150 per year, and ARA applies a minimum fee of €90 per year. Registration itself is required regardless of volume.

1,500 kg of packaging is roughly 3,750 to 6,000 standard corrugated shipping boxes. Smaller e-commerce brands shipping to Austria may fit within the flat-rate Kleinmengenregelung; brands with meaningful Austrian volume will exceed it and pay per-kilogram rates.

How to Register: EDM + ARA

Step 1: Register in EDM (national register)

The EDM portal (edm.gv.at) is Austria's national electronic data management system for producer registration, typically accessed via the USP (Unternehmensserviceportal). All companies placing packaging on the Austrian market must register here. The EDM registration captures:

• Company legal name and address
• Austrian UID (Umsatzsteuer-Identifikationsnummer, the Austrian VAT number) if you have one, or EU VAT number
• NACE/ONACE economic activity code
• Contact details for compliance correspondence
• Estimated annual packaging volumes by category

Upon completion, you have an EDM registration. This is your official Austrian packaging producer identification, and it is what Amazon Austria and other marketplaces will ask for.

Step 2: Register with ARA

With your EDM registration in place, proceed to ARA (ara.at) to sign up as a system participant. You will need to provide your registration details, company details, and an estimate of your packaging by material and level.

ARA will issue you a participation contract. Once signed and processed, you are enrolled and can begin submitting declarations.

Timeline

EDM registration typically takes 1 to 2 weeks. ARA participation setup takes a further 1 to 2 weeks. Plan for 3 to 4 weeks total from starting the process to being fully enrolled.

What to Declare

ARA declarations cover all household packaging by material category and packaging level. The Austrian system uses the following material categories:

• Paper and cardboard — corrugated boxes, folding cartons, paper bags, tissue paper, paper labels, paper tape
• Plastic — poly mailers, bubble wrap, plastic film, rigid plastic containers, EPS foam (expanded polystyrene)
• Glass — glass bottles, glass jars
• Ferrous metals — steel tins, tinplate cans, steel closures
• Aluminium — aluminium foil, aluminium lids, aluminium tubes
• Wood — wooden pallets (if reaching consumers), wooden packaging
• Composites / other — multi-material packaging, laminated pouches, mixed-material structures

Packaging is classified by level in line with EU definitions: primary (product packaging), secondary (e-commerce shipping carton for B2C), and tertiary (transport packaging). The classification of the shipping carton as secondary for direct-to-consumer shipments is the same principle that applies in other EU markets.

ARA Fee Structure for 2026

ARA fees are charged per kilogram of packaging placed on the Austrian market. The 2026 household packaging rates by material, per ARA's Tarifblatt 2026 (excluding VAT):

Austrian plastic packaging fees are among the higher rates in the EU. At €1.04 per kilogram for household plastics, ARA's rate is in the same order as Germany's typical dual-system plastic rates, and of a similar magnitude to Spain's flexible-film rate (around €1.27/kg via Ecoembes). Italy's CONAI charges plastic by recyclability band (fascia), ranging from €40 to €790 per tonne.

Eco-modulation in Austria

ARA has announced eco-modulation intentions — adjusting rates based on the recyclability of packaging — but the 2026 Tarifblatt remains a flat per-category tariff. If eco-modulated adjustments are introduced in future tariff sheets, the actual rate you pay could differ from the base rates above depending on your specific packaging types.

A worked example

You ship 1,800 orders per year to Austria. Each order includes:

• Corrugated cardboard box: 240g
• LDPE poly mailer: 22g
• Paper tissue wrap: 10g

Annual totals: cardboard 450 kg, plastic 39.6 kg.

ARA fees: (450 × €0.208) + (39.6 × €1.040) = €93.60 + €41.18 = €134.78 per year.

Austria's per-kg rates, particularly for plastics, are among the higher in the EU, so the fee total for the same packaging volume tends to be higher than in many other markets.

Reporting Frequency and Deadlines

The March 15 quantity-report deadline is earlier than Germany's completeness declaration (May 15) but later than Belgium's Fost Plus deadline (February 28). For brands selling across several EU markets, the first quarter of the year is the critical reporting window.

Austria vs. Other DACH Market: Fee Comparison

Austria's plastic rate sits within the same order as Germany's typical dual-system range, and Austria's cardboard rate is slightly higher than typical German rates. For brands with high cardboard-to-plastic ratios (typical for most e-commerce), the two DACH markets end up in a broadly similar cost bracket per kilogram.

Non-Austrian Companies

Since the 2021 Novelle to the Verpackungsverordnung (effective 1 January 2023), foreign distance sellers without an Austrian establishment must appoint a Bevollmächtigter (authorized representative) in Austria to handle their packaging obligations. This applies to EU companies as well as non-EU companies — it is a packaging-law requirement, not a fiscal one. Several compliance service providers offer authorized-representative services and pan-European EPR registration including Austria.

ARA's portal and primary communications are in German. Austria does not provide an official English-language EPR registration path, unlike some Northern European markets. Budgeting for translation or compliance consultant support is realistic if your team does not have German language capability.

Enforcement

Austrian EPR enforcement is active and multi-channel. Austrian authorities monitor producer registrations in EDM and can flag companies selling into Austria without valid registration. Austria is also one of the EU countries where Amazon most consistently enforces EPR registration requirements for sellers on both Amazon.at and Amazon.de shipping to Austrian addresses. Non-compliant sellers face listing restriction and, in egregious cases, reporting to Austrian authorities who can impose administrative fines under the Verpackungsverordnung.

The incoming PPWR regulation from August 2026 will further tighten enforcement norms across the EU. Austria, with its existing robust system, is well-positioned to enforce the new requirements quickly.

Getting Started

The checklist for Austrian packaging EPR compliance:

• Calculate your annual Austrian packaging volume from order data and packaging BOMs (check whether you fit within the 1,500 kg Kleinmengenregelung flat-rate route)
• Register in the EDM portal (edm.gv.at), typically via the USP
• Register with ARA at ara.at
• Submit your annual quantity report by March 15 (and the Anhang-3 report via EDM by March 31 where applicable)
• Pay ARA invoices within 30 days
• Provide your Austrian registration details to Amazon and any other marketplaces that request them

Austria naturally sits in the same compliance sprint as Germany for brands covering the DACH region. Both require national register steps (LUCID for Germany, EDM for Austria) alongside PRO registration. Both have active marketplace enforcement. Completing both at the same time reduces the overhead of managing two separate registration processes.

For a full picture of EPR across EU markets, the EPR compliance guide for e-commerce covers how each country's system fits into the broader EU framework. If you are registering across multiple countries simultaneously, the multi-country EPR strategy guide explains how to sequence and structure those registrations efficiently. The packaging BOM guide is the practical starting point for building the packaging data you need before any declaration can be calculated. Tools like Pack Declare automate the calculation of ARA declaration quantities from your order and packaging data.