| Registration |
Mandatory registration with the Central Packaging Register (LUCID) before placing packaging on the market. |
Mandatory registration with an approved collection and recovery system (e.g. ARA, Reclay) before placing packaging on the market. |
DE: §9 VerpackG
AT: §13g AWG, §3 VerpackVO |
| System Participation / Licensing |
Obligation to participate in a dual system (e.g. Grüner Punkt, Interseroh) for packaging that typically ends up as household waste. |
Obligation to sign a licensing contract with an authorized collection & recycling system; fees based on material type and annual volume. |
DE: §7 VerpackG
AT: §13g AWG, §4 VerpackVO |
| Quantity Reporting |
Regular data reporting to both the LUCID register and the dual system, specifying materials and annual quantities. |
Mandatory annual reporting to the contracted collection system and documentation in the Austrian edicts database. |
DE: §10 VerpackG
AT: §13g AWG |
| Record-Keeping and Documentation |
Companies must retain documentation of system participation, contracts and reports for at least three years. |
Retention period of at least seven years; documentation must be available for inspection upon request. |
DE: §11 VerpackG
AT: §22 AWG |
| Information Duties toward Customers |
No direct obligation toward end consumers, but companies must ensure correct system participation and proper disposal routes. |
Information duty regarding return and recycling options for specific packaging types (especially transport packaging). |
DE: §15 VerpackG
AT: §3(2) VerpackVO |
| Obligations for E-Commerce |
Applies only to online sellers shipping filled packaging to end consumers (e.g. e-commerce retailers). Sellers of empty packaging are not affected. |
Same applies: online sellers sending filled packaging to Austrian customers are first distributors and must license it. Sellers of empty packaging are not affected. |
DE: §7 VerpackG
AT: §13g AWG |
| Penalties for Non-Compliance |
Fines up to €200 000 and sales ban for unregistered packaging. |
Administrative fines up to €37 000 and sales ban for non-reported packaging. |
DE: §34 VerpackG
AT: §79 AWG |