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 Austria and other smaller operators — but ARA holds the largest market share and is the most commonly used system for packaging declarations.

Critically, Austria also maintains a separate national packaging register: the ERA (Elektronische Register Austria) system, managed by the Umweltbundesamt (Austrian Federal Environment Agency). Registration in ERA is a prerequisite for ARA participation and is also used for official compliance reporting to Austrian authorities. This two-step structure — national register first, then PRO — is similar to Portugal's SIRAPA + 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 threshold for the simplified reporting track: companies placing less than 15 tonnes of packaging on the Austrian market per year may use a simplified declaration. However, registration itself is required regardless of volume.

15 tonnes of packaging is roughly 37,500 to 60,000 standard corrugated shipping boxes. Most active e-commerce brands shipping to Austria will be well below this threshold and will use simplified reporting.

How to Register: ERA + ARA

Step 1: Register in ERA (national register)

The ERA system (era.gv.at) is Austria's national packaging register. All companies placing packaging on the Austrian market must register here first. The ERA 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 receive an ERA registration number. This number is your official Austrian packaging producer ID. It is what Amazon Austria and other marketplaces will ask for.

Step 2: Register with ARA

With your ERA number, proceed to ARA (ara.at) to sign up as a system participant. ARA's registration portal links directly to ERA, so it can verify your pre-registration. You will need to provide your ERA number, 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

ERA 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 indicative rates by material:

Austria has some of the highest plastic packaging fees in the EU. At approximately €0.52 per kilogram, Austrian plastic rates exceed those of Spain (€0.295), Italy (€0.155), and Portugal (€0.320), though they are lower than Germany's top-tier plastic rates.

Eco-modulation in Austria

ARA applies eco-modulation adjustments based on the recyclability of your packaging. Packaging that meets ARA's published design for recyclability guidelines receives a discount on the base rate. Packaging that is difficult or impossible to recycle at scale receives a surcharge. The 2024 eco-modulation reform extended these adjustments across more material subcategories, so the actual rate you pay may 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 × €0.110) + (39.6 × €0.520) = €49.50 + €20.59 = €70.09 per year.

Austria has higher per-kg rates than many other EU markets, so the fee total is materially higher than Portugal or Italy for the same packaging volume.

Reporting Frequency and Deadlines

The February 28 deadline is earlier than most other EU markets. France is due at end of February too, making February a critical month for brands selling across both markets. Germany's completeness declaration is due May 15. The Austrian deadline is notably earlier than Spain (March 31) and Belgium (April 30).

Austria vs. Other DACH Market: Fee Comparison

Austria's plastic rates are significantly lower than Germany's, though Austria's cardboard rates are slightly higher. For brands with high cardboard-to-plastic ratios (typical for most e-commerce), Austria is more expensive per kg than Italy but less expensive than Germany.

Non-Austrian Companies

Foreign companies can register in ERA and with ARA directly, without needing an Austrian legal entity. The ERA portal accepts EU VAT numbers from other member states. Non-EU companies may need to obtain an Austrian fiscal identifier or appoint a fiscal representative. Several compliance service providers offer 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. The Umweltbundesamt (Federal Environment Agency) monitors ERA registrations and flags 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 are above or below 15 tonnes)
• Register in ERA at era.gv.at
• Register with ARA at ara.at using your ERA number
• Submit your annual declaration by February 28
• Pay ARA invoices within 30 days
• Provide your ERA number to Amazon and any other marketplaces that request it

Austria naturally sits in the same compliance sprint as Germany for brands covering the DACH region. Both require national register steps (LUCID for Germany, ERA for Austria) before 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.