Stupid Austria packaging-recycling law

Background info

We do pay for recycling all cardboard and plastic we buy or import.
We do send proof of the amount we licensed to the German authorities.

Sadly, there is no European licensing.
That’s obviously bad with 27 EU countries.

We have absolutely no problem doing the same for the cardboard and plastic our shipment to Austria make up.
It’s a tiny amount. Licensing it is not overly expensive and after serveral weeks of research, easy to do. The price is mainly made up of an administrative fee per license. The actual amount of licensed material is mere cents.
Just even more yearly bureaucracy to handle.

The problem

The problem is not licensing our materials for recycling in Austria.
The problem is that Austria demands a company in Austria to act as a representative.
§ 16b Verpackungsverordnung 2014 „Bevollmächtigter für ausländische Versandhändler (Verpackung)“..“

There is no minimum or threshold anymore
They demany this the very moment any business sends a single paper envelope to Austria.
There was a Minimum business size called „Kleinstabgeber“ but is it discontinued 2022-12-31.

And enlisting with any Austrian representative („Bevollmächtigter“) is really expensive.
While the recycling makes up 40-80ct (mainly due to a minimum administrative fee),
we would have to charge an additional 8€ per delivery to Austria to offset this.


Insted of 8,8€, we will raise the shipping prices for Austrian customers by 3.10€ per parcel to offset a part of this additional cost.
Starting with February update to shipping prices because DHL lowered it’s monthly „energy surcharge“ for German destinations.
All non-recurring cost for registration will thus be paid by us (and thus by all customers collectively) and the recurring cost is distributed based on the amount of parces to Austria we shipped before the Covid-19 pandemic, supply chain issues and global recession.

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