Romania EPR

What is Romania EPR Packaging

Extended Producer Responsibility (EPR) in Romania is a regulatory system that requires companies to take financial and operational responsibility for the management of packaging waste they place on the market. This framework is governed by Law 249/2015 on packaging and packaging waste, along with subsequent amendments and government ordinances. In alignment with the EU Packaging and Packaging Waste Regulation (PPWR), the Romanian system ensures that producers contribute to national recycling and recovery targets. The primary body managing environmental data and compliance is the Environmental Fund Administration (Administrația Fondului pentru Mediu - AFM).

Does this apply to e-commerce & online sales

Yes, EPR rules apply to all forms of distance selling. Foreign e-commerce companies and online marketplaces that ship packaged products directly to Romanian consumers (B2C) are considered producers. They are responsible for the packaging of the goods as well as the shipping packaging (tertiary packaging) used for delivery. Under the updated PPWR rules, marketplaces must verify that third-party sellers are registered and compliant to allow them to continue selling in the region.

Who is the “producer” under Romania EPR?

A "producer" in Romania is defined as any legal entity that first places a packaged product on the national market. This includes:

1. Manufacturers based in Romania who package their own products.

2. Importers who bring packaged products from abroad into Romania.

3. Foreign distance sellers shipping directly to Romanian end-users.

4. Service providers who package goods at the point of sale.

Who must register for EPR packaging in Romania

All entities defined as producers must register with the Environmental Fund Administration (AFM). Additionally, they must fulfill their recycling and recovery obligations by either establishing an individual system or, more commonly, by contracting with a licensed Producer Responsibility Organization (PRO). Registration is mandatory regardless of whether the company is located in Romania or abroad.

Romania EPR Packaging Registration Threshold

Romania operates a zero threshold policy for EPR registration and reporting. Every company placing packaging on the Romanian market must comply from the first gram of material. While there is no minimum volume to trigger the registration requirement, a punitive tax of 2 RON per kilogram is applied to the Environmental Fund for any portion of the mandatory recycling targets that a producer fails to meet.

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Packaging Covered (and Excluded)

The EPR system covers all types of packaging placed on the market:

• Primary (Sales) packaging: The immediate wrap for the consumer.

• Secondary (Grouped) packaging: Used to group products.

• Tertiary (Transport) packaging: Used for shipping (pallets, stretch film, boxes).

Materials include plastic (including PET), paper/cardboard, glass, metals (steel/aluminum), and wood. Exclusions are only granted for specific specialized items like medical packaging or certain hazardous material containers covered by other waste streams.

Producer Responsibility Organization (PRO)

In Romania, the collective fulfillment of obligations is handled by several licensed PROs (also known as OIREP). Notable organizations include:

• Eco-Rom Ambalaje

• Fepra

• Clean Recycle

• GreenPoint Management

• Eco Synergy

These organizations collect fees from producers to fund the national collection, sorting, and recycling infrastructure.

EPR Registration in Romania

The registration process involves:

1. Identifying packaging materials and annual volume estimates.

2. Appointing an Authorized Representative (mandatory for non-resident companies).

3. Signing a contract with a licensed PRO to transfer recovery obligations.

4. Registering with the Environmental Fund Administration (AFM) to obtain a unique producer ID.

Authorized Representative

For foreign companies (non-residents) selling into Romania, the appointment of a local Authorized Representative (AR) is mandatory. The AR must be a legal entity based in Romania that assumes the legal responsibility for the producer's registration, data reporting to the AFM, and ensuring the payment of eco-fees and potential taxes to the Environmental Fund.

What Data Must Be Reported

Producers must report detailed information via their PRO or directly to the AFM:

• Total weight (in kg) of packaging placed on the market.

• Material composition (plastic, paper, glass, etc.).

• Packaging type (household vs. non-household).

• Reporting must be accurate to avoid the 2 RON/kg penalty for missed recycling targets.

First Reporting Period & EPR Reporting Deadlines

Reporting in Romania is typically performed monthly.

• Monthly Declaration: Data must be submitted to the PRO and the AFM by the 25th day of the following month.

• Annual Reporting: A summary report for the entire calendar year is generally finalized alongside the December submission.

Labels & Marketing Claims

Romania adheres to EU-wide labeling standards for packaging material identification (e.g., PET 01, PAP 20). Starting in 2026, all packaging must feature harmonized labels for sorting and disposal instructions. Romania also operates a Deposit-Return System (SGR) for beverage containers, which requires a specific logo and barcode for compliance.

EPR Eco Fees & Eco-Modulation

Fees paid to the PRO vary based on the material type and current recycling market rates. In accordance with PPWR 2026, Romania is implementing eco-modulation, where fees are adjusted based on the recyclability and durability of the packaging. Higher fees apply to complex, multi-material, or non-recyclable packaging.

Risks, Penalties & Common Mistakes

Non-compliance with Romanian EPR laws can lead to:

• Fines: Ranging from RON 20,000 to RON 40,000 for failure to register or report.

• Environmental Fund Tax: A punitive fee of 2 RON per kg for any unmet recovery targets.

• Common Mistakes: Failing to report transport packaging (pallets) and missing the strict monthly reporting deadlines.

What E-Commerce Sellers Should Do Now

1. Appoint a local Authorized Representative in Romania immediately.

2. Sign a contract with a licensed PRO (OIREP) to manage recycling targets.

3. Ensure your business is registered with the Environmental Fund Administration (AFM).

4. Establish a monthly data tracking system for all packaging weights sent to Romania.

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FAQ

• No, the threshold is zero; you must comply from your first sale.

• Reporting in Romania is mandatory on a monthly basis.

• No, but as a foreign seller, you must appoint a local Authorized Representative.

• The AFM is the government authority that monitors the Environmental Fund and EPR compliance.

• Yes, for specific beverage containers, participation in the SGR is required in addition to standard EPR.