Romania EPR

What is Romania EPR EEE

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment (EEE) in Romania is a legal framework that places the financial and organisational responsibility for end-of-life collection, treatment, recycling, and disposal of waste electrical and electronic equipment (WEEE) on the companies that manufacture or first introduce those products onto the Romanian market. The obligation exists throughout the full lifecycle of EEE, including the waste phase.

The Romanian legal framework for WEEE has been in place since 2006, when Romania first transposed the original EU WEEE Directive. The current operative legislation is Government Emergency Ordinance No. 5/2015 on Waste Electrical and Electronic Equipment (OUG 5/2015), which transposed EU Directive 2012/19/EU into Romanian national law. This ordinance underwent a fundamental revision through Law No. 127/2024, which entered into force on 17 May 2024 and introduced the most significant changes to Romania's WEEE framework since 2015.

Law No. 127/2024 restructured obligations for producers, collective organisations, and treatment operators, introduced per-category minimum collection rates for the first time, and tightened the conditions for licensing collective schemes. From 1 January 2025, the new provisions on collective organisation licensing and staged per-category collection rates became applicable. Romania is also required to transpose amending Directive (EU) 2024/884, which member states must implement by 9 October 2025, clarifying producer responsibility for photovoltaic panels and updating labelling standards to reference EN 50419:2022.

The broad aim of the Romanian WEEE regime is to ensure producers — not consumers or the state — finance the proper management of electronic waste, in line with the polluter pays principle embedded in EU environmental law.

Does This Apply to E-Commerce & Online Sales

Yes. Romania's WEEE legislation applies to all companies that place EEE on the Romanian market, regardless of the channel through which that supply takes place. The obligation arises from the act of first making EEE available in Romania, not from having a physical presence there.

Distance sellers and cross-border e-commerce operators that sell EEE directly to Romanian end consumers from abroad are treated as producers under OUG 5/2015 and carry the same registration, reporting, and financial obligations as domestically established manufacturers and importers. There is no carve-out for online-only or low-volume foreign sellers.

This position reflects the EU-wide interpretation of the WEEE Directive: any company using distance communication to supply EEE to consumers in a member state where it has no physical establishment is considered a producer in that member state and must either register directly (where possible) or appoint an Authorized Representative to fulfil its obligations on its behalf.

Online marketplace platforms have also come under increasing scrutiny across EU member states. Since 2023, major platforms such as Amazon have implemented verification requirements to ensure that sellers listing regulated EEE hold valid national registrations. Sellers that are not registered with the National Agency for Environmental Protection (ANPM) risk being removed from marketplace listings, in addition to facing direct regulatory penalties.

Who is the "Producer" Under Romania EPR?

Under OUG 5/2015, as amended by Law No. 127/2024, the term "producer" (producător) has a broad definition covering any entity that first places EEE on the Romanian market under its own name or trademark, regardless of the sales channel. The following categories of companies qualify as producers:

1. Domestic manufacturers that produce EEE in Romania and supply it on the local market under their own brand.
2. Importers that bring EEE manufactured outside Romania — whether from other EU member states or third countries — and place it on the Romanian market.
3. Brand owners and private label operators that sell EEE under their own name, even where the physical manufacturing is outsourced.
4. Distance sellers — including foreign e-commerce companies — that supply EEE directly to Romanian end consumers using distance communication techniques, regardless of whether they are established in Romania.
5. Foreign companies selling into Romania that have no legal entity registered in the country. Such companies are required to appoint an Authorized Representative in Romania to discharge their legal obligations.

Under Law No. 127/2024, producers retain responsibility for EEE throughout the full product lifecycle, including the waste phase. Critically, a producer may not transfer responsibility for the same EEE category to more than one collective organisation. The law also clarified that when a contract between a producer and a collective organisation is terminated, the collective organisation remains liable for managing the WEEE corresponding to quantities of EEE that had already been financed by that producer during the contract period.

Who Must Register for EPR EEE in Romania

All producers of EEE must register with the National Register of EEE Producers maintained by the National Agency for Environmental Protection (ANPM — Agenția Națională pentru Protecția Mediului). Registration must take place before EEE is first placed on the Romanian market. Operating without a valid registration number is a breach of OUG 5/2015 and exposes the producer to administrative sanctions.

Upon successful registration, ANPM issues a registration number that the producer must communicate to all sales channels and distributors through which its products are sold in Romania. This number serves as proof of compliance for retailers, distributors, and marketplace platforms.

Registration is conducted through ANPM's Integrated Environmental System, accessible via the SIM-EEE application at raportare.anpm.ro. Producers must complete the application using the EEE subdomain and Annex 01 (producers) within the system.

The Environmental Fund Administration (Administrația Fondului pentru Mediu — AFM) plays a parallel role as the body that certifies compliance with collection targets and to which financial contributions (penalties) are owed when annual targets are not met. Certain reporting and financial interactions with the system are also directed through AFM.

Foreign companies without a Romanian-registered legal entity cannot register directly and must do so through an Authorized Representative established in Romania (see the Authorized Representative section below).

Romania EPR EEE Registration Threshold

Romania applies no de minimis threshold for EEE EPR. All producers placing any quantity of EEE on the Romanian market are required to register with ANPM, regardless of the volume or value of EEE placed on the market. There is no minimum weight, unit count, or turnover figure below which a company would be exempt from the registration obligation.

The absence of a threshold reflects the structure of OUG 5/2015 and its implementing provisions. Every producer, from the largest consumer electronics brand to a small specialist importer, carries the full set of registration, reporting, and financial obligations from the first unit placed on the market.

This zero-threshold approach is a significant compliance consideration for foreign e-commerce sellers who may assume that small volumes into Romania create no obligations. They do. Whether a producer manages its obligations individually or through a collective organisation, registration is mandatory and pre-market.

EEE Categories Covered (and Excluded)

Romania's WEEE framework incorporates the EU's open-scope approach, which has applied since 15 August 2018. Under this framework, all EEE is covered unless it falls within a specific listed exclusion. The legislation uses the six-category classification structure introduced by the recast WEEE Directive:

1. Temperature exchange equipment — refrigerators, freezers, air-conditioning units, heat pumps, dehumidifiers, and other equipment used for temperature exchange.
2. Screens and monitors — televisions, computer monitors, laptop computers, notebooks, and tablet computers, where the screen surface exceeds 100 cm².
3. Lamps — fluorescent lamps, LED lamps, high-intensity discharge lamps, compact fluorescent lamps, and other light-emitting devices (excluding incandescent bulbs where still permitted).
4. Large equipment — washing machines, dishwashers, large medical imaging devices, large industrial tools, large IT and telecommunications equipment, and any equipment where at least one external dimension exceeds 50 cm.
5. Small equipment — vacuum cleaners, microwaves, small tools, smoke detectors, thermostats, small medical devices, small leisure and sports equipment, and similar; all external dimensions are 50 cm or less.
6. Small IT and telecommunications equipment — mobile phones, GPS devices, pocket calculators, routers, personal computers, printers, and similar equipment; all external dimensions are 50 cm or less.

Romania's national legislation also references the pre-2018 ten-category framework (large household appliances, small household appliances, IT and telecommunications equipment, consumer electronics, lighting equipment, electrical and electronic tools, toys and leisure equipment, medical devices, monitoring and control instruments, and automatic dispensers) in the context of older scheme contracts and historical reporting. However, the operative scope for new compliance purposes is the open-scope six-category approach.

Photovoltaic panels are covered under Romania's WEEE framework. Law No. 127/2024 expressly excludes photovoltaic panels from the new per-category minimum collection rate obligations introduced from 2025, but they remain regulated products subject to producer registration and take-back obligations. Directive (EU) 2024/884, which Romania must transpose by 9 October 2025, confirms that responsibility for waste from photovoltaic panels placed on the market after 13 August 2012 lies with the producer of the EEE.

Exclusions under the Romanian framework include equipment designed for military or national security purposes, equipment destined for space, large-scale fixed industrial installations and large-scale stationary infrastructure, means of transport (excluding electric two-wheel vehicles not type-approved), non-road mobile machinery available exclusively for professional use, active implantable medical devices, and equipment specifically designed for research and development purposes made available on a business-to-business basis only.

Producer Responsibility Organization (PRO)

Romania operates a collective organisation (organizație colectivă) model. Producers may fulfil their WEEE obligations either individually — by establishing their own take-back and management systems — or collectively, by contracting with a licensed collective organisation (the Romanian equivalent of a PRO). The vast majority of producers use the collective route in practice.

Collective organisations are authorised by the Ministry of Environment, Waters and Forests (Ministerul Mediului, Apelor și Pădurilor) and must meet stringent licensing conditions. Law No. 127/2024 introduced significant new requirements for collective organisations from 1 January 2025, including:

• A minimum market share of at least 5% for at least one authorised EEE category, certified by AFM.
• A financial guarantee of RON 2 million (approximately EUR 400,000) in favour of AFM, valid for the entire licence period, to secure payment of fiscal contributions to AFM when collection targets are not met.
• Financial provisions covering 100% of the management costs for all EEE financed by their producer members, regardless of when the WEEE arises.
• Founding membership and shareholding restricted exclusively to EEE producers registered with ANPM that do not themselves hold authorisations for WEEE collection and treatment.

All existing collective organisations were required to seek relicensing under these new criteria as of 1 January 2025. The principal collective organisations active in the Romanian EEE market include:

1. ECOTIC — Romania's first PRO for electronic waste, founded in 2006. ECOTIC represents over 600 affiliated producers and importers and has collected and recycled in excess of 320,000 tonnes of WEEE since its establishment. ECOTIC introduced the Green® Stamp, a voluntary compliance symbol for WEEE management.
2. Environ Association — a non-governmental, non-profit organisation founded in 2007. Environ manages approximately 20% market share of the Romanian EEE market, representing around 900 producers and importers.
3. RECOLAMP — a collective organisation specialising in the lighting equipment category (lamps).
4. ARCwaste — a newer collective scheme also active in the WEEE space.

A producer may not contract the same EEE category to more than one collective organisation simultaneously. When changing collective organisations, producers should be aware that the former scheme retains liability for managing WEEE corresponding to previously financed EEE quantities.

EPR Registration in Romania

The registration process for EEE EPR in Romania involves the following steps:

1. Classify your EEE products. Identify which of the six EEE categories your products fall into. This classification determines the applicable collection targets, collective organisation selection, and eco-fee rates.
2. Appoint an Authorized Representative (for foreign companies). If your company has no legal entity registered in Romania with a Romanian tax identification number, you must appoint an Authorized Representative before registration can be completed. The AR acts as your legal contact with ANPM, AFM, and the collective organisation.
3. Register with ANPM via the SIM-EEE system. Access the online registration portal at raportare.anpm.ro, select the Waste domain and EEE subdomain, and complete the application using Annex 01 (producers). Upon completion, ANPM issues a user account and access credentials for the SIM-EEE reporting application. Registration must be completed before the first EEE is placed on the market.
4. Obtain your ANPM registration number. Once registered, ANPM issues an official EEE producer registration number. This number must be communicated to all sales channels, distributors, and retailers in Romania.
5. Select and contract with a licensed collective organisation. The producer (via the AR for foreign companies) signs a contract with an authorised collective organisation for each relevant EEE category. The collective organisation assumes responsibility for meeting collection, treatment, and recycling targets on the producer's behalf.
6. Register with AFM. Interaction with the Environmental Fund Administration is required for the financial aspects of compliance — specifically, reporting quantities placed on the market and making fiscal contributions to AFM when collection targets are not met.
7. Communicate eco-fees to buyers. From the date of Law No. 127/2024 entry into force, producers are required to communicate the environmental management fee (eco-fee) for each EEE category to potential buyers prior to the point of sale, in addition to displaying the fee separately on invoices and website order pages.
8. Begin reporting. Ongoing reporting through the SIM-EEE system is required, covering quantities of EEE placed on the market per category and volumes of WEEE managed.

Authorized Representative

Under OUG 5/2015, foreign companies that place EEE on the Romanian market without a locally registered legal entity must appoint an Authorized Representative (reprezentant autorizat) established in Romania. This requirement is rooted in the EU WEEE Directive and has applied in Romania since the original transposition of that directive.

Importantly, Romania requires foreign companies to appoint not only an Authorized Representative for environmental compliance purposes but also a Tax Representative to fully cover their reporting and registration duties with the national producer register and with collective take-back schemes. The AR handles the environmental compliance aspects — registration with ANPM, contracting with the collective organisation, and environmental reporting — while the Tax Representative manages fiscal reporting and payments to AFM.

The Authorized Representative must be a legal entity established and registered in Romania. It assumes legal accountability for the foreign producer's compliance obligations in Romania and acts as the primary point of contact for ANPM, AFM, and the collective organisation. Key responsibilities of the AR include:

1. Registering the foreign producer in ANPM's National Register of EEE Producers via the SIM-EEE system.
2. Signing and maintaining a contract with a licensed collective organisation on behalf of the producer.
3. Reporting quantities of EEE placed on the Romanian market through the SIM-EEE application.
4. Representing the producer before Romanian authorities in administrative matters, audits, and enforcement proceedings.
5. Monitoring legislative changes affecting the producer's obligations in Romania.

The AR requirement applies regardless of the volume of EEE placed on the Romanian market. There is no minimum threshold below which the requirement is waived for foreign companies.

Regarding EU-level developments: in December 2025, the European Commission proposed a suspension of the AR obligation for EU-based companies until 2035 (COM(2025) 983). If adopted, this would remove the AR requirement for, for example, a German company selling into Romania. However, this proposal had not yet been formally adopted as of the date of this guide. Until it is, the existing rules continue to apply. Non-EU companies (UK, US, and other third-country sellers) would remain subject to the AR requirement even if the proposal is adopted.

What Data Must Be Reported

Producers registered with ANPM and contracting with a collective organisation are required to collect and report the following data:

1. Quantities of EEE placed on the Romanian market, reported by EEE category and measured in kilograms. This data is the basis for calculating the collective organisation's collection obligations, the producer's share of responsibility, and any fiscal contributions due to AFM.
2. Annual reports via the SIM-EEE application — submitted to ANPM through the online system, covering all EEE placed on the market during the preceding calendar year, disaggregated by category.
3. Quantities of WEEE managed — collected, treated, recycled, recovered, and disposed of, reported per category and in kilograms, either through the collective organisation or individually.
4. Eco-fee amounts — the environmental management fees applied per category of EEE, which must be disclosed to buyers prior to the point of sale and shown separately on invoices. These must be maintained accurately in internal records.
5. Documentation supporting compliance — contracts with the collective organisation, evidence of WEEE management, and records substantiating the figures reported to ANPM and AFM.
6. Collective organisation reports — the collective organisation reports to ANPM and AFM on behalf of its member producers regarding total WEEE collected and managed. However, producers remain individually responsible for ensuring the accuracy of the data they supply to the collective organisation.

First Reporting Period & EPR Reporting Deadlines

Obligations begin from the first moment EEE is placed on the Romanian market. Registration with ANPM must be completed and the ANPM registration number obtained before any products are sold into Romania.

Key recurring deadlines:

1. Annual report to ANPM — producers and acquirers submit annual reports on WEEE management for the preceding calendar year through the SIM-EEE application. Reports must be filed by 31 March of the following year. The collective organisation submits a joint management report to ANPM on behalf of all its member producers.
2. Eco-fee disclosure — ongoing obligation to disclose the management fee per EEE category to buyers prior to sale and on invoices; there is no specific annual deadline, but the disclosure must be accurate and current at all times.
3. Collection target compliance — the national collection target is 65% of the average weight of EEE placed on the Romanian market in the three preceding calendar years. Under Law No. 127/2024, additional per-category minimum collection rates apply from 1 January 2025, staged as follows: at least 15% from 1 January 2025, at least 20% from 1 January 2026, at least 30% from 1 January 2027, at least 40% from 1 January 2028, and at least 50% from 1 January 2029 (excluding photovoltaic panels). These per-category targets are in addition to — not instead of — the overall 65% national target.
4. Fiscal contributions to AFM — when the annual collection targets are not met, producers and collective organisations are required to pay a contribution to AFM. The current rate is RON 2 per kg of the shortfall between the target and actual WEEE managed, with the exception of lighting equipment, for which the rate is RON 4 per kg. These contributions are assessed and collected on an annual basis by AFM.

For a foreign company that begins placing EEE on the Romanian market during the course of a calendar year, the obligation to register and appoint a collective organisation applies from the first placement. The first annual report to ANPM covers that partial year and is due by 31 March of the following year.

Labels & Marketing Claims

EEE placed on the Romanian market must comply with mandatory labelling requirements under OUG 5/2015 and the WEEE Directive:

1. Crossed-out wheeled bin symbol (WEEE symbol) — all EEE must bear the crossed-out wheeled bin symbol, affixed to the product in a legible and indelible manner. If the size or intended use of the equipment makes it impractical to mark the product directly, the symbol must appear on the packaging, in the user manual, or on the warranty or guarantee document. This symbol communicates to users that the product must not be disposed of as unsorted municipal waste and is eligible for separate collection.
2. Date marking — the product marking must indicate that the EEE was placed on the market after 13 August 2005, which is the reference date from which producer responsibility obligations attach. This date indication, together with the producer's name, must comply with the European standard referenced in the legislation. Following the adoption of Directive (EU) 2024/884, this standard has been updated to EN 50419:2022, which Romania must incorporate into its national labelling requirements by 9 October 2025.
3. Producer identification — the producer's name must be clearly identifiable on the equipment or its labelling.
4. Eco-fee disclosure — under Law No. 127/2024, producers must disclose the environmental management fee applicable to each EEE category to potential buyers prior to the point of sale. For distance sellers and e-commerce operators, this means the eco-fee must be displayed visibly on the product page or order page, separately from the product price, before the customer completes a purchase. On invoices, the eco-fee must be listed as a separate line item. This obligation was expanded by Law No. 127/2024 from applying only at the invoice stage to applying also at the pre-sale stage.
5. Hazardous substance restrictions — EEE placed on the Romanian market must comply with the restrictions on hazardous substances under Directive 2011/65/EU (RoHS), implemented in Romania through corresponding national legislation. Products containing lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB), or polybrominated diphenyl ethers (PBDE) above permitted thresholds may not be placed on the market.

Green and sustainability claims made in connection with EEE are subject to general Romanian and EU rules on misleading commercial practices. Claims about recyclability or environmental performance should be substantiated and consistent with the product's actual characteristics.

EPR Eco Fees & Eco-Modulation

Romania's EEE EPR system uses a weight-based financial contribution model. Producers pay fees to their contracted collective organisation based on the quantity and category of EEE placed on the Romanian market. These fees cover the collective organisation's costs for collecting, transporting, treating, recycling, and disposing of WEEE on behalf of its member producers.

Collective organisation fees: The specific per-kg rates vary by collective organisation and by EEE category, reflecting the relative cost of managing different product types. Cooling and refrigerating equipment, for example, requires more complex and costly treatment than simple small appliances. Fee schedules are set in the contract between the producer and the collective organisation and are typically reviewed annually.

AFM fiscal contributions for non-compliance: Where the annual collection targets are not met — either at the national level or at the per-category level introduced from 2025 — a fiscal contribution is owed to AFM. Under current legislation, this contribution is RON 2 per kg of the gap between the target and the actual volume managed, except for lighting equipment, for which the rate is RON 4 per kg. This contribution is treated as a fiscal obligation with a tax character, not merely an administrative penalty. Its payment by the collective organisation does not extinguish the underlying obligation to actually collect and recycle the WEEE.

Eco-fee disclosure obligation: As noted in the labelling section, producers must separately itemise the environmental management fee on invoices and display it to potential buyers before sale. The eco-fee is not a government-mandated fixed rate but is set by each collective organisation and passed through by the producer. The fee must accurately reflect the actual management cost for the relevant EEE category.

Eco-modulation: Romania has not implemented a formal eco-modulation framework that adjusts fees based on product design attributes such as recyclability, repairability, or use of recycled materials. Fees are determined primarily by the weight and category of EEE placed on the market. Future regulatory developments at EU level — including the full review of the WEEE Directive mandated by the end of 2026 — may introduce harmonised eco-modulation requirements across member states.

Risks, Penalties & Common Mistakes

The following compliance failures are the most frequently observed among foreign companies entering the Romanian EEE market:

1. Selling EEE without ANPM registration. Operating without a valid registration number is a direct breach of OUG 5/2015. Penalties include administrative fines and, in serious or repeated cases, prohibition on placing products on the Romanian market.
2. Failing to appoint an Authorized Representative and Tax Representative. Foreign companies without a Romanian legal entity that register without appointing both an AR and a Tax Representative have incomplete compliance coverage. The AR handles environmental obligations; the Tax Representative handles fiscal reporting to AFM. Omitting either role creates gaps in legal coverage.
3. Contracting one collective organisation for multiple EEE categories and then changing organisations. Under Law No. 127/2024, a producer may not transfer responsibility for the same EEE category to more than one organisation simultaneously. When contracts are terminated, the former organisation remains liable for previously financed WEEE. Producers should understand this before moving between schemes.
4. Underreporting EEE placed on the market. Inaccurate volume reporting reduces the collective organisation's financial resources for WEEE management and distorts the calculation of the national collection target shortfall. Underreporting is a regulatory breach and can trigger audits.
5. Failing to display eco-fees to buyers before sale and on invoices. Law No. 127/2024 expanded this obligation to the pre-sale stage. E-commerce operators that do not show the eco-fee separately on their product pages or order confirmation screens are in breach of the disclosure requirements applicable from May 2024.
6. Missing the 31 March annual reporting deadline. Late or absent SIM-EEE reports are a direct breach of the ordinance. ANPM may apply administrative sanctions for late filing.
7. Assuming the collective organisation manages all risks. Under Law No. 127/2024, producers retain responsibility throughout the EEE lifecycle, including the waste phase. Choosing a collective organisation that fails to meet its authorisation obligations or is unable to pass the relicensing process from January 2025 could expose producers to direct liability for unmanaged WEEE contributions to AFM.
8. Labelling non-compliance. Products missing the crossed-out wheeled bin symbol, producer identification, or the required date indicator are non-compliant. Following Romania's transposition of Directive (EU) 2024/884 by 9 October 2025, products must also reference the updated standard EN 50419:2022.

Enforcement is carried out by the National Environmental Guard (Garda Națională de Mediu) and ANPM, with AFM responsible for the fiscal contribution mechanism. Penalties under OUG 5/2015 include administrative fines and, for more serious breaches, prohibition on placing products on the market.

What E-Commerce Sellers Should Do Now

Companies placing or planning to place EEE on the Romanian market should take the following steps as a priority:

1. Determine whether your products fall within the scope of OUG 5/2015 using the six-category open-scope EEE classification.
2. Appoint an Authorized Representative and a Tax Representative, both established in Romania, before placing any products on the market or initiating registration.
3. Register with ANPM via the SIM-EEE system (raportare.anpm.ro) through your AR and obtain your official EEE producer registration number.
4. Select a licensed collective organisation for each relevant EEE category and execute the required contracts. Verify that the organisation has successfully obtained or maintained its licence under the new conditions introduced by Law No. 127/2024 from January 2025.
5. Communicate your ANPM registration number to all Romanian distributors, retailers, and marketplace partners.
6. Implement processes to display eco-fees separately on product pages, order confirmations, and invoices before sale, in compliance with Law No. 127/2024.
7. Set up internal volume tracking to record EEE placed on the Romanian market by category and by weight, as this data underpins annual reporting and collective organisation fee calculations.
8. Schedule the 31 March annual reporting deadline in your compliance calendar and confirm with your AR which entity is responsible for SIM-EEE submission.
9. Verify that all EEE products bear the crossed-out wheeled bin symbol, producer identification, and the required date marking. Prepare to update labelling to comply with EN 50419:2022 following Romania's transposition of Directive (EU) 2024/884 by 9 October 2025.
10. Monitor the staged per-category minimum collection rate obligations applying from 2025 through to 2029, and assess with your collective organisation how they may affect your financial exposure under the AFM contribution mechanism.

FAQ

• Is EPR registration for EEE mandatory for all companies selling into Romania, regardless of size or volume?

Yes. There is no minimum volume threshold or turnover exemption for EEE in Romania. All producers placing any quantity of EEE on the Romanian market must register with ANPM and obtain an EEE producer registration number before their first sale. This applies to domestic manufacturers, importers, brand owners, and foreign distance sellers alike. Operating without registration is a breach of OUG 5/2015 and subject to administrative sanctions.

• Do foreign companies need a local representative to comply with Romania EEE EPR?

Yes, and uniquely, Romania requires two distinct representatives. Foreign companies without a Romanian-registered legal entity must appoint both an Authorized Representative (for environmental compliance — registration with ANPM, collective organisation contracting, and environmental reporting) and a Tax Representative (for fiscal reporting and payments to the Environmental Fund Administration). Both roles are needed to achieve full compliance coverage. Neither requirement can be waived based on low sales volumes.

• What is the eco-fee disclosure obligation introduced by Law No. 127/2024?

Law No. 127/2024, which entered into force on 17 May 2024, extended the eco-fee disclosure obligation from invoices to the pre-sale stage. Producers must now display the environmental management fee applicable to each EEE category visibly to potential buyers before they complete a purchase — on the product page or order confirmation page of an e-commerce site. The fee must also continue to appear as a separate line item on invoices. For e-commerce operators, this means the product listing itself must include the eco-fee amount, displayed separately from the product price.

• What labelling must appear on EEE products sold in Romania?

All EEE must carry the crossed-out wheeled bin symbol, affixed directly to the product in a legible and indelible manner. Where this is impractical due to product size or intended use, the symbol may appear on the packaging, user manual, or warranty document. The product must also carry the producer's name and an indication that it was placed on the market after 13 August 2005, formatted in compliance with the applicable standard (EN 50419:2022 following Romania's transposition of Directive (EU) 2024/884 by October 2025). Products must also comply with RoHS hazardous substance restrictions.

• Do online marketplaces bear compliance responsibility for WEEE in Romania, or does it rest entirely with the seller?

The primary legal obligation for EEE EPR compliance rests with the producer — the company that manufactures or imports EEE for supply on the Romanian market. Major marketplace platforms operating in the EU, including Amazon, have since 2023 implemented verification requirements under which sellers must provide proof of WEEE compliance (including a valid ANPM registration number) to maintain listings for regulated products. While the marketplace does not bear the producer's regulatory obligations, failure to register means a seller risks losing access to these channels in addition to facing direct enforcement action from Romanian authorities. Foreign sellers should ensure their ANPM registration number is current and available for platform verification before listing regulated EEE in Romania.