EPR in Romania: Obligations of E-commerce Sellers 

Introduction

If you sell products to Romania, obligations arising from Extended Producer Responsibility (EPR) may affect your business sooner than you expect. In cross-border sales, companies often focus primarily on tax issues such as VAT or OSS, while overlooking local regulations regarding waste management and recycling.

In practice, the lack of analysis of EPR obligations is one of the most common causes of compliance problems in international e-commerce. Many sellers only learn about these obligations when a sales platform requires them to provide an environmental registration number or proof of participation in a recycling system.

Contrary to popular belief, environmental obligations in Romania do not only apply to companies with a local registered office. The regulations can also cover foreign enterprises that place products or packaging on the Romanian market through distance selling.

This guide is intended for manufacturers, importers, and online sellers directing their offer to customers in Romania.

Definition of EPR

Extended Producer Responsibility (EPR) is a regulatory system in which entities placing products on the market are obliged to finance the collection, sorting, and recycling of waste generated from those products.

In practice, this means that an enterprise selling packaged products or placing goods such as electronic equipment or batteries on the market must participate in the management system for waste generated at the end of the life cycle of these products.

In Romania, the EPR system covers several regulated waste streams. For e-commerce sellers, the most common will be:

• packaging
• electrical and electronic equipment (WEEE)
• batteries and accumulators

The EPR system is not limited solely to a financial obligation. It also includes registration in relevant national registers, maintaining records of products placed on the market, and submitting periodic reports on the quantities of products or packaging placed on the market.

Who is subject to the obligations (obliged entities)

A key element of the EPR system is determining which entity is considered a producer within the meaning of environmental regulations.

In Romania, EPR obligations may specifically apply to:

• manufacturers producing packaged products within the territory of Romania
• importers bringing products in from outside the European Unionimporters bringing products in from outside the European Union
• enterprises acquiring goods from other EU member states and placing them on the Romanian market
• distributors selling private label products
• online sellers shipping products directly to consumers in Romania

In cross-border sales models, the actual sales structure is of particular importance. If an enterprise sells goods directly to customers located in Romania and ships them to the end recipient, it may be considered the entity placing those products or packaging on the Romanian market.

Legal basis for obligations

The Extended Producer Responsibility system in Romania is based on national waste management laws and sectoral regulations regarding specific product categories.

One of the key legal acts is:

Law No. 249/2015 on the management of packaging and packaging waste.

This law defines the principles of the packaging recycling system as well as the obligations of producers and importers placing packaging on the Romanian market.

The EPR system in Romania also includes regulations regarding:

• waste electrical and electronic equipment (WEEE)
• batteries and accumulators

These regulations implement requirements resulting from European Union directives on waste management; however, their practical implementation takes place through national systems for registration, reporting, and recycling financing.

Competent authority

The main institution responsible for managing the EPR system in Romania is:

Administrația Fondului pentru Mediu (AFM) – Environment Fund Administration. The AFM is responsible for:

• maintaining national registers of producers
• supervising the financing of the waste management system
• monitoring the fulfillment of environmental obligations by enterprises
• imposing fees and administrative sanctions

Registers

Enterprises placing products or packaging on the Romanian market must be entered into the relevant environmental registers. These registers are maintained by the AFM and other institutions supervising specific waste streams. Depending on the type of product, an enterprise may be obliged to:

Rejestry te są prowadzone przez AFM oraz inne instytucje nadzorujące poszczególne strumienie odpadów. W zależności od rodzaju produktu przedsiębiorstwo może być zobowiązane do:

• register in the AFM system for packaging
• register in the system for electrical and electronic equipment
• register in the system for batteries and accumulators

In practice, enterprises very often fulfill these obligations through producer responsibility organizations, which in Romania operate as OIREPs (Organizații care implementează obligațiile privind răspunderea extinsă a producętorului).

Main EPR Obligations in Romania 

Registration

The first step in fulfilling EPR obligations is to complete the proper registration before starting to sell products on the Romanian market.

This process includes:

• identification of the relevant waste streams
• registering the enterprise in the appropriate national systems
• submitting data regarding the products or packaging placed on the market

For most e-commerce sellers, the key stream will be the packaging system. In practice, enterprises often fulfill their obligations by cooperating with an OIREP organization. Choosing the right organization can be significantly important, as some OIREPs also offer support in representing foreign producers and the administrative handling of EPR obligations.

Authorized Representative (AR) in Romania

For foreign enterprises selling products directly to Romania, appointing an authorized representative is, in practice, very often necessary.

Although detailed requirements may vary depending on the waste stream, in practice, an authorized representative is usually required for most product categories covered by the EPR system, including packaging, electrical equipment, and batteries.

An authorized representative is an entity based in Romania that acts on behalf of the producer regarding the fulfillment of environmental obligations. They may be responsible for, among other things:

• registration in national systems
• submitting environmental reports
• communication with administrative authorities
• fulfillment of reporting obligations to the AFM

In the case of packaging, the formal obligation to appoint an authorized representative does not always result directly from the regulations; however, in practice, it often proves indispensable for conducting reporting and communication with the AFM system.

It is also worth noting that some OIREP organizations can serve as the authorized representative for foreign producers. In such cases, cooperation with the appropriate organization can be a more cost-effective and organizationally efficient solution.

Confirmation of Registration (EPR Number)

After completing the registration process, the enterprise receives a registration number in the relevant environmental system.

This number serves as confirmation of fulfilling the registration obligation and may be required by sales platforms or trade partners.

In practice, for many online sellers, obtaining such a number is a condition enabling sales on certain marketplace platforms.

Reporting and recording

Entities covered by the EPR system in Romania must maintain detailed records regarding the quantities of products and packaging placed on the market. This data forms the basis for:

• preparing environmental reports
• calculating recycling levels
• calculating environmental fees

Reporting in Romania takes place periodically and, in many cases, is cyclical. In practice, for many enterprises, reporting occurs on a monthly cycle.

Therefore, it is particularly important to implement an internal system for monitoring the quantities and weights of products and packaging placed on the market.

Charges

Enterprises placing products on the Romanian market are obliged to finance the waste collection and recycling system.

These obligations can be fulfilled through:

• cooperation with an OIREP organization
• direct payment of fees to the AFM environmental fund

In practice, most enterprises use OIREP organizations, which take over the obligation to ensure recycling levels. Choosing the appropriate OIREP organization can have a significant impact on the total cost of EPR compliance.

This is due to the fact that some organizations also offer authorized representative services or administrative support regarding reporting.

Requirements for Labeling Packaging and Products

Romanian regulations also provide for obligations regarding the labeling of products and packaging.

These most often concern:

• identification of packaging materials
• the crossed-out wheeled bin symbol for electrical equipment
• markings regarding batteries and accumulators

The purpose of these markings is to facilitate proper waste segregation and to provide users with environmental information.

Information obligations for purchasers

Producers placing products on the Romanian market should also provide users with information regarding the proper handling of waste.

This information can be provided via:

• instructions attached to the product
• markings on the packaging
• information on the product page in the online store
• email communication after the purchase

Waste streams and exemptions

The Romanian EPR system covers several main product categories:

• packaging
• electrical and electronic equipment
• batteries and accumulators

In practice, Romanian regulations do not provide for broad exemption thresholds based solely on small quantities of products placed on the market.

This means that EPR obligations may arise at the moment the first product or packaging is placed on the market.

Consequences of non-compliance

Failure to comply with EPR obligations in Romania can lead to administrative sanctions and financial penalties.

Depending on the type of violation, enterprises may be subject to:

• financial penalties
• the obligation to pay outstanding environmental fees
• administrative audits

In the case of e-commerce sellers, lack of compliance can also lead to operational problems, such as blocking sales on marketplace platforms that require confirmation of environmental registration.

Summary

The Extended Producer Responsibility system in Romania constitutes an essential regulatory element for enterprises placing products on the national market.

Companies selling goods to customers in Romania — including through cross-border sales — should assess whether their products or packaging are subject to the EPR system and ensure appropriate registration and reporting.

In practice, this means the necessity of:

• identifying the relevant waste streams
• registering in the appropriate national systems
• maintaining records of products and packaging
• financing the recycling system

Support in fulfilling EPR obligations

Rulity Consulting supports enterprises selling to Romania in the practical organization of compliance with the EPR system.

The process begins with an analysis of the product portfolio and the sales model to determine which waste streams are triggered by the enterprise's activities.

Based on this, the correct path for fulfilling obligations is defined, including registration in the relevant national systems, selecting a recovery organization, and implementing reporting procedures.

In the case of foreign enterprises, support is also provided in organizing the appointment of an authorized representative and preparing the necessary documentation.