Packaging reporting in Austria: why the invoice is the wrong data basis and shipping data the right one

If you ship goods to end customers in Austria, you know the recurring obligation: you report the packaging you have placed on the market to a collection and recycling system and license it. In practice, this report is often created in a spreadsheet, compiled from invoice items and article master data. That is understandable, but risky from a professional standpoint. Because the invoice shows what was sold. It does not reliably show what was actually packed and shipped.

How packaging reporting works in Austria

A brief overview (legal status 28.09.2026, not legal advice): anyone who places packaging on the Austrian market for the first time, for example as a manufacturer, importer, packer or mail-order retailer to end customers, must join a collection and recycling system. The best known is ARA, and there are other systems as well.

Reporting is done in kilograms, per tariff category (including paper, glass, plastic, ferrous metal, aluminum, beverage carton, composite materials) and separated into household and commercial packaging. This classification determines the tariff and the reporting route. Size limits of 1.5 m² of surface area or 5 liters of volume serve as a guide, but special rules apply to some packaging types regardless of size. Since 1 January 2023, commercial packaging must also participate in a system. How often you report depends on the expected annual fee. The annual closing report is generally due by 15 March of the following year.

And the PPWR? The EU Packaging Regulation (Regulation (EU) 2025/40) has applied since 12 August 2026. It does not create a central EU register: the producer registers remain national, and reporting in Austria continues. Many requirements take effect in stages over the coming years, for example the obligation to minimize packaging under Art. 10 from 1 January 2030. For your ongoing reporting, this means: the Austrian framework remains the benchmark. A clean data basis is, if anything, becoming more important.

The actual problem: invoice is not the same as shipping

Why isn't the invoice enough? Because the relevant quantity arises not at the sales document, but at the parcel:

• Split and partial deliveries: One order, several parcels. That means several shipping boxes and more filler material.
• Consolidated parcels: Several orders in one box. That means only one shipping package.
• The shipping packaging itself: Box, filler material, tape and label appear on no invoice item. But they are actually created with every parcel.
• Free and replacement deliveries, product samples: No invoice or a zero invoice, but actually packed and shipped. That makes them reportable.
• Returns and credit notes: They do not automatically reduce the packaging already placed on the market.
• Dropshipping and fulfillment: Who places on the market here? No invoice answers this question of roles.
• Packaging changes during the year: The same article is packaged differently at different points in time.

Each of these cases shifts the reported kilograms, sometimes up, sometimes down. A report can look clean and still be wrong from a professional standpoint.

The more reliable data basis: the actual parcel

The more robust approach doesn't start at the invoice, but at the shipping event. The ERP, for example weclapp, holds the real shipments and parcels: what was shipped when, in which box and with which filler material? You combine this shipping and parcel data with a versioned packaging bill of materials (BOM). It contains the product packaging per unit and the shipping packaging per parcel, each with material, weight and validity period. That way the quantity arises exactly where it physically occurs.

Traceable to the source

Traceability is what matters. Every kilogram line in the draft report can be traced back to the individual parcel, the item and the BOM version used.

Special cases are not silently treated as zero. If a role or a document is unclear, the case is marked as open and blocks approval instead of producing a wrong number. At the end there is a versioned draft including a difference report against the values actually submitted. That is not a black box, but a verifiable chain.

What we do and what we don't

To delimit the scope: we create a draft report and the associated document chain. You make the report in the portal yourself. We submit nothing, assume no legal representation and give no blanket compliance guarantee. We provide the traceable data basis and the professional assistance. The substantive approval and the portal action stay with you. This is not an off-the-shelf product, but a deliberately delimited, verifiable work step.

Pilot partner wanted (Austria first)

We want to test this approach on a closed historical reporting period and are looking for a pilot partner. A good fit is a trading company based in Austria that already reports to its collection and recycling system itself today. It should have shipping and parcel data for a past period and be able to name a person who gives professional approval. weclapp users preferred. Together we create a verifiable draft, compare it with the actual report and measure data effort, deviations and operating costs.

How the pilot works and who it suits, you can read on our Packaging Reporting pilot page.

Sounds like your company? Write to Markus directly: markus@wals.pro

Sources

Legal status 28.09.2026. Editorial article, not legal advice. Specific questions about roles and classification are best clarified case by case with a qualified professional.

• ARA, licensing and online reporting: ara.at
• WKO, information on the Packaging Ordinance 2014 (Verpackungsverordnung 2014): wko.at
• Unternehmensserviceportal (business service portal), packaging: obligations for companies: usp.gv.at
• EU Packaging Regulation (Regulation (EU) 2025/40): eur-lex.europa.eu