Packaging EPR in Romania: Who Pays, What Gets Reported and What It Costs

Extended producer responsibility is not an environmental tax. It is a mechanism that shifts the cost of collecting and recycling packaging from the public budget to the company that puts it on the market.

The distinction matters practically. A tax is paid and forgotten. An EPR mechanism gives you a budget line that rises or falls depending on how well you organise compliance, and from 2030 on what packaging you choose.

This article is written for companies placing packaged goods on the Romanian market from abroad, as well as for local operators. It sets out how the system works today and what is about to change.

Who has obligations

The obligation sits with the economic operator that first makes the packaging available on the Romanian market. In practice that means manufacturers, importers and distributors introducing packaged products, along with companies packing under their own brand.

Whether you made the packaging is irrelevant. What matters is whether you are the first to make it available in Romania. An importer bringing packaged goods in from Asia carries the same obligations as a local producer, even without ever touching a packing line.

The legal framework rests mainly on Law no. 249/2015 on the management of packaging and packaging waste and on Government Emergency Ordinance no. 196/2005 on the Environment Fund, as subsequently amended.

Two routes to compliance

You have two options, and the choice between them has direct financial consequences.

The individual system means organising your own collection and recycling flow and demonstrating that you meet the targets on your own. This is realistic only where your packaging comes back easily, for example in business to business relationships where waste stays on site or is returned by distributors.

Transferring responsibility to a licensed producer responsibility organisation, known locally as an OIREP, is the route most companies selling to end consumers take. The organisation assumes legal responsibility towards the authorities for the quantities you report, manages the collection and recycling network and provides traceability. Licensing is granted by the Ministry of Environment.

If you fail to meet your targets individually in a given year, contracting a transfer organisation becomes mandatory.

What gets reported

Records must be kept by quantity across two axes at once: by material, meaning plastic, paper and board, glass, metal and wood, and by packaging type, meaning primary, secondary and transport packaging.

This is where most companies fail. Not on legal interpretation, but on the fact that packaging data does not exist in the ERP at the required level of granularity. Packaging weight per unit sold is rarely a maintained field, and reconstructing it retroactively across several years is an expensive exercise.

Reports are filed electronically, accompanied by the corresponding accounting records. There is a periodic dimension, tied to the contribution for quantities not recovered, and an annual one covering total quantities placed on the market broken down by material.

What it costs

The cost has two components that behave differently.

The contribution to a producer responsibility organisation is negotiated, varies by material, and covers packaging taken into a system that meets its legal targets.

The contribution to the Environment Fund Administration is fixed: 2 lei per kilogram, meaning 1,400 lei per tonne, for quantities not recovered, regardless of material and regardless of why the target was missed.

The second mechanism is punitive by design. It is more expensive than organised compliance, precisely so that it does not become a convenient option. Companies that discover discrepancies during an inspection pay retroactively, which turns a record keeping problem into a cash flow one.

Recycling targets vary by material. The usual reference points are 50 percent for plastic and 75 percent for paper and board, with an overall recycling objective of 65 percent, under Law no. 249/2015.

Where the deposit return system fits, and why separation matters

Packaging covered by Romania's deposit return system falls outside the classic transfer obligations for the flow collected through that system, but must be reported separately.

A company placing both in-scope and out-of-scope packaging on the market runs two parallel flows, with separate records. Confusing the two is one of the most frequent causes of non-compliance found during inspections.

On top of that come operational costs of their own: marking packaging with the system logo and integrating with the operator's IT system.

What changes with the PPWR

The European regulation does not replace the national EPR system. It frames it.

Regulation (EU) 2025/40 harmonises product requirements for packaging while leaving EPR registration and payment national. A Romanian registration does not cover Germany or Spain.

Three things do change materially.

The national producer register aligns to a harmonised European format through an implementing act, and registration becomes a condition of making packaging available on the market.

Online platforms take on an obligation to verify that sellers hold valid EPR registration in each country of sale.

Fees become modulated according to the recyclability grade of the packaging. In Romania the eco-modulation mechanism is still being operationalised across the transfer organisations and is not yet applied uniformly. See what eco-modulation means in practice.

If you also sell in other Member States, obligations multiply rather than transfer. See what EPR across several Member States involves.

What to do in practice

Start with the data, not the contracts. Without packaging weight per reference, broken down by material and type, no negotiation with a transfer organisation is informed and no report survives an inspection.

Then check that your records correctly separate the deposit return flow from the rest. It is the cheapest check in the whole process and the most frequently skipped.

Integrate reporting into the ERP. Manual reporting works until the first retroactive inspection.

Finally, connect material decisions to future cost. Once eco-modulation becomes operational, choosing multilayer packaging over a mono-material is no longer only a technical decision. It is a recurring budget one.

Frequently asked questions

Do I have EPR obligations if I only import and resell?

Yes, if you are the first to make the packaged product available on the Romanian market. An importer carries the same obligations as a local producer for the packaging it introduces.

What happens if I miss the recycling targets?

You pay the Environment Fund contribution, 2 lei per kilogram of the quantity not recovered, per material. It is significantly more expensive than complying through an organised system.

Does transport packaging count?

Yes. Pallets, pallet wrap, collation cases and crates are packaging and belong in the records, even though they never reach the end consumer. It is the most common omission from the inventory.

Does the deposit return system exempt me from EPR?

No, only for the flow the system covers. The rest of the portfolio stays in the classic regime, and the two flows are reported separately.

Can I manage obligations myself, without a transfer organisation?

Legally yes, through the individual system. Practically it is realistic only where packaging returns easily, typically in business to business settings. For sales to end consumers, transferring responsibility is the standard route.

Where we come in

We work on the part that makes the difference: building the quantitative packaging inventory at the required level of granularity, verifying flow separation, and estimating future exposure as eco-modulation becomes operational.

We are not a producer responsibility organisation and we do not take on the obligation in your place. What we do is give you the data and the structure to negotiate on an informed basis and report correctly.

See our services or book a thirty minute call.