The direct answer
Foreign distance selling to private end consumers requires local representation. German registration does not replace Austrian compliance.
What to check
Representation since 2023
WKO describes a notarised appointment for foreign distance sellers from 1 January 2023. The representative needs an Austrian establishment and service address. WKO · Packaging Ordinance, 15 July 2026
Packaging class and scheme
Distinguish household and commercial packaging. For commercial packaging, documented upstream supplier participation is also relevant. WKO · Austrian packaging obligations
Your action plan
The following steps are our suggested way to organise your project.
- Separate Austrian B2C and B2B sales in your data export.
- Check the authorisation and appointment process before launch.
- Map packaging types and material weights to the right contract.
- Keep supplier declarations with your own reporting records.
Prepare your records
Sales model, packaging list, material weights, supplier declarations and representation documents.
Frequently asked questions
Can a German address replace local representation?
For this appointment WKO specifies an establishment and service address in Austria.
How can SINNO help?
SINNO can consolidate data and tasks and coordinate suitable external providers. Local tasks are agreed separately.
Sources and scope
This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.