The obligation arises in one situation only: the packaging reaches the Romanian market for the first time without any Romanian company placing it there. That is, when a company from another EU Member State or from a third country ships packaged products directly to end users in Romania, through its own online shop or through a marketplace. It is then the "producer" within the meaning of the law and must appoint a legal entity in Romania as its authorised representative. Circulad'OR takes over, under a written mandate, the registration, the reporting to the OIREP (licensed producer responsibility organisation) and the declarations to the AFM (Environmental Fund Administration).
Do you need an authorised representative for packaging? Ask for a free assessment of your situation →You are established in another Member State or in a third country and ship parcels directly to consumers in Romania, without a local importer. Nobody in Romania declares that packaging in your place: you are the "producer" and you need an authorised representative.
You sell through eMAG, Amazon, Temu, Allegro or other platforms, and the goods leave your warehouse outside Romania straight to the customer. The platform does not take over your obligation; on the contrary, the PPWR requires it to check that you are registered and represented.
Today, the Romanian company making the intra-Community acquisition declares the packaging itself. The PPWR, however, defines as "producer" the party that delivers directly to the end user in another Member State. We analyse, channel by channel, who bears the obligation, before signing any mandate.
The importer (or the distributor making the intra-Community acquisition) is the "responsible economic operator": it registers, calculates and declares the packaging. The same applies if you have your own entity in Romania. For these companies, we offer the services on the Environmental Services page.
Producers established in another Member State of the European Union or in a third country, who place products on the territory of Romania, are required to appoint a legal entity established in Romania as their authorised representative, to fulfil the obligations incumbent on them under extended producer responsibility schemes, in accordance with the legislation applicable to each waste stream.
For packaging, the specific obligations are those set out in Law no. 249/2015 on packaging and packaging waste management and in O.U.G. no. 196/2005 on the Environmental Fund: annual recovery and recycling targets, the monthly declaration to the AFM and the contribution of RON 2/kg for any shortfall, fulfilled individually or by transferring responsibility to a licensed organisation (OIREP).
Why the importer does not need a representative: Law no. 249/2015 places the obligations on the "responsible economic operator", that is, on the party that places the packaged product on the national market for the first time. When the goods enter Romania through an importer or through a distributor making the intra-Community acquisition, that party is responsible and makes the declarations. An authorised representative is needed only when the chain has no link in Romania: distance selling directly to the end user.
The Regulation, applicable from 12 August 2026, says the same thing, with more precise definitions. A "producer" is also a party that, established in another Member State or in a third country, makes packaging or packaged products available for the first time on the territory of a Member State, directly to end users, including through distance contracts (art. 3 point 15 letters (c) and (d)). Exactly these producers are required to appoint, by written mandate, an authorised representative for extended producer responsibility in each Member State where they place packaging on the market without being established there (art. 45). The representative is the person through whom the producer fulfils its EPR obligations, while the producer remains liable for the accuracy of the data submitted.
Art. 44 establishes, in each Member State, a national register of packaging producers: registration takes place in each State in which the packaging is placed on the market for the first time, and for producers established outside that State the registration is made by the authorised representative. Online platform providers are, in turn, required to check, for sellers delivering to Romania, that they are registered and, where they are not established here, that they have an authorised representative; a seller without a representative risks no longer being able to sell through the platform.
We start from your business model: what you sell, to whom, through which channel, with which sales, grouped and transport packaging. We determine whether you are a "producer" within the meaning of Romanian law and the PPWR for each channel, what obligations fall to you and from when.
We draft the written mandate, in Romanian and English, with clear limits on each party's liability. We register as authorised representative with the Romanian authorities and, once the national register of producers becomes operational, we make your registration in it.
We remind you to send us, every month, the quantities of packaging placed on the Romanian market, broken down by material, weight and primary / secondary level, in our reporting form. We take them over, check them formally and pass them on to the OIREP and the AFM.
Through our partnership with OIREP Reciclad'OR, we submit the monthly quantities report (Annex 3), so that the recycling targets are met through the OIREP, not through the contribution to the AFM.
Each month we file the declaration of Environmental Fund obligations, based on the quantities you send us and the OIREP reports, and keep the record of receipts. If differences arise, we prepare the corrective declarations with supporting documents.
We respond to AFM requests, prepare the file for inspections, inform you when the framework changes (the producer register, the PPWR implementing acts, labelling requirements) and tell you exactly what you have to do and by when.
Business model, sales channels, packaging used. We determine whether and from when the obligation applies to you.
We sign the representation mandate; you remain responsible for the accuracy of the data, we for fulfilling the obligations.
Registration with the authorities, the OIREP contract.
Quantities submitted by the 10th, OIREP report by the 15th, AFM declaration by the 25th. The same routine every month.
The complete archive for each month, ready for an AFM inspection or for a check by the platform you sell on.
Regulation (EU) 2025/40 requires each Member State to set up a national register of producers, to monitor extended producer responsibility obligations. Under art. 44 para. (1), the register is to be established within 18 months of the entry into force of the first implementing act adopted by the European Commission under art. 44 para. (14). In Romania, the steps to establish and operationalise the register are under way; the registration procedure and the responsible authority will be announced together with the regulatory framework. The clients we represent are registered by us, on the day the register becomes operational.
Want to know when and how to register?
Write to us - we will let you know when it opens →
The first conversation is free and answers exactly that: whether or not you are a "producer" for your sales in Romania, what obligations you have, from when, and at what real monthly cost. We work in Romanian and English.
Contact us Call 031 9303 office@circulador.ro