As of August 19, 2026. Supplement to the main article “What do I need to keep in mind when packing and shipping my thank-you gifts?” This is not legal advice.
Shipping within Austria is simple. Everything else—including Germany—is a bit more complicated.
Under packaging regulations, what matters isn't where Startnext is located, but where your package ends up.
What do I need to do when shipping within Austria?
Register, license, report. The PPWR did not initially change any of this on August 12, 2026—the 2002 Waste Management Act and the 2014 Packaging Ordinance continue to serve as the legal basis.
Specifically:
1. Register. A one-time registration on the Federal Environment Agency’s EDM portal: https://edm.gv.at — the easiest way is through the Business Service Portal.
2. Licensing. Participation in one of the approved collection and recycling systems. There are currently six approved systems, coordinated by the Packaging Coordination Office (VKS). The best-known is ARA: https://www.ara.at
3. Report. Submit an annual volume report to your system or via the EDM.
Is there an exemption for small quantities?
Small-scale generators producing up to 1,500 kg of household packaging per year can obtain a flat-rate license. However, there is no general de minimis threshold. The flat rate should apply to most crowdfunding projects—check with your chosen platform.
What are the requirements for the shipping box?
If you purchase a plain, pre-made cardboard box with an integrated adhesive strip from an Austrian supplier, that supplier has already established the supply chain in Austria and obtained the necessary packaging license. In that case, you will have no obligations of your own.
Important: The supplier must initiate the supply chain in Austria. A box that you purchase from a German retailer and ship to Austria is not licensed for the Austrian market.
And as always: don't add anything, no custom logo, no used cardboard.
How can I keep the effort to a minimum?
When planning your thank-you gift, consider right from the start which types of packaging are truly necessary:
- Please ask manufacturers and printers to ship products unpackaged, without plastic bags, shrink wrap, or hang tags.
- Use a new, plain, pre-made cardboard box with a built-in closure from an Austrian supplier.
- Do not add tape, packing material, tissue paper, or your own logo. A standard shipping label is fine.
- If possible, set Austria as the delivery area. Offer supporters in Germany and other countries a digital option or pickup.
These measures can reduce or eliminate obligations.
What are the shipping policies for Germany and other EU countries?
This also applies to Germany—the largest target market for many Austrian projects.
As soon as you ship directly to a supporter in Germany, you become the manufacturer there for the purposes of extended producer responsibility. For Germany, this means:
- Registration in the LUCID Packaging Registry (https://lucid.verpackungsregister.org/) — you must complete this yourself; an authorized representative cannot do it for you
- Participation in a dual system
- Quantity Report
- An authorized representative in Germany
And the same applies to every other EU country. There is no de minimis threshold—one package is enough.
Realistically, the costs amount to several hundred euros per country per year, regardless of the quantity.
Recommendation: Calculate these costs before launching your campaign if you expect support from Germany. For backers outside of Austria, a digital version of the thank-you gift is the simplest option.
What remains unclear?
In Austria, foreign senders were required to appoint an authorized representative even before the PPWR took effect (Section 12b(2) of the AWG). The Ministry of Climate Protection and the Chamber of Commerce have differing interpretations of how this provision relates to the new regulation in Art. 45(3) of the PPWR.
Austria does not currently have its own manufacturer registry under Art. 44 of the PPWR—it is contingent on a long-overdue EU implementing regulation. Mandatory implementation is not expected until 2028 at the earliest.
If your case depends on this question, contact your Chamber of Commerce.
Where can I get help?
- WKO, EU Packaging Regulation (PPWR): https://www.wko.at/abfall/eu-verpackungsverordnung-ppwr
- WKO, PPWR Country Overview (Requirements by EU Country, continuously updated): https://www.wko.at/abfall/ppwr-laenderuebersicht
- ARA, PPWR Guide: https://www.ara.at/uploads/Dokumente/PPWR_Leitfaden/ARA-PPWR-Leitfaden-07_2026_v2.pdf
- Federal Environment Agency's EDM Portal: https://edm.gv.at
If you have questions about specific target countries, the WKO Country Overview is a good place to start. For specific individual cases, your Chamber of Commerce can provide further assistance.
This post is not a substitute for legal advice. The legal situation is currently changing frequently. If you have specific questions, contact your Chamber of Commerce or a specialized law firm.