FEPRA EPR · Frequently asked questions
Answers, not references to the law.
54 questions our clients ask us, with short answers and the legal framework at the end. From "what is a PRO" to how you declare pallets, bags or sugar-cane trays. Can't find the answer? The FEPRA client relations team will answer you.
More than 1,500 companies have placed their trust in us. Among them:
The basics
About PROs and your obligation
What extended producer responsibility means, who has it and what happens if you do not meet it.
What is a PRO?
PRO stands for producer responsibility organisation (in Romanian OIREP, "organisation implementing extended producer responsibility"): a company licensed by the Ministry of Environment that takes over your company's obligation to recycle the packaging it places on the market. You report the quantities every month, the PRO funds collection and recycling, gives you the proof and helps you with the AFM declaration. Explained at length.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste.
PRO, OIREP or OTR: which is the right term?
They mean the same thing. "OTR" (responsibility transfer organisation) was the name used in Romania before 2019. Today the law uses the phrase "organisation implementing extended producer responsibility obligations", shortened in the market to OIREP; in English, a producer responsibility organisation (PRO).
Who is obliged to meet the packaging obligations?
Any company that places packaged products on the Romanian market: you manufacture in Romania, import or purchase packaged products from other EU countries, sell under your own brand products made by others, over-package products for resale, place service packaging on the market (including bags) or rent out packaging professionally. The obligation can be met individually or by transferring it to a PRO.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 16.
What does "packaging placed on the national market" mean?
Packaging is any product, whatever the material, intended to contain, protect, handle, deliver or present goods, from raw materials to finished products. It is considered placed on the national market when it is first made available in Romania: at import or intra-EU purchase for packaging coming from abroad, and at first supply for packaging produced here. The company that puts its brand on a product made by someone else is considered the one that placed it on the market.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
What are the packaging categories: primary, secondary, tertiary, reusable?
- Primary packaging (sales packaging): the sales unit for the consumer, at the point of purchase. Example: the juice bottle, the cereal box.
- Secondary packaging (grouped packaging, over-packaging): groups several sales units and can be removed from the product without affecting it. Example: the pack of 6 bottles, the film holding the packs together.
- Tertiary packaging (transport packaging): makes handling and transport of several units or groups easier. Example: the transport box, the pallet, the pallet wrap. It does not include road, rail, ship or air containers.
- Reusable packaging: designed for several cycles, refilled or reused for the same purpose; it does not become waste when it is returned for reuse.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
What material types is packaging reported on?
Seven groups, the same you find in FEPRA's fees: paper and cardboard, plastic, PET (reported separately within plastic), glass, steel, aluminium and wood. Composite packaging (for example beverage cartons made of cardboard, aluminium and plastic) is reported on each material in its composition.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste; Decision 2005/270/EC.
Who bears the responsibility and which authority checks?
Romania applies the principle of extended producer responsibility: the company that places the packaging on the market is responsible for its collection and recycling once it becomes waste. Quantities and contributions are managed by the Environmental Fund Administration (AFM), where you file the monthly declaration; the National Environmental Guard and AFM can inspect the records.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste; GEO no. 196/2005 on the Environmental Fund.
Can I meet my obligations without a PRO?
Legally, yes: individually, with your own collection and recycling system, records, audit and reporting. In practice it pays off only for very few companies, with large volumes and returnable packaging.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 16 para. (5).
What happens if I do nothing?
You owe AFM 2 lei for every kilogram in the target that you do not prove recycled, plus possible fines for declarations not filed, and AFM can check previous years. See what it would cost you with and without a PRO.
Legal framework: GEO no. 196/2005 on the Environmental Fund, art. 9 para. (1) letter d.
I sell online, through marketplaces. Does this concern me?
Yes. The parcel, film, box and filling are packaging you place on the market. From August 2026, the platforms check this too, under the new European packaging regulation (PPWR).
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste; Regulation (EU) 2025/40.
Working together
Contract, fees and reporting with FEPRA
How you sign, how much you pay, what you do month by month and what you get back.
How is the fee calculated?
Per kilogram of packaging placed on the market, with a different fee for each material and for each stream (municipal or industrial/commercial). The fees are fixed for the whole year and public. Fees and cost calculator.
Are there hidden costs or a minimum invoice?
No. You pay the per-kilogram fee for the declared quantities. No contract administration cost, no platform subscription, no minimum invoice.
Can the fee change during the year?
No. The fee in the contract stays the same from January to December, so that you can budget your environmental cost from the start.
How can I reduce the cost of the packaging I place on the market?
Without a PRO, you pay AFM 2 lei for every kilogram of the legal target that you do not prove recycled. Under a contract with FEPRA you pay a per-kilogram fee several times lower, applied to the whole quantity, and the proof of recycling comes from us. Compare the two costs for your quantities.
Legal framework: GEO no. 196/2005 on the Environmental Fund.
Can I switch to FEPRA from another PRO during the year?
Yes. The contract with us starts on the signing date, and the earlier quantities stay with the previous PRO. We help you make sure no month is left uncovered.
From when am I covered?
From the date the contract is signed. Quantities placed on the market before that date remain your responsibility or that of the previous PRO.
Do I need a digital signature?
Not for the contract with FEPRA, which you sign electronically, from your phone or computer. For the AFM-online account, the portal accepts an account with a digital certificate or with a username and password; the AFM guide explains both options.
What documents do I need in order to sign?
The company details (name, tax ID, registered office), the contact person and the AFM registration. The rest we fill in together. How it works, step by step.
I do not know my packaging quantities. Can I sign?
Yes. You start with an estimate, and the client relations team helps you correct it in the first months of reporting.
What do I have to do, as a client, month by month?
Enter in FEPRA 2.0, between the 1st and the 20th of the month, the quantities of packaging placed on the market in the previous month, by material and by packaging type. The platform validates them and prepares your data for the AFM declaration. The rest, contracting collectors, recycling, the proof and the reporting to the authorities, we manage.
What happens if I do not manage to report by the 20th?
Call or write to us and we find a solution so that your AFM declaration is filed on time, but please do not make a habit of it.
What documents do I need for the AFM declaration?
Only the monthly report validated in FEPRA 2.0 (Annex 3), generated from the quantities you declared. You file the declaration from your company's account on the AFM portal, by the 25th of the month for the previous month.
Legal framework: Order no. 591/2017 (the Environmental Fund declaration form); GEO no. 196/2005 on the Environmental Fund, art. 10.
Who in my company is responsible for sending the information to AFM?
Your company, through the person you appoint as environmental officer. The law requires every economic operator to have a person trained in waste management, in-house or external. The FEPRA client relations team works with this person, but the declaration is filed in your company's name.
Legal framework: GEO no. 92/2021 on the waste regime, art. 23.
Do I get proof that my packaging was recycled?
Yes. Annex 3 after each validation, the traceability of the quantities with documents for every tonne, available in the platform, and the certificate with the CO₂ emissions avoided, ready to use in ESG reporting. Our figures are checked every year by an external auditor.
What do I get after signing and who answers my questions?
A colleague from the client relations team sends you your login details for FEPRA 2.0, walks you step by step through the packaging classification and your first report, and answers whenever you have a question. Support is included in the fee. When the legislation changes, you get a short briefing with what concerns you.
From client questions
Packaging classification: real cases
The answers given by the FEPRA client relations team in the FEPRA 2.0 platform, on real cases. They are general recommendations; for your situation, ask the team.
I use recycled PET (rPET) packaging. Are there special rules, or is the plastic charge lower?
No. Packaging made wholly or partly of recycled plastic has the same legal regime as virgin plastic packaging and is declared the same way. The share of recycled material does not affect the contribution to the Environmental Fund.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste; Directive (EU) 2019/904; Regulation (EU) 2021/770.
I use plastic bags with an adhesive flap, for online sales and in the shop. How do I classify them?
It depends on the channel. For online sales, the bag with an adhesive flap is classified as transport packaging. For direct sales in the shop, as service packaging. The eco-tax of 0.15 lei per bag is owed only for service packaging, that is, in the second case.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste; GEO no. 196/2005 on the Environmental Fund; Order no. 1448/2020.
The cardboard boxes used for transport, for delivering products to customers: primary, secondary or tertiary?
Primary packaging when the box carries a single product. If it carries several products, it becomes secondary or tertiary packaging, depending on its role.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
How are the padded paper envelopes used for delivery classified?
As primary packaging.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
How are jewellery boxes (cardboard and foam), received free of charge from the supplier, classified?
As primary packaging: they are the sales packaging of the jewellery, not transport boxes.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
How are the large cardboard boxes in which I receive imported goods (wholesale) classified?
As secondary or tertiary packaging, depending on their role: grouping several sales units, or transport packaging.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
Is the branded tape I use to seal the boxes delivered to customers declared?
Yes, it is classified as primary packaging and declared under the material it is made of.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
How do I declare wooden gift hampers with several products?
As secondary packaging: the hamper groups several sales units, each individually packaged, and can be separated from the products without affecting them.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
I place cables on the market. How do I declare the drums they are wound on?
Drums are primary packaging. The cable is a single sales unit, placed directly on the drum, so the drum has the function of sales packaging, not transport packaging.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1.
I sell, together with the products, bags with the company logo. How do I classify them and do I have to charge the eco-tax?
Bags customised with your brand are packaging placed on the market by you and are declared. For carrier bags two charges apply, whether they have handles or not:
- the 2 lei/kg contribution for packaging, declared monthly to AFM by the 25th of the month for the previous month (with a PRO, this obligation is taken over by us);
- the eco-tax of 0.15 lei per bag plus VAT, declared quarterly to AFM by the 25th of the month following the quarter. It is shown separately on the sales documents and displayed visibly at the point of sale.
The eco-tax does not apply to bags that comply with the EN 13432 standard (biodegradable and compostable), but only if you hold a test report issued by a laboratory accredited at European level.
Legal framework: GEO no. 196/2005 on the Environmental Fund, art. 9 para. (1) letters d) and q).
Are customised paper bags, used for corporate gifts, service packaging?
Yes. Bags handed to customers, whatever they are filled with and even if offered free of charge, are packaging placed on the market under your brand and are declared to the Environmental Fund.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 16 and Annex 1.
I want to use biodegradable bags. What obligations do I have?
The legislation does not yet have specific rules for biodegradable packaging; all packaging falls under Law 249/2015. We recommend keeping strict records by material type and holding the technical data sheets that prove the composition. For the eco-tax of 0.15 lei per bag, the exemption applies only to bags that meet the requirements of SR EN 13432:2002, proven with test reports for each batch. For unclear situations, ask AFM for a written opinion.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste; GEO no. 196/2005 on the Environmental Fund; Order no. 578/2006 (Methodology for calculating contributions to the Environmental Fund), art. 51–53.
I buy "bio" sugar-cane trays. Do I declare them and how do I classify them?
Until specific rules appear, our recommendations are: sugar-cane packaging contains cellulose, similar to cardboard, so it is declared to AFM under paper and cardboard; packaging made of starch or polylactic acid (PLA) cannot be treated as plastic and is not declared. Keep the technical data sheets for each type of packaging; the composition cannot be established from the invoice. For any uncertain category, ask AFM for a written opinion.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 2.
I import vacuum film and trays that I sell to customers, who pack products with their own labels in them. Who declares?
If your customers put their own brand on the products packed in these materials, the obligation to declare to the Environmental Fund is theirs. If the products do not carry the customers' brand, the obligation is yours, as importer.
Legal framework: GEO no. 196/2005 on the Environmental Fund.
Is packaging made of several materials (pallets with nails, composite packaging) declared on each material?
Yes. Composite packaging and packaging made of several materials is calculated and reported on each material in its composition, under Decision 2005/270/EC. The obligation applies from 2025; a material that represents less than 5% of the packaging's mass can be exempted.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 17 para. (5); Decision 2005/270/EC, art. 6c.
Do I have to put recycling symbols on the packaging? What markings do I use?
Operators who mark packaging to identify the material must apply the numbering and abbreviation system in Annex 3 to Law 249/2015, directly on the packaging or on the label, visibly, legibly and durably. Non-compliance is fined from 8,000 to 16,000 lei. For imported products (for example from China) you can send the supplier the labels, so that the packaging enters Romania already marked, following the same system.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 9 and Annex 3.
From client questions
Pallets and reusable packaging
The most common topic in reports: who declares pallets, when they are deducted and how records are kept.
I recover most of my pallets. Can I report only the difference between those sent and those recovered?
Only with records. The law requires you to keep monthly statements, based on financial and accounting documents, for the packaging placed on the market, and the reused quantity is recognised only from the accounting records. If you treat pallets as reusable packaging, you must mark them "reusable packaging", organise a take-back system with a return rate of at least 80% and keep accounting records of the rotations.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 10 para. (4) and art. 16; Order no. 578/2006 (Methodology for calculating contributions to the Environmental Fund), art. 22.
Do pallets held in custody and returned to the partner have to be declared in the months they are with me?
If you have supporting documents showing that the pallets returned in month X are those previously received in custody, we consider that they no longer need to be declared to AFM: they do not become waste in Romania. The condition is very strict tax records of the pallets received and returned. We recommend consulting your accountant and, if needed, asking AFM for an opinion.
I buy pallets on the domestic market for the warehouse. Do I declare them? And if I resell some?
It depends on their source and on what you do with them:
- pallets from import, from domestic production or from a wood recycler, on which you put products: you declare them, at first use;
- pallets already declared by someone else, proven with documents: you do not declare them again;
- pallets bought as products and resold as such, with no goods on them: you are a distributor, they are not declared, but neither are they deducted from the quantities you use;
- pallets imported with goods and kept in the country: you declare them at import; if you sell them later, the quantity is not deducted, the waste stays in Romania.
Ask your suppliers about the source of the pallets, so that the same quantity is not declared twice or not at all.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 16 and Annex 1; Order no. 578/2006 (Methodology for calculating contributions to the Environmental Fund), point 24.
Imported products arrive on pallets that do not appear on the invoice. How do I enter them in the accounts?
Pallets are reusable packaging that must be recorded in the accounts at fair value, in separate inventory accounts. In practice: you establish the pallet type (euro or non-euro) at import, determine the weight (your own weighing procedure or technical data sheets from the supplier), record them at fair value when first placed on the market, keep records by number and weight (purchased, in stock, delivered) and deliver goods on pallets in compliance with the Accounting Law and the Fiscal Code.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 10 para. (6); Order no. 1503/2017, art. 22; Accounting Law no. 82/1991; Order no. 1802/2014.
I returned pallets to the foreign supplier on a delivery note, but the return invoices were issued in other months. How do I correct the AFM declaration?
The corrective declaration is filed with supporting documents: the goods delivery notes, the tax invoices, the CMR and any other document proving the return. In the cover letter you explain why invoicing was done in month X for previous months; as long as the quantities on the invoices match those on the delivery notes, AFM should have no reason to reject the correction. We recommend attaching the pallet weighing report as well.
Legal framework: Order no. 591/2017; Order no. 1503/2017, Annex 1.
What does the obligation to have a share of reusable packaging (5% per year) mean?
It applies to companies that place beer, cider, fermented beverages, juices, nectars, soft drinks, waters, wines and spirits on the market in non-reusable primary packaging made of glass, plastic or metal, between 0.1 and 3 litres. From 2020, the weight of reusable packaging must be at least 5% of the weight of the packaging used in a year (but not less than the 2018–2019 average), increasing by 5% a year up to and including 2025.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 10 para. (5) and art. 11.
What is non-reusable primary packaging?
The law does not define the term directly, but it defines the components: primary packaging is the sales packaging for the consumer, and reusable packaging is packaging designed for several cycles, refilled or reused for the same purpose. Therefore, non-reusable primary packaging is sales packaging designed for a single cycle, for example the bottle, can or flask that is not refilled.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, Annex 1; GD no. 1074/2021, annex.
Beyond packaging
DRS, permits and other environmental obligations
The deposit return system, the annual endorsement of the environmental permit and other reports our clients come across.
What obligations do I have under the deposit return system (DRS, in Romania SGR)?
If you place beverages (beer, cider, fermented beverages, juices, nectars, soft drinks, waters, wines, spirits) on the market in non-reusable primary packaging made of glass, plastic or metal, between 0.1 and 3 litres, you must:
- register with the DRS administrator (RetuRO) before placing the products on the market and sign a contract with it;
- mark the DRS packaging and report every month, by the 10th, the quantities placed on the market in the administrator's software;
- charge the deposit to your customers and pay it to the administrator by the 25th of the following month, together with the administration fee;
- inform consumers about products in DRS packaging and allow inspections by the authorities.
Fines range from 4,000 to 50,000 lei, depending on the obligation breached. DRS packaging is no longer declared to the PRO for the part taken over through the system; the client relations team helps you draw the line.
Legal framework: GD no. 1074/2021 establishing the deposit return system, as amended.
Do vegan oat-based drinks, in PET or HDPE, fall under the DRS?
Yes. Oat drinks with various flavours are beverages within the meaning of the government decision, and non-reusable primary plastic packaging between 0.1 and 3 litres, marked DRS, falls under the deposit return system.
Legal framework: GD no. 1074/2021, annex (meaning of terms).
My environmental permit is approaching expiry. What do I have to do?
The permit remains valid as long as you obtain the annual endorsement. The endorsement application is filed with the county Environmental Protection Agency (APM), the authority that issued the permit, at least 60 and at most 90 days before the issue date (for example, for a permit issued on 29 August, between 29 May and 29 June), with: the standard application, the annual environmental report or the reports required by the permit, the declaration on your own responsibility that the activity is carried out under the same conditions, and proof of payment of the fee (100 lei for the environmental permit, 300 lei for the integrated permit). It can also be sent scanned, by e-mail, with confirmation of registration. Failure to file leads to suspension of the activity, and filing after the deadline to suspension of the permit for a period equal to the delay. Partner collectors receive automatic notifications in FEPRA 2.0 70, 23, 7 and 1 day before expiry.
Legal framework: Law no. 219/2019 (art. 16 of GEO no. 195/2005); the annual endorsement procedure, art. 5.
I have been asked to report in the NONIED Register. What is it and how is it done?
It is the report on the compliance of the activity with the provisions of the environmental permit, drawn up by operators holding an environmental permit, in SIM (the Integrated Environmental System), the online platform of the National Environmental Protection Agency (ANPM). You log in at raportare.anpm.ro (or register with the eForm if you have no account), request access to the NONIED Register from your profile (the Industrial Emissions domain) and fill in the form: activity and production details, site coordinates, emissions monitoring, waste, stacks. The reporting period is 1 April to 30 May, for the previous year, unless the permit sets other dates. The completed form is downloaded and filed with APM, with a registration number.
I have a shop and want to collect used oil from customers. What is the procedure?
Any operator that collects used oils (vegetable or mineral) must hold an environmental permit for each collection point, with the corresponding NACE codes, and the environmental obligations that come with it. If you only allow a collector to place containers in your car park, the collector is the one that must hold the permit for that point.
Legal framework: GEO no. 92/2021 on the waste regime; GEO no. 195/2005 on environmental protection.
I export packaging waste from my own imports to a recycler in the EU, to recycle in my own name. What conditions must I meet?
Since 2019, objectives met individually can be achieved only with waste from your own packaging placed on the national market, with separate records. For deliveries abroad you need at least: a recycling services contract with the operator that holds the facility; the waste recorded in separate inventory accounts, at fair value; invoicing in line with the Fiscal Code; proof of actual recycling (processing document, recycling declaration or certificate, production report with the R3 operation); the recycler's environmental permit or an equivalent document; Annex VII to Regulation 1013/2006 completed in full, with the waste code, the quantities delivered and received, the R3 operation and the recycler's confirmation; on all transport documents and on the invoice, a statement that the waste is entrusted for meeting recycling objectives, with your company's details. The annual reports to the authorities remain mandatory.
Legal framework: Law no. 249/2015 on the management of packaging and packaging waste, art. 15–17; Order no. 1503/2017, art. 23–25; Regulation (EC) no. 1013/2006; GD no. 856/2002.
Didn't find the answer?
Write to us or call us. The FEPRA client relations team answers your specific situation, without jargon. People, not robots.