Is there a minimum volume before Romanian EPR applies?
This is the most common question in the emails we receive from small webshops: a handful of parcels a month to Romanian customers, and the seller wants to know whether that is below some line. The honest answer is about how the obligation is defined, not about a number.
Romanian extended producer responsibility attaches to the act of placing packaged goods, electrical equipment or batteries on the Romanian market, not to a turnover or volume threshold below which nothing applies. A company sending a small number of parcels into Romania is, in principle, in scope and has to register and report the quantities it actually places on the market, however small. What low volume changes is the size of the contribution and the effort of reporting, not whether the duty exists.
- Trigger
- Placing goods on the Romanian market, from the first shipment
- Exemption by volume
- Not something to rely on; scope is assessed per stream and product
- What low volume changes
- The amount payable, not the duty to register and report
- Nil months
- Still reported, once registered
Why sellers expect a threshold
Several EU countries have simplified regimes or de minimis arrangements for very small quantities, and sellers reasonably assume Romania works the same way. Others were told by a marketplace that they were below a limit, which usually referred to the platform's own verification trigger, not to the law.
Treating a platform's verification threshold as a legal exemption is the single most expensive assumption we correct. The platform can stop asking; the Romanian obligation continues to accumulate month by month.
What we look at instead of a number
- Which streams your products fall under: packaging alone, or also electrical equipment and batteries.
- Whether you are the first company placing the goods on the Romanian market, or someone before you is.
- Whether you sell directly to Romanian consumers or through a Romanian business that takes over that position.
- Whether packaging is added in Romania, which counts as yours.
Where the position genuinely depends on the case
Last reviewed: September 2026
Questions about scope
I send five parcels a month to Romania. Do I really have to register?
In principle yes: the obligation follows from placing goods on the Romanian market rather than from reaching a volume. The amounts involved will be small, but registration and monthly reporting are what make the position clean.
My marketplace says I am below the threshold. Is that the law?
Usually it is the platform's own verification rule, not a legal exemption. The legal obligation is separate and continues regardless of what the platform currently checks.
Can the obligation sit with my Romanian customer instead?
It can, where a Romanian company imports and resells under its own responsibility and is therefore the first to place the goods on the market. This depends on the actual arrangement, which we assess.
Is it cheaper to stop selling to Romania?
For most sellers no: the contribution scales with the quantities placed on the market, so small volumes mean small amounts. The cost that hurts is several undeclared years, not the monthly figure.
Tell us what you sell in Romania
Send us your product and packaging types and roughly how much you ship to Romania. We reply with the obligations that apply to you and what registration would involve.