For commercial packaging, participation in a collection and recycling system is not yet mandatory. However, this will change from 1.1.2023. Until then, companies can still implement their own solution without the help of a system and organize collection and recycling of their packaging material on their own. The duties for commercial packaging include: Obligation to take back B2B-packaging free of charge (with the exception of deliveries to major accumulation points). Obligation to return the packaging to the upstream take-back obligor by the end of the following calendar year at the latest. Alternatively, reuse or appropriate recovery on one’s own initiative is possible. Obligation to keep records and to report the quantities of packaging handed in for suppliers at major collection points (Annex 3 old). Obligation to record and report commercial packaging placed on the market, broken down by packaging material, by March 31 for the previous calendar year. Obligation to provide information to subsequent distribution stages (distributors and primary obligated parties) Recording and reporting obligation of the primary obligated party on packaging delivered to major accumulation points (Annex 3 old). Information obligation in the form of a legally binding declaration in the case of participation by upstream or downstream distribution stages of the primary obligated party Reporting obligation for packaging for which there is no participation in a collection and recovery system (Annex 3 old). Possible complementary licensing to 100% (§ 10 para. 7) is only possible for the last time for the calendar year 2022 (deadline: 31 March 2023). Annual obligation to report data pursuant to § 13 (3a) by March 15 for the previous calendar year. Unless a flat-rate solution is used. In 2022, for the last time, the small-scale distributor rule for commercial packaging can be used. A producer can invoke the small-scale distributor status if  his total annual turnover in Austria is below €730,000 and if certain thresholds for commercial packaging quantities are not exceeded (e.g. max 300 kg paper/cardboard/cardboard, max 100 kg plastic per year). The full requirements for the small-scale distributor role can be found on this info page from the Austrian Chamber of Commerce. The small-scale distributor status grants relief from all obligations mentioned above. Companies that invoke this status only have to properly dispose of the packaging at the request of their customers. The small dispenser regulation expires on 31.12.2022! After that date, participation in a collection and recovery system is mandatory for all commercial packaging.