Selling Packaged Products into Romania: What Counts as Packaging?

When a foreign company sells goods in Romania, its packaging obligations usually begin with a basic but important task: identifying what actually counts as packaging in the product flow.

This is harder than it sounds. The box around the product is obvious. The protective film, grouped carton, delivery envelope, pallet wrap, labels and fulfilment materials can be less obvious. Missing these components can make internal data incomplete before any reporting or compliance decision is even considered.

Packaging is broader than the retail box

Romanian Law no. 249/2015 defines packaging broadly as an item intended to contain, protect, handle, deliver or present products, from raw materials to processed goods, from the producer to the user or consumer. The law also provides examples and exclusions.

The practical lesson is simple: do not start with a generic category called “product packaging”. Start with the journey of each product.

For a product sold online, the flow might include:

the primary packaging around the product;
a secondary carton grouping several products;
transport packaging used by the supplier;
fulfilment packaging added for the Romanian shipment;
labels, tape, protective material or inserts that are part of the delivery.

Not every item will have the same treatment, and some items can fall outside the definition. The classification should be based on the item’s function and use, not its commercial name.

The three packaging levels are a useful working method

For operational purposes, separate the data into three levels:

Primary packaging

This is the packaging that reaches the end user as part of the sales unit. Examples may include a bottle, a pouch, a retail carton or a jar.

Secondary packaging

This groups products into larger units, such as a carton containing multiple retail boxes. It may be removed before the product reaches the final customer.

Transport packaging

This protects or handles goods during transport. It can include outer cartons, stretch film, protective corners or pallets, depending on the use and the specific facts.

The distinction matters because packaging data should be granular enough to explain what was sold, where it was used and how the weight was calculated.

Do not rely on estimates alone

A company often starts with a reasonable commercial estimate: “Each product uses about 100 grams of packaging.” That may help during an internal scoping exercise, but it is not a robust basis for ongoing compliance work.

Build the file from evidence wherever possible:

supplier packaging specifications;
bills of materials;
technical drawings or product data sheets;
packaging purchase invoices;
actual packaging weights from sample checks;
SKU-level sales and delivery data;
written confirmation from fulfilment providers about added materials.

Where data is estimated, label the methodology, the assumption, the date and the person responsible. This makes it easier to replace estimates with verified figures later.

Pay attention to cross-border logistics

One of the most common gaps appears in cross-border e-commerce. A manufacturer may provide the weight of the retail box, while a warehouse or fulfilment partner adds an outer box, void fill, tape and a shipping label. If the business wants a complete view of packaging that reaches Romania, it needs data from both parts of the chain.

The same applies where a Romanian distributor repacks goods before resale. The written agreement and the actual workflow should be reviewed together; one does not automatically describe the other.

A packaging-data checklist for foreign companies

For each product route into Romania, prepare a simple table with:

product and SKU;
sales channel;
entity placing the product on the market;
packaging component;
packaging level;
material;
weight per unit;
source of the weight;
period and quantity sold or shipped;
owner of the source data.

This is not a statutory template. It is a practical record that allows a finance, logistics or compliance team to understand the figures behind a declaration or an external provider’s calculation.

Link packaging data to PPWR preparation

The same data file is useful for PPWR readiness. Regulation (EU) 2025/40 introduces packaging requirements in stages, including requirements connected with sustainability, labelling, recycled content, recyclability and waste prevention. Not every obligation applies at the same time or to every format, but the basic material and component data should be available before the business needs it.

How we can help

We help businesses organise packaging information into a clear, usable inventory, identify gaps between supplier data and Romanian sales flows, and prepare a document checklist for further EPR and PPWR assessment.

Explore EPR & PPWR compliance support in Romania

This article is general information and does not constitute legal, tax or regulatory advice for a particular business.