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Authorisation procedure and Trade Register aspects for CAEN 3291

The establishment of a company whose main or secondary activity is the CAEN code 3291 - Manufacture of brooms and brushes requires compliance with the standard registration procedure at the Trade Register (ONRC), supplemented by additional checks regarding raw materials and the technological process. When filing the registration application, the founders must specify in the articles of association the main activity according to the Classification of Activities in the National Economy and complete the sworn statement provided for by Law 359/2004, certifying compliance with the legal operating conditions. For this CAEN class, there are no special prior authorisation requirements from ONRC, but it is necessary to mention the specific operations: manufacture of brushes, paintbrushes, brooms, toothbrushes, brushware. If the activity involves excisable goods or the possession of wood waste, additional documents may be required. The administrator must declare the exact object of activity to avoid incorrect classifications that would lead to subsequent updates in the Trade Register.

Regulatory framework, specific approvals and supervisory bodies

The main normative act governing this activity is Law no. 84/1998 on trademarks and geographical indications, applicable to finished products, and the health legislation if toothbrushes are manufactured. There is no special environmental permit for small-scale processing of wood or plastic fibres, but if emission thresholds are exceeded or hazardous waste (paints, varnishes) is generated, the operator must obtain an environmental permit from the Environmental Protection Agency. The Environmental Guard and the Territorial Labour Inspectorate check compliance with safety standards when handling brushing machinery. If recycled materials are used, the provisions of GEO 92/2021 on the waste regime apply. The supervisory bodies are: the Tax Authority (ANAF) (for fiscal obligations), the Public Health Directorate (if products come into contact with food under Regulation EC 1935/2004), and the ITM for working conditions. For exporting straw brooms to the EU, a phytosanitary certificate issued by the National Sanitary Veterinary and Food Safety Authority is required.

Tax management, ANAF audit risk and specific accounting

From a taxation perspective, micro-enterprises with a turnover of less than EUR 500,000 may apply the 1% tax on revenue if they have at least one employee, but manufacturing often involves high material costs (wood, natural bristles, plastic, metal). The tax base is determined after deducting expenses for raw materials and depreciation of machinery. VAT is applied at the standard rate of 19%. Attention must be paid to VAT adjustment for intra-Community acquisitions of textile or plastic raw materials. ANAF frequently checks the correctness of the classification under CAEN code 3291, especially if the company imports brooms from China and repackages them - the risk of reclassification as a distributor (CAEN code 4645) can generate tax differences. For accounting, inventories of raw materials (brush wire, wood for handles) are valued at acquisition cost, and production costs are allocated to orders. Separate records by product type (brooms, brushes, paintbrushes) are recommended for the correct calculation of production costs. The obligation to submit the annual single declaration to ANAF regarding estimated income applies to sole proprietorships and individual enterprises carrying out this activity. At the same time, reporting through the RO e-Factura system is mandatory for all invoices issued in B2B relationships. From an audit risk perspective, any discrepancy between physical and book stocks attracts penalties, and the lack of acquisition documents for plastic materials may lead to a presumption of tax evasion. The use of wood waste as raw material requires the completion of traceability forms according to GEO 92/2021.