Extended Producer Responsibility in the Czech Republic and Slovakia – What you need to know before starting sales
Similar to other European Union countries, the Czech Republic and Slovakia have regulations governing the responsibility of entities introducing packaging, electrical and electronic equipment, and batteries to the market. When selling through e-commerce platforms, companies without a presence in the Czech Republic or Slovakia are also subject to mandatory registration. Unregistered sellers may face financial penalties (up to 500,000 CZK in the Czech Republic and 1,200 – 120,000 € in Slovakia).
Packaging registration in the Czech Republic and Slovakia
Before commencing sales in the Czech Republic and Slovakia, you must register your packaging and sign agreements with local recovery organizations.
In the Czech Republic, entrepreneurs introducing packaging in quantities not exceeding 300 kg per year and with an annual turnover below 25,000,000.00 CZK are exempt from registration. However, these entrepreneurs can voluntarily register.
In Slovakia, before planned sales, registration and entry into the national packaging register are required. For companies without a presence in Slovakia, designating a representative under Extended Producer Responsibility is necessary.
Typically, packaging registration takes about 8-12 weeks. The confirmation of registration is a certificate issued by the packaging recovery organization.
Registered businesses are obligated to submit reports on the quantities of packaging introduced to the Czech and Slovak markets. Czech market reports can be challenging due to their complexity compared to the Slovak market, mainly because of the numerous categories of reportable packaging.
In 2022, Slovakia introduced another category of products subject to registration: non-packaging products. This category includes items such as plastic crates, books, postage stamps, cigarette papers, and toilet paper. Separate registration and agreements with recovery organizations are required for this product group. Manufacturers are entered into the national register and receive certificates confirming compliance.
Registration of electrical and electronic equipment and batteries in the Czech Republic and Slovakia
Registration related to packaging may not always suffice – manufacturers introducing electrical and electronic equipment and batteries in the Czech and Slovak markets are subject to separate regulations. This obligation also applies to foreign manufacturers selling directly to end users. For companies without a presence in Slovakia, designating a representative under Extended Producer Responsibility is necessary. Local recovery organizations can act as representatives.
The registration process takes 8 to 12 weeks, and the confirmation of registration is a certificate issued by the recovery organization. Registered entities are entered into national registers.
Similar to packaging, reporting the quantities of equipment and batteries introduced to the market is necessary. Equipment categories may vary slightly across different recovery organizations.
Visible fees for electronic and electrical equipment
Both in the Czech Republic and Slovakia, invoices must indicate the amount of recycling fees paid for specific equipment. This requirement applies to all invoices, regardless of the sales method or whether the recipient is a consumer or a business. Several methods can be used to display these fees on invoices, with a focus on making it easy to determine the recycling fee amount for each product.
