Knowledge Base: E-commerce Accounting and VAT Compliance

Extended Producer Responsibility in the Czech Republic and Slovakia

Extended Producer Responsibility in the Czech Republic and Slovakia – What you need to know before starting sales

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Date14 Jun 2024
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Category

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.

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The author of the article is take-e-way GmbH - personal WEEE representative for Germany

Take-e-way GmbH was founded in 2004 and is a one-stop shop for all manufacturers, importers and users of electrical and electronic equipment who need support in properly fulfilling the legally imposed obligations arising from the sale of products.

This publication is non-binding information and serves for general information purposes. The information provided does not constitute legal, tax or management advice and does not replace individual advice. Despite careful processing, all information in this publication is provided without any guarantee for the accuracy, up-to-date nature or completeness of the information. The information in this publication is not suitable as the sole basis for action and cannot replace actual advice in individual cases. The liability of the authors or amavat® are excluded. We kindly ask you to contact us directly for a binding consultation if required. The content of this publication iis the intellectual property of amavat® or its partner companies and is protected by copyright. Users of this information may download, print and copy the contents of the publication exclusively for their own purposes.

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