Czech Republic
Extended producer responsibility for packaging in Czech Republic
The Czech system is based on Act No 477/2001 Coll. on Packaging (continuously amended, most recently by Act No 542/2020 Coll.) and the overarching Waste Act No 541/2020 Coll.. These laws transpose the EU Packaging Directive and make producers finance collection and recycling of all packaging they place on the market. Compliance is supervised by the Ministry of Environment (MŽP) and executed chiefly through the collective scheme EKO-KOM. The framework is commonly referred to as EPR Czech Republic and is a pre-condition for lawful trade in packaged goods.
Who must register for EPR in Czech Republic
Any entity that first places packaging on the Czech market must comply, including:
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Manufacturers / packers established in Czechia.
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Importers / distributors bringing packaged goods from abroad.
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E-commerce sellers without a Czech establishment (must act via an authorised representative).
This captures B2C and B2B supply chains; retail chains that brand-label products count as producers.
What the package includes
The law covers all primary, secondary and tertiary packaging made of:
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Paper & cardboard
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Plastics (incl. PET, HDPE, other polymers)
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Metals (steel, aluminium)
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Glass
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Wood
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Composite & “other” materials
Single-use and reusable packaging are in scope once first marketed.
Threshold
Obligations apply in full when both of these limits are exceeded in the previous calendar year:
300 kg total packaging placed on the market and
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Annual turnover > CZK 25 million (≈ €1 million).
Businesses below either limit still keep internal records, but may forgo registration and fee payment.
EPR registration procedure in Czech Republic
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Choose a PRO (the dominant one is EKO-KOM, but several niche schemes exist).
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Sign a “Contract on Collective Fulfilment” and pay the one-off registration fee (€66 excl. VAT in EKO-KOM).
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Receive your EPR registration Czech Republic ID (IČO-style number); marketplaces may request it.
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Report packaging weights quarterly via the PRO portal and pay material-specific eco-fees by the due dates.
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Keep data and invoices for at least five years for possible MŽP audit.
Authorized representative
Foreign companies that sell packaged goods directly to Czech consumers must appoint an authorised representative domiciled in Czechia. The AR signs the PRO contract, files reports and pays fees on the producer’s behalf, ensuring Ministry of Environment EPR requirements are met.
Reporting Deadline
Quarterly weight statements and fee payments must reach the PRO within 30 days after quarter-end:
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Q1: Reports must be filed between 1 and 30 April.
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Q2: Reports must be filed between 1 and 31 July.
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Q3: Reports must be filed between 1 and 31 October.
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Q4: Reports must be filed between 1 and 31 January of the following year.
Late filing triggers penalty surcharges from the scheme and inspection risk from MŽP.
Who Assumes Responsibility?
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Czech manufacturers / packers bear full responsibility as soon as a product is first placed on the Czech market.
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Importers or distributors are fully liable at the point of customs clearance, unless an upstream licence has already covered the product’s obligations.
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Foreign distance sellers assume liability—through an authorised representative—when they sell directly to a Czech consumer.
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Producer Responsibility Organisations (PROs), such as EKO-KOM, take on operational duties for collection, recycling and transferring the required data.
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The Ministry of the Environment (MŽP) handles enforcement and registry tasks, including audits and the imposition of fines.
Extended producer responsibility for EEE in Czech Republic
Who Must Register for EEE EPR in Czech Republic ?
Producers, importers, and distributors of Electrical and Electronic Equipment (EEE) in the Czech Republic must comply with Extended Producer Responsibility (EPR) regulations. This includes:- Manufacturers producing EEE in the Czech Republic for domestic or international markets.
- Importers bringing EEE into the Czech Republic from other EU or non-EU countries.
- Distributors and resellers placing EEE products on the Czech market under their own brand, unless the original manufacturer or importer is already registered.
- Online sellers and marketplace operators supplying EEE to consumers in the Czech Republic. However, under EU regulations, marketplace operators are generally not considered responsible for EPR unless they act as importers or directly place products on the market.
What the equipment includes
All household and professional devices that depend on ≤ 1 000 V AC / 1 500 V DC fall under six open-scope categories set in Annex I to Act 542/2020:
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Temperature-exchange equipment
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Screens & monitors ≥ 100 cm²
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Lamps
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Large equipment (> 50 cm)
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Small equipment (≤ 50 cm)
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Small IT & telecom devices (≤ 50 cm)
Threshold
Businesses must register for EEE EPR in Czech Republic if they place any quantity of EEE on the Czech market. There is no de minimis threshold for registration, meaning all producers, regardless of volume, must comply with EPR obligations.EPR Registration Procedure
- Determine EPR Obligation: Assess whether your company falls under the EPR scope based on product type and market activities.
- Choose Compliance Method:
- Register individually with the relevant authority.
- Join a Producer Responsibility Organization (PRO) for collective compliance.
- Register with the Ministry of the Environment: Submit an application including business details, product categories, and expected quantities placed on the market.
- Register in the Seznam výrobců elektrozařízení (Registry of EEE Producers): This is a mandatory step for all companies placing EEE on the Czech market.
- Sign a Contract with a Compliance Scheme: If joining a PRO, sign an agreement and submit necessary documentation.
- Pay Registration Fees: Fees vary based on the compliance scheme and product categories.
- Obtain a Registration Number: Upon approval, receive a unique registration number required for reporting and compliance.
Authorized Representative
Foreign companies without a physical presence in the Czech Republic must appoint an Authorized Representative. The AR assumes responsibility for ensuring compliance with all EPR obligations, including registration, reporting, and financial contributions. If your company does not have a local presence, Lovat’s Authorized Representative service ensures full compliance with EPR regulations.Reporting Deadlines
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Q1 – The portal opens on 1 April, and the filing must be submitted by 30 April (30 days later).
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Q2 – The portal opens on 1 July, with the submission due by 30 July.
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Q3 – The portal opens on 1 October, and the deadline is 30 October.
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Q4 – The portal opens on 1 January of the following year; submissions are due by 30 January.
Who Assumes Responsibility?
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Czech manufacturers or packers bear full responsibility as soon as a product is first placed on the Czech market.
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Importers or distributors assume full liability at customs clearance, unless the product has already been licensed upstream.
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Foreign distance sellers are liable—through an authorised representative—once they make a direct B2C sale to a Czech consumer.
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Producer Responsibility Organisations (e.g., ASEKOL) take on the operational duties: collection, recycling and mandatory data transfer.
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The Ministry of the Environment (MŽP) and the Czech Trade Inspection Authority (CTIA) handle enforcement and fines through market-surveillance activities.
Penalties for Non-Compliance
Failure to comply with EPR requirements can result in:-
- Fines of up to several million Czech koruna, depending on the severity of the violation.
- Market restrictions, including bans on selling non-compliant products.
- Legal action, if EPR violations result in environmental harm or unfair competition.