Czech Republic
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Packaging
About
Packaging
About
EEE
About
EEE
Packaging
EEE
Packaging
EEE
Czech Republic: Extended Producer Responsibility (EPR) for Packaging
Since January 1, 2021, the extended producer responsibility system waste streams have been implemented for packaging (the “Packaging Act”), Act No. 541/2020 Coll.Who bears the responsibility?
The Packaging Act and its associated regulations apply to all:- Producer
- Distributors
- Importers
- Manufacturers
What constitutes packaging?
- Paper and cardboard
- Metals
- Plastics
- Glass
- Wood
- Aluminium
Thresholds
The producers are obligated to comply if thresholds extend 300kg and the annual turnover exceeds CZK 25 million.Producers’ Responsibilities for EPR
The producer must register with the appropriate organization to obtain the packaging registration number: 1 EPR registration in Czech Republic- The producer must conclude a contract with the eco-operator to get a certificate of participation in the system, including an Identification Number.
- Quarterly payment Rewards for ensuring the take-back and utilization of packaging waste.
- Annual payment of the Fee for registration in the combined fulfillment system.
- Producers are required to present quarterly packaging reports.
Authorized Proxy
The producer must appoint an authorized proxy based in Czechia to fulfill the packaging law requirements on the producer’s behalf.Reporting Deadline
- 1st quarter from 1st April to April 30th.
- 2nd quarter from July 1st to 30th July.
- 3rd quarter from October 1st to October 30.
- 4th quarter from January 1 of the following year to January 30 of the following year.
Sanctions in case of violation
Authorities may impose fines up to 10,000,000 CZK if the business fails to ensure recover of packages put to the market. This fine may be imposed repeatedly.Who Must Register for EPR?
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.
Examples of Products Subject to EPR
EEE products covered under the EPR framework include, but are not limited to:- Household appliances (e.g., refrigerators, washing machines, vacuum cleaners)
- IT and telecommunications equipment (e.g., computers, laptops, smartphones)
- Consumer electronics (e.g., televisions, audio systems, gaming consoles)
- Lighting equipment (e.g., LED bulbs, fluorescent lamps)
- Electrical tools (e.g., drills, saws, lawnmowers)
- Medical devices (e.g., thermometers, diagnostic equipment)
- Monitoring and control instruments (e.g., thermostats, smoke detectors)
Threshold for Registration
Businesses must register for EPR 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 (AR)
Foreign companies without a physical presence in the Czech Republic must appoint an Authorized Representative (AR). 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
Registered producers must submit periodic reports detailing the amount of EEE placed on the market. Reporting requirements and deadlines depend on the chosen compliance method: Individual Compliance (Direct Registration with Authorities):- Quarterly Reports: Usually required within 30 days after the end of each quarter.
- Annual Reports: Must be submitted by March 31 of the following year.
- Reporting deadlines vary depending on the PRO’s internal requirements. Many schemes require quarterly or semi-annual reporting.
- Some PROs consolidate reporting for multiple members, potentially reducing the administrative burden.
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.
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