Slovakia EPR guide | Lovat Compliance

Slovakia: Extended Producer Responsibility (EPR) for packaging

In Slovakia, the implementation of Extended Producer Responsibility (EPR) regulations commenced in 2016, initially focusing on sorted packaging waste. Subsequently, Act No. 302/2019 Coll. has significantly expanded and refined the responsibilities and obligations outlined in the Waste Act, with a specific emphasis on Single-use Beverage Packaging.

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Who is considered responsible?

The Packaging Act and the regulations apply to all:

Manufacturer;
Distributors;
Imports products;
Packs or fills products.

What do you mean by packaging?

Glass;
Metals Aluminium;
Plastics and Plastics PET;
Paper and Cardboard;
Composite beverage carton;
Metals steel;
Wood.

Thresholds

Regarding the prerequisite for system involvement, there is no set minimum; all producers and sellers must register.

Producers’ Obligations for Extended Producer Responsibility (EPR) in Slovakia

The producer has to record with the National Register of Obliged Parties with the assistance of the Ministry of Environment to receive the registration (EPR) number.
The producers or distributors must have contracts for take-back schemes and should have a minimum contract period of 2 years with Eco-operators.
The producers are required to make eco-contributions in the amount established by the government.
A quarterly report must be submitted, even a zero report with the amounts of packaging

Authorized representative

The Slovak and foreign producers must nominate an authorized representative based in Slovakia to register the packaging law requirements on behalf of the producer, and the agreement is granted for at least one year.

Deadline Reporting

The possibility to submit by the 15th day of the preceding month.

Fines or punishment

Following the new requirement of January 2021, the producer who does not fulfill the obligation or submits the incorrect quantities, the charges can range from 4.000 € to 350.000 €.

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Extended Producer Responsibility (EPR) for non-packaging in Slovak Republic

Plastic-based products pervade every aspect of our society. The term “non-packaging plastic” encompasses a wide range of materials used in the production of various goods. These items may be entirely composed of plastic, either in a singular form or as a blend, or they may incorporate multiple materials, including plastics amalgamated to create intricate products.

Who is considered responsible?

Responsibility lies with the producer of a non-packaged product, defined as an individual or entity engaged in business activities that involve:

Manufacturing or organizing the manufacturing of a non-packaging product.
Transporting or arranging for the transportation of a non-packaging product.
Importing or arranging for the import of a non-packaging product.

What is considered a non-packaging material?

A non-packaging product refers to an item not intended for packaging or that does not serve as packaging. It falls into one of the following product categories, contributing to municipal waste:

Plastic products made from PET material, excluding raw materials, preforms, and fibers for industrial use. Also, plastic products made from PE, PP, PS, PVC, or PA material, excluding raw materials, fibers, and industrial-use products.
Paper and paperboard, including imported paper and paperboard products, except for certain printing products.
Glass, including plate glass.

Thresholds

No specific minimum thresholds are set, necessitating all producers to register under Extended Producer Responsibility (EPR) for non-packaging materials.

Registration procedure

Compliance registration for non-packaging materials regulations in Slovakia entails several steps:

Register as a manufacturer of non-packaged products after releasing them on the market.
Register with an Authorized Representative based in Slovakia.
Enroll in a compliance scheme to cover the costs of collecting and recycling non-packaging materials.
Fulfill the required license fee payment.
Obtain the Extended Producer Responsibility (EPR) number for the company.
Report the quantity of non-packaging products released into the market.

Authorized representative

Foreign companies must appoint a representative in Slovakia, known as the Authorized Representative (AR). This individual or entity acts on behalf of the foreign company, ensuring compliance with all applicable laws and regulations in Slovakia.

Deadline Reporting

Reporting frequency is quarterly, with submissions required electronically by the 10th day after the previous quarter ends.