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EEE
Slovenia: Extended Producer Responsibility (EPR) for packaging
The regulations regarding Extended Producer Responsibility (EPR) were initiated in Slovenia back in 2006. However, notable changes took place on April 24, 2021, when the new Slovenian decree no. 54/21 concerning packaging management came into effect, leading to the elimination of the minimum threshold requirement. Another adjustment stipulated by the law is that foreign remote sellers are now obligated to appoint an accredited proxy for compliance.Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment (EEE) in Slovenia
Extended Producer Responsibility (EPR) is a legislative framework requiring producers of Electrical and Electronic Equipment (EEE) to take responsibility for their products' entire lifecycle, including proper collection, recycling, and disposal of waste. In Slovenia, this is regulated by the Environmental Protection Act (ZVO-1) and its amendments.Who is Considered Responsible?
In Slovenia, the term "producer" concerning Electrical and Electronic Equipment (EEE) encompasses companies that:- Manufacture EEE under its brand.
- Import EEE into Slovenia from other countries.
- Distribute or sell EEE directly to end-users.
What the EEE includes
In Slovenia, Electrical and Electronic Equipment (EEE) falls into six main categories:- Temperature Exchange Equipment: e.g., refrigerators, air conditioners.
- Screens and Monitors: e.g., TVs, monitors larger than 100 cm².
- Lamps: All types of lighting equipment.
- Large Equipment: e.g., washing machines, copiers, solar panels (over 50 cm in size).
- Small Equipment: e.g., vacuum cleaners, clocks, smoke detectors (under 50 cm).
- Small IT and Telecom Equipment: e.g., phones, routers, PCs (under 50 cm).
Thresholds
In Slovenia, all companies placing Electrical and Electronic Equipment (EEE) on the market are required to register and comply with relevant regulations, regardless of the quantity involved. There are no exemptions based on thresholds.Registration Procedure
To adhere to EEE regulations in Slovenia, companies should follow these steps:- Select an Accredited Producer Responsibility Organization (PRO) to manage EEE compliance.
- Appoint an Authorized Representative (AR) if the company is foreign to ensure compliance with Slovenian laws.
- Submit the required legal documents for company registration.
- Sign a cooperation agreement with the PRO to formalize the partnership.
- Pay the applicable licensing fees associated with compliance services.
- Obtain an Extended Producer Responsibility (EPR) number as proof of compliance registration.
- Submit annual compliance reports on EEE quantities placed on the market and related activities
Authorized Representative
Foreign companies are mandated to appoint an Authorized Representative in Slovenia. The AR acts on behalf of the foreign entity to ensure adherence to Slovenian EEE regulations.Reporting Deadline
EEE producers must submit EEE reports annually. The submission deadline is March 31st of the following year.Sanctions for Non-Compliance
Failure to comply with reporting and registration requirements can result in fines ranging from €1,000 to €100,000, depending on the severity of the violation, and administrative sanctions such as restrictions on market activities.Who bears the responsibility in Slovenia?
The Packaging Act and its associated regulations are applicable to all:- Manufacturers;
- Packers;
- Importers;
- Traders;
- Online shops.
What constitutes packaging according to the Packaging Act of Slovenia?
- Glass;
- Aluminium Metals;
- Plastics, encompassing PET and PVC;
- Paper;
- Metals, encompassing steel and Aluminium;
- Wood;
- Alternative Materials (including Ceramics, Straw, Cork, Textiles).
Thresholds
There exists no predetermined minimum threshold, and all producers must register EPR packaging as soon as they introduce a single packaged item.Producers’ Responsibilities for Extended Producer Responsibility (EPR) in Slovenia
Depending on the type of EPR products, the producer must register with the appropriate authority to obtain the packaging registration number:1. Registration
The producer is required to enroll on the Slovenian Environment Agency (ARSO) website to obtain the registration (EPR) number. Producers must establish agreements with one of six Eco-operators to acquire a Certificate of Adherence. Registration should encompass a financial guarantee.2. Fee Payments
In accordance with the contract with the eco-operator, producers are obligated to make eco-contributions corresponding to each type of material.3. Reporting
Annual reports detailing packaging quantities must be submitted.Authorized Proxy
The producer must appoint an authorized proxy based in Slovenia to fulfill the packaging law requirements on the producer’s behalf.Reporting Deadline
The deadline for submitting the yearly report in Slovenia is by March 31st.Penalties or Sanctions
A fine of EUR 4,000 will be levied in case of the producer’s non-compliance with the obligations outlined in Article 10 of the regulation.
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