Slovenia
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Packaging
EEE
About
Packaging
About
Packaging
About
EEE
About
EEE
Packaging
EEE
Packaging
EEE
Extended producer responsibility (EPR) for packaging in Slovenia
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.Who must register for EPR in Slovenia
Under the EPR registration Slovenia scheme, the following are considered obligated producers:- Companies producing, importing, or filling packaging in Slovenia
- Distributors, retailers, or online sellers placing packaged goods on the Slovenian market
- Foreign distance sellers supplying directly to Slovenian end-users
What the package includes
EPR packaging Slovenia covers a wide scope of packaging types, including:- Primary packaging: directly in contact with the product (e.g. bottles, wrappers)
- Secondary packaging: group packaging (e.g. shrink wrap, boxes)
- Tertiary packaging: transport packaging (e.g. pallets, crates)
- All materials: plastic, paper/cardboard, glass, metal, wood, composite
Threshold
As of 2024, there is no official de minimis threshold — all producers placing packaging on the Slovenian market must comply with the Slovenia EPR registration requirements. However, simplified procedures may apply to micro-producers (volume-based exemptions can apply if less than 15,000 kg/year).EPR registration procedure in Slovenia
To comply with EPR registration Slovenia, producers must:- Register with ARSO (Slovenian Environment Agency)
- Join a licensed packaging waste compliance scheme (e.g. Dinos, Interseroh, Slopak)
- Submit data on packaging materials and quantities placed on the market
- Pay eco-contributions or tariffs based on type and volume of packaging
Authorized representative
Foreign companies without a Slovenian legal entity must appoint an authorized representative Slovenia EPR. This entity is legally responsible for:- ARSO registration
- Data reporting
- Eco-fee payments
- Fulfilling all packaging EPR obligations
Reporting deadline
Under the current regulations, producers must:- Report packaging data quarterly to their compliance scheme
- Submit an annual report summarizing total packaging placed on the market
- First quarterly report is usually due by April 30, and final annual data is due by March 31 the following year
Who assumes responsibility?
Responsibility lies with:- Producers and importers of packaged goods
- Foreign sellers, via their authorized representative Slovenia EPR
- E-commerce platforms, if they fulfill on behalf of non-compliant third-party sellers
Duties of each group
- Producers: Register with ARSO, join a compliance scheme, report data, and pay recycling fees
- Authorized Representatives: Act on behalf of foreign businesses to ensure compliance
- Compliance Schemes: Handle logistics, recycling, target fulfillment, and reporting to ARSO
- ARSO and MOPE: Enforce regulation and monitor target achievement
Extended producer responsibility (EPR) for 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 must register for EPR in Slovenia
Under EPR registration Slovenia requirements, the following entities are obligated:- Domestic manufacturers and brand owners of electrical and electronic equipment
- Importers and distributors placing EEE on the Slovenian market
- Distance sellers and e-commerce providers offering EEE directly to consumers in Slovenia
- Foreign entities selling into Slovenia (must appoint a representative)
What the package 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.EPR registration procedure in Slovenia
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 assumes responsibility?
Responsibility falls on:- Domestic producers and importers
- E-commerce sellers and online platforms
- Foreign companies, via their appointed authorized representative Slovenia EPR
Duties of each group
- Producers/Importers: Must register, report annually, pay eco-fees, and finance take-back
- Authorized Representatives: Handle compliance for non-resident producers
- Compliance Schemes: Organize collection, recovery, awareness campaigns, and reporting to ARSO
- ARSO and Ministry: Supervise implementation, data validation, and apply sanctions when needed
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