Packaging registration in the Czech Republic and Slovakia – what you need to know

  • Last update: 30.04.2024
  • Published: 19.04.2024
  • Read in: 5 min

In recent times, the Czech Republic and Slovakia have seen a significant increase in Polish sellers entering their markets. This surge is largely due to Allegro launching dedicated versions of its platform in these countries.

Packaging Registration in the Czech Republic and Slovakia – What You Need to Know

However, the expansion process presents challenges for many. It’s important to remember not only the tax obligations, which we have discussed in the context of and, but also the need for packaging registration, reminiscent of Poland’s BDO registry. If you’re keen to learn more about this topic, you’ve come to the right place. This article provides information on packaging registration in the Czech Republic and Slovakia, including:

  • What is extended producer responsibility?
  • Which entity is obliged to register packaging?
  • What legal bases regulate the issue of packaging registration in the Czech Republic and Slovakia?
  • What specific obligations fall on businesses introducing packaging to the market in the Czech Republic and Slovakia?
  • Where can one carry out registration related to market introduction of products in packaging?

Extended producer responsibility

Extended producer responsibility refers to a set of duties and actions, including packaging registration, packaging records, and recycling, associated with the introduction of new products to the market.

Who is obligated to register packaging in Slovakia and the Czech Republic?

Every manufacturer must register packaging before introducing it to the Czech and Slovak markets. It is important to clarify that this term applies to any natural person who:

  1. Uses packaging to pack goods or fills goods into packaging and introduces them to the market under their own trademark;
  2. Orders products that are packed or filled for them and introduced to the market under their trademark;
  3. Introduces goods to the market in a manner other than described above, or transports, or arranges their transportation across the border and there introduces them to the market or distribution;
  4. As a distributor, provides packaging to the final consumer for the immediate packaging of goods, either for a fee or free of charge;
  5. As a distributor, uses packaging to package distributed goods or fill them with distributed goods;
  6. Introduces packaging to the market, except for the person who delivers unused, empty packaging to the individuals mentioned above.
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Legal Bases Regulating Packaging Registration

Packaging regulations in EU member states stem from EU law, governed by two directives:

  • Directive 94/62/EC of 20 December 1994 on packaging and packaging waste;
  • Directive 2018/852 of 30 May 2018 amending Directive 94/62/EC on packaging and packaging waste.

National authorities incorporate regulations from these directives into domestic laws.


Czech Republic

In the Czech Republic, the legal basis regulating packaging issues is Act No. 477/2001 Coll., on packaging and on amendments to certain acts (Packaging Act), dated 4 December 2001. It defines the duties and rights of individuals and enterprises, as well as the competencies of administrative bodies in terms of packaging registration, market introduction, packaging disposal, recycling, remedial measures, and offenses. According to the law, in the Czech Republic, the person introducing packaging to the market (manufacturer, importer, or seller) is responsible for its disposal and recycling. These regulations also apply to entrepreneurs from outside the Czech Republic operating in this market.



In Slovakia, the relevant legislation is the Act of 17 March 2015 on waste and on amendments to certain acts, also known as suo.

Packaging obligations in the Czech Republic and Slovakia

In both the Czech Republic and Slovakia, entities introducing products in packaging to the market must fulfill obligations related to extended producer responsibility. These include:

  1. Registration in the local equivalent of the BDO registers;
  2. Cooperation with a packaging recovery organization;
  3. Ensuring the possibility of free return of used packaging;
  4. Maintaining records and submitting reports on the quantity and types of packaging introduced;
  5. Paying fees dependent on the amount of packaging introduced;
  6. Ensuring packaging quality standards and labeling in compliance with EU requirements.

Failure to meet these obligations may result in financial penalties, making compliance all the more crucial.


Products subject to EPR obligations in the Czech Republic and Slovakia

In Slovakia and the Czech Republic, in addition to packaging, the following also fall under extended producer responsibility obligations:

  • Electrical and electronic equipment;
  • Batteries and accumulators;
  • Vehicles;
  • Tires.

In Slovakia, the term “non-packaging” refers to products made of paper, cardboard, glass, or plastics, such as newspapers, books, or tableware, which also fall under EPR obligations.


Obligations related to the sale of batteries and electrical and electronic equipment in the Czech Republic and Slovakia

For the sale of batteries or electrical and electronic equipment, mere packaging registration may not suffice, as these items must also be marked with the symbol of a crossed-out wheeled bin in every EU country.

Who is exempt from packaging registration in the Czech Republic?

In the Czech Republic, businesses generating an annual turnover of less than CZK 25,000,000 and introducing less than 300 kg of packaging to the market annually are exempt from the registration obligation. However, they may opt for voluntary registration.

Importantly, using this exemption, businesses are still required to keep records of packaging to confirm, during inspections, that waste totals do not exceed 300 kg. Additionally, packaging must meet quality standards, and labeling must comply with EU requirements.

What packaging is subject to registration, record-keeping, and reporting?

Registration of packaging materials in the Czech Republic and Slovakia covers all packaging introduced to the market, including single-use and reusable packaging, industrial packaging, secondary packaging (e.g., boxes and cartons), primary packaging (e.g., bottles or blisters), and transport facilitation packaging (e.g., pallets or shrink wrap).

Packaging Registration Process in the Czech Republic

The packaging registration process in the Czech Republic and fulfilling related obligations take place at the Czech Ministry of Environment, with the registration application to be submitted within 60 days from the date the obligation arises.

However, properly fulfilling these obligations requires knowledge of Czech and EU regulations, making errors, which could result in financial penalties, a real possibility. Therefore, the most common solution regarding extended producer responsibility in the Czech Republic is to cooperate with a company that provides comprehensive services related to the registration, recycling, and reporting of packaging waste.

EKO KOM is the most well-known institution of this kind in the Czech Republic, but other service providers include ASEKOL, EKOLAMP, RECYKLA, and REKOM.

In the case of cooperation with a packaging recovery organization, the entrepreneur still has a quarterly obligation to report the data of packaging introduced to the Czech market (quantity and type) and to pay the required annual fee set by the central packaging register.

Information on packaging registration in Slovakia

The registration process related to packaging, its records, and recycling in Slovakia also takes place at the Slovak Ministry of Environment.

The first step is registration in the Slovak equivalent of BDO, known as ISOH, before the first introduction of the product to the market. For foreign manufacturers, it’s necessary to cooperate with an authorized representative in Slovakia, who will assist in fulfilling EPR obligations. This process involves granting written authorization for at least one year. The appointed authorized representative commits to performing all duties on behalf of the entrepreneur in accordance with applicable regulations, including conducting registration and submitting reports on time.

Once this is done, similar to the Czech Republic, cooperation with a packaging recovery organization, known as OVZ, is established, also handled by the authorized representative.

This is a common practice, and example entities for such cooperation include ENVI PAK, NATUR-PACK, and OZV PLANETA.

However, it’s important to note that after establishing cooperation, the entrepreneur’s obligations still include packaging labeling according to EU standards, as well as keeping records of packaging introduced to the market and reporting data to the Ministry of Environment.

This record involves the quantity and type of packaging, batteries, and electrical and electronic equipment introduced to the Slovak market. Additionally, it’s the producer’s responsibility to inform the final consumer about the ways and places of packaging disposal and waste generated from product use. This can be achieved by including instructions in the relevant languages and providing information about the disposal process.

Furthermore, businesses in Slovakia that do not exceed 100 kg of packaging waste annually are not required to use OVZ services, but it’s still recommended.

Penalties for non-registration of packaging in the Czech Republic and Slovakia

The obligation to register packaging in the Czech Republic and Slovakia also applies to businesses without a local presence, selling through marketplace platforms. Failure to comply can result in a financial penalty of up to 500,000 CZK (approx. 19,700 EUR) in the Czech Republic or between 1,200 and 120,000 EUR in Slovakia.

Packaging registration in the Czech Republic and Slovakia – summary

Packaging management is a significant legal aspect that businesses must consider when introducing products to the market, especially Polish entrepreneurs who sell products in the Czech Republic or Slovakia, significantly influenced by Allegro’s recent expansion into these markets.

Therefore, it’s advisable to familiarize oneself with packaging waste management issues in these countries and diligently fulfill the obligations imposed on entrepreneurs, as neglect in this area can lead to hefty financial penalties.

However, if you plan to sell products in the Czech Republic or Slovakia, remember the VAT tax. If you encounter any difficulties or need support with registration, settlements, or declarations, or if you want to use VAT OSS, schedule a consultation, and our experts will gladly assist you and your company!

For more knowledge, check out our articles on tax obligations on and or about VAT tax in the Czech Republic and Slovakia, and get to know the Czech e-commerce market!

Tomasz Połeć Tomasz is a co-founder of Taxology and a tax advisor (license No. 12104), with 15+ years of experience in Polish and international consulting firms. Leveraging his expertise from numerous tax reviews and audits, he offers proficient tax advisory services to e-commerce companies. He specializes in advising on VAT and CIT settlements in e-commerce and logistics.