Articles · 2026-09-18
What happens if you do not register for packaging EPR
A fine is not the first thing that happens. An inspectorate can stop your packaging until you fix it, and in Czechia you must prove the exemption, not them.
The question arrives late, usually from someone who has just learned that registration was a condition of selling and not a formality afterwards. What happens now? The honest answer is that the fine is the part everyone asks about and the least likely thing to come first.
What is the first thing that actually happens?
An inspection, or a customer asking for a number you do not have. Authorities find unregistered producers through the people who buy from them, through customs data on imports, and through the schemes' own member lists. The first letter is usually an order to put it right within a period, not a demand for money.
Can they stop me selling?
In Czechia, yes, and it is written in the act itself. The Czech Environmental Inspectorate may prohibit placing packaging on the market or in circulation until the breach is remedied, taking the nature and gravity of the breach into account, and it may suspend that placing while it decides (Act 477/2001, § 43). For a manufacturer, a stop order costs more in a week than a fine costs at all: the goods are ready and they cannot go.
How large are the fines?
In Czechia the packaging act's highest bracket is 10 million CZK, and one of the offences carrying it is breaching the record and reporting duties of § 15 — the very duties a producer thinks of as paperwork. That figure comes from a Supreme Administrative Court judgment quoting § 44(2) of the act rather than from the text of the section itself, so it is given here with its provenance and not as a certainty.
For the other member states we have not read the penalty sections in the law. This is where most articles start inventing. We publish a figure when we have read it at source, with the date, and not before.
Does the PPWR set the penalties?
No. Article 68 leaves penalties to the member states, which must lay down the rules and notify them. Until national rules arrive, the packaging law already in force in each country is what an inspector uses — which is why the answer differs so much across the 27. The register, the threshold and the deadline for each country are in our table, each row with a source and a check date.
Who has to prove what?
This is the part that catches people, and Czechia writes it plainly: a producer relying on the exemption must be able to show, on request, that it stayed under both conditions — 300 kg of packaging a year and 25 million CZK of turnover. Whoever cannot prove it for a period is treated as having carried every duty in that period (§ 15a(3) and (4)).
Read that twice. The authority does not have to prove you passed the threshold. You have to prove you did not. A shipment record showing kilograms per material, per year, with the weight frozen on the line, is that proof. An estimate made afterwards is not.
What about the years before I registered?
Registration does not erase them. The duty attached when the packaging was first made available, so the periods before registration are exactly the ones an inspector asks about — and the ones you can only answer from records kept at the time. What an EPR number is and how to apply for one covers the registration itself.
What should I do if I am already late?
Register, and keep the evidence of what you did and when. A producer who registers late with complete records is in a different position from one who registers late and cannot say what was placed on the market. The second is not a paperwork problem; it is the case where the presumption above does the damage.
What a spreadsheet cannot do here
It will hold the kilograms. It will not show that this figure came from these shipments on these dates, that the weight was the one in force then, and that the supplier said so on a named day. Under a rule that puts the burden of proof on you, that difference is the whole case.
What Tarafex does
The kilograms come from shipment lines with the weight frozen on the line, every supplier answer is kept with a name and a date, and every country row in our EPR table carries its source and the date it was checked. We do not register you, we are not your authorised representative, and we do not pay a scheme on your behalf.
Sources: Czech Act 477/2001, § 43 and § 15a, read at source 18 September 2026; § 44(2)(h) as quoted in a Supreme Administrative Court judgment; Regulation (EU) 2025/40, Article 68. Penalty figures for the other member states are deliberately absent until we have read them in the law. This is information, not legal advice.