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Packaging EPR in the Czech Republic
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Checked 2026-09-16 · 6 sources · 2 open questions
- Register
- Seznam osob (MŽP) — for a producer that complies on its own; a producer whose contract with EKO-KOM covers ALL its packaging is not entered (§ 14(12)). EKO-KOM is the authorised packaging company (AOS)
- Authority
- Ministerstvo životního prostředí (MŽP)
- Law
- Zakon c. 477/2001 Sb., o obalech; Zakon c. 541/2020 Sb., o odpadechtwo different notions of producer run side by side and they do NOT replace each other: PPWR attaches the conformity documentation to whoever puts packaging on the market under its own name or trademark, while act 477/2001 attaches the EPR registration and the EKO-KOM system. A Czech amendment was announced for the same date, 12 Aug 2026. 💶 Entry in the Seznam osob carries a registration fee of 800 CZK (§ 30). ⏱ REGISTRATION deadline: within 60 days of the duty arising — this is the deadline to register, NOT a reporting cadence.
- Who registers
- You register yourself unless your scheme contract covers all your packaging
- Threshold
- 300 kg a yearTWO conditions, both must hold: no more than 300 kg of packaging a year AND annual turnover of no more than 25,000,000 CZK (§ 15a, in force since 1 January 2021). Then the duties in §§ 10–15 do not apply — take-back, recovery, records and entry in the Seznam osob. The 4.5 million CZK still printed in older guidance, EKO-KOM's FAQ among it, is the limit from before 2021. Whoever cannot prove both conditions is treated as having carried every duty for that period (§ 15a(4)).
- Authorised representative
- Only for distance selling to consumerspověřený zástupce — OPTIONAL for a person not established in Czechia (§ 13a), but MANDATORY for a distance seller from another state selling single-use plastic packaging listed in parts C or D of annex 4 directly to consumers or other end users. The representative files the entry in the Seznam osob in its own name (§ 14(3)); EKO-KOM itself may not act as one (§ 20(10)).
- Household packaging schemes
- EKO-KOM
- Industrial packaging schemes
- EKO-KOM
What is not settled
- Threshold Not established at sourceThe limits above are taken from the Czech packaging act as in force on 1 December 2025, before the PPWR applied. Whether § 15a still releases a small producer now that the PPWR applies is not established at source: the Czech amendment announced for 12 August 2026 has not been read.
- Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.
The same in every EU country
- PPWR Art. 44 — registration is a precondition for placing packaging on that market
- PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
- set nationally, Art. 68; national rules due by 12 Feb 2027
- Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029
Sources
Countries with the same answer
We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.
Tarafex
The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.
See what Tarafex does →
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