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Packaging EPR in Slovakia

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Checked 2026-09-03 · 3 sources · 2 open questions

Register

Register výrobcov vyhradeného výrobku — filed through the ISOH portal

Authority

Ministerstvo životného prostredia SR (MŽP)

Law

Zákon o odpadoch; Vyhláška 366/2015, § 15the producer must be registered with MŽP BEFORE placing the product on the Slovak market. In packaging the ‘producer’ is the one who packs the product or imports packed products — not the physical maker of the packaging. Signing a contract with an OZV means the OZV files the registration application for you; an OZV or a third person may file for several producers at once.

Who registers

You register yourself in the national system

Threshold

100 kg a calendar yearthis is NOT an exemption — it is a REPORTING trigger in reverse. A producer placing UNDER 100 kg a year who does not use an OZV must file the annual report itself. Producers who comply through an OZV do not file at all; the OZV files cumulatively for everyone it represents.

Authorised representative

Mandatory for a producer established abroadsplnomocnený zástupca — a producer with no seat or place of business in Slovakia must appoint one

Reporting

Annually, by 28 Februarythe annual report covers the whole calendar year and is due by 28 February of the following year. It asks for quantities placed on the market, plastic bag quantities, recovery and recycling rates achieved and packaging-waste collection data. ⚠️ producers must also keep their own running records, and OZV clients typically report quantities to the OZV QUARTERLY — by the 10th day after the quarter in NATUR-PACK’s case.

Also required

Membership of an OZV

Household packaging schemes

ASEKOL SK, E-cycling s.r.o., ELEKOS, ENVI-PAK, NATUR-PACK, NOWAS, Reclay Systems s.r.o (formerly RECobal), SEWA, 1. východoslovenská OZV

Industrial packaging schemes

NA - Although it seems the EPR scheme does not yet incorporate commercial and industrial packaging, some PROs provide services for those.

What is not settled

• Register Not established at sourceFiling through the ISOH portal is described with a Slovak eID login. How a foreign producer without one files in practice was not established \u2014 in practice this is what the authorised representative or the OZV does.
• 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

• isoh.gov.sk authority
• isoh.gov.sk authority
• naturpack.sk scheme

Countries with the same answer

• Denmark Live
• France Live
• Greece Live
• Austria Live
• Belgium Live
• Cyprus Live

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