Czech Republic and Slovakia EPR in 2026: EKO-KOM, OZV obligations, WEEE and battery streams, and CEE marketplace verification

By Operator One Editorial — 2026-06-14

Key takeaways

• Czech packaging: EKO-KOM clients file a quarterly statement within 30 days after each quarter ends, while producers fulfilling Act No. 477/2001 Coll. individually enter the Ministry of the Environment's List of Persons within 60 days and report by 15 February. The only exemption (§15a) requires both 300 kg or less of packaging a year and turnover of CZK 25,000,000 or less.
• Slovakia: §27(18) of Act No. 79/2015 Coll. on Waste requires a producer with no seat or place of business in Slovakia to appoint a Slovak-established authorised representative by written mandate of at least one year, and producers must register in the Register of Producers of Reserved Products (RVVV).
• Czechia is less strict on representation: §13a of Act No. 477/2001 Coll. and §11 of Act No. 542/2020 Coll. let a non-Czech producer appoint a Czech representative, but §61 of Act No. 542/2020 Coll. makes it mandatory for EEE distance sellers to Czech end users, and Article 56(3) of Regulation (EU) 2023/1542 requires one for battery distance sellers in each Member State.
• The EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026: Article 45(3) requires an EPR authorised representative in each Member State where a producer sells packaging directly to end users from abroad, and Allegro now asks packaging producers for a separate EPR number per country.
• Slovakia's deposit return scheme under Act No. 302/2019 Coll. has charged 15 cents on single-use plastic bottles and cans of 0.1 to 3 litres since 1 January 2022; Czechia has no single-use beverage deposit scheme, but PPWR Article 50 sets a 90 percent separate collection target for these formats by 1 January 2029.
• Non-compliance is priced: §45 of the Czech Packaging Act allows fines up to CZK 10,000,000 for its most serious offences; under §122 of Act No. 542/2020 Coll. a producer that does not apply for the List of Producers faces up to CZK 500,000; and under §117(3) of Slovakia's Act No. 79/2015 Coll. failing to register in the RVVV or to appoint a required representative can cost up to EUR 120,000.

Why Czechia and Slovakia sit together, but not quite

The Czech Republic and Slovakia share a regulatory shape: both run producer-responsibility schemes that collect fees from obliged producers, and both keep separate streams for packaging, electrical and electronic equipment (WEEE) and batteries. In Czechia, packaging EPR sits in Act No. 477/2001 Coll. on Packaging and WEEE and battery EPR in Act No. 542/2020 Coll. on End-of-Life Products. In Slovakia, all three streams sit in Act No. 79/2015 Coll. on Waste. On top of both national systems, the EU Packaging and Packaging Waste Regulation (EU) 2025/40 has applied directly since 12 August 2026, and the EU Batteries Regulation (EU) 2023/1542 has applied since 18 February 2024.

For a seller established elsewhere in the EU, for example a consumer-electronics brand shipping from a German warehouse to Czech and Slovak buyers via Allegro, Kaufland.cz and Kaufland.sk, the compliance work in the two countries looks similar. The legal detail is where they diverge, above all on whether a local representative is mandatory.

In Operator One's experience, it works best to treat Czechia and Slovakia as two sets of registrations, two scheme contracts per stream and two reporting calendars, run on one shared operational rhythm. Running them as a single block is where mistakes get made.

EKO-KOM: the Czech packaging stream

Under §13(1) of the Czech Packaging Act (Act No. 477/2001 Coll.), a person placing packaging on the Czech market fulfils its take-back and recovery obligations in one of three ways: individually at its own cost, by transferring them contractually together with ownership of the packaging, or by a contract with an authorised packaging company. EKO-KOM is an authorised packaging company whose clients include distributors, fillers and producers of packaged goods, and Kaufland's seller guidance for Kaufland.cz directs online sellers to register with it.

What the Czech packaging rules require:

• De minimis: §15a of Act No. 477/2001 Coll. exempts a person only if it places 300 kg or less of packaging on the Czech market in a calendar year and its annual turnover is CZK 25,000,000 or less. Both conditions must hold.
• EKO-KOM clients: EKO-KOM requires a quarterly statement of packaging placed on the market within 30 days after each calendar quarter ends, a quarterly payment for take-back and recovery, and an annual registration fee of CZK 1,600 excluding VAT (CZK 800 for the State Environmental Fund plus CZK 800 administrative fee). EKO-KOM publishes its per-material fee rates on its own site.
• Individual fulfilment: a person bearing the obligations itself must apply for entry in the Ministry of the Environment's List of Persons within 60 days of the obligation arising (§14(4)), keep continuous records, report the previous calendar year to the Ministry by 15 February (§15(1)(b)) and retain supporting documents for at least five years (§15(1)(d)). Applicants seated outside the Czech Republic may file the application in English (§14(6)).
• Representation: under §13a, a person not established in the Czech Republic may appoint a Czech-established "pověřený zástupce" (authorised representative) by written contract. It is mandatory only for distance sellers of the single-use plastic items listed in parts C and D of Annex 4 to the Act.

The Czech Packaging Act, in its consolidated version of 1 December 2025, regulates deposits only for reusable deposit packaging (§9). There is no statutory deposit return scheme for single-use beverage bottles and cans in Czechia.

Slovakia: OZV-led packaging, structurally similar, operationally distinct

Slovakia runs packaging EPR under Act No. 79/2015 Coll. on Waste. Producers contract with a licensed producer responsibility organisation (organizácia zodpovednosti výrobcov, OZV). The Slovak Ministry of the Environment's ISOH list of packaging OZVs names nine organisations, including NATUR-PACK, ENVI-PAK, Reclay Systems and SEWA.

Key differences from the Czech setup:

• State register: under §27(4)(a) of Act No. 79/2015 Coll., every producer of a reserved product must register in the Register of Producers of Reserved Products (Register výrobcov vyhradeného výrobku, RVVV), filed electronically through the Ministry's ISOH system. This is separate from the OZV contract.
• Mandatory authorised representative: §27(18) to (20) require a producer with no seat or place of business in Slovakia to appoint a Slovak-established authorised representative (splnomocnený zástupca). The mandate must be written, cover all of the producer's rights and obligations under the Act and last at least one year, and the representative is then responsible for compliance in its own name. Unlike Czech packaging law, there is no direct route.
• Deposit return scheme: Slovakia's scheme under Act No. 302/2019 Coll. has run since 1 January 2022 and is administered by Správca zálohového systému. It covers single-use plastic bottles and cans of 0.1 to 3 litres at 15 cents per container, and excludes milk-based drinks, syrups and spirits above 15 percent alcohol. Producers register their beverage containers with the Administrator and pay the deposits and fees for each container placed on the market.

For beverage sellers, Slovak deposit registration sits on top of the OZV packaging contract under Act No. 79/2015 Coll. The two are not substitutes.

WEEE in both countries: ASEKOL, REMA, SEWA, ENVIDOM and others

WEEE (electronics) is a separate registration with a separate scheme. In Czechia, ASEKOL and REMA Systém both describe themselves as collective systems for electrical equipment under Act No. 542/2020 Coll. In Slovakia, the Ministry's ISOH list of OZVs for electrical equipment names nine organisations, including SEWA, ENVIDOM, ASEKOL SK and NATUR-PACK.

What a non-resident electronics seller needs to do:

• Czechia, registration before sale: §21(1) of Act No. 542/2020 Coll. requires every producer to apply for entry in the Ministry of the Environment's List of Producers no later than the day it first places the products on the market. For producers in a collective system, the system operator enters the producer's data within 30 days of the contract (§21(5)).
• Czechia, representation: §11 lets a producer not established in Czechia appoint a Czech-established representative, which cannot be a collective system operator. §61(1) makes the appointment mandatory for a producer that sells EEE by distance selling directly to end users in Czechia from another state.
• Slovakia: register in the RVVV and act through a Slovak authorised representative if you have no Slovak seat (§27 of Act No. 79/2015 Coll.). An EEE producer may contract with only one OZV for each EEE category listed in Annex 6 to the Act.
• Marking: Annex IX of the WEEE Directive 2012/19/EU requires the crossed-out wheeled bin symbol, printed visibly, legibly and indelibly.

Batteries: small stream, sharp enforcement

The EU Batteries Regulation (EU) 2023/1542 is a directly applicable regulation, not a directive that needs transposing. It was published on 28 July 2023, entered into force on 17 August 2023 and has applied since 18 February 2024, with its extended producer responsibility chapter (Chapter VIII) applying from 18 August 2025 under Article 96. National EPR rules sit in Act No. 542/2020 Coll. in Czechia and Act No. 79/2015 Coll. in Slovakia.

• Czechia: Act No. 542/2020 Coll. §3 defines a battery producer as a business placing batteries on the market, including batteries built into vehicles, electrical equipment or other products or supplied with them. REMA Systém fulfils battery obligations for its producers in cooperation with REMA Battery.
• Slovakia: the ISOH list of OZVs and third parties for batteries names ten organisations, including the OZV SEWA and the third party INSA.
• Distance sellers: Article 56(3) of Regulation (EU) 2023/1542 requires a producer selling batteries directly to end users in another Member State to appoint an authorised representative for extended producer responsibility in each Member State where it sells, by written mandate.
• Labelling: under Article 13, batteries must carry the general information label from 18 August 2026 or 18 months after the relevant implementing act enters into force, whichever is later.
• Battery passport: under Article 77, from 18 February 2027 a digital battery passport is required only for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. Portable batteries in headphones, torches or toys are outside it.

Because Czech law counts built-in batteries, a product such as wireless headphones can bring a seller into three Czech streams: packaging, WEEE and batteries. Slovakia is the same, which adds three more registrations or scheme contracts.

PPWR from 12 August 2026: what changed in both countries

The Packaging and Packaging Waste Regulation (EU) 2025/40 applies from 12 August 2026 (Article 71) and, as a regulation, binds Czechia and Slovakia directly alongside Act No. 477/2001 Coll. and Act No. 79/2015 Coll.

• Article 45(1) gives producers extended producer responsibility for packaging they make available for the first time on the territory of a Member State.
• Article 45(3) requires a producer that makes packaging or packaged products available directly to end users in a Member State other than its own (producer types (c) and (d) of Article 3(1), point 15) to appoint, by written mandate, an authorised representative for extended producer responsibility in each such Member State.
• Article 44 obliges producers to register in national registers of producers, which each Member State must set up within 18 months of the Commission's first implementing act on registers.
• Article 45(4) requires online platforms that let consumers conclude distance contracts to obtain each producer's registration information and registration numbers for the consumer's Member State, plus a self-certification, before allowing the producer to use their services.
• EKO-KOM states that its updated reporting methodologies apply from 12 August 2026.

Allegro and Kaufland CZ/SK: what they ask for

Allegro launched allegro.cz in the Czech Republic on 10 May 2023 and allegro.sk in Slovakia in 2024. Kaufland runs separate marketplaces for Czechia (Kaufland.cz) and Slovakia (Kaufland.sk).

• Allegro, batteries: since 18 August 2025, Allegro requires sellers with producer status for batteries or battery-containing products to provide a separate EPR number for each country they sell into, citing Regulation (EU) 2023/1542. Allegro warns that registration can take several weeks.
• Allegro, packaging: from 12 August 2026, Allegro asks packaging producers for their EPR register number, a separate one per country of dispatch, plus acceptance of a declaration of packaging conformity, submitted in the Account Details tab. Allegro states that without an EPR number it cannot display the number in your offers and your sales will not be compliant with EU law.
• Kaufland.cz: Kaufland's seller guidance states that since 1 July 2022 online sellers and manufacturers placing packaging on the Czech market must register with EKO-KOM.
• Kaufland.sk: Kaufland's guidance states that since 1 July 2022 sellers placing packaging on the Slovak market must register with the Slovak Ministry of Environment.
• Enforcement: Kaufland documents hiding offers for sellers without a valid registration number on Kaufland.de (for WEEE from 1 July 2023). It does not publish an equivalent enforcement date for Kaufland.cz or Kaufland.sk.

See our marketplaces page for the live channel list.

Non-resident registration: the operational shape

The two countries differ. In Czechia, a producer established elsewhere can generally register in its own name: the List of Persons accepts applications in English (§14(6) of Act No. 477/2001 Coll.), and a Czech representative is optional, except for EEE distance sellers (§61 of Act No. 542/2020 Coll.) and distance sellers of certain single-use plastic items (§13a of Act No. 477/2001 Coll.). In Slovakia, any producer without a Slovak seat must act through a Slovak authorised representative (§27(18) of Act No. 79/2015 Coll.). PPWR Article 45(3) and Batteries Regulation Article 56(3) add EU-level representative duties for cross-border sales directly to end users. That leaves three structures:

• Incorporate a local entity in Czechia and/or Slovakia. This is slow and capital-intensive.
• Appoint an authorised representative for each stream in each country where one is required. This works, but multiplies counterparties and contracts.
• Sell through a Merchant of Record. Where an EU-established Merchant of Record is the legal seller placing them on the Czech or Slovak market, the producer obligations attach to that entity in its own name. The brand's own registrations do not transfer to it, and the Slovak representative requirement still applies if the Merchant of Record has no Slovak seat. See our compliance glossary for definitions.

In Operator One's experience, the right structure depends on volume, catalogue breadth and how many EU markets are in scope. A single-category seller targeting only Czechia and Slovakia may manage with direct Czech registration and one Slovak representative. A multi-category brand selling across many EU marketplaces usually finds the per-country representative model heavy to administer.

How to register, step by step

1. Map your streams per country List which products bring packaging, EEE, batteries (including built-in batteries) and, for Slovakia, deposit-bearing beverage containers onto the Czech and Slovak markets, and check whether the Czech §15a packaging exemption (300 kg and CZK 25,000,000 turnover) applies.
2. Set up Czech packaging compliance Contract with an authorised packaging company such as EKO-KOM and file quarterly statements within 30 days of each quarter end, or fulfil individually and apply for the Ministry of the Environment's List of Persons within 60 days under Act No. 477/2001 Coll.
3. Register Czech WEEE and batteries before first sale Join a collective system such as ASEKOL or REMA Systém, or apply yourself, so you are in the List of Producers no later than the day you first place products on the market (§21 of Act No. 542/2020 Coll.). Appoint a Czech representative if you distance-sell EEE to Czech end users (§61).
4. Appoint a Slovak authorised representative and register If you have no Slovak seat, appoint a Slovak-established representative by written mandate of at least one year (§27(18) of Act No. 79/2015 Coll.), register in the RVVV via ISOH, contract an OZV per stream (one per EEE category), and register beverage containers with Správca zálohového systému.
5. Cover the EU-level representative duties From 12 August 2026, appoint a packaging EPR authorised representative where PPWR Article 45(3) applies, and a battery EPR representative in each Member State where Batteries Regulation Article 56(3) applies.
6. Load registration numbers into marketplaces Enter a separate EPR number per country in Allegro for batteries (required since 18 August 2025) and packaging (from 12 August 2026), and keep the EKO-KOM and Slovak Ministry registration evidence that Kaufland.cz and Kaufland.sk guidance refers to.

Frequently asked questions

Do I need to register with EKO-KOM to sell into the Czech Republic?

You need to meet Czech packaging duties, and EKO-KOM is the usual route. Under §13 of Act No. 477/2001 Coll., a person placing packaging on the Czech market either fulfils them individually or contracts with an authorised packaging company such as EKO-KOM. Individual fulfilment means entering the Ministry of the Environment's List of Persons within 60 days. The §15a exemption applies only at 300 kg or less of packaging a year and turnover of CZK 25 million or less.

What are the reporting deadlines for Czech packaging?

EKO-KOM clients submit a quarterly statement of packaging placed on the Czech market within 30 days after each calendar quarter ends, pay quarterly, and pay an annual registration fee of CZK 1,600 excluding VAT. Producers fulfilling Act No. 477/2001 Coll. individually instead keep continuous records, report the previous calendar year to the Czech Ministry of the Environment by 15 February, and retain supporting documents for at least five years.

Do I need an authorised representative in Slovakia if my company is not Slovak?

Yes. Section 27(18) of Slovakia's Act No. 79/2015 Coll. on Waste requires a producer with no seat or place of business in Slovakia to appoint a Slovak-established authorised representative. The mandate must be written, cover all of the producer's rights and obligations and last at least one year. The representative then answers for compliance in its own name, including registration in the Register of Producers of Reserved Products (RVVV).

Does Slovakia's deposit return scheme apply to drinks I sell online?

Slovakia's deposit return scheme under Act No. 302/2019 Coll. has run since 1 January 2022 and is administered by Správca zálohového systému. It covers single-use plastic bottles and cans of 0.1 to 3 litres at 15 cents per container, excluding milk-based drinks, syrups and spirits above 15 percent alcohol. Producers register containers with the Administrator and pay deposits and fees, on top of their OZV packaging contract.

Does the Czech Republic have a deposit return scheme for PET bottles and cans?

Not for single-use beverage containers as of September 2026. The Czech Packaging Act, Act No. 477/2001 Coll. in its consolidated version of 1 December 2025, regulates deposits only for reusable packaging (§9). PPWR Regulation (EU) 2025/40 Article 50 does require Member States to ensure deposit return systems so that 90 percent of single-use plastic bottles and metal beverage containers up to three litres are collected separately by 1 January 2029, subject to its derogations.

What happens if I sell into Czechia or Slovakia without EPR registration?

You risk fines, and marketplaces ask for your registration numbers. Section 45 of the Czech Packaging Act allows fines up to CZK 10,000,000 for its most serious offences. Under §122 of Act No. 542/2020 Coll., a producer that does not apply for the List of Producers faces up to CZK 500,000, and other producer offences reach CZK 5,000,000. Under §117(3) of Slovakia's Act No. 79/2015 Coll., failing to register in the RVVV or to appoint a required representative can cost up to EUR 120,000. Allegro states that without a country EPR number it cannot display the number in your offers and your sales are not compliant with EU law.

Do I need EPR numbers to sell on Allegro in Czechia and Slovakia?

Yes, for regulated products. Since 18 August 2025, Allegro has required sellers with producer status for batteries or battery-containing products to give a separate EPR number for each country, following Regulation (EU) 2023/1542. From 12 August 2026, under PPWR Regulation (EU) 2025/40, Allegro also asks packaging producers for a per-country EPR register number and a packaging conformity declaration, entered in the Account Details tab.

What changed for Czech and Slovak packaging on 12 August 2026?

PPWR Regulation (EU) 2025/40 has applied directly in Czechia and Slovakia since 12 August 2026 under Article 71. Article 45(3) requires producers selling packaging directly to end users in another Member State to appoint, by written mandate, an authorised representative for extended producer responsibility there. Article 45(4) makes online platforms collect producers' registration numbers and a self-certification before letting them sell to consumers.

If a Merchant of Record is the seller, who carries Czech and Slovak EPR?

The entity that places the goods on the Czech or Slovak market, as defined in Act No. 477/2001 Coll., Act No. 542/2020 Coll. and Act No. 79/2015 Coll. Where a Merchant of Record sells the stock as the legal seller, those producer obligations attach to the Merchant of Record in its own name. Registrations do not transfer between legal entities, and a Merchant of Record without a Slovak seat still needs a Slovak authorised representative.

Where a Merchant of Record carries the obligation

Operator One acts as the Merchant of Record: it is the legal seller, and listings show the client as Brand and Operator One as the seller. Where Operator One is the entity placing goods on the Czech or Slovak market, the packaging, WEEE and battery producer obligations under Act No. 477/2001 Coll., Act No. 542/2020 Coll. and Act No. 79/2015 Coll. attach to Operator One, registered in its own name, per country and per stream. EPR registrations do not transfer between legal entities. Where a market requires a locally established authorised representative, as Slovakia does, Operator One commonly arranges one as part of onboarding, though not in every market. Product conformity, including CE marking and the EU Declaration of Conformity for electronics, stays with the manufacturer. See the compliance glossary for the terms used here.

Sources: Regulation (EU) 2025/40 (PPWR), EUR-Lex; Regulation (EU) 2023/1542 on batteries, EUR-Lex; Directive 2012/19/EU on WEEE, EUR-Lex; Czech Act No. 477/2001 Coll. on Packaging (consolidated); Czech Act No. 542/2020 Coll. on End-of-Life Products; Slovak Act No. 79/2015 Coll. on Waste, Slov-Lex (version from 1 January 2026); EKO-KOM client obligations; Správca zálohového systému, Slovakia; Slovak Ministry of the Environment ISOH OZV register; Allegro: packaging EPR numbers; Allegro: battery EPR numbers; Kaufland Global Marketplace EPR guidelines.