EKO-KOM: who must register, fees and reports

Methodology: Marek Galetka, founder of Pravano. English translation of our Czech article, which a person approved before publication; every number, date and legal reference of the translation is checked automatically against the original.

Cross-checked as of 5 October 2026 · based on primary sources

Updated 5 October 2026. Based on Czech Act No. 477/2001 Coll. on Packaging. An informative readiness check, not a legal service or an official audit. Original: česká verze.

When a company says “we have to deal with EKO-KOM”, it usually means the obligations under Act No. 477/2001 Coll. on Packaging. EKO-KOM is the way to meet them: according to the website of the Ministry of the Environment (as at 2 September 2026), EKO-KOM, a.s. is the only company with an authorisation decision (decisions from 2002 to 2024). This article explains who has the obligations, when they can be avoided, what exactly has to be done and what it costs under the act. It is based on the version of the act in effect from 1 December 2025.

What EKO-KOM is and what a “contract on joint fulfilment” means

The Packaging Act requires anyone who places packaging on the market or puts it into circulation to ensure the take-back of packaging (Section 10) and the recovery of packaging waste (Section 12). Anyone who places it by selling to consumers must in addition inform consumers, among other things, of how take-back is ensured and of waste prevention (awareness-raising, Section 11(1)); anyone who places on the market single-use plastic packaging listed in Annex 4, Part C or D (for example beverage bottles up to 3 litres, beverage cups, plastic carrier bags, food containers for immediate consumption) pays municipalities, under a contract, the costs of cleaning up litter from it (Section 10a) and carries out extended awareness-raising (Section 11(2) and (3)). This can be done in three ways (Section 13(1)): independently at one's own cost, by transferring the obligations to another person together with the transfer of ownership of the packaging (the contract must say so expressly), or by a contract on joint fulfilment with an authorised packaging company.

An authorised packaging company is a joint-stock company authorised by the Ministry of the Environment to provide joint fulfilment (Section 16, Section 17). EKO-KOM, a.s. holds such an authorisation; the ministry does not list any other authorised company on its packaging pages. A company concludes a contract with it, reports its quantities of packaging to it and pays it contributions; EKO-KOM ensures the collection network and the recovery of waste on its behalf. The act allows a contract with only one authorised company, covering all the packaging the company places on the market (Section 13(1)(c)); deposit-return packaging is the exception.

Whom the obligations concern

The person bearing the obligations is “the person who places packaging on the market or puts it into circulation” (Section 10(1), Section 12(1)). Typically this is whoever packs their own goods, the importer of packaged goods and an online shop that sends goods in a box with filling; putting into circulation is any handover of packaging in the Czech Republic to another person for distribution or use, on its own or together with a product (Section 2(e)). For manufacturers of empty packaging it is more complicated: a product from which packaging is only to be made is a “packaging means” (obalový prostředek, Section 2(r)), and according to the current FAQ of EKO-KOM the responsibility begins only with the completion of the packaging (closing, labelling and the like) or with the import of a packaged product – with the exception of single-use plastic packaging means listed in Annex 4, Part D (beverage cups, food containers). If a company does not prove that its packaging did not become waste in the territory of the Czech Republic, it has the take-back and recovery obligation.

A foreign seller that is not established in the Czech Republic may appoint an authorised representative (Section 13a(1)); for selected single-use plastic packaging sold at a distance directly to consumers in the Czech Republic it must appoint one (Section 13a(2)). Conversely, a Czech company that sends such packaging to consumers in another member state must have a representative under the rules of that state (Section 13a(3)). In addition, Article 45(3) of the PPWR has applied directly since 12 August 2026: anyone who supplies packaging or packaged products directly to end users in a member state other than the one in which it is established must appoint in writing an authorised representative for extended producer responsibility there – for all packaging, not only for selected plastic packaging. This also concerns foreign sellers supplying end users in the Czech Republic directly.

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Exemption for small companies: 300 kg and CZK 25 million

The act provides for one exemption (Section 15a). The obligations under Sections 10 to 15 (take-back, recovery, entry in the List, records) need not be fulfilled by a person that meets both conditions at the same time: in a calendar year it places on the market or puts into circulation no more than 300 kg of packaging, and its annual turnover does not exceed CZK 25,000,000.

Three things that are often forgotten:

The conditions apply together. A small online shop with a turnover of CZK 5 million that sends out 400 kg of cardboard does not have the exemption.
As soon as it is clear that the conditions will not be met in a given year, the company must ensure the obligations without delay (Section 15a(2)), not only from the following year.
Meeting the conditions is proved at the request of the inspection authority (Section 15a(3)). A company that does not prove it for the period concerned is treated as if it had all the obligations (Section 15a(4)). Weighing packaging and keeping documents therefore pays off even for a company that believes it is below the limit.

The exemption does not cover Sections 3 to 6 (prevention, conditions for placing packaging on the market, technical documentation); these apply to everyone who places packaging on the market.

The List of Persons at the ministry: who registers and who does not

Anyone who bears any of the obligations under Sections 10 to 12 or Section 12a(1) must submit an application for entry in the List of Persons kept by the Ministry of the Environment within 60 days of the obligation arising (Section 14(1) and (4)). A registration fee of CZK 800 is paid for the entry and in subsequent years a records fee of the same amount, due each 15 February for the past year (Section 30(1)).

Registration is not required, however, for a company that has a contract on joint fulfilment covering all its packaging (Section 14(12)(a)), nor for a seller to consumers for whom another person demonstrably fulfils the obligations for all packaging (Section 14(12)(b)). This is why most companies with an EKO-KOM contract are not in the List: the authorised company fulfils the obligation for them. Whoever fulfils the obligations themselves or has transferred them by contract belongs in the List.

Changes to the registered data are notified within 14 days (Section 14(9)). The List is public (Section 14(11)).

Records and reports

A person subject to entry in the List must (Section 15(1)) keep continuous records of packaging and packaging waste, report the data for the past year to the ministry by 15 February of the following year at the latest (through the ISPOP reporting system or a data box, the Czech official electronic mailbox), prove the accuracy of the data on request and keep the documents for at least 5 years.

A company with a contract with an authorised company does not keep these state records; it reports its quantities of packaging to its authorised company. With EKO-KOM this is a quarterly report on packaging production submitted within 30 days after the end of the quarter, broken down into commercial packaging (sales, grouped, transport) and industrial packaging (EKO-KOM page Client obligations, as at 2 September 2026). The basis is the same in both cases: an inventory of packaging by material and weight. How to compile it is described in our Czech article Packaging records: the basis for PPWR and EPR registration.

What it costs

There are two statutory fees, both small: CZK 800 for entry in the List and CZK 800 a year for records in it (Section 30(1)). The real cost is the contributions paid to the authorised company for the packaging placed on the market. The act does not set their amount; it is determined by the authorised company's fee schedule, which must cover the costs of collection and recovery and must be eco-modulated, i.e. take account of the recyclability of the packaging (Section 21(1)(k) and (l), Section 44(3)); the authorised company must publish its fee schedules on its website (Section 21(1)(o)). At EKO-KOM the fee is invoiced quarterly according to the report and the applicable price list; the annual registration fee is CZK 1,600 excluding VAT and includes the records fee of CZK 800 paid to the State Environmental Fund (SFŽP) under Section 30 and an administrative fee of CZK 800 charged by EKO-KOM (EKO-KOM page Client obligations, as at 2 September 2026; the price list is Annex 3 to the terms and conditions in the version from 1 July 2026 and changes, which is why we do not quote rates per kilogram). Less recyclable packaging is more expensive here too, not only under the PPWR.

What you risk

For failing to ensure take-back (Section 44(2)(g)) or the recovery of packaging waste (point (k)), a fine of up to CZK 10,000,000 may be imposed (Section 45(1)(e)). Failure to apply for entry in the List (point (o)) is up to CZK 500,000, a breach of the records obligation (point (q)) up to CZK 1,000,000 (Section 45(1)(b) and (c)). A fine of up to CZK 500,000 also applies for failing to notify changes to the registered data within 14 days (point (p)), and up to CZK 1,000,000 for a client of the authorised company that does not cooperate with it when an auditor verifies the accuracy and completeness of the reported quantities of packaging each year (Section 23a(2) and (5), Section 44(2)(r)). Under Section 31, state administration in the area of packaging is exercised by, among others, the Ministry of the Environment, the Czech Environmental Inspectorate (ČIŽP), the Czech Trade Inspection Authority (ČOI) and the customs authorities. What a company that joins late risks, how long offences take to become time-barred and from when the EKO-KOM contract covers packaging is described in the article Joining EKO-KOM late: ČIŽP fines, limitation and past periods.

What the PPWR changes

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) does not repeal or replace the Czech Packaging Act. Your existing obligations, i.e. the contract with EKO-KOM or entry in the List, continue to apply. The PPWR adds an extra layer: from 12 August 2026 the declaration of conformity and technical documentation of packaging, the recyclability requirement, PFAS limits for food-contact packaging and, when selling directly to end users in another member state, the obligation to appoint an authorised representative for extended producer responsibility there (Article 45(3)). The new registers of producers under Article 44 of the PPWR await an implementing act of the Commission; we follow the status in our Czech article Register of packaging producers: EPR registration under the PPWR. An overview of the whole regulation is on the page PPWR.

Frequently asked questions

We have a contract with EKO-KOM. Do we still have to register in the List of Persons kept by the ministry?

No, if the contract covers all the packaging you place on the market (Section 14(12)(a)). If part of your packaging is outside the contract, the obligation to register remains for it.

We are a small online shop. When are we exempt from the obligations?

When you place on the market no more than 300 kg of packaging a year and at the same time have a turnover of up to CZK 25 million (Section 15a(1)). You must prove both conditions on request; without documents you are treated as if you had the obligations (Section 15a(4)).

Do boxes and fillers from suppliers that we merely repack count towards the 300 kg?

The limit counts packaging that you place on the market or put into circulation; handing a box over to a customer is putting it into circulation (Section 2(e)). The act does, however, allow another person to demonstrably fulfil the obligations for you, typically a supplier who placed the packaging on the market and has a contract with the authorised company (Section 14(12)(b)); you must be able to document this. In the check we assess it according to how the packaging travels on and what the contract with the supplier says.

We sell only abroad. Does the Czech act concern us?

The obligation of take-back and recovery is tied to packaging that becomes waste in the territory of the Czech Republic (Section 10(1), Section 12(1)). For goods sold to another state, you deal with the rules of that state. If you supply end users there directly, since 12 August 2026 you must, under Article 45(3) of the PPWR, appoint in writing an authorised representative for extended producer responsibility there – for all packaging, not only for selected plastic packaging (cf. Section 13a(3)).

Will the PPWR replace the contract with EKO-KOM?

No. The PPWR applies alongside the Czech act and adds obligations (declaration of conformity, recyclability, PFAS). The registers of producers under the PPWR are a new layer whose form awaits an implementing act of the Commission.