Authorised representative for packaging in Slovakia: when a foreign producer needs one

Methodology: Marek Galetka, founder of Pravano. English translation of our Slovak 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 29 September 2026 · based on primary sources

Updated 29 September 2026. Based on Act No. 79/2015 Coll. on Waste and Regulation (EU) 2025/40 (PPWR). An informative readiness check, not a legal service or an official audit. Original: slovenská verzia.

If you have neither a registered office nor a place of business in Slovakia but sell packaged products directly to Slovak end users (typically through an online shop), you have been a producer in Slovakia under the PPWR since 12 August 2026, and the obligations of a producer of packaging under the Slovak Waste Act apply to you. With this comes an obligation that is often overlooked when entering the Slovak market: appointing an authorised representative with a registered office in the Slovak Republic. This article explains when the obligation arises, what the representative does and what you risk without one.

When the obligation arises

Two conditions must be met at the same time. First, you are a producer in Slovakia. According to the guidance of the Ministry of Environment of the Slovak Republic (No. 46177/2026, updated on 14 September 2026), since 12 August 2026 this has not been assessed under Section 52(11) of the Waste Act but under Article 3(1), point 15 of the PPWR. A foreign company is a producer in Slovakia in particular if it supplies packaged products here for the first time directly to end users (point (d)), or if it makes transport packaging, service packaging or primary production packaging available here for the first time directly to end users (point (c)). If you sell to a Slovak company that makes the goods available on the Slovak market for the first time, that company is, as a rule, the producer (point (b)). Second, you have no registered office or place of business in Slovakia. If both apply, the obligation under Section 27(18) of the Waste Act arises.

What an authorised representative is

A producer of a reserved product that has no registered office or place of business in the Slovak Republic must appoint, for the fulfilment of its obligations under the Waste Act and by a written mandate, an authorised representative with a registered office or place of business in the Slovak Republic (Section 27(18)). The mandate must cover all the rights and obligations of the producer of packaging and is granted for at least one year (Section 27(19)). The representative is then responsible for fulfilling all the obligations of the producer and acts in its own name (Section 27(20)).

You are reading a general explanation. The free check will tell you how the packaging obligations affect your company specifically. Start the free check →

How this relates to registration and the PRO

Appointing a representative is a separate obligation in addition to the others. Before placing packaging on the Slovak market, a producer of packaging must register in the Register of Producers of Reserved Products, kept by the Ministry of Environment of the Slovak Republic (Section 30(1)), and fulfil its reserved obligations individually or collectively through a producer responsibility organisation (PRO; Slovak abbreviation OZV). The authorised representative ensures these steps for the foreign producer but does not replace them: registration and fulfilment through a PRO must actually take place. Details are in the article Packaging EPR in Slovakia: registration in the Register of Producers.

Why your Slovak customers care too

A supplier's registration is not only your concern. A distributor that supplies to an end user packaging from a producer that is not entered in the Register of Producers of Reserved Products takes over the obligations of the producer of packaging in respect of that packaging (Section 56(8)). A Slovak trader selling goods from an unregistered foreign supplier thus takes over its packaging obligations – which is why reputable customers check their suppliers' registration and representation, and a missing representative becomes a commercial risk for you.

The representative under the Waste Act and under the PPWR

The Slovak authorised representative under Section 27 of Act No. 79/2015 Coll. already exists and works today. In addition, Article 45(3) of the PPWR has applied since 12 August 2026: a producer under Article 3(1), point 15(c) and (d) must appoint in writing an authorised representative for extended producer responsibility in each member state in which it makes packaging or a packaged product available for the first time and in which it is not established. On 10 December 2025 the Commission proposed postponing the application of Article 45(3) until 1 January 2035 (COM(2025) 982); as at 1 October 2026 the proposal had not been adopted, so the obligation applies in full. The proposal does not expressly address the Slovak obligation under Section 27(18) of the Waste Act. The Slovak act has not yet been aligned with the regulation; the ministry is preparing an amendment, including rules on penalties. Slovakia must lay down penalties for breaching the PPWR itself by 12 February 2027 (Article 68 of the PPWR).

What you risk if you fail to comply

Failure to appoint an authorised representative under Section 27(18) and (19) is an administrative offence punishable by a fine of €1,200 to €120,000 (Section 117(3)). The same range applies to failure to register (Section 30(1) to (4)). Supervision is carried out by the Slovak Environmental Inspectorate.

Primary sources

Frequently asked questions

We are a Czech company supplying packaged goods to Slovakia. Do we need an authorised representative?

It depends on whom you supply. If you sell packaged products directly to end users in Slovakia (for example through an online shop), you have been a producer there since 12 August 2026 under Article 3(1), point 15(d) of the PPWR and, without a registered office in the Slovak Republic, you must appoint, by a written mandate, an authorised representative with a registered office or place of business in the Slovak Republic (Section 27(18) of Act No. 79/2015 Coll.; Article 45(3) of the PPWR also requires a representative). If you supply a Slovak company that makes the goods available on the Slovak market for the first time, that company is, as a rule, the producer (point (b)).

For how long is the mandate granted?

The mandate must cover all the rights and obligations of the producer of packaging and is granted for at least one year (Section 27(19)).

Is this the same as registration or a contract with a PRO?

No. Appointing an authorised representative is a separate obligation in addition to registration in the Register of Producers of Reserved Products and to fulfilling reserved obligations through a PRO. The representative then ensures these obligations for you and acts in its own name (Section 27(20)).

What do we risk if we do not appoint a representative?

Failure to appoint an authorised representative under Section 27(18) and (19) is an administrative offence punishable by a fine of €1,200 to €120,000 (Section 117(3) of Act No. 79/2015 Coll.).