Pravano · Knowledge base · Packaging / PPWR

Packaging EPR in Slovakia: registration in the Register of Producers

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 place packaging on the Slovak market – you pack goods, fill them into packaging under your own brand, or bring packaged goods into Slovakia from abroad – you are, as a rule, a producer of packaging and extended producer responsibility (EPR) applies to you. Since 12 August 2026 the producer is determined under the PPWR, but you still fulfil the obligations under the Slovak Waste Act. The first and indispensable step is registration. This article explains who registers, where, when and what follows.

Who is the producer of packaging from 12 August 2026

Until 11 August 2026 the producer of packaging was defined by Section 52(11) of Act No. 79/2015 Coll. According to the guidance of the Ministry of Environment of the Slovak Republic of 4 August 2026 (No. 46177/2026, updated on 14 September 2026 as version 1.4, No. 66800/2026), this definition has not been applied since 12 August 2026 and the producer is determined directly under Article 3(1), point 15 of the PPWR, Regulation (EU) 2025/40. The Slovak act has not yet been aligned with the regulation; the ministry is preparing an amendment.

Under the PPWR, the producer is a manufacturer, importer, distributor or other person who, irrespective of the selling technique used, including distance contracts, in particular:

• is established in the Slovak Republic and makes packaged products available for the first time within or from the territory of the Slovak Republic (point (b)) – typically a company that packs goods, sells them under its own brand, or buys packaged goods abroad and makes them available on the Slovak market for the first time;
• is established in another member state or in a third country and supplies packaged products for the first time directly to end users in Slovakia (point (d)) – typically a foreign online shop;
• is established in a member state and unpacks packaged products in Slovakia without being their end user (point (e)), unless another person under points (a) to (d) is the producer.

Similar rules apply to transport packaging and the other types of packaging listed in points (a) and (c).

In practice this means: a Slovak company that buys packaged goods abroad and sells them in Slovakia is, as a rule, the producer itself. A foreign supplier is the producer in Slovakia under point (d) only if it supplies packaged products directly to end users. Mind the terms: in the PPWR the producer is the person with extended producer responsibility (point 15), whereas the manufacturer (point 13) is the one who manufactures packaging or a packaged product, or has it designed or manufactured under its own name or trademark.

What did not change on 12 August 2026

What changes is the legal basis of the definition of the producer, not the obligations themselves under the Waste Act: registration in the Register of Producers of Reserved Products, fulfilment of reserved obligations through a PRO, records, the report and the PRO fees all continue. Penalties for breaching the PPWR itself must be laid down by Slovakia by 12 February 2027 (Article 68 of the PPWR). The European Commission recommends giving priority to corrective steps when non-compliance is found; the ministry points this out in its updated guidance of 14 September 2026, but expressly states that this recommendation is not legally binding for inspections or for imposing penalties in the Slovak Republic – the inspection authority proceeds under Slovak law.

Registration in the Register of Producers of Reserved Products

A producer of packaging is a producer of a reserved product (Section 27(2)) and must register in the Register of Producers of Reserved Products before placing packaging on the Slovak market; the register is kept by the Ministry of Environment of the Slovak Republic (Section 27(4)(a), Section 30(1)). A producer that is not entered in the register may not place products on the Slovak market (Section 30(1), second sentence). The ministry makes the entry within 10 working days of receiving the application (Section 30(5)); changes to the registered data are notified within 30 days (Section 30(6)). The register is publicly accessible (Section 30(10)).

Do not confuse: this Slovak Register of Producers of Reserved Products exists and works today. It is something other than the future register of producers under Article 44 of the PPWR, which does not exist yet. These are two different registers.

How you fulfil reserved obligations: through a PRO or individually

A producer of packaging fulfils its reserved obligations (information, collection and recycling targets, waste management, records and reporting) in one of two ways (Section 27(6)): individually, through its own system authorised by the ministry, or collectively, through one producer responsibility organisation (PRO; Slovak abbreviation OZV) for packaging. By concluding a contract with a PRO, responsibility for fulfilling most obligations passes to the PRO (Section 27(11)), and you attach confirmation of this contract to the application for entry in the register (Section 30(3)).

Individual fulfilment is possible only if the waste from your packaging will not form part of municipal waste (Section 54(3)); for ordinary consumer packaging, a contract with a PRO is therefore in practice the only route. A Slovak PRO fulfils the packaging obligations of the producers it represents, and there are several PROs for packaging in Slovakia, so a producer chooses one.

Records and the report by 28 February

A producer of packaging must keep and retain records of packaging and report data from them to the ministry (Section 27(4)(h)). The report on the data from the records for a calendar year is submitted by 28 February of the following year by a producer fulfilling its reserved obligations individually and by the PRO for the producers it represents; a producer fulfilling them collectively does not submit the report itself, but must provide the PRO with true and complete data and substantiate them within 30 days on request (Section 27(12)). Records are kept for five years. Details are in the article Packaging report and records in Slovakia by 28 February.

Until 31 December 2026 the procedure follows Decree No. 366/2015 Coll.; electronic reporting through the information system under Decree No. 89/2024 Coll. takes effect only on 1 January 2027 (postponed by Decree No. 369/2025 Coll.), so the report for 2026 is still submitted under the previous rules.

Relief for small quantities (below 100 kg)

A producer that places in total less than 100 kg of packaging on the Slovak market in a calendar year is not subject to obligations such as the contract with a PRO or the collection and recycling targets (Section 54(6)). The relief does not cover registration and records: such a producer must still register in the Register of Producers of Reserved Products and keep records with a report by 28 February. The 100 kg threshold is assessed in total for all packaging per year.

Foreign producers: the authorised representative

A producer of a reserved product that has no registered office or place of business in the Slovak Republic must appoint, 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 and is granted for at least one year (paragraph 19); the representative is then responsible for fulfilling all the obligations and acts in its own name (paragraph 20). Since 12 August 2026 Article 45(3) of the PPWR also requires a representative: a producer under Article 3(1), point 15(c) and (d) must appoint one in writing 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, and it does not expressly address the Slovak obligation under Section 27(18). Details in the article Authorised representative for packaging in Slovakia.

An unregistered supplier is a risk for the customer

A distributor of packaging that supplies directly to an end user packaging originating 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 (typically foreign) supplier thus takes over its packaging obligations, which is why customers check their suppliers' registration.

What you risk if you fail to comply

Failure to register (Section 30(1) to (4)) and failure to appoint an authorised representative (Section 27(18) and (19)) are punished by a fine of €1,200 to €120,000 (Section 117(3)). Breach of the record-keeping and reporting obligation (Section 27(4)(h)) by a fine of €500 to €50,000 (Section 117(1)). Failure to ensure collection and recycling under Section 54(1)(d) and (e) by a fine of €2,000 to €250,000 (Section 117(5)). Supervision is carried out by the Slovak Environmental Inspectorate.

This article is a general explanation, not individual legal advice. A specific overview for your company (Pravano Kompas) comes with the free check – in writing, within 2 working days.