Packaging PROs in Slovakia: collective versus individual fulfilment

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 10 September 2026 · based on primary sources

Updated 10 September 2026. Based on Act No. 79/2015 Coll. on Waste. An informative readiness check, not a legal service or an official audit. Original: slovenská verzia.

When you are a producer of packaging in Slovakia, the law imposes so-called reserved obligations on you: ensuring the collection and recycling of packaging waste, informing consumers, keeping records and reporting data. You do not have to fulfil these obligations yourself. Act No. 79/2015 Coll. offers two routes, and for most companies only one of them is usable.

Two ways of fulfilling reserved obligations

Under Section 27(6), a producer of packaging fulfils its reserved obligations either individually, through its own system authorised by the ministry, or collectively, through one producer responsibility organisation (PRO; Slovak abbreviation OZV) for packaging. Collective fulfilment is the usual route: the PRO organises collection and recycling for the producers it represents and fulfils other obligations.

What the PRO takes over and what remains for you

By concluding a contract on the fulfilment of reserved obligations, responsibility for their fulfilment passes to the PRO (Section 27(11)), except for the targets under Section 27(4)(e), (g) and (l). What remains for you is mainly providing the PRO with true and complete data on packaging and substantiating them within 30 days on request (Section 27(12)). The PRO keeps the records and submits the report for the producers it represents.

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When individual fulfilment is possible at all

Individual fulfilment is possible only if the waste from your packaging will not form part of municipal waste (Section 54(3)). Ordinary consumer packaging ends up in household municipal waste, so it does not meet this condition. For most producers of consumer goods, a contract with a PRO is therefore in practice the only realistic route. Individual fulfilment is rather an option for industrial or transport packaging that is returned outside the municipal system.

How it relates to registration

The contract with a PRO (with collective fulfilment) and registration are two separate steps that must take place before placing packaging on the market. Below 100 kg of packaging a year no contract with a PRO is needed, but registration is (Section 54(6)). You attach a confirmation of the contract with the PRO to the application for entry in the Register of Producers of Reserved Products (Section 30(3)). Details on registration are in the article Packaging EPR in Slovakia: registration in the Register of Producers and on the report in the article Packaging report and records in Slovakia by 28 February.

What to check with a PRO

Before signing the contract, clarify which obligations the PRO actually takes over for you, what data you must hand over and by when, and how the fee for the represented quantity of packaging is calculated. Since you are responsible for the accuracy of the data you hand over, it pays to have your packaging records in order before the first report through the PRO.

Primary sources

Act No. 79/2015 Coll. on Waste (Slovakia), Section 27(6) (methods of fulfilment), (11) (transfer of responsibility to the PRO), (12) (data for the PRO), Section 30(3) (confirmation of the contract), Section 54(3) (condition for individual fulfilment)

Frequently asked questions

Do I have to have a contract with a PRO?

In practice yes, for ordinary consumer packaging, if you place at least 100 kg of packaging a year on the Slovak market; below this threshold the obligation to fulfil through a PRO does not apply, but registration and records remain (Section 54(6)). Individual fulfilment is possible only if the waste from your packaging will not form part of municipal waste (Section 54(3) of Act No. 79/2015 Coll.), a condition that ordinary packaging does not meet. In practice, a contract with a producer responsibility organisation (PRO) is therefore the only route.

What does the PRO take over from me?

By concluding the contract, responsibility for fulfilling most reserved obligations passes to the PRO (Section 27(11)), except for the targets under Section 27(4)(e), (g) and (l). What remains for you is mainly providing the PRO with true and complete data.

Can I have several PROs at the same time?

Collective fulfilment takes place through one PRO for packaging (Section 27(6)). A producer therefore chooses one PRO.

How does the PRO relate to registration?

You attach confirmation of the contract with the PRO to the application for entry in the Register of Producers of Reserved Products (Section 30(3)). Registration and the contract with the PRO (with collective fulfilment) are separate steps that must take place before placing packaging on the market. Below 100 kg of packaging a year no contract with a PRO is needed, but registration is (Section 54(6)).