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PPWR · Regulation (EU) 2025/40 · Czech Republic and Slovakia

Packaging and PPWR in the Czech Republic and Slovakia.
Does it apply to you?

From 12 August 2026 all packaging needs a declaration of conformity and technical documentation – and in Slovakia, whoever first makes packaged products available there (packing them, selling them under their own brand or bringing them in from abroad) is usually a producer under PPWR and is also bound by Act No. 79/2015 Coll. on Waste. We check what exactly applies to you.

up to €350,000 – fine in Slovakia under the Waste Act · Section 117 of Act No. 79/2015 Coll., depending on the type of breach, imposed by the Slovak Environmental Inspectorate (SIŽP). In the Czech Republic, packaging without a declaration of conformity must not be placed on the market and supervisory authorities may order its withdrawal; the amount of penalties under PPWR has not yet been set there.

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Free and without obligation · a few questions · no registration

You answer a few questions and within 2 working days you receive your Pravano Kompas: which obligations apply to you in the Czech Republic and in Slovakia. We communicate in English, in writing.

PPWR in a nutshell

What it is, who it concerns and since when it applies.

What applies under EU law?

PPWR is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste. As a regulation it applies directly throughout the EU. It sets the requirements that all packaging placed on the market must meet and who is responsible for them.

Who does it concern?

Anyone who places packaging or packaged goods on the market in the EU: packaging manufacturers, fillers and packers, importers, packaging distributors and online shops. Who carries the main obligations as manufacturer is decided by the role under the regulation, not by who physically made the packaging; for micro-enterprises the obligation may pass to the packaging supplier.

Since when does it apply?

The regulation applies from 12 August 2026: declaration of conformity and technical documentation for packaging, the recyclability requirement (according to Commission guidance, for now within the scope of the existing requirements of Directive 94/62/EC) and PFAS limits for food-contact packaging. Registration in the new producer registers awaits a Commission implementing act; but anyone who supplies end users directly in another EU Member State where they are not established must appoint an authorised representative for extended producer responsibility there from 12 August 2026 (Art. 45(3)). Further obligations phase in gradually: among others from 12 February 2027 (option of your own container for takeaway food and drinks, Art. 32), from 12 February 2028 (empty space in sales packaging reduced to a minimum, Art. 24(4); compostable tea bags and fruit stickers, Art. 9), from 12 August 2028 (harmonised labelling) and from 1 January 2030 (design-for-recycling criteria and recyclability classes, recycled content, the empty-space limit, format bans and packaging minimisation including the ban on superfluous elements – for the latter according to Commission guidance). For labelling and part of the 2030 obligations, later adoption of Commission acts may push the date back.

Czech Republic: what applies nationally?

Your existing obligations under the Czech Packaging Act are not affected – the new producer register under PPWR is an additional layer. The Commission was to adopt the implementing act on the registration format under Art. 44(14) by 12 February 2026, and as of 29 September 2026 it has not been adopted. Penalties for breaching PPWR are to be set by Member States by 12 February 2027 (Art. 68); in the Czech Republic no legislation sets them yet and the government draft adapting the Packaging Act was not in the Chamber of Deputies as of 1 October 2026. Existing obligations and penalties under the Packaging Act continue to apply.

Slovakia: what applies nationally?

From 12 August 2026 PPWR also determines who is a producer of packaging in Slovakia. Under Art. 3(1)(15) PPWR this is mainly a company established in Slovakia that first makes packaged products available on the market there – packs them itself, sells them under its own brand or buys them abroad – and a foreign company that supplies packaged products directly to end users in Slovakia, typically an online shop. According to the guidance of the Ministry of Environment of the Slovak Republic (MŽP SR), the previous definition in Section 52(11) of the Waste Act no longer applies from 12 August 2026. Producer obligations under Act No. 79/2015 Coll. on Waste – registration, compliance through a producer responsibility organisation (OZV), records and reporting – continue to apply. The Act has not yet been aligned with PPWR; the ministry is preparing an amendment and in the meantime issued guidance (4 August 2026, updated 14 September 2026).

What are the risks?

Without a declaration of conformity you must not place packaging on the market, and supervisory authorities may order its withdrawal from the market. In Slovakia, the Slovak Environmental Inspectorate (SIŽP) may impose a fine under Section 117 of the Waste Act for breaches of that Act – up to €350,000, depending on the type of breach. Penalties for breaching PPWR itself must be set by Slovakia by 12 February 2027 (Art. 68). In its guidance of 14 September 2026 the Slovak ministry refers to the European Commission’s recommendation to prioritise remediation when non-compliance is found, but states that it is not legally binding – the inspection authority proceeds under Slovak law.

What can go wrong

  • Without a declaration of conformity you must not place packaging on the market – and who prepares it is decided by the role under the regulation, not by who made the packaging
  • For food-contact packaging, PFAS limits apply from 12 August 2026 and are tested in a laboratory
  • You must request documentation from your suppliers in good time; nobody will deliver it at the last minute
  • Slovakia: placing packaging on the market without registration in the Register of Producers of Reserved Products – without it, products must not be placed on the Slovak market (Section 30(1)).
  • Slovakia: taking over someone else’s packaging obligations – if your supplier is not registered, its obligations pass to you as distributor (Section 56(8)).

What we do for you

  • We sort your packaging portfolio and determine which obligations apply to you – including whether, from 12 August 2026, you are a producer in Slovakia under Art. 3(1)(15) PPWR and what follows from that
  • We prepare the declaration of conformity, technical documentation and letters to suppliers
  • For Slovakia we go through registration, compliance through an OZV, records and reporting by 28 February – including whether the relief for up to 100 kg applies to you (Section 54(6)); if you are a foreign company, we check the obligation to appoint an authorised representative (Section 27(18) of the Waste Act, Art. 45(3) PPWR)
  • We draw up a plan for the obligations that apply from 12 August 2026 and for the follow-up deadlines in 2028 and 2030
Scope of the check

What exactly we go through.

Czech Republic

  • Role: whether you place packaging on the market, fill it, import it or sell under your own brand
  • Your packaging portfolio and materials against the requirements of the regulation
  • Declaration of conformity and technical documentation
  • PFAS limits for food-contact packaging
  • Registration in the extended producer responsibility system
  • 2030 deadlines: recyclability classes, recycled content and the empty-space limit

Slovakia

  • Producer status under Art. 3(1)(15) PPWR (packer, brand, import, distance selling) – Section 52(11) no longer applies from 12 August 2026
  • Registration in the Register of Producers of Reserved Products (Section 30) – before placing on the market; registration within 10 working days
  • Individual vs. collective compliance through a producer responsibility organisation (OZV) – Section 27(6)
  • Collection, recycling and recovery rates under Annex 3 (Section 54(1))
  • Records and reporting of packaging data by 28 February (Section 27(4)(h))
  • Relief for small quantities of up to 100 kg a year (Section 54(6)) – and what remains despite it
  • Authorised representative for a foreign producer (Section 27(18)–(20), Art. 45(3) PPWR)
  • Heavy metals limit of 100 mg/kg in packaging (Section 53(3))

The scope is based on verified facts – every point is linked to a specific provision of the EU act or of the Czech or Slovak law in its current wording. The binding texts are the legislation itself; our English outputs explain it and cite the provisions.

Packages and prices

A fixed price in advance. No hourly billing.

The check is free. A fixed price for the result, not for time. Prices in euros, excluding VAT.

Map Start

€199

For a small online shop: up to 3 product groups or packaging types

  • Map of obligations for your role
  • Recommended next steps
  • Delivery usually within 5 working days
  • 3 months of Watch free

Delivery usually within 5 working days of confirming the scope and receiving your documents.

Order Map Start
✓ Money-back guarantee

Map

€890

For an online shop or manufacturer with a full packaging portfolio

Everything in Map Start, plus:

  • Overview of your full packaging portfolio (no 3-group limit)

Delivery usually within 10 working days of confirming the scope and receiving your documents.

Order Map
✓ Money-back guarantee
Recommended

Guide

€1,690
fixed price for up to 10 items · ~€169 per item
Scope by number of different packaging items:

For a company that wants the documents done, not just to know what to do

Everything in Map, plus:

  • Declaration of conformity + documentation
  • Letters to suppliers
  • 30/60/90-day action plan
Order Guide

Ongoing Support

from €3,390

For a company with a larger packaging portfolio that wants us to accompany the whole implementation

Everything in Guide, plus:

  • Implementation in practice
  • Support during remediation
  • Tailored consultations
  • 6 months of Watch free (instead of 3)

Delivery according to the scope agreed in the confirmation, usually 6 to 10 weeks.

Order Ongoing Support

What each package includes

Map StartMapGuideOngoing Support
Scope up to 3 product groups or packaging typesfull portfoliofull portfolio, price by number of packaging itemsfull portfolio, with full support
Map of obligations for your role (with citations of the law) ✓✓✓✓
Recommended next steps ✓✓30/60/90-day action plan30/60/90-day action plan
Ready-made documents ——declaration of conformity + documentationdeclaration of conformity + documentation
Letters to suppliers ——✓✓
Implementation, support and tailored consultations ———implementation, support during remediation, consultations
Indicative delivery time usually within 5 working daysusually within 10 working daysusually 3–5 weeksusually 6–10 weeks
Watch free 3 mo.3 mo.3 mo.6 mo.
Money-back guarantee ✓✓——
Price credited on upgrade within 60 days towards Map and Guidetowards Guide——

PPWR Watch €169 per month keeps track of rule changes in this area for you: a report every Monday, cancel any time with effect from the end of the month. Order the Watch →

Prices excluding VAT · fixed price for the result · paid by bank transfer against an invoice in EUR due in 14 days (we may ask for payment in advance for Guide and Ongoing Support, and for any package from companies established outside the EU – Terms Art. 4.2). For small companies there is Map Start at €199. By ordering you agree to the terms and conditions (English translation; the Czech version prevails).

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FAQ

What you ask most often.

We buy our packaging from a supplier. Is that not the supplier’s job?
The supplier is responsible for its own product, but the declaration of conformity and documentation for the packaging you place on the market with your goods are usually needed by you. One exception is essential, though: if you are a micro-enterprise (fewer than 10 persons and an annual turnover or balance sheet total of up to €2 million) and you have your packaging made under your brand by a supplier from the same country, the regulation considers the supplier, not you, to be the manufacturer; for the declaration of conformity and technical documentation (Art. 15) this also applies with a supplier from another EU Member State. That is why we start by determining your role – and the Guide includes letters with which you request the necessary documents from your suppliers.
We are a foreign company without a seat in the Czech Republic or Slovakia. What do we need?
Since 12 August 2026, anyone who first supplies packaged goods or transport, service or primary production packaging directly to end users in another EU Member State where they are not established (typically an online shop shipping to customers abroad) must appoint in writing an authorised representative for extended producer responsibility there (Art. 45(3) PPWR); the Commission’s proposal to suspend this obligation had not been adopted as of 1 October 2026. Slovakia: if you are a producer there – for example as an online shop supplying packaged products directly to end users in Slovakia – you must appoint, by written mandate, an authorised representative with a registered office or place of business in Slovakia (Section 27(18)–(20) of the Waste Act), who fulfils all packaging producer obligations on your behalf.
Do we need to deal with the register of packaging producers now?
The registration obligation is in the regulation, but the Commission was to adopt the implementing act with the registration format by 12 February 2026 under Art. 44(14), and as of 29 September 2026 it has not been adopted (the draft was open for comments from 6 August to 10 September 2026). Until it is issued, the eighteen-month period for Member States to set up the new registers has not started either. In the Czech Republic, your existing obligations under the Czech Packaging Act are not affected – the new register is an additional layer. We monitor the status of the register and will let you know as soon as there is something to do.
Do the empty-space and recycled-content limits already apply from 2026?
No. The ≤ 50% empty-space limit (Art. 24) and the minimum recycled content in plastics (Art. 7) are aimed at 1 January 2030, with a proviso: they start to apply either on that date or three years after the relevant implementing acts are issued, whichever is later. The Commission is to issue the methodology for them in implementing acts (for recycled content by 31 December 2026, for empty space by 12 February 2028), so the actual date may move. But do not confuse this: the requirement itself that packaging be recyclable has applied since 12 August 2026 – packaging is classified into classes A/B/C only from 2030.
Slovakia: we buy goods abroad and bring them into Slovakia. Are we the producer of the packaging?
Usually yes. From 12 August 2026 the producer is determined under Art. 3(1)(15) PPWR: a company established in Slovakia that first makes packaged products available on the market in Slovakia is the producer under point (b). A foreign supplier is the producer in Slovakia under point (d) only if it supplies packaged products directly to end users in Slovakia. According to the guidance of the Slovak Ministry of Environment (MŽP SR), the previous definition in Section 52(11) of the Waste Act (including the rule on transport across the state border) no longer applies.
Slovakia: we place less than 100 kg of packaging on the market a year. Does this concern us?
Yes, partly. The relief under Section 54(6) exempts you from the contract with an OZV and from collection and recycling targets, but registration in the Register of Producers of Reserved Products, keeping records and reporting by 28 February remain.
Slovakia: our supplier is not in the register. What does that mean for us?
If the packaging producer you buy goods from is not registered in the Register of Producers of Reserved Products, its packaging obligations relating to that packaging pass to you as distributor (Section 56(8)). That is why customers check their supplier’s registration.
Is the Map or the Guide the same as an audit with a guarantee of compliance?
No. It is an informative assessment of readiness and support with documentation – not a legal service or an official audit. We help you get ready; final responsibility and legal interpretation remain with you.
Knowledge base

In depth: the national rules explained.

Open the knowledge base →
Quick check

3 minutes to fill in. Within 2 working days you know what applies to you.

We will send you the Pravano Kompas: an overview of obligations for your company, deadlines and recommended steps. Free and without obligation.

1 · Packaging / PPWR – a few questions

We only ask for facts about your company. What follows from them is our job – under the rules of the market you sell to.

2 · Five more things

Select everything that applies.

This decides who carries the manufacturer’s obligations under Article 15 (documentation, declaration of conformity).

Some obligations depend on whether a company is established in the EU – that is why we ask.

On top of the EU rules we apply the national layer of the market you sell to: local acts, authorities and deadlines.

3 · Where should we send the Pravano Kompas?

By sending the form you acknowledge that the Pravano Kompas is free indicative information, not a legal service, and that we process your data under our Privacy Policy. We prepare the Pravano Kompas with the help of AI and a person approves it. We send marketing messages only with your separate consent. We communicate in English in writing.

Done.

Thank you! We will send you the Pravano Kompas within 2 working days. A confirmation has just been sent to your e-mail – if it does not arrive, please also check your spam or promotions folder.

What happens next: we assess your answers against the full text of the rules, a person checks and approves the result, and the Pravano Kompas comes to you by e-mail within 2 working days.

Meanwhile you can look at the pricing – from the Map of your obligations to complete documentation.

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