The PPWR is prompting a revision of the Czech Packaging Act No. 477/2001 Coll. Until national legislation is updated, businesses must comply with both the EU regulation and existing Czech rules. Future national provisions are expected to clarify registration, monitoring and penalties.
The Czech Ministry of the Environment (Ministerstvo životního prostředí, MŽP) oversees packaging and EPR and maintains the national “Seznam osob” register. EKO-KOM a.s. is currently the country’s only state-authorised producer responsibility organisation (PRO) for packaging. As such, it plays a central role in implementing these requirements. Companies can fulfil their EPR obligations through EKO-KOM, including businesses based in other EU member states. However, foreign companies must now also appoint a legally Authorised Representative in the Czech Republic. EKO-KOM will only accept new members who can provide proof of appointment.
What does this mean for cross-border B2C sales?
Other than having to fulfil EPR obligations and appoint an Authorised Representative in the Czech Republic, some rules remain unclear. Some regulations regarding national implementation of the PPWR, particularly Articles 45 and 46, have not yet been fully clarified.
Need help navigating the PPWR? Get in touch with the take-e-way advisory team for support with Czech packaging regulations and EPR requirements across the entire EU.
