EU Packaging Regulation (PPWR) in Slovakia

1. PPWR vs the Slovak Waste Act 

Regulation (EU) 2025/40 on packaging and packaging waste (‘PPWR’) entered into force on 11 February 2025 and will applies directly in all EU Member States – including Slovakia – from 12 August 2026.

Slovakia has not yet brought its Waste Act (Act No. 79/2015 Z. z.) into line with the PPWR. An amendment is currently being prepared. As the PPWR is an EU regulation and is directly applicable, it takes precedence over any conflicting national legislation. The Slovak Ministry of the Environment (MŽP) has published a guideline for the transitional period (status 14 September 2026), which is updated on an ongoing basis.

Please note:

• The definition of ‘producer’ in Section 52(11) of the Waste Act ceased to apply from 12 August 2026
• The exemption for small producers (under 100 kg/year) has been unclear since 12 August 2026, and its application is currently being clarified with the Slovak Ministry of the Environment. 

2. Definition of a producer 

The PPWR redefines the term ‘producer’ , thereby deviating from the previous definition in the Slovak Waste Act. The definition in the PPWR takes precedence and must be applied in Slovakia in accordance with the Commission guidelines and FAQs.

Foreign companies not established in Slovakia which import packaged goods into Slovakia and make them available on the market there must assess for themselves whether they are considered producers within the meaning of the PPWR. This applies to both purely B2B and B2C deliveries. In general, the distinguishing factor is whether a final consumer (who may also be a business) in Slovakia is supplied.

3. Obligations of the producer in Slovakia 

Registration

Producers must register in the national register of each Member State in which they place packaging on the market for the first time. In Slovakia, registration takes place via the ISOH (Informačný systém odpadového hospodárstva). Packaging may not be placed on the market without registration. Registration is only possible after a contract has been concluded with a producer responsibility organisation (OZV/PRO) and is therefore usually carried out by the producer responsibility organisation (OZV/PRO) on the basis of a power of attorney.

Extended Producer Responsibility (EPR)

Producers must generally participate in an extended producer responsibility scheme unless they are authorised as an ‘individual producers. In Slovakia, this involves entering into a contract with a producer responsibility organisation (OZV/PRO – current list of PROs) and the payment of financial contributions towards waste management. The contractual PRO is responsible for fulfilling the recordkeeping and reporting obligations.

Authorised representative

Foreign producers not established in Slovakia must, in accordance with Section 27 of the Slovak Waste Act, appoint an authorised representative (splnomocnený zástupca) established in Slovakia. The details of the authorised representative must be provided as part of the registration process in the Producers’ Register. The power of attorney must also be submitted. The obligation to appoint an authorised representative applies equally to producers supplying both B2B and B2C markets in Slovakia. The authorised representative fulfils all the producer’s obligations in their own name and is liable for compliance with them. When an authorised representative is appointed, the contract with a producer responsibility organisation (OZV/PRO) is usually concluded by the authorised representative. 

Packaging requirements

• The EU Declaration of Conformity for packaging must be available in the Slovak language (machine translation is permitted).
• Labelling requirements: Packaging labelling and manufacturer’s details in accordance with the requirements of the PPWR must be available in the Slovak language. 

4. Competent authorities

The Slovak Ministry of the Environment is responsible for the implementation and methodological guidance regarding the PPWR. Monitoring compliance with waste and packaging legislation is the responsibility of the Slovak Environmental Inspectorate (SIŽP). 

5. Practical steps for foreign companies 

• Check whether your company is considered a ‘producer’ within the meaning of the PPWR
• Register with the Slovak ISOH register
• Appoint an authorised representative in Slovakia
• Enter into a contract with an OZV (producer responsibility organisation)
• Prepare an EU declaration of conformity for packaging (Slovak version)
• Check labelling and marking requirements (Slovak version)
• Keep records of and report the quantities of packaging placed on the Slovak market