Czech Republic EPR
What is Czech Republic EPR packaging
Czech packaging EPR is governed by Act No. 477/2001 Coll., on Packaging (as amended). It makes persons who place packaging on the market or into circulation responsible for ensuring take-back and recovery obligations, most commonly via the authorised packaging company EKO-KOM (collective compliance).Does this apply to e-commerce & online sales
Yes. If you sell packaged goods into Czechia (including B2C e-commerce) and you are considered the party placing packaging on the market (often the importer or distance seller), EPR obligations apply.Who is the 'producer' under Czech EPR
In practice, the “producer” is the entity that places packaging on the market / into circulation—the EKO-KOM system guide summarises this as entities that fill, import, or sell to the Czech Republic.
Who must register for EPR packaging
Entities placing packaging on the market must register in the Ministry of Environment's List of Subjects unless qualifying for the small-entity exemption.Registration threshold
Exemption applies if BOTH conditions are met:- ≤ 300 kg of packaging per calendar year AND
- annual turnover ≤ CZK 25,000,000.
Detailed EPR Guidance for each Jurisdiction
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Packaging covered and excluded
Broadly, the regime covers packaging placed on the Czech market (sales/transport/group packaging, etc.). Key “special” areas include deposit returnable packaging requirements and single-use plastic packaging “littering” cost reimbursement rules (since 2023).Producer Responsibility Organization (PRO)
Czechia uses an authorised packaging company model; EKO-KOM is the main authorised packaging company providing collective compliance for take-back and recovery obligations.EPR registration process
Most companies join EKO-KOM via contract for collective compliance. Application must be submitted within 60 days from when obligations commence. Two tracks usually exist:- Collective compliance (typical) via EKO-KOM - Join by signing a Contract on Collective Compliance (EKO-KOM onboarding flow includes registration form → contract → fee payment → certificate).
- Individual compliance - The EKO-KOM guide notes collective compliance is not the only way (other ways exist under Section 13), but it’s less common in practice for most companies.
Authorized representative
Czech law explicitly allows appointing an authorised representative:- must be appointed by written agreement
- must be a business person established in the Czech Republic
- fulfils the obligations of the party placing packaging on the market/into circulation (with limited exceptions).
Data reporting requirements
At a minimum, entities in scope must keep records on packaging/packaging waste and report data from records for the previous calendar year. In collective compliance, EKO-KOM typically collects packaging data and handles system-level obligations, while you still must keep adequate records.First reporting period
In the Czech Republic, packaging reporting under EKO-KOM is generally required on a quarterly basis, with annual reporting only possible in exceptional cases depending on the contract and volumes.EPR reporting deadlines
Quarterly reports must be submitted within 30 days after the end of each calendar quarter.Labels & marketing claims
Key Czech-law labelling/marking obligations are most explicit around deposit returnable packaging (e.g., marking as deposit returnable packaging as per implementing rules). For environmental/“green” marketing claims, treat these as a separate consumer protection / unfair commercial practices topic (not an “EPR label requirement”), and validate claims carefully.
Eco fees & eco-modulation
- The Packaging Act defines eco-modulation as taking into account packaging’s environmental impact (e.g., reusability/recyclability, hazardous substances) when the authorised packaging company determines the contribution amount.
- In collective compliance, fees are generally linked to the amounts and materials of packaging you report (EKO-KOM collects data and payments based on reported production).
Risks & penalties
Penalties: the Packaging Act provides for fines up to CZK 10,000,000 for certain offences (with lower brackets such as CZK 50k / 500k / 1m / 5m depending on the offence category). Common mistakes (seen in practice):- assuming VAT registration = EPR compliance (it doesn’t)
- missing List registration / missing the 15 Feb annual reporting cycle
- under-reporting packaging (especially transport/e-commerce packaging)
- no authorised representative where needed for a non-established seller.
What e-commerce sellers should do now
- Map your flows: who imports / who is first placing on CZ market (incl. marketplace vs own webshop).
- Check if you qualify for the 300 kg + CZK 25m exception; document it if you rely on it.
- If in scope, choose compliance route (typically EKO-KOM) and get your contract + certificate in place.
- Set up packaging data capture by material/weight; align internal reporting calendar to 15 Feb.
- If not established in CZ, assess whether you need an authorised representative.
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