Czech Republic EPR

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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. 
If you stop meeting the conditions during the year, obligations kick in once it becomes apparent. 

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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).  
This is particularly relevant for non-Czech established sellers.  

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

  1. Map your flows: who imports / who is first placing on CZ market (incl. marketplace vs own webshop).  
  2. Check if you qualify for the 300 kg + CZK 25m exception; document it if you rely on it.  
  3. If in scope, choose compliance route (typically EKO-KOM) and get your contract + certificate in place.  
  4. Set up packaging data capture by material/weight; align internal reporting calendar to 15 Feb
  5. If not established in CZ, assess whether you need an authorised representative. 

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FAQ for EPR Czech Republic

Is EKO-KOM the only option?

 Collective compliance via the authorised company (EKO-KOM) is the common route, but the system guide notes it’s not the only possible compliance method under Czech law.  

Do I need to register even if I join EKO-KOM?

 - The act requires registration in the Ministry’s “List”; in practice, collective compliance arrangements often interact with List/registration handling, but you should still confirm that your entity (or your authorised representative) is correctly covered.    

What is Czech Republic EPR EEE

The Czech Republic's EEE EPR framework is governed by Act No. 542/2020 Coll. on End-of-Life Products (zákon č. 542/2020 Sb., o výrobcích s ukončenou životností), which transposed the EU WEEE Directive (Directive 2012/19/EU) into Czech national law and replaced the previous Act No. 185/2001 Coll. on Waste. Implementing details are set out in Decree No. 16/2022 Coll. on the handling of certain end-of-life products. The legislation establishes rules for placing EEE on the Czech market, for take-back, treatment, and re-use of end-of-life equipment, for financing EEE waste management, and for the obligations of producers, final sellers, and distributors. The competent authority overseeing EEE EPR is the Ministry of Environment of the Czech Republic (MŽP), which maintains the Registry of EEE Producers (Seznam výrobců elektrozařízení). The enforcement body is the Czech Environmental Inspectorate (ČIŽP), which conducts inspections and verifies compliance with Act No. 542/2020. There is no de minimis threshold for EEE EPR registration in the Czech Republic — the obligation applies from the very first device placed on the Czech market.

Does This Apply to E-Commerce & Online Sales

Yes. Act No. 542/2020 explicitly captures online sellers and marketplace operators supplying EEE to Czech consumers. All producers — regardless of establishment location — must comply with EEE EPR obligations when placing electrical and electronic equipment on the Czech market for the first time. Foreign companies without a physical presence in the Czech Republic must appoint an authorised representative to manage registration, reporting, and compliance on their behalf. Online marketplaces are generally not considered responsible for EEE EPR unless they act as importers or directly place products on the market under their own name. The Czech Environmental Inspectorate (ČIŽP) can cooperate with Czech Customs to enforce EEE EPR obligations, including at the point of import, against non-compliant producers.

Who is the "Producer" under Czech Republic EPR?

Under Act No. 542/2020, the following entities are considered producers of EEE:
  1. Manufacturers producing EEE in the Czech Republic for domestic or international markets.
  2. Importers bringing EEE into the Czech Republic from other EU or non-EU countries under their own name.
  3. Distributors and resellers placing EEE on the Czech market under their own brand, unless the original manufacturer or importer is already registered.
  4. Online sellers supplying EEE to consumers in the Czech Republic, regardless of where the seller is established.
  5. Private label owners whose brand name appears on EEE manufactured by third parties.
  6. Economic operators who prepare EEE for re-use — treated as producers for the second life of the equipment where applicable.

Who Must Register for EPR EEE in Czech Republic

All producers placing EEE on the Czech market must register in the Registry of EEE Producers (Seznam výrobců elektrozařízení), maintained by the Ministry of Environment (MŽP). Registration is a mandatory precondition for placing EEE on the Czech market. Producers must also join a licensed collective scheme (PRO) for EEE take-back and recycling, or establish their own individual take-back system subject to MŽP approval. Licensed collective schemes operating in the Czech Republic for EEE include RETELA, REMA System, Asekol, and others listed in the MŽP register of licensed collective systems (seznam kolektivních systémů OEEZ). Upon joining a collective scheme and completing registration, producers receive a unique registration number required for reporting and compliance.

Czech Republic EPR EEE Registration Threshold

There is no de minimis threshold for EEE EPR registration in the Czech Republic. Act No. 542/2020 requires registration and compliance from the very first device placed on the Czech market, regardless of volume or turnover. This applies equally to small e-commerce sellers and large multinational manufacturers.

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EEE Categories Covered (and Excluded)

The Czech Republic applies the open scope approach under Annex I to Act No. 542/2020, covering all EEE operating at voltages not exceeding 1,000V AC or 1,500V DC unless specifically excluded. The six open-scope categories are: Large household appliances Refrigerators, washing machines, dishwashers, cookers, electric heaters, air conditioners, and similar large appliances. Small household appliances Vacuum cleaners, toasters, coffee machines, irons, hair dryers, electric clocks, and similar small devices. IT and telecommunications equipment Computers, laptops, tablets, smartphones, printers, routers, and related devices. Consumer electronics and photovoltaic panels Televisions, radios, audio and video equipment, cameras, and photovoltaic panels. Lighting equipment Fluorescent lamps, LED lamps, high-intensity discharge lamps, and luminaires (excluding filament bulbs). Other EEE (open scope) All remaining EEE within the voltage parameters not captured in the above categories, including electrical and electronic tools, toys, medical devices, monitoring instruments, and automatic dispensers. Key exclusions:
  • EEE specifically designed and installed as part of another type of equipment that can only function as part of that equipment
  • Large-scale fixed installations and large-scale stationary industrial tools
  • Military or space equipment specifically designed for these purposes
  • Implanted and infected medical devices
  • EEE operating above 1,000V AC or 1,500V DC

Producer Responsibility Organization (PRO)

The Czech Republic operates a multi-PRO system for EEE. Licensed collective schemes authorised by MŽP manage take-back, recycling, and reporting on behalf of their member producers. The main licensed collective systems include: RETELA — one of the established collective schemes for EEE in the Czech Republic, managing take-back infrastructure and recycling across product categories. REMA System — a collective scheme covering EEE and batteries, part of a broader European compliance network. Asekol — a specialist collective scheme for small EEE and IT equipment, managing a nationwide network of red Asekol collection boxes in stores and public spaces. The MŽP publishes the full list of licensed collective systems (seznam kolektivních systémů OEEZ) on its website. Producers should confirm which scheme is accredited for their specific EEE categories before signing a membership agreement.

EPR Registration in Czech Republic

The registration process for EEE producers in the Czech Republic is as follows:
  1. Confirm whether your EEE falls within scope of Act No. 542/2020 based on voltage rating and open-scope category list.
  2. If established outside the Czech Republic, appoint an authorised representative established in the Czech Republic before initiating registration.
  3. Register in the Registry of EEE Producers (Seznam výrobců elektrozařízení) with the Ministry of Environment (MŽP), providing company details, EEE categories, brand names, and authorised representative information.
  4. Select and join a licensed collective scheme — RETELA, REMA System, Asekol, or another MŽP-licensed PRO — by signing a service agreement and submitting required documentation.
  5. Pay registration fees — fees vary by collective scheme and EEE category.
  6. Receive your unique EEE registration number upon approval — this number is required for reporting and compliance.
  7. Submit quarterly reports on EEE placed on the Czech market and end-of-life equipment collected and processed.
  8. Pay contributions to the collective scheme based on EEE weight and category.
  9. Maintain records for audit by ČIŽP.

Authorized Representative

Foreign companies without a physical presence in the Czech Republic must appoint an authorised representative established in the Czech Republic before any registration can be completed. The AR assumes full responsibility for all EEE EPR obligations, including registration in the MŽP registry, collective scheme membership, quarterly reporting, financial contributions, and communication with ČIŽP. Important development: In December 2025, the European Commission proposed suspending the authorised representative requirement for EU-established companies until 2035 under Proposal COM(2025) 983. This proposal has not been formally adopted as of May 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers must submit quarterly reports through their collective scheme and the MŽP registry system covering:
  • Total weight (kilograms) of EEE placed on the Czech market during the quarter, broken down by the six open-scope categories under Act No. 542/2020
  • Separate reporting for household (B2C) versus non-household (B2B) EEE where applicable
  • Weight of end-of-life equipment collected and processed during the reporting period
  • Brand names under which EEE was placed on the market
  • Projected sales volumes (provided at registration for the current and following year)
  • Recycling and recovery rates for registered product groups where required

First Reporting Period & EPR Reporting Deadlines

EEE EPR has been mandatory in the Czech Republic for many years. The current framework under Act No. 542/2020 has been in place since 2021. Key recurring deadlines:
  • Quarterly: EEE placed-on-market and end-of-life equipment collected declarations — submitted through the collective scheme
  • Annual: Summary compliance reporting to MŽP through the collective scheme
  • Annual ISPOP: Required only if the company has a physical presence in the Czech Republic and exceeds waste thresholds — not applicable to most foreign e-commerce sellers
Specific quarterly submission dates should be confirmed with the chosen collective scheme at the time of membership registration.

Labels & Marketing Claims

Crossed-out wheeled bin symbol All EEE placed on the Czech market must carry the crossed-out wheeled bin symbol, indicating separate collection. The symbol must be visible, legible, and indelible on the product itself. Where this is not possible due to the size or function of the product, the symbol must appear on packaging, instructions for use, or warranty documentation. CE marking Mandatory for applicable EEE categories under EU product safety legislation. RoHS compliance EEE must comply with Directive 2011/65/EU (RoHS) restricting hazardous substances. RoHS compliance in the Czech Republic is overseen by the Ministry of Industry and Trade — separately from EEE EPR administered by MŽP. Language requirements Consumer-facing information on EEE sold in the Czech Republic must be provided in Czech where required under Czech consumer protection law. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including the Czech Republic.

EPR Eco Fees & Eco-Modulation

Czech collective schemes set contribution rates for member producers based on the weight and category of EEE placed on the Czech market. Contributions are calculated on a per-kilogram basis by EEE category and cover the costs of take-back infrastructure, collection, treatment, and recycling. The Czech Republic does not currently apply a formal eco-modulation framework adjusting EEE contributions based on product repairability, recyclability, or eco-design criteria. As the Ecodesign for Sustainable Products Regulation (ESPR) implementing regulations for specific EEE product groups are adopted, eco-design criteria may influence future contribution structures. Specific fee schedules should be confirmed with the chosen collective scheme at the time of membership registration.

Risks, Penalties & Common Mistakes

  1. Placing EEE on the Czech market without MŽP registration. The Czech Environmental Inspectorate (ČIŽP) conducts inspections and can impose significant fines for non-compliance with Act No. 542/2020. ČIŽP can cooperate with Czech Customs to target non-compliant importers.
  2. Failing to appoint an authorised representative. Foreign companies without Czech establishment must appoint an AR before registration can be completed. Operating without an AR is a compliance breach.
  3. Missing the no-threshold rule. There is no de minimis exemption for EEE in the Czech Republic — the obligation applies from the very first device. Small e-commerce sellers often incorrectly assume they are below a registration threshold.
  4. Assuming one EU registration covers the Czech Republic. EEE EPR registration is national. Registration in another EU member state does not fulfil Czech obligations. A separate MŽP registration and Czech collective scheme membership are required.
  5. Choosing the wrong collective scheme. The MŽP publishes a list of licensed collective systems. Producers should confirm which scheme covers their specific EEE categories before signing a contract.
  6. Confusing ISPOP reporting with EEE EPR reporting. ISPOP is the Czech national environmental reporting platform managed by CENIA — but most foreign e-commerce sellers without a Czech physical presence do not report to ISPOP. EEE EPR reporting is handled separately through the collective scheme system.
  7. Missing the crossed-out wheeled bin symbol. The symbol is mandatory on all EEE. Missing or non-compliant marking is independently actionable by ČIŽP.

What E-Commerce Sellers Should Do Now

  1. Confirm whether your products qualify as EEE under Act No. 542/2020 based on voltage rating and product function.
  2. If established outside the Czech Republic, appoint an authorised representative established in the Czech Republic.
  3. Register in the Registry of EEE Producers (Seznam výrobců elektrozařízení) with the Ministry of Environment (MŽP).
  4. Select and join a licensed collective scheme — RETELA, REMA System, Asekol, or another MŽP-licensed PRO.
  5. Receive your EEE registration number and use it for all reporting and compliance purposes.
  6. Set up quarterly reporting of EEE placed on the Czech market by category and weight through your collective scheme.
  7. Ensure all EEE products carry the crossed-out wheeled bin symbol — visibly, legibly, and indelibly — and comply with RoHS hazardous substance restrictions.
  8. Maintain records for audit by ČIŽP.

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FAQ

Is EEE EPR mandatory in the Czech Republic?
  • Yes. EEE EPR has been mandatory in the Czech Republic for many years and is currently governed by Act No. 542/2020 Coll. on End-of-Life Products. All producers placing EEE on the Czech market must register in the MŽP Registry of EEE Producers, join a licensed collective scheme, submit quarterly reports, and pay contributions. There is no de minimis threshold — the obligation applies from the very first device.
Do foreign brands selling online into the Czech Republic need to register?
  • Yes. Act No. 542/2020 explicitly captures online sellers supplying EEE to Czech consumers, regardless of where the seller is established. Foreign companies must appoint an authorised representative established in the Czech Republic before registration can be completed. The Czech Environmental Inspectorate can cooperate with Czech Customs to enforce these obligations against non-compliant importers.
Is there a minimum volume threshold for EEE EPR in the Czech Republic?
  • No. There is no de minimis exemption for EEE in the Czech Republic. Registration and compliance are required from the very first device placed on the Czech market, regardless of volume or annual turnover.
Which collective scheme should I join?
  • The MŽP publishes a full list of licensed collective systems for EEE. Main options include RETELA, REMA System, and Asekol. Producers should confirm which scheme covers their specific EEE categories — Asekol, for example, specialises in small EEE and IT equipment. Contact multiple schemes and compare contribution rates and service terms before signing.
What is the difference between EEE EPR reporting and ISPOP reporting in the Czech Republic?
  • These are completely separate systems. EEE EPR reporting is handled through the collective scheme system under Act No. 542/2020. ISPOP is the Czech national environmental reporting platform for waste, emissions, and wastewater — it applies only to companies with a physical presence in the Czech Republic that exceed specific waste thresholds. Most foreign e-commerce sellers without Czech presence do not have ISPOP obligations.

What is Czech Republic EPR Batteries

The Czech Republic's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States without requiring national transposition. The Regulation has applied in stages since 18 February 2024, with EPR and waste management obligations fully in force from 18 August 2025.

At national level, the Czech Republic has implemented battery EPR through its Waste Act and subordinate legislation, with a long-standing collective system for battery collection and recycling that predates the EU Battery Regulation. The battery sector has operated under EPR principles since 2009, when Directive 2006/66/EC was transposed into Czech law. The enforcement body is the Czech Environmental Inspectorate (ČIŽP — Česká inspekce životního prostředí), which conducts inspections and verifies compliance for both Czech-based companies and foreign businesses selling into the Czech market.

The EU Battery Regulation replaced the previous Batteries Directive 2006/66/EC in full from 18 August 2025. It covers all battery types regardless of chemistry or form, whether sold separately or incorporated into products or vehicles. The Czech Republic is adapting its existing national framework to align with the new Regulation's requirements. A national public producer register for batteries under the new Regulation is being established and is expected to be operational by April 2026.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation explicitly captures distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Czech consumers via an online store — with no physical establishment in the Czech Republic — is treated as a producer and must comply with Czech battery EPR obligations.

The enforcement body, ČIŽP, has authority to inspect both Czech-based companies and foreign businesses selling into the Czech market. It can cooperate with the Czech Customs Office where there is suspicion of non-compliance involving imports.

Major online marketplaces including Kaufland already require sellers to provide a valid Czech battery EPR registration number to sell battery-containing products on their platform. Zalando's Czech battery EPR registration verification is scheduled to launch by 30 April 2026.

Who is the "Producer" under Czech Republic EPR?

Under Regulation (EU) 2023/1542 and Czech national waste legislation, a producer is any person who, in the course of commercial activity, makes batteries available on the Czech market for the first time. This covers:

  1. Manufacturers established in the Czech Republic who produce and sell batteries domestically under their own brand.
  2. Importers bringing batteries into the Czech Republic from non-EU countries for the first time under their own name.
  3. Companies introducing batteries from another EU Member State into the Czech Republic for the first time.
  4. Private label owners whose brand name appears on batteries manufactured by third parties.
  5. Distance sellers and online retailers established outside the Czech Republic who sell batteries or battery-containing products directly to Czech consumers.
  6. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Who Must Register for EPR Batteries in Czech Republic

All producers placing batteries on the Czech market must register with the competent authority and join an approved collective PRO or establish an individual compliance arrangement.

The Czech Environmental Inspectorate (ČIŽP) is the primary enforcement authority. The national public producer register for batteries under Regulation (EU) 2023/1542 is being established and is expected to be operational by April 2026. Until the register is publicly launched, producers fulfil registration obligations by contracting with an approved collective organisation.

The two approved PROs for batteries in the Czech Republic are ECOBAT s.r.o. and REMA Battery s.r.o. Joining either PRO constitutes the compliance arrangement for collection and recycling obligations.

Czech Republic EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Czech market must register and comply, regardless of size or volume.

The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely.

For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

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Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in the Czech Republic:

Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. The most commonly encountered category for e-commerce sellers.

Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles.

Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles.

Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027. In 2022, ECOBAT was authorised for all battery categories including EV batteries, the first time this category was formally covered.

Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Subject to carbon footprint declarations, battery passports from 2027, and detailed collection obligations.

Key exclusions:

  • Batteries designed for military or space equipment — outside scope entirely
  • Batteries in nuclear installations — excluded
  • Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

The Czech Republic operates a dual PRO system for batteries with two approved collective organisations:

ECOBAT s.r.o. — the longest-established battery PRO in the Czech Republic, operating since 2003. ECOBAT covers all battery categories including portable, automotive, industrial, and EV batteries. It manages a nationwide collection network and reports to the competent authority on behalf of its members. As of recent data, ECOBAT holds approximately 76% of the Czech battery market by volumes placed on market.

REMA Battery s.r.o. — a second approved collective organisation, related to the WEEE compliance organisation REMA. REMA Battery accounts for approximately 24% of the Czech battery market.

Producers may join either organisation. Membership constitutes the compliance arrangement for collection, recycling, and reporting obligations. The PRO reports aggregated compliance data to the competent authority on behalf of member producers.

EPR Registration in Czech Republic

The registration process for battery producers in the Czech Republic is as follows:

  1. Determine whether your business qualifies as a producer under the EU Battery Regulation and Czech waste legislation.
  2. If established outside the Czech Republic, appoint an authorized representative established in the Czech Republic before registering.
  3. Contact either ECOBAT s.r.o. (ecobat.cz) or REMA Battery s.r.o. and apply for membership as a battery producer.
  4. Declare the quantities and categories of batteries placed on the Czech market.
  5. Pay the applicable contributions to the PRO based on declared volumes and battery category.
  6. Once the national public producer register is operational (expected by April 2026), register as a producer and obtain a national battery EPR registration number to provide to marketplaces and distributors.
  7. Retain records of declared volumes and contribution payments for inspection by ČIŽP.

Authorized Representative

Under Regulation (EU) 2023/1542 (Article 57), producers established outside the Czech Republic must appoint an authorized representative — a legal or natural person established in the Czech Republic — to fulfill EPR obligations on their behalf. This requirement applies to all foreign producers selling batteries into the Czech Republic without a Czech establishment.

The authorized representative is responsible for registration, PRO membership, reporting, and serving as the point of contact for ČIŽP during inspections.

Important development: In December 2025, the European Commission proposed suspending the authorized representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of April 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers registered through ECOBAT or REMA Battery must declare and report the following data:

  • Total weight (kilograms) of batteries placed on the Czech market during the reporting period, broken down by battery category (portable, LMT, SLI/automotive, industrial, EV)
  • Battery chemistry type where relevant to contribution calculations
  • Brand names under which batteries were placed on the market
  • Collection and recycling performance data, compiled and reported by the PRO to ČIŽP on behalf of members
  • For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities, as required under the EU Battery Regulation

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been in place in the Czech Republic since 2009 under the former Batteries Directive. The new EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

  • 18 February 2024: EU Battery Regulation begins applying. CE marking and substance restrictions in force.
  • 18 August 2025: EPR registration, waste management, and labelling obligations fully in force under the new Regulation.
  • April 2026: National public producer register expected to be operational. Producers must register and obtain an EPR registration number.
  • 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries. Portable batteries must be removable and replaceable by end users.
  • 18 August 2027: Due diligence obligations in force (delayed from 2025 under Omnibus IV).

Annual reporting schedules are set by the PRO and ČIŽP. Producers should confirm declaration submission timelines with their chosen PRO at the time of membership registration.

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm.

Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb.

Capacity marking Portable and rechargeable batteries must display capacity information.

QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027.

CE marking Mandatory from 18 August 2024.

Language requirements Consumer-facing information on batteries sold in the Czech Republic must be provided in Czech where required under Czech consumer protection law.

Environmental claims All environmental and sustainability claims must comply with Czech consumer protection law and the Unfair Commercial Practices Directive. The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including the Czech Republic.

EPR Eco Fees & Eco-Modulation

ECOBAT and REMA Battery set contribution rates for their members based on the weight and category of batteries placed on the Czech market. Specific fee schedules should be confirmed directly with the chosen PRO at the time of membership registration, as rates vary by battery category and are subject to annual review.

Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance such as durability, recyclability, and recycled content — is required across all Member States. The Czech Republic's specific eco-modulation framework under the new Regulation has not been published as of April 2026.

Risks, Penalties & Common Mistakes

  1. Placing batteries on the Czech market without PRO membership. ČIŽP has authority to inspect foreign businesses and can impose penalties for non-compliance with waste legislation. Operating without a PRO arrangement is a breach of both Czech waste law and the EU Battery Regulation.
  2. Failing to appoint an authorized representative. Non-EU and non-Czech producers must appoint a Czech-established representative. Without one, registration and PRO membership cannot be properly established.
  3. Assuming one EU registration covers the Czech Republic. Battery EPR registration is national. Membership in a PRO in another EU member state does not fulfil Czech obligations.
  4. Missing the national producer register deadline. Once the public register is operational (expected April 2026), producers must register and obtain an EPR registration number. Marketplaces including Kaufland already require this number.
  5. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025. Labels must include Czech-language consumer information where required.
  6. Missing the QR code deadline of August 2026. Companies should begin QR code implementation well in advance.
  7. Failing to prepare for battery passport requirements. Industrial (>2 kWh) and EV battery producers must have Digital Battery Passports in place by February 2027.

What E-Commerce Sellers Should Do Now

  1. Confirm whether your products contain batteries and whether they are being sold to Czech consumers.
  2. If established outside the Czech Republic, identify and appoint an authorized representative established in the Czech Republic.
  3. Contact ECOBAT s.r.o. (ecobat.cz) or REMA Battery s.r.o. and apply for PRO membership as a battery producer.
  4. Declare battery volumes by category and weight and pay applicable contributions to your chosen PRO.
  5. Monitor the launch of the national public battery producer register (expected by April 2026) and register to obtain your Czech EPR registration number.
  6. Provide your EPR registration number to marketplaces where you sell battery-containing products in the Czech Republic — Kaufland already requires this.
  7. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and Czech-language consumer instructions as required.
  8. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

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FAQ

Is battery EPR mandatory in the Czech Republic?

  • Yes. Battery EPR has been mandatory in the Czech Republic since 2009 under the former Batteries Directive. From 18 August 2025, the new EU Battery Regulation (2023/1542) fully replaced the Directive. All producers placing batteries on the Czech market must join an approved PRO — ECOBAT or REMA Battery — declare volumes, and comply with collection and recycling obligations. A national public producer register is expected to be operational by April 2026.

Do foreign brands selling online into the Czech Republic need to register?

  • Yes. Distance sellers and e-commerce operators selling batteries or battery-containing products to Czech consumers are captured as producers under the EU Battery Regulation and Czech waste legislation. Non-Czech companies must appoint an authorized representative established in the Czech Republic. ČIŽP has authority to inspect foreign businesses for compliance.

Is there a minimum volume threshold below which registration is not required?

  • No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Czech market must register and comply regardless of size.

Which PRO should I join — ECOBAT or REMA Battery?

  • Both ECOBAT and REMA Battery are approved collective organisations covering all battery categories. ECOBAT is the larger and more established organisation with approximately 76% of the market. The choice between them is commercial — both fulfil the same legal obligations. Producers should contact both and compare contribution rates and service terms.

What languages must battery labels be in for the Czech market?

  • Consumer-facing information on batteries sold in the Czech Republic must be provided in Czech where required under Czech consumer protection and product safety law. Labels and instructions available only in other languages may not satisfy Czech market surveillance requirements.

Textile EPR law in Czech Republic: None enacted

Czech Republic is not among the countries with enacted textile EPR legislation.

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February 12, 2026 310
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