TL;DR

• Put packaging on the Czech market first and you carry take-back and recovery duties under Act No. 477/2001 Coll., including imports and cross-border e-commerce.
• Exempt only if you stay under 300 kg of packaging a year AND under 25,000,000 CZK turnover. Both, and you carry the burden of proving it.
• 1 authorised packaging company, EKO-KOM, so there is nothing to compare offers against.
• Registration deadline is 60 days from placing packaging on the market. Sign a collective compliance contract and the scheme enters you on the register itself.
• Cost: 1,600 CZK a year excluding VAT, plus a quarterly amount on weight.
• Packaging type moves the bill far more than material. Rigid plastic as sales packaging is 15,839 CZK a tonne; the same plastic as transport or industrial packaging is 830.
• Reusable packaging meeting the Section 13(3) criteria is 0 CZK a tonne, every material, every category.
• Quarterly statement within 30 days of quarter end. 15 February carries 3 separate annual duties, and EKO-KOM handles 2 of them for its members. Records kept 5 years.
• Fines reach 10,000,000 CZK for recovery failures, and they can be repeated.
• Since 12 August 2026, PPWR Article 45(3) makes an authorised representative mandatory for producers established in another member state who sell into Czechia. EKO-KOM cannot be it, because Section 20(10) bars the scheme from that role.

Who has to register for packaging EPR in Czechia?

Anyone who is first to put packaging on the Czech market or into circulation there. The Act defines placing on the market to include cross-border transport of packaging from another EU member state into Czechia, and import from outside the EU, so a warehouse in Poland or a factory in Shenzhen sits inside the rules.

That catches:

• Fillers and packers operating in Czechia
• Importers bringing packaged goods in from anywhere
• Distributors and retailers further down the chain, unless someone upstream has provably taken the obligation
• Distance sellers shipping to Czech customers from abroad, through their own site or a marketplace

A VAT registration does nothing here. The 2 regimes run on separate registers, so holding 1 says nothing about the other.

National scope matters too. A German LUCID number, a Polish BDO entry, or a French UIN covers Germany, Poland and France. None reaches Czechia.

Do you qualify for the 300 kg exemption?

Section 15a lifts the obligations in Sections 10 through 15, which covers take-back, recovery, records, and entry on the List of Entities, when you meet both conditions:

• Packaging placed on the market or into circulation of 300 kg or less per calendar year, and
• Annual turnover of 25,000,000 CZK or less

Both. Cross 1 and the relief disappears.

Section 15a(2) adds a trap: the moment it becomes clear you will not stay under the limits this year, the obligations start immediately, so a strong Q4 can put you in scope before you have finished working out whether you were ever out of it.

Sections 15a(3) and (4) put the burden of proof on you. If an inspector asks and you cannot show the figures, you are treated as having carried every obligation for that whole period. So keep the weight calculations and the turnover figures somewhere you can pull them from quickly, even while you qualify.

Marketplace sellers should read the turnover half carefully. Allegro’s guidance tells sellers that when working out annual turnover, you account for all marketplaces you sell in. A Polish seller doing solid domestic volume and testing the Czech market with 40 kg of packaging a year stays well under 300 kg and still falls in scope, because the turnover condition failed on the home business alone.

What counts as packaging in the Czech system?

The Act splits packaging 3 ways, and the split drives the price:

1. Sales packaging, the unit the consumer takes home
2. Group packaging, the shrink wrap or tray bundling sales units together
3. Transport packaging, the outer boxes and pallets that move goods

Sitting outside those is industrial packaging, used only for products going to another business and never to a consumer. The 2026 price list charges industrial packaging at the same rates as group and transport packaging, which is the single most useful thing to know before you classify anything.

Sales packaging costs more because it carries a take-back duty on top of the recovery duty. Everything else carries recovery and recycling alone.

How do you comply, and who do you sign with?

Section 13(1) gives exactly 3 routes.

a) Run your own system: build and operate take-back and recovery at your own cost.

b) Transfer the obligation along the chain, together with ownership of the packaging, provided the contract transferring ownership says so expressly.

c) Sign a contract on collective compliance with an authorised packaging company, covering all the packaging you place on the market.

Route (a) looks open until you reach Section 10(2), which requires an own system’s collection points to cover at least 90% of Czech municipalities and 90% of the Czech population. That is a national container network, and for a company shipping pallets or parcels the arithmetic settles it.

Route (b) works in a proper B2B chain where the counterparty signs for it and you can evidence the transfer to an inspector later.

Which leaves route (c) for almost everyone, and there is 1 company to sign with. EKO-KOM, a.s. has held the authorisation since the Ministry issued its decision on 28 March 2002. In 2024 the European Commission told Czechia that appointing EKO-KOM as the only authorised company for over 2 decades may breach EU competition rules, which indicates how settled the arrangement has been. Allegro’s own seller documentation puts it the same way, calling EKO-KOM the only company authorised by the Czech government.

Guides telling you to gather quotes from several Czech packaging schemes are describing a market that does not exist. The Act does allow for more than 1 authorised company, and Sections 21b and 21c are written for that scenario, so this could change. As of October 2026 it has not.

Do you need a Czech authorised representative?

Since 12 August 2026, yes, if your company is established in another EU member state and you sell packaged goods to Czech end users. The answer changed on that date, and it changed through EU law.

Under the PPWR: Article 45(3) of Regulation (EU) 2025/40 requires a producer falling within Article 3(1) point (15), letter (c) or (d), to appoint an authorised representative for extended producer responsibility, by written mandate, in each member state where it first makes packaging available other than the one where it is established. A Polish company shipping packaged goods to Czech consumers sits inside that description.

For a producer established outside the EU, the second subparagraph leaves each member state to decide whether to require a representative, so the Czech national position governs there.

A Commission proposal under the environmental omnibus package would suspend Article 45(3), and it was still moving through the European Parliament during 2026. Until something is adopted the requirement stands as written, and we track it on our PPWR page.

Under Czech law: Section 13a of the Packaging Act predates the PPWR and sets a narrower rule, which is why older guidance says an authorised representative is optional. Section 13a(1) gives a producer not established in Czechia the entitlement to appoint one, and the Act expressly lets a foreign applicant file the registration in English. Section 13a(2) then makes appointment mandatory for businesses selling the single-use plastic packaging and packaging means listed in Parts C or D of Annex 4 directly to Czech consumers or end users from another country, covering beverage containers up to 3 litres, food containers, cups, wrappers for immediate-consumption food, and plastic carrier bags. Failing to appoint one where Czech law requires it is a listed offence under Section 44(2)(n).

So the Czech Act’s optional route has been overtaken for cross-border distance sellers, and Section 13a still governs the mechanics. The appointment has to be in writing, the representative has to be a licensed business established in Czechia, and the design and marking duties in Sections 3 to 6 stay with you.

Section 20(10) is the provision that catches people: the authorised packaging company may not act as an authorised representative. EKO-KOM cannot do this for you. A separate Czech-established party has to, and bin2green provides that service.

How do you register, step by step?

2 paths, and the shorter one is the one most companies take.

Through EKO-KOM

1. Work out what you will be charged for: check with your suppliers whether they hold a collective compliance contract and whether they already pay for the packaging they send you. This becomes the basis of your records, and an error here follows you into every quarterly statement afterwards.

2. Fill in the registration form: EKO-KOM returns a confirmation of registration by email, usually within a day. That confirmation can be shown to customs while the contract is still completing.

3. Sign the contract on collective compliance: 3 copies arrive by post, 2 in Czech and 1 English translation for information. Your statutory body signs 2 and returns them, EKO-KOM countersigns and sends 1 back.

4. Pay the annual fee: 1,600 CZK excluding VAT, which splits into 800 CZK for the statutory registration fee going to the State Environmental Fund under Section 30, and 800 CZK for EKO-KOM’s administration.

5. Collect your EK number and certificate: once the invoice is paid, your client identification number in the format EK-xxxxxxx is generated and the Certificate of Integration follows.

EKO-KOM then registers its clients in the Ministry’s List of Entities automatically and regularly. Section 14(12) backs this up, removing the duty to apply for the List from anyone holding a collective compliance contract that covers all their packaging. For most companies the Ministry filing everyone worries about never happens by hand.

Filing with the Ministry yourself

For the individual route under Section 13(1)(a) or the transfer route under (b), Section 14 sets the rules.

The deadline is 60 days from when the obligation starts. That is the date for the calendar.

The application goes in either as 2 hard copies plus an electronic copy on a data carrier, or electronically with a recognised electronic signature.

It has to contain your company identification details, the identification details of the foreign company plus the written authorisation where a representative files on its behalf, a description of how you provide take-back under Section 10(1), how you handle consumer awareness under Section 11, how you ensure recovery under Section 12, proof the 800 CZK registration fee has been paid, and what materials your packaging is made from including whether it is sold to consumers.

Then you wait: the Ministry has 30 days from a complete application to make the entry and 14 days after that to notify you. A thin file gets a request for more with a deadline of at least 30 days, and Section 14(7) lets the Ministry enter you on the List anyway on the available data and refer you to an inspection authority if you ignore it.

Keep it current: any change to the registered details gets reported within 14 days.

The registers themselves are public. Packaging sits in the List of Entities at visoh2.mzp.cz, records go through ISPOP, and electrical equipment producers register in the List of Manufacturers.

What does Czech packaging EPR cost?

2 charges. A flat 1,600 CZK a year excluding VAT, and a quarterly amount calculated on the weight of packaging you reported against the published tariff.

EKO-KOM explains how it builds the rates: the largest input is what municipalities spend handling packaging waste, reported through contractual questionnaires, with the costing methodology agreed with the Union of Towns and Municipalities. Sorting costs and secondary raw material prices move it from there, so the rates track collection costs and stay outside your control.

Every figure below comes from the price list valid from 1 January 2026 and excludes VAT.

Sales packaging, single use

All figures CZK per tonne.

Beverage PET up to 3 litres is priced separately, and the spread is the clearest piece of eco-modulation in the Czech system:

Opaque colour costs 46% more than clear on virgin PET. Same polymer, same weight, same product, different pigment.

Group, transport and industrial packaging

The 2026 list charges industrial packaging at the same rates as group and transport packaging, and those rates sit an order of magnitude below sales packaging.

All figures CZK per tonne. Glass carries no line in the group and transport table. It appears at 1,852 CZK a tonne in the sales and industrial tables, so a glass container moving between businesses is priced as industrial packaging.

Rigid plastic at 15,839 as sales packaging against 830 as transport packaging is roughly 19 times, on identical material at identical weight. Classification moves your invoice more than material choice does, and it is the thing most companies set once and never revisit.

Reusable packaging

0 CZK a tonne: every material, every category, across sales, group, transport and industrial.

The condition is that the packaging meets the criteria in Section 13(3) of the Act, which is what separates the zero-rated pages of the price list from the paid ones. You still report the weight, since a share of reusable packaging reaches municipal waste anyway.

For a B2B operation running returnable crates or a pallet pool, this is the difference between a 5-figure invoice and a rounding error.

The litter charge

Since 2023 EKO-KOM also collects the payment reimbursing municipalities for cleaning up litter from certain single-use plastics, under Section 10a. The 2026 rate is 859 CZK a tonne, applied to beverage containers, packets and wrappers, cups for beverages, food containers, and plastic carrier bags. It sits on top of the normal packaging rate, so a plastic carrier bag carries both.

A worked example

2 companies, same 15 tonnes a year, different invoices.

Company A, consumer goods: 3 tonnes of rigid plastic sales packaging, 12 tonnes of corrugated transport cartons.

Company B, B2B components: the same 3 tonnes of rigid plastic, this time as industrial packaging, and the same 12 tonnes of corrugated.

6 times the bill on identical tonnage, with nothing changed except who the packaging was destined for.

What brings the bill down

Ask suppliers for their EK client number: only packaging in the paid category generates a charge for you. Packaging your supplier already covered is pre-paid, packaging your customer contractually took on is non-paid, and packaging leaving the Czech market is exported. None of those 3 costs you anything, and all of them still get reported. EKO-KOM’s principle is that a client should never pay a fee for packaging another client has already paid for, and the fee moves down a supply chain much as VAT does. A Czech filler pays, then puts its EK number on the invoice with a note that the fee was paid, and you record that packaging as pre-paid. EKO-KOM publishes a standard declaration document for this.

Classify correctly: anything going only to another business is industrial packaging, at the group and transport rate.

Put recyclate in beverage PET: rPET is charged at 2,822 a tonne against 15,420 for virgin, with a separate discount of 6,525 CZK per tonne of recyclate, capped at 35% of the weight of the PET packaging. On 10 tonnes at that ceiling: 6.5 t of virgin at 15,420 comes to 100,230 CZK, 3.5 t of rPET at 2,822 comes to 9,877 CZK, and the discount removes 22,838 CZK, landing at 87,269 CZK against 154,200 CZK for the all-virgin version. Around 43% less. The PPWR minimum for PET beverage bottles is 25%, so the tariff pays you past the legal floor.

Drop decorative pigment: Clear beverage PET at 15,420 against coloured opaque at 22,585 puts about 7,165 CZK a tonne on the colour.

Look at reusables: zero rate, every material. This works far more easily in B2B logistics than in consumer retail, and where it works it removes the line.

What do you report, and when?

A quarterly statement of packaging placed on the market or into circulation, due within 30 days of the quarter ending. Quarterly is the default for EKO-KOM clients, and annual payment is a concession granted the following year where remuneration stayed under a set minimum amount, which is tied to the size of your bill, not your company.

3 separate duties land on 15 February:

• The annual data notification to the Ministry for the previous calendar year, under Section 15(1)(b)
• The fee for staying on the List of Entities for the previous calendar year, under Section 30(1)
• The recycled plastic content notification under Section 12a(3), if you place the single-use plastic packaging listed in Part B of Annex 4 on the market

Since 1 January 2025, PET bottles up to 3 litres have had to contain at least 25% recycled plastic, rising to 30% from 2030.

EKO-KOM clients satisfy the Ministry-facing annual duty through the system, with no direct filing of their own. EKO-KOM aggregates client data and submits the summary with the current client list.

What the statement contains, structurally: trade packaging divided into sales, group and transport; industrial packaging undivided, since all of it carries the same rate; a material breakdown following Annex 3; reusable packaging on separate lines; and littering-relevant single-use plastic packaging on its own lines. Industrial packaging gets dedicated sheets in the statement, the blue J1-3, J1-3K, O1-3 and O1-3K pages.

Section 15(1) also sets the record duties: keep records of packaging and packaging waste, prove the data is true on request from the Ministry or the Czech Environmental Inspectorate, and keep the supporting documents at least 5 years. 5 years is longer than most companies keep shipping data by habit, and the clock catches anyone who changed warehouse systems or 3PL partners mid-stream, so export the weights before any migration.

On confidentiality, which comes up often: EKO-KOM states that the quantity each company places on the market is treated as confidential and never disclosed to a third party except where the law requires it. The Ministry receives the summary plus the client list.

What happens if you file late or get it wrong?

Late statement, faster invoice: the standard invoice due date is 30 days, and delivering the statement late cuts it to 10 days. Nobody announces this; the invoice simply arrives compressed.

No statement at all: if the statement is not sent or the invoiced fee goes unpaid, the contract on collective compliance can be terminated, which puts you back under Sections 10 and 12 in your own name, along with the 90% coverage requirement.

Wrong numbers: Section 23a obliges the authorised company to have an auditor verify the correctness and completeness of the quantities its clients reported, and Section 23a(5) obliges you to cooperate with that verification. Under-reporting tends to get found.

Statutory fines: the ceilings published in EKO-KOM’s system guide are up to 10,000,000 CZK where you cannot demonstrate recovery of the statutory percentage, and that one can be imposed repeatedly; up to 1,000,000 CZK for failing to keep packaging records; and up to 10,000,000 CZK for breaching the 100 µg/g heavy metals limit. Failing to submit the application for entry on the List is a separate listed offence under Section 44(2)(o), as is failing to notify a change within 14 days under Section 44(2)(p).

Enforcement arrives from several directions. The Czech Environmental Inspectorate checks take-back, recovery and the authorised representative rules under Section 40. The Czech Trade Inspection Authority checks retailer take-back to consumers. Under Section 41, customs authorities can examine whether packaging entering Czechia meets the Act’s requirements and refer it onward, which is why that EKO-KOM confirmation email is worth having early.

Exposure also accumulates. A company that started shipping into Czechia in 2023 and never registered carries every quarter of that behind it, and the position worsens with time. Handling it deliberately is a different job from a clean first registration, and we take that on.

What did PPWR change on 12 August 2026?

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and started applying on 12 August 2026. It applies directly, with no Czech transposition step.

The Commission’s interpretive notice sets out the shape: under Article 45(1) the producer pays the collection and recovery costs in each member state, and to do that it must register and report to the national authorities as specified in Article 44. There is no single-window filing, so a seller shipping into several markets carries a registration and a reporting calendar in each. Article 45(3) is the authorised representative provision, covered above.

EKO-KOM has already moved on this. Its general terms and conditions were amended with effect from 1 July 2026 to reference PPWR obligations alongside the Packaging Act.

The harmonised registration format the PPWR calls for was due from the Commission in early 2026 and has been slow to arrive, so national registers still ask for different fields in different shapes. And the authorised representative requirement has been subject to proposed relief under the Commission’s environmental omnibus package, with the scope still moving through the European Parliament as of mid-2026. Until something is adopted, the requirement stands as written. We keep our PPWR page current as the implementing acts arrive.

The direction of travel shows in the 2026 tariff already. Clear PET costs less than coloured, recyclate costs less than virgin, and reusables are free, so the spread between well-designed and poorly-designed packaging should keep widening.

Where do people get Czech packaging EPR wrong?

Reporting packaging somebody else already paid for: Sellers who never ask suppliers for an EK number record everything as paid and get billed on cardboard that was already covered. Unwinding a stack of over-reported statements takes longer than setting them up correctly.

Reporting B2B packaging as sales packaging: roughly 19 times the rate on plastics, every quarter, and it is the setting most companies choose once and never revisit.

Leaving transport packaging out: Pallets, stretch film, outer cartons, and void fill are all reportable weight. E-commerce sellers under-report this more than any other category, because the shipping box reads as logistics.

Relying on the exemption with no paperwork: Section 15a(4) is unforgiving. No proof, no exemption, all obligations retroactively.

Czechia and Slovakia, side by side

Most sellers who reach 1 of these markets reach both, and the 2 regimes disagree in ways that catch people.

The timing row is the sharpest difference, since a Czech seller has 60 days of room and a Slovak seller has none. Full detail in our Slovak packaging guide.

FAQ

Who has to register for packaging EPR in the Czech Republic?

Anyone who first places packaging on the Czech market, including importers and distance sellers shipping from abroad. The Act counts cross-border transport from another EU member state and import from outside the EU as placing on the market, so no Czech entity or warehouse is needed to create the obligation.

Is there a minimum before Czech packaging EPR applies?

Yes, under Section 15a, and it needs both conditions met: 300 kg or less of packaging per calendar year and turnover of 25,000,000 CZK or less. You carry the burden of proving both, so keep the figures even while you qualify.

How much does Czech packaging EPR cost?

A flat 1,600 CZK a year excluding VAT, plus a quarterly amount on weight. Rigid plastic as sales packaging runs 15,839 CZK a tonne and the same plastic as transport or industrial packaging runs 830, per the 2026 price list.

Which packaging scheme should I join in Czechia?

EKO-KOM is the only authorised packaging company, so collective compliance runs through it. The Act permits individual compliance and contractual transfer as alternatives, and both are rare because an own system has to cover 90% of Czech municipalities and 90% of the population.

When do I have to register for Czech packaging EPR?

Within 60 days of first placing packaging on the Czech market. Signing a collective compliance contract covering all your packaging removes the duty to apply for the List of Entities yourself, because the scheme handles the entry.

Do I need a Czech company to register for packaging EPR?

No, and since 12 August 2026 a producer established in another EU member state selling to Czech end users has to appoint a Czech-established authorised representative under PPWR Article 45(3). Czech law adds its own mandatory case under Section 13a(2), covering distance sales of the single-use plastic packaging listed in Parts C or D of Annex 4.

Is an authorised representative optional in Czechia?

Section 13a of the Packaging Act made it optional for most packaging, and PPWR Article 45(3) overtook that for cross-border distance sellers from 12 August 2026. For producers established outside the EU, the PPWR leaves the question to each member state.

Can EKO-KOM act as my authorised representative in Czechia?

No. Section 20(10) of the Packaging Act bars the authorised packaging company from that role, so a separate party established in Czechia has to take it.

Why is sales packaging more expensive than transport packaging in Czechia?

Sales packaging carries a take-back obligation on top of the recovery obligation, while group, transport and industrial packaging carry recovery and recycling alone. The 2026 list prices industrial packaging at the group and transport rate.

When is the Czech EPR packaging report due?

The quarterly statement is due within 30 days of the quarter ending, and the annual data notification to the Ministry falls on 15 February for the previous calendar year under Section 15(1)(b). 2 other duties share that date, and EKO-KOM handles the Ministry notification and the List fee for its members.

Do I pay Czech packaging fees on packaging my supplier already paid for?

No. You record it as pre-paid and pay nothing on it. Get the supplier’s EK client number and keep the declaration on file, because the record has to hold up if an inspection asks how the packaging was accounted for.

Does exported packaging attract Czech packaging fees?

No. Packaging placed on a market outside Czechia carries no fee, and the duty to record it survives, so leaving exports out of the statement is a records breach on weight you were never going to pay for.

Is reusable packaging free in the Czech EPR system?

The 2026 price list charges reusable packaging meeting the Section 13(3) criteria at 0 CZK a tonne across every material and category. You still report the weight.

How long do I have to keep Czech packaging records?

5 years under Section 15(1)(d), and you have to be able to prove the data is true on request from the Ministry or the Czech Environmental Inspectorate.

What are the fines for Czech packaging EPR non-compliance?

Up to 10,000,000 CZK where you cannot demonstrate recovery of the statutory percentage, repeatable, and up to 1,000,000 CZK for record-keeping failures. Failing to register at all is a separate listed offence under Section 44.

Where bin2green fits

A Czech entity with a modest packaging footprint can run this in-house. The EKO-KOM registration form is short and the quarterly statement is arithmetic. If you are weighing outside help against signing with EKO-KOM alone, our comparison of a compliance service and a scheme sets out the difference.

It stops being in-house work at a few specific points:

• You are a foreign seller who needs an authorised representative: Section 20(10) bars EKO-KOM from that role, so it falls to a separate Czech-established party. That is what we do.
• Your classification has drifted: Packaging set up as sales packaging years ago and B2B ever since, sitting at roughly 19 times the rate it should. We audit that during onboarding, and it tends to be the first thing that pays for itself.
• Nobody ever asked the suppliers: Mapping paid against pre-paid across a real supply chain takes a few days once and keeps working every quarter afterwards.
• You want the number before committing to packaging design: Colour, recyclate share and reusability all move the bill, and the price list lets you model it before the tooling order goes in.
• You have been selling for years with nothing filed: Historic exposure needs handling on purpose.
• You are running Czechia and Slovakia together: 2 laws, 2 registers, and calendars that do not line up. We run both.
• You sell a boxed device with a battery in it: Packaging, WEEE and batteries are 3 registers with 3 schedules for 1 product.

Send us a year of packaging weights and we will tell you what the invoice should look like, and where it is currently wrong. Our pricing page shows what our side of it costs. Get in touch.

Sources

• Act No. 477/2001 Coll., the Packaging Act, consolidated English translation
• EKO-KOM price list valid from 1 January 2026
• The Guide of the EKO-KOM System, version 24-02
• EKO-KOM general terms and conditions, as amended from 1 July 2026
• EKO-KOM on how it sets the rates
• European Commission, statement of objections on Czech packaging waste competition, June 2024
• Czech waste information system, List of Entities for packaging
• waste information system, List of Manufacturers for electrical equipment
• ISPOP, Czech environmental reporting system
• Allegro, what waste and packaging regulations apply in Czechia
• Regulation (EU) 2025/40, the PPWR
• European Commission notice on the interpretation of the PPWR, C(2026)3702