EPR Obligations EU → 🇨🇿 Czech Republic
EPR in the Czech Republic 2026: Packaging, WEEE & Batteries
The Czech small-producer exemption no longer applies since 12 August 2026, authorized representatives report to EKO-KOM, and the Green Dot goes digital-only after 12 February 2027.
Last reviewed: · Sources linked below
Short answer: if you sell packaged goods to Czech end users, the EU Packaging Regulation (PPWR) applies to you since 12 August 2026. According to the Czech Ministry of the Environment (MŽP), the national small-producer exemption in § 15a of the packaging act no longer applies from that date. Distance sellers established in another country must appoint an authorized representative under Art. 45 PPWR, and authorized representatives report to EKO-KOM, the Czech packaging scheme.
Czech Republic at a glance
- Packaging register / scheme(s)
- EKO-KOM; authorized representatives report to EKO-KOM (MŽP, 19 Oct 2026).
- Authorized representative
- Required for distance sellers selling directly to Czech end users under Art. 45 PPWR (EU or non-EU established).
- WEEE
- Separate producer-responsibility regime; representative rules for foreign sellers not confirmed in our sources – we check the current route for you.
- Batteries
- EU Battery Regulation EPR regime applies since 18 Aug 2025; Czech representative rules not confirmed in our sources.
- Thresholds
- The § 15a small-producer exemption (up to 300 kg and up to CZK 25 million turnover) no longer applies from 12 Aug 2026.
- Penalties
- Czech penalty amounts are not confirmed in our sources; PPWR penalty rules are due EU-wide by 12 Feb 2027.
- Marketplace checks
- Amazon announced EU-wide packaging EPR compliance from 12 Aug 2026; eBay requires numbers per country and may hide listings.
- What changed in 2026
- PPWR applies; § 15a exemption ends; Green Dot only via QR/digital marking after 12 Feb 2027; national amendment proposed.
- What changed in 2026
- Packaging
- Green Dot
- WEEE
- Batteries
- Authorized representative
- Deadlines
- Penalties
- FAQ
What changed in 2026
On 19 October 2026 the Czech Ministry of the Environment (Ministerstvo životního prostředí, MŽP) published a methodological communication on selected areas of the EU Packaging Regulation (EU) 2025/40. It answers the questions most foreign sellers have about the Czech market after 12 August 2026.
| Topic | Position of MŽP (19 Oct 2026) |
|---|---|
| Small-producer exemption (§ 15a) | No longer applies from 12 Aug 2026 (previously up to 300 kg of packaging and up to CZK 25 million turnover) |
| Authorized representatives | Report to EKO-KOM |
| Green Dot | Only via QR code or digital marking after 12 Feb 2027 |
At EU level, the PPWR entered into force on 11 February 2025 and applies from 12 August 2026. The European Commission has asked member states to enforce the representative duty "in a constructive and pragmatic" way while an exemption is negotiated.
Proposal – not yet law Czech packaging-law amendment: a national amendment is proposed under which the register would be kept by the scheme and collective compliance would become mandatory. It has not been adopted.
Proposal – not yet law EU omnibus: the Council position of 21 October 2026 would exempt EU-established producers placing under 1 tonne of packaging per year in another member state from the representative duty until 2032; the Parliament adopted its position on 20 October 2026. It does not cover non-EU sellers. More: PPWR 2026 update.
Packaging obligations in the Czech Republic
A packaging producer is the business that first makes packaging available on the Czech market. A seller established elsewhere who ships packaged goods directly to Czech end users is a distance seller under the PPWR and the producer of that packaging, including shipping cartons and filling material.
The end of the § 15a exemption matters most for small cross-border sellers: a low volume of packaging is no longer, by itself, a reason to stay out of the system.
- Map your Czech packaging. Record every type of packaging that reaches Czech customers, by material and weight.
- Check your status. If you were relying on § 15a (up to 300 kg and up to CZK 25 million turnover), re-assess: MŽP says the exemption no longer applies from 12 August 2026.
- Appoint an authorized representative if you are a distance seller. Art. 45 PPWR requires one in each member state where you first make packaging available, other than your own.
- Set up reporting with EKO-KOM. According to MŽP, authorized representatives report to EKO-KOM.
- Review your labels. Plan the switch of the Green Dot to QR code or digital marking before 12 February 2027.
Contract details, reporting intervals and fees depend on your packaging and should be confirmed with EKO-KOM. We check the current route for you.
Green Dot: digital only after 12 February 2027
According to MŽP, after 12 February 2027 the Green Dot may only be used via a QR code or digital marking. If your packaging still carries a printed Green Dot for the Czech market, include this in your next artwork update.
EU-harmonised packaging labelling under the PPWR is expected from 12 August 2028, or 24 months after the implementing acts – these acts had not been adopted as of September 2026.
WEEE obligations (electrical and electronic equipment)
Electrical and electronic equipment is covered by a separate producer-responsibility regime from packaging. Our verified sources do not yet confirm whether foreign distance sellers need a Czech authorized representative for WEEE, or which penalties apply. We do not guess: as part of the free obligation check, we confirm the current registration and representative route for your products.
Battery obligations
Batteries are governed EU-wide by the Battery Regulation (EU) 2023/1542, whose EPR regime applies since 18 August 2025. Czech representative rules for batteries are not confirmed in our sources; we check them for you.
- From 18 February 2027 (reported): QR code on all batteries, removability and replaceability rules, and a battery passport for EV, LMT and industrial batteries above 2 kWh.
- 18 August 2027 (reported): due-diligence obligations, postponed by Regulation (EU) 2025/1561.
- Proposal – not yet law The EU Omnibus would also suspend the batteries representative duty; Parliament voted on 20 October 2026, the Council position is pending.
Authorized representative in the Czech Republic
An authorized representative is a business that fulfils a producer's EPR obligations in a member state on behalf of a producer established elsewhere. Under Art. 45 PPWR, producers who sell packaged products directly to end users in another member state – whether EU or non-EU established – must appoint one in each member state where they first make packaging available, other than their own. For the Czech Republic, MŽP confirms that authorized representatives report to EKO-KOM.
How Certify helps
- Free obligation check. Tell us what you sell, how much packaging reaches Czech customers and through which channels.
- Route mapping. We map your packaging, WEEE and battery duties and check the current route with EKO-KOM and the authorities.
- Representation. Certify can act as your authorized representative and coordinate reporting – also in the other EU countries you ship to.
More on the role: authorized representative explained (register-epr.com).
Deadlines relevant for the Czech Republic
| Date | Scope | What happens | Status |
|---|---|---|---|
| 18 Aug 2025 | EU batteries | EPR regime of the Battery Regulation applies | Confirmed |
| 12 Aug 2026 | EU / Czech Republic | PPWR applies; § 15a small-producer exemption no longer applies | Confirmed |
| 12 Feb 2027 | Czech Republic | Green Dot only via QR code or digital marking | Confirmed |
| 12 Feb 2027 | EU | Member-state PPWR penalty rules due | Reported |
| 18 Feb 2027 | EU batteries | QR code, removability, battery passport (EV/LMT/industrial >2 kWh) | Reported |
| Pending | Czech Republic | National packaging-law amendment Proposal – not yet law | Proposal |
All countries in one view: EPR deadline calendar 2026–2027.
Penalties in the Czech Republic
We have not been able to verify current Czech penalty amounts for packaging, WEEE or battery breaches from official sources, so we do not quote figures. EU-wide, member states must lay down PPWR penalty rules by 12 February 2027.
The more immediate commercial risk is on marketplaces: Amazon may need to stop selling non-compliant products, and eBay may hide listings where the required EPR number is missing.
Frequently asked questions – EPR in the Czech Republic
Does the Czech small-producer exemption still apply?
No. According to the Czech Ministry of the Environment (MŽP), the § 15a exemption for small producers (up to 300 kg of packaging and up to CZK 25 million turnover) no longer applies from 12 August 2026.
Who do authorized representatives report to in the Czech Republic?
According to MŽP's methodological communication of 19 October 2026, authorized representatives report to EKO-KOM.
Can I still print the Green Dot on packaging for the Czech market?
According to MŽP, after 12 February 2027 the Green Dot may only be used via a QR code or digital marking. Plan the artwork change before that date.
Do foreign online sellers need an authorized representative in the Czech Republic?
Under Art. 45 PPWR, producers who sell packaged products directly to end users in another member state, whether EU or non-EU established, must appoint an authorized representative in each member state where they first make packaging available, other than their own. This includes the Czech Republic.
Is the Czech packaging law changing?
A national amendment is proposed under which the register would be kept by the scheme and collective compliance would become mandatory. It is a proposal and not yet law.
What are the penalties in the Czech Republic?
We have not verified current Czech penalty amounts from official sources, so we do not quote figures. Member states must lay down PPWR penalty rules by 12 February 2027.
- MŽP – Metodické sdělení k vybraným oblastem nařízení EU 2025/40 (19 Oct 2026, PDF)
- EUR-Lex – Regulation (EU) 2025/40 (PPWR)
- European Commission – EPR for packaging and small businesses
- Council of the EU – press release of 21 October 2026
- eBay – Packaging and Packaging Waste Regulation
This page is general information, not legal advice. Last reviewed 27 October 2026.
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