Extended producer responsibility

What it means

Extended producer responsibility puts the waste phase of a product onto whoever first places it on the Slovak market: collection, transport, recovery and recycling, paid for by them. It covers packaging, non-packaging products, electrical equipment, batteries, tyres and vehicles.

A producer in this sense is not only someone who manufactures. An importer is one, and so is any e-shop that buys goods abroad and sells them here: the packaging the goods arrived in was placed on the market by them, not by their supplier.

It is not to be confused with the duties of a waste producer. A business that generates waste in its own operations, such as packaging from raw materials or scrapped equipment, handles its disposal and records as the waste producer; extended producer responsibility concerns the products the business sends on to the market, and funds their future collection from someone else.

How it works in practice

The duties are met by contracting a producer responsibility organisation, which arranges collection and reports it to the state on the company’s behalf; individual compliance is a rare exception. Before the first delivery the company must be entered in the register of producers kept by the environment ministry.

The company records the quantities placed on the market in kilograms by material and reports them at the agreed intervals. The fee to the organisation is an ordinary operating cost; passed on to the customer it becomes a recycling fee in the price, not a tax. The same figures resurface in ESG reporting and in customer questionnaires.

When vetting a client we also look for the less obvious cases. A company that has electrical equipment made by a subcontractor and sells it under its own brand is the producer, although it manufactures nothing itself, and a company that packs goods in its own packaging places that packaging on the market.

What to watch out for

The classic e-shop mistake is assuming a foreign supplier has already dealt with the packaging. It has not, because the importer placed it on the Slovak market, and the environmental inspectorate fines retrospectively while the unreported years still have to be paid to the organisation.

The opposite mistake is just as costly: a company also reports the packaging of goods bought from a Slovak supplier that has already placed it on the market and paid for it. The recycling fee is paid twice, and an overpayment for past periods is hard to recover from the compliance organisation, if it can be recovered at all.