Frequently asked questions – packaging producers

The term producer is defined by the Waste Act as an entity that:

· packs or fills products into packaging

· orders the packaging of the product that it markets in the Slovak Republic under its trademark

· imports to Slovakia products / raw materials for production / components packed in a packaging

· provides packaging for immediate packing to the consumer or packs the distributed goods into such packaging itself

· manufactures or imports empty packaging intended directly for the consumer.

· A producer is obliged to keep records of all packaging used for packing of goods, their protection.

· Meets the criteria listed in the appendix No. 7 of the Waste Act.

· Also Non-returnable components of packaging used for identical purposes are also considered packaging.

Information video is available HERE

• Producers have to continuously keep their internal records at their companies so that it is possible to fill in the required data from it in a defined extent in the system of the PRO NATUR-PACK, which submits the summary reports on behalf of all producers represented and keeps the reported data. TThe record keeping can be performed by different methods, e.g.:
   
  • detailed records directly in the data sheets of the products by application of a software,
  • recording and maintaining of production, import and export evidence in tables (e.g. Excel),
  • other methods (by determining gross/net weights from invoices, data retrieved directly from suppliers...).
• Record are to be kept separately for reserved products (packaging / non-packaging products / electric and electronic equipment / batteries and accumulators), and subsequently data from evidence are electronically reported on a quarterly basis directly to the PRO NATUR-PACK.
• Data from evidence from clients are reported to the Ministry directly by the PRO NATUR-PACK.

A manufacturer can choose the evidence keeping method which suits to him; it is important it will allow for filling requested data in a defined extent in the system of the PRO NATUR-PACK, which is submitting the summary report on behalf of all represented manufacturers and keeps the recorded data. If the manufacturer (a PRO NATUR-PACK  client) is not able to deal with the evidence, he can address the assigned sales manager who will recommend an appropriate method for evidence keeping respecting the reserved products and company profile. However, such recommendation is not binding for a company.

Yes, in compliance with the cooperation agreement it is necessary to submit quarterly even a zero report.

• Membership in the NATUR-PACK system is free of charge.
• Amount of fees depends on the amount of packaging placed on the Slovak market by the client. The fee is calculated as the amount of products in tons / kg, placed on the Slovak market, multiplied by the tariff for respective commodity (VAT exempt). Minimum fee is 25 EURO (VAT exempt) per a quarter, including administrative costs and client services.

• Obligations  for products are transferred to you if the supplier from which you purchase the products is not registered in the Register of Producers.
• You can check the suppliers in the register managed by the Ministry of Environment on the web-page HERE.

Labelling of packaging products is not obligatory according to the Waste Act! However, if you will decide to label the packaging, you have to do it in compliance with the Act, i.e.:

• If you decide to label the packaging regarding its material composition, you shall do it in compliance with a special regulation – Commission Decision 97/129/EC from 28 January 1997, setting out the identification system for packaging materials pursuant to the Directive of European Parliament and Council 94/62/EC on packaging and packaging waste (Special edition of the Official Journal of the EU chapter 15/vol. 3, Official Journal of the European Union ES L 50, 20 February 1997) – options of graphical labelling is available also in the Annex No. 14 of the MoE SR Regulation No. 373/2015 Coll.
• labelling according to the previous paragraph must be visible and easily legible and must be reasonably permanent and still after opening the package,
• the packaging can also be marked with information on how to handle it (Annex No. 14 of the EPR Regulation No.373/2015)

Information video is available HERE

For packaging, the Act allows for two methods, namely:

• INDIVIDUALLY, by creation of an individual packaging waste handling system – this option is allowed only if the manufacturer is able to declare that his packaging waste will not end up in the municipal waste! Further, authorization for the individual performance of obligations shall be granted to him by the MoE SR. The Act does not address the specific form of proof.
• COLLECTIVELY, by means of an PRODUCER RESPONSIBILITY ORGANIZATION (so called PRO) for packaging.

PRO for packaging ensures performance for both, packaging and non-packaging products on the basis of authorization granted by the Ministry of Environment.

Yes, the Act allows the packaging manufacturer who places on the market of the Slovak Republic totally less than 100 kg per calendar year to fulfill only selected obligations, e.g.:

• to register in the Register of manufacturers of reserved products and to notify changes of the registered data,
• to record and keep evidence,
• to notify the Ministry the data from evidence in the established scope and to keep the notified data.

• If the manufacturer will exceed the limit 100 kg during a year, a contract shall be agreed with a PRO immediately after such finding and the report the amounts of evidenced packaging per respective year.
• On behalf of our clients who place on the market less than 100 kg of packaging per year in summary we in PRO NATUR-PACK fulfill all corresponding obligations.

No, the Act does not allow it. You are obliged to involve into report amounts of all packaging you produce, regardless where the waste will be generated and how the waste producer handle it.

• Ministry of Environment and Slovak Environmental Inspection are the control authorities.
• State administration in waste management is also carried out by:
  • Slovak Trade Inspection, state supervision authority in the waste management for controlling of compliance with certain legal obligations of the Waste Act, e.g. obligations related to plastic carrying bags.
  • Customs Office and Criminal Office of Financial Administration (state administration authorities for taxes, fees and customs) in cross-border movement of waste by road transport (concerning electric and electronic equipment, and batteries and accumulators).