New obligation for schools performing separated waste collection

(pursuant to the Art. 16a of the Waste Act)

Dear representatives of schools, dear representatives of the partner self-governments,

schools and school facilities * (hereinafter referred to as „schools “) have the new obligations resulting from the new regulation in the sector of waste management legislation since July 1st, 2020.


What does the new obligation mean?

Every school that performs separated collection of waste from packaging and waste from non-packaging products originated in the households (so called “school waste collection”) is obliged to notify the following:

    • data on the type and amount of the collected waste, and
    • information on the next waste holder  which received the separated collected components

(Art 16a, par. 1 of the Act No. 79/2015 Coll. on waste, as amended (hereinafter referred to as “Waste Act”).

Moreover, we would like to notice the school representatives that according to the new Art. 16a, par. 2 of the Waste Act, the selected obligations of the waste holder pursuant to the Art 14, par. 1 a) to e) of the Waste Act apply to the school.

Who does the school report data to?

The school reports data to:

    • respective municipality, and
    • producer responsibility organization for packaging (hereinafter referred to as “PRO”) with which the municipality / city has a contractual relationship regarding the performance of separated waste collection and handling.

What are the deadlines for reporting the data by the school?

The deadline for data delivery is set out to the end of respective month after finalized quarter; i.e. until April 30th for the first quarter; until July 31st for the second quarter; until October 30th for the third quarter, and until January 31st for the fourth quarter.

When has the school to perform this obligation for the first time?

The application amendment of the Waste Act (No. 460/2019 Coll.) sets out the effectiveness of this new obligation to July 1st, 2020. It means that the schools will fulfill this duty for the third quarter of the year 2020 until October 30th, 2020 (delivery to the municipality and the contractual PRO for the municipality).

*) Art. 2 x) of the Act No. 245/2008 Coll. on  education and training (“School Act”), as amended.

Where I can find the detailed conditions of the school waste collection?

More detailed conditions of waste collection in schools are available in General binding regulations on municipal waste and minor construction waste handling on the municipal territory, that can be adjusted by the municipalities according to the Art. 16a, par. 4 of the Waste Act in the respective regulation.

The legal obligations related to the school waste collection are described in the Art. 16a of the Waste Act.

Neither the law nor its implementing regulations stipulate the form for reporting the requested data. Thus, NATUR-PACK prepared for you the form that can be used for the notification. You can download the document in Word format HERE, or in PDF format HERE.

What if the founder of the school is the municipality and the school has not a legal personality (having not its identification code)?

In the case when a municipality is a founder of a school, and the school has not a legal personality, the quarterly obligations are transferred to the municipality that is obliged to report the quarterly data to the contracted PRO.

Why it is important to report these data?

The data reporting is important, as the notified waste amounts are entering:

  • the achievement of collection targets for packaging waste and waste from non-packaging products being a component of municipal waste,
  • the calculation of separation proportion in the municipality according to the Act No. 329/2018 Coll. on fees for waste deposition, as amended, while the acknowledgement of amount of waste from the school separation helps the municipalities to achieve a higher separation efficiency.


Which data are to be delivered to whom and in which time periods?

The data on production of combined waste and municipal waste from separated waste collection of packaging and non-packaging products (i.e. also from the school collection) reflecting the previous year are reported by the municipalities not only to the contracted PRO, but also to MoE SR until February 28th. The reported data serve as a basis for calculation of collection targets.

(Art. 81, par. 25 of the Waste Act, effective since January 1st, 2021)

In case of any complementary questions please do not hesitate to contact our regional manager that is located in your region.