FAQ

  • 1. When do I have to register the company in the Register of producers of electrical and electronic equipment (EEE)?

    Producer of electrical and electronic equipment which is not listed in the Register of producers of electrical and electronic equipment may not introduce electrical and electronic equipment to the Slovak market. It is therefore necessary to apply for registration in this register even before the placing of electrical and electronic equipment on the market, i.e. before the import / production itself. NATUR-PACK performs such registration automatically after signing the agreement with the producer.

  • 2. We have started importing a new range of EEE which is not among our currently registered categories, how should we proceed?

    In case the producer starts importing electrical and electronic equipment not listed in the categories of his electrical and electronic equipment registered so far, it is necessary to register them. Additional registration will be done by the producer via web-page of NATUR-PACK in the section „For members“, where the client logs in and mark the new category of electrical and electronic equipment. Subsequently NATUR-PACK will ensure notification of this change to the Register of producers of electrical and electronic equipment.

  • 3. When, where and in how is it necessary to state the recycling fee at the time of sale?

    Producer of electrical and electronic equipment is obliged upon sale to display on its packaging, label or on a tax or other similar document drawn up during its sale the amount of recycling fee. This obligation applies only to so-called „household electrical and electronic equipment“. The amount of the recycling fee must not exceed the best estimate of the actual costs of collection, transport and processing of waste from electrical and electronic waste from households. The recycling fee must be displayed in a visible way throughout the entire distribution chain.

  • 4. How to display the recycling fee when selling electrical and electronic equipment?

    It is up to the producer how to state the recycling fee. He can involve it into the price of the electrical and electronic equipment with following information on its amount incorporated into the price of the electrical and electronic equipment or he can show the price of the electrical and electronic equipment and the amount of recycling fee separately.

  • 5. Am I obliged to state the recycling fee when selling, even if I am only an EEE distributor in Slovakia?

    Yes, as a distributor of electrical and electronic equipment you are obliged to display the recycling fee when selling electrical and electronic equipment, if it was specified by the producer of electrical and electronic equipment.

  • 6. How do I find out the amount of the recycling fee?

    The recycling fee amounts for the NATUR-PACK clients are determined in the contract on fulfillment of obligations of the electrical and electronic equipment producer.

  • 7. How do I fill in the report for EEE (Total weight of a specific group of EEE and number of pieces, or weight of one piece of EEE and number of pieces)?

    Report on electrical and electronic equipment is filled in with a sum of total mass of particular group of electrical and electronic equipment in kilograms (kg) and total number of electrical and electronic equipment pieces (pcs) in particular group.

  • 8. What is considered electrical and electronic equipment?

    Electric and electronic equipment means devices which need an electrical current or an electromagnetic field for their operation. You can find more detailed definitions including exceptions HERE.

  • 9. I only import occasionally/a little, what fee will I pay?

    Membership in the NATUR-PACK system is free of charge. The amount of fess depends on the amount of electrical and electronic equipment placed on the Slovak market by the client. The fee is calculated as multiplication of EEE amount per category placed on the market during the respective quarter and recycling fee (tariff) determined in the contract. Minimum fee is 25 EUR (without VAT) per quarter, and it includes administrative costs and client services.

  • 10. What other obligations do I have as an EEE producer apart from registration?

    You can find information on the basic obligations of a producer of electrical and electronic equipment HERE.

  • 11. Who controls the fulfillment of the obligations of the producer/distributor of EEE in the company?

    Ministry of Environment SR and Slovak Environmental Inspection are the control authorities. State administration in the sector of the waste management is performed also by:

    • Slovak Trade Inspection, a state supervisory authority in the waste management sector controlling the performance of certain obligations of the Waste Act, e.g. obligation to label the electrical and electronic equipment and to display the recycling fee.
    • Customs Office and Criminal Office of Financial Administration (state authorities for taxes, fees and customs) for the cross-border movement of waste via road transport, e.g. for cross-border movement of the electrical and electronic equipment which is not waste.
  • 12. I am not a producer of electrical and electronic equipment (EEE), I only have a shop; do I have to be registered in the register of producers?

    “Producer of electrical and electronic equipment” pursuant to the Waste Act No.79/2015 Coll. means every natural person – entrepreneur or legal entity who:

    a) has its registered office or place of business in the territory of the Slovak Republic and produces electrical and electronic equipment under its own name or trademark;

    b) has its registered office or place of business in the territory of the Slovak Republic and repeatedly sales under its own name or trademark in the territory of the Slovak Republic electrical and electronic equipment produced by different suppliers;

    c) has its registered office or place of business in the territory of the Slovak Republic and places on the market of the Slovak Republic in the framework of business activities electrical and electronic equipment from another state;

    d) sells electrical and electronic equipment in the territory of the Slovak Republic by means of remote communication and has its registered office or place of business in another state;

    e) has its registered office or place of business in the territory of the Slovak Republic and on the basis of a contract concluded at a distance sells electrical and electronic equipment directly to the user in another EU member state.

    So even if you do not manufacture electrical and electronic equipment, but import it from abroad and then sell it, you are considered a producer of electrical and electronic equipment. The same applies even if you run an online store. The obligations of a producer apply to you also in case when you provide electrical and electronic equipment to the end user who is not enlisted in the Register of producers of electrical and electronic equipment.

  • 13. If I import EEE for my own use, do I have to be registered in the register of EEE producers? Do I have to submit an annual report for these EEEs? Do I have an obligation only for EEE for household purposes or also for business purposes?

    The obligations apply to the electrical and electronic equipment for households as well as for business purposes. If a producer imports EEE for his own business purposes, he must fulfill the legal requirements set out in the Art27 par. 7 of the Act (especially to have the electrical and electronic equipment in his possession during its entire lifespan), and only certain obligations of producer apply to him, e.:

    • To be registered in the Register of electrical and electronic equipment producers,
    • To notify modifications of the registered data,
    • To ensure material composition, construction and labelling of the electrical and electronic equipment,
    • To record and retain evidence and to submit to the Ministry the annual report until 28 February of the following calendar year,
    • To ensure handling of the generated waste at least in the extent of the legally established limits.
  • 14. If I produce EEE and subsequently export it outside the territory of the Slovak Republic, do I have to be registered in the register of EEE producers?

    Yes, we recommend registering even in this case.

  • 15. How do I determine if EEE falls into the household use category?

    Pursuant to the Waste Act No.79/2015 Coll., waste electrical and electronic equipment from households means waste EEE originating from households and from trade, industrial, institutional and other resources which is similar to that waste originating from households in its character and amount. Waste from electrical and electronic equipment that is likely to be used by households and non-household users is always considered household electrical waste.

    Thus, if it is commonly available electrical and electronic equipment which can appear in the households, like personal computer, telephone, television, light resources, refrigerator and other commonly available EEE, such EEE are consider as household electrical and electronic equipment even if they are installed in the premises of legal entities and they can serve them for the performance of their business activities.

  • 16. How do I categorize EEE?

    A producer classifies his electrical and electronic equipment pursuant to the Waste Act No. 79/2015 Coll. into six categories listed in the Annex No. 6, pat II. of the above Act. In order to fill in the quarterly report for NATUR-PACK it is necessary to classify the equipment in more detail into the individual categories according to the sample shown in the contract agreement. The producer himself is responsible for the classification of electrical and electronic equipment into the appropriate categories. Correct classification of electrical and electronic equipment into the categories and further to the price list for electrical and electronic equipment by the client – producer can be assisted by the appointed sales manager of NATUR-PACK, a.s.

  • 17. When do I report EEE in the quarterly report for NATUR-PACK when I import/purchase or sell them?

    Electric and electronic equipment is reported in the time of their placing on the SR market. The producer can choose whether to keep records of imports/purchases or sales. As long as the producer only imports he can operate on imports, i.e. purchase. If he also exports out from the Slovak Republic, it is preferred to operate on sales (i.e. the real sales abroad and in Slovakia during the given quarter). Purchase records mean that the producer involves the purchased electric and electronic equipment into evidence in the time of their purchase. In contrary, records by sales mean that the producer registers only electric and electronic equipment as sold products during the given period.

  • 18. How does EEE re-collection work, where do I report re-collection and what are the fees?

    After accumulation of waste of the electrical and electronic equipment by re-collection from citizens the client shall submit a request for transport by filling and delivery of the form on the web-page HERE.

    Subsequently, the client will be contacted to arrange a pick-up date.

    Such transport is free of charge for the producers who signed the contract with our company.

  • 19. How does the invoicing work regarding re-collection?

    In the framework of the quarterly invoicing, 0.02 € is deducted from the invoiced amount for electrical and electronic equipment per each kg of delivered waste EEE from re-collectionThis deduction is pre-conditioned by identical categories of the electrical and electronic equipment, i.e. delivered waste EEE shall belong to the same category as contained in the invoice for electrical and electronic equipment. Minimum invoiced amount after such deduction is 25 € without VAT.