Frequently asked questions – producers of non-packaging products

  • 1. When is a product considered a non-packaging product?

    Non-packaging product is a product (pursuant to the Art. 73 par. 3 of the Waste Act) which:

    • is not a packaging or is not intended for packing,
    • is made of:
      • plastics (6 particular types – PET, PE, PP, PS, PVC and PA,  except of raw materials, pre-forms and fibers intended for industrial use),
      • paper and paperboard including the printing products (except hygienic and sanitary paper, articles of paper used for hygiene and sanitary purposes, cigarette paper, carbon copy-paper, filtration paper, paper and paperboard for production of tarred or asphalted paper, fiscal stamps, books) or
      • glass,
    • has a potential to end up in the municipal waste.

    Thus, the obligation can apply to the importer, producer, or an entity for which the product is produced, if he knows/can identify all 3 criteria at the same time.

  • 2. How can a producer of non-packaging products ensure collection, recovery and recycling obligations?

    Regarding the non-packaging products the Act allows only one form of ensuring, namely

    • COLLECTIVELY, by means of a PRODUCER RESPONSIBILITY ORGANIZATION (so-called PRO) for packaging,

    as such products end up in the municipal waste after termination of their consumption; therefore only collective performance is acceptable. PRO for packaging ensures the fulfillment of obligations for both, packaging and non-packaging products.

  • 3. Is there an exception for small entrepreneurs in the law?

    Yes, the Waste Act allows the producer of non-packaging products who places on the market of the Slovak Republic less than 100 kg in total per calendar year to fulfill only certain selected obligations, e.g.:

    • to register in the Register of producers of reserved product and to notify about any modifications of the registered data,
    • to keep and maintain records,
    • to report the recorded data to the Ministry within the established scope and to retain the notified data.
  • 4. What if I have less than 100 kg of non-packaging products now, but will exceed the amount during the year?
    • If the producer exceeds the limit of 100 kg in the course of the year, it is necessary to sign a contract with a PRO immediately upon such discovery and to report all amounts of non-packaging products recorded during the respective year.
    • We also fulfill all obligations on behalf of all PRO NATUR-PACK's clients who place less than 100 kg of non-packaging products on the market in total per year.
  • 5. In what form is it necessary to keep records?
    • Producers shall continuously keep their own records in their company, which will enable them to fill the requested data in the PRO NATUR-PACK's system within the established scope; NATUR-PACK submits the summary report on behalf of all producers represented and retains the reported data. The record keeping can be performed by different methods, e.g.:
      • using software and keep records directly in the product data sheets,
      • recording and keeping data on production, import and export in tabular form (e.g. Excel),
      • other methods (by determining gross / net weights from the invoices, direct data retrieval from the suppliers...)
    • The records shall be kept separately for the individual reserved products (packaging / non-packaging products / electrical and electronic equipment / batteries and accumulators). Data from the records shall be reported  electronically to the PRO NATUR-PACK, on a quarterly basis.
    • Data from the records from the clients are reported to the Ministry directly by PRO NATUR-PACK.
  • 6. As a client of the PRO NATUR-PACK, do I submit a quarterly report even if I do not place any non-packaging products on the market?

    Yes, according to the valid cooperation agreement it is necessary to submit even a zero value quarterly report.

  • 7. What are the producer's fees when fulfilling obligations by concluding a contract with the PRO NATUR-PACK?
    • The NATUR-PACK system membership is free of charge.
    • The fees depend on the amounts placed on the Slovak market by the client. The fees are calculated as multiplication of the amount of products in tons / kg placed on the Slovak market and the tariff per respective commodity (without VAT). Minimum fee is 25 EUR (without VAT) per quarter, including the administrative costs, educational activities for the public and client services.
  • 8. Who controls the fulfillment of the manufacturer's obligations arising from the Waste Act?
    • 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. obligations related to the plastic carrier bags.
      • 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 (relevant for electrical and electronic equipment and batteries and accumulators).