Frequently asked questions – producers of non-packaging products
1. Leaflets, business cards, invoices, ... are they non-packaging products?
It is necessary to consider if the product has a potential to end-up in the municipal waste or not. However, this product shall not become a part of the municipal waste immediately. If the producer of the non-packaging products is not able to demonstrate that such non-packaging products will not become a part of the municipal waste at the end of their life-cycle, waste from such products is considered to be a part of the municipal waste.
a) If the entrepreneur prints-out the leaflets / invoices/ business cards on the commonly available paper size on its own office printer, do they belong to the non-packaging products?
In such case the leaflets / invoices / business cards are not considered to be non-packaging products with no regard to the fact that they have a potential to end-up as a part of the municipal waste. The reason is that the office paper as such is considered to be a non-packaging product, therefore the obligation is fulfilled by the producer / importer of this office paper.
b) If the entrepreneur asked a printing company to print leaflets / business cards… are they considered to be a non-packaging products?
In such case it is necessary to determine whether such products have a potential to end-up as a part of the municipal waste, i.e. whether they are intended for use by public. If so, such products will be considered to be a non-packaging products.
2. How to register into the Register of producers of non-packaging products?
The producer of the non-packaging products is obliged to ask the Ministry for the registration into the Register of Producers of Non-packaging Products before placing the products on the market.
The format for this application is attached to the Annex No. 4 to the Regulation No. 373/2015 Coll. on the Extended Producer Responsibility of the Producers of Specified Products and on Management of the Specified Waste Streams.
Signing-up the cooperation agreement on fulfillment of the producers obligations with the PRO NATUR-PACK means that the registration is ensured by the company NATUR-PACK on behalf of the producer.
3. How can the producer of non-packaging products ensure the waste collection, recovery and recycling obligations?
The Act allows only one possibility of ensuring the obligations regarding the non-packaging products and it is COLLECTIVELY, by means of a PRODUCER RESPONSIBILITY ORGANIZATION (so called PRO) for packaging as these products will end-up at the end of their life cycle as a part of the municipal waste, thus, only collective fulfillment is allowed. PRO for packaging ensures fulfillment of the obligations for packaging as well as non-packaging products.
4. What obligations result from joining the NATUR-PACK system for the producer of non-packaging products towards the PRO NATUR-PACK?
The producer of non-packaging products according to the Waste Act is obliged to deliver to the PRO complete and true data and information necessary for the proper performance of the delegated obligations, and also to reimburse the expenses resulting from the performance of these obligations.
The PRO NATUR-PACK ensures for its clients, in addition to the submission of the application to the Register, also the notification of modifications of data included in the application to the Register to the MoE SR not later than 30 days after modification occurs. Thus, it is important that our client will inform us about such modification without delay.
Moreover, a producer of non-packaging product submits to the PRO NATUR-PACK the quarterly information on the quantity of the non-packaging product that he placed on the SR market. On the basis of the quarterly report on the quantity of the non-packaging products he will pay a quarterly remuneration to the PRO. The amount of such payment results from the reported quantity of the non-packaging products and the unit fees for the individual commodities. The fees are based on the actual expenses related to the collection and processing of the waste from non-packaging products.
The PRO NATUR-PACK further ensures collection, transport, recovery and recycling of the necessary amount of the waste from non-packaging products, and on the basis of these quantities it elaborates the annual report for the Ministry.
Education activities and awareness campaigns for the end users form an integral part of the delegated obligations, and the PRO NATUR-PACK will certainly ensure them also.
5. What ensures the PRO NATUR-PACK for the represented producers?
The PRO NATUR-PACK ensures the performance not only of the reserved obligations for its represented producers, but also e.g.:
- Application for the registration in the Register of the Producers of Non-packaging Products and notification of changes,
- Keeping of evidence,
- Collection, recovery and recycling of the waste from the non-packaging products to the full extent, minimally to the amount of the collection share,
- Market proportion and collection share,
- Elaboration and delivery of the report based on the evidence of ensured recovery and recycling to the MoE SR,
- Information to the consumer, education activities and awareness campaigns,
- Advisory services in the sector of the EPR for non-packaging products.
6. Does the Act defines any exceptions for small producers?
The Waste Act does not define any limit where the Act should not apply. However, a limit is stipulated for which only certain obligations apply for the producer, and this limit is defined as 100 kg of the non-packaging products per year, e.g.:
- to be registered in the Register of the Producers of Reserved Products and to notify the potential changes of the registered data,
- to keep and to maintain the evidence,
- to report to the Ministry data from evidence in the defined extent and to keep the reported data.