Basic obligations

Packaging means a product which is used for packing the goods, their protection, handling, supply and presentation, from raw materials to products, from producer to user or consumer, and which fulfills the criteria listed in the Annex No. 7; also non-returnable components used for the identical purposes are also considered packaging.

More detailed division of packaging

Placing of a packaging product on the market in the Slovak Republic means a moment when a packaging or a product packed therein passes for a fee or free of charge from the manufacture phase, cross-border transport from another Member State to the Slovak Republic or import from non-EU countries to the Slovak Republic to the distribution phase or use.

Reusable packaging is a packaging designed, constructed and placed on the market of the Slovak Republic to overcome at least two trips or rotations during its life cycle, which is repeatedly filled or repeatedly used for the identical purpose for which it was intended; such packaging will become packaging waste when no longer subject to reuse, by the moment of its disposal.

Reusable packaging is counted into the quantity of packaging placed on the market or distributed by its producer only once, at the time of their first placing on the market in the Slovak Republic (they are no longer reported upon subsequent use); this is not relevant in case of reusable wooden pallets (e.g. EUR pallets) that are counted as packaging as late as they become waste.

ATTENTION!  Single-use wooden pallets, as well as other wooden packaging, plastic or metallic pallets and transport boxes are recorded as before, i.e. in the time of their first use!

Packaging producer (Art. 52 par. 11) is a natural person – entrepreneur or legal entity, who:

  1. uses packaging for packing the goods, or fills goods to the packaging and places such goods on the market under his own trade mark,
  2. is a person for whom the goods are packed or filled and under whose trade mark the goods are placed on the market,
  3. places packed goods on the market in a manner other than referred to in a) and b), or transports or asked another subject to transport the goods in packaging across the border of the Slovak Republic and places it on the market or distribution in the Slovak Republic,
  4. as a distributor delivers packaging (for a fee or free of charge) to the end user for direct packing of goods,
  5. uses the packaging as a distributor for packing the distributed goods or parts thereof, or for filling it with the distributed goods, or
  6. places packaging on the market, except a person who supplies unused empty packaging to the persons referred to in a), b), c) d) or e), or to the person who packs or fills goods for a person referred to in b).

Packaging producer:
a) uses packaging for packing the goods, or fills goods to the packaging and places such goods on the market under his own trade markPACKER/FILLERpacks or fills goods to the packaging under his own trade mark
(Art. 52, par. 11 a) of the Act)
b) is a person for whom the goods are packed or filled and under whose trade mark the goods are placed on the marketTRADE MARKorders packing of goods that he places on the market under his own trade mark
(Art. 52, par. 11 b) of the Act)
c) places packed goods on the market in a manner other than referred to in a) and b), or transports or asked another subject to transport the goods in packaging across the border of the Slovak Republic and places it on the market or distribution in the Slovak Republic.IMPORT / PACKING WITHOUT TRADE MARKimports to Slovakia products/ goods packed in packaging, or fills goods to packaging without trade mark
(Art. 52, par. 11 c) of the Act)
d) as a distributor delivers packaging (paid or unpaid) to the end user for direct packing of goodsSALES POINT THAT SUPPLIES PACKAGING
(bag for fruits, carrier bag, ...)
offers packaging to the consumer for direct packing
(Art. 52, par. 11 d) of the Act)
e) uses the packaging as a distributor for packing the distributed goods or parts thereof, or for filling it by the distributed goodsSERVICE PACKAGING
(delicatessen – plastic cup...)
packs himself/directly the distributed goods into such packaging
(Art. 52, par. 11 e) of the Act)
f) places packaging on the market, except a person who supplies unused empty packaging to the persons referred to in a), b), c) d) or e), or to the person who packs or fills goods for a person referred to in b)IMPORTER/PRODUCER OF EMPTY PACKAGING FOR THE CONSUMER
– not direct packing (bags, glass bottles for preserved meals...)
produces/imports empty packaging intended direct to the consumer
(Art. 52, par. 11 f) of the Act)

Basic obligations for packaging

A company that is considered a packaging manufacturer has the following selected obligations:

  • to be registered in the Register of producers of packaging products maintained by the Ministry of Environment and to notify about any change of the registered data (https://www.isoh.gov.sk/uvod/zivotna-situacia-registracia.html ),
  • to keep and retain records and to notify the Ministry in a defined extent and to retain the notified data,
  • to fulfil the information obligation in relation to the public and to the processing facility for the reserved waste stream in compliance with the special section of this part of the Act
  • to bear all financial expenses related to the collection, transport, preparation for reuse, recovery, recycling, processing or disposal of separately collected waste belonging to the reserved waste stream.

In the PRO NATUR-PACK we perform all above obligations of the packaging manufacturer on behalf of all our clients on the basis of a signed contract on fulfillment of reserved obligations.

How to comply with the obligations of the packaging manufacturer? (Only by one of the following procedures)

Individually – in case the manufacturer proves that the products placed on the market will not end up in municipal waste (i.e. by the citizen); the individual fulfillment requires authorization

Collectively – by means of a Producer Responsibility Organization, having an authorization by the Ministry of Environment; fulfillment of the obligations by means of NATUR-PACK is possible after signing a contract HERE

Separately – in case when the manufacturer will place on the SR market less than 100 kg of all packaging products per year.

Cooperation with the PRO NATUR-PACK on the basis of undersigned contract

The quarterly report serves for the delivery of data on the amounts of packaging placed on the market by the client of PRO NATUR-PACK during the preceding quarter. The report is delivered electronically by the 10th day after termination of the preceding quarter.

We alert our clients to the report delivery obligation by an automatic system message and by phone.

The client is obliged to:

  1. Record the amounts of packaging placed on the market
  2. Report the amount from its records to NATUR-PACK's system, electronically on a quarterly basis, section For members https://vykazy.naturpack.sk/
Deadlines for delivery of quarterly reports
Report coveringFrom *To
1st quarter1 April10 April
2nd quarter1 July10 July
3rd quarter1 October10 October
4th quarter1 January10 January

* possibility to submit the report until the 15th day of the preceding month