Product stream
Non-packaging Products
A Slovakia-only EPR stream for defined non-packaging products made from specified plastics, paper and cardboard, and glass, where the resulting waste forms part of municipal waste.
This product stream exists as a separate obligation in Slovakia. It does not have an equivalent national scheme in the Czech Republic, so Czech obligations for the same goods are handled under the other streams.
A Slovakia-only stream
Non-packaging products are a specific Slovak EPR category under the Waste Act. The regime covers defined products that are not packaging or intended for packaging and fall within specified material groups, including specified plastics, paper and cardboard, and glass. The resulting waste must also fall within the municipal-waste system.
Typical examples can include household and kitchen glassware, mirrors and other glass products; plastic household, kitchen, bathroom and garden products; and paper products such as marketing and POS materials, newspapers, magazines, notebooks and writing pads. The legislation contains specific material definitions, inclusions and exclusions, so each product must be classified individually.
The expected waste route is an essential part of the assessment. If a producer can demonstrate that the relevant products will not become municipal waste — for example through a documented B2B supply and use route — the relevant quantities may fall outside the non-packaging-products regime. B2B status by itself is not sufficient. If the non-municipal waste route cannot be demonstrated, the applicable Slovak rules treat the resulting waste as municipal waste for this purpose.
Typical obligations
- Determine whether the product falls within the statutory non-packaging-products material and product scope and whether the resulting waste forms part of municipal waste.
- Identify the responsible producer for the Slovak market, including the applicable manufacturing, cross-border supply, import or distance-selling model.
- Complete the applicable Slovak producer registration and, where the full EPR regime applies, arrange collective fulfilment through a producer responsibility organisation (PRO) for packaging.
- Maintain the required quantity and material-composition data and provide the contractual PRO with the data and reports required under the applicable compliance model.
- Maintain evidence supporting any quantities claimed to fall outside the regime because the resulting waste will not form part of municipal waste.
Country requirements
Slovakia
Slovakia
Non-packaging Products are governed by the Slovak Waste Act as a separate Slovakia-only EPR stream. For producers subject to the full regime, the reserved producer-responsibility obligations are fulfilled collectively through a contractual producer responsibility organisation (PRO) for packaging.
The statutory small-volume regime applies where a producer places less than 100 kg of non-packaging products on the Slovak market in a calendar year. In that case, specified EPR obligations do not apply in the same way as under the full collective regime, while the applicable registration, evidence and direct data-reporting requirements must still be assessed and fulfilled.
Under Decree No. 371/2015 Coll., producers maintain detailed material-composition data. Under collective fulfilment, these data are provided to the contractual PRO on an ongoing basis and within the deadlines set by that PRO. PRO reporting formats may require more detailed or more frequent data than the statutory state-reporting structure. The product scope, municipal-waste test, evidence supporting any non-municipal B2B route, registration status and reporting calendar are therefore confirmed for each producer.
Frequently asked questions
Do your non-packaging products obligations apply in Slovakia?
Tell us what you sell and where you sell it. We will come back with the obligations that actually apply — per country and per product stream.