EKO-KOM: When do you have to register packaging and pay fees?
EKO-KOM: when do you have to keep packaging records and pay fees?
If your business uses packaging, imports goods from abroad, packs takeaway food or sells products in packaging, you may be required to keep packaging records and participate in the EKO-KOM system.
What is EKO-KOM?
EKO-KOM is an authorised packaging company that operates the collective compliance system for take-back and recovery obligations for packaging waste in the Czech Republic. In practice, it is a system through which companies contribute to sorting, collection and recycling of packaging.
Who has to keep packaging records?
The obligation may apply to businesses that place packaging or packaged products on the market or into circulation in the Czech Republic. The most common situations include:
Import from abroad
You import packaged goods, packaging or packaging materials into the Czech Republic.
Packing goods
You pack takeaway food, use packaging for customers or re-pack products.
Sale and distribution
You resell packaging, place it on the market under your own brand or as part of distribution.
In practice, this obligation may apply to restaurants, bistros, cafés, e-shops, food manufacturers, importers, distributors and wholesalers.
When does the obligation begin?
The obligation arises when you first place packaging or a packaged product on the market or into circulation in the Czech Republic. From that moment, you need to deal with registration, packaging records, regular reports and payment of the relevant fees.
Obligation arises
You start importing, packing, re-packing or selling packaging or packaged products in the Czech Republic.
Registration
The most common solution is to conclude a contract with the authorised packaging company EKO-KOM.
Packaging records
You keep records by material, weight, packaging type and period.
Report and payment
You submit regular reports and pay fees according to the amount of packaging.
Exemption for small businesses
The obligation to register, keep records and pay fees may not apply to small businesses if they meet both conditions below at the same time.
Does this apply to your business?
Below is a quick overview of the most common situations in food service, e-shops, manufacturing and wholesale.
| Activity | EKO-KOM obligation | Note |
|---|---|---|
| You import packaged goods from abroad | Yes | Typically, you are the person placing the packaging on the market in the Czech Republic. |
| You pack takeaway food in disposable packaging | Yes | For example menu boxes, bowls, cups, bags or pouches. |
| You re-pack goods or use your own label | Yes | This may mean placing packaging into circulation under your business activity. |
| You sell goods for which the fee has already been paid | Usually not | It is advisable to have proof that the supplier fulfilled the obligation. |
| You are under 300 kg of packaging and under CZK 25 million turnover | No | Applies only if both limits are met at the same time. |
How do you know that the packaging fee has been paid?
If you buy packaging from a supplier, it is important to have clear proof that the packaging fee has been handled in the EKO-KOM system. A logo on the packaging alone may not be sufficient proof.
Information on the invoice
The supplier may state that the packaging fee has been paid, or include the EKO-KOM contract number.
Supplier declaration
You can request confirmation that the fee for the specific packaging has been paid in the EKO-KOM system.
Archiving documents
Keep invoices, supplier declarations and other documents for a possible inspection.
Transparency at Wepack.cz
For products from Wepack.cz, we state on the invoice that the packaging fee has been paid. This gives you clearer documentation for accounting and possible inspection.
What should be recorded?
Packaging records should be clear and traceable. In practice, the main items tracked are material, weight, packaging type and the period in which the packaging was placed on the market or into circulation.
What are the risks if obligations are breached?
If a company does not deal with its obligations, an inspection may cause problems. The risk is not only the fees themselves, but also proving records retrospectively and possible penalties.
- The fine can reach up to CZK 1,000,000.
- It may be necessary to pay fees retroactively according to the amount of packaging.
- The company must be able to prove correct records and documents.
- Import or distribution may create additional administrative complications.