The Ministry of the Environment of the Slovak Republic has issued guidance on the definition of a packaging producer under the PPWR Regulation and on the submission of registration data
On 22 October 2026, the Ministry of the Environment of the Slovak Republic issued guidance on the practical application of the definition of a packaging producer under Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste (PPWR). The document addresses the identification of packaging producers in accordance with the rules applicable from 12 August 2026 and the provision of registration data in connection with the change to the definition of a packaging producer.
The guidance is based on the fundamental rule that the packaging producer is the entity that first makes the packaging or packaged product available on the territory of the Slovak Republic. It clarifies how to identify the producer for individual types of packaging, as well as for supplies from abroad. In the case of transport packaging, service packaging and primary production packaging, the producer is generally considered to be the physical manufacturer, whilst the marking of the packaging with a trade name or trade mark is also taken into account. In the case of packaging and packaged products supplied from abroad, the decisive factor is whether the Slovak recipient redistributes them or whether they are intended directly for the end user. The document also contains specific examples of determining the manufacturer of packaging in various supply and distribution relationships.
The second part of the guidance deals with the provision of record-keeping data by packaging manufacturers for whom, as a result of changes to the legislation, there has been a change in the scope of the recorded quantities of packaging placed on the Slovak market. The Ministry of the Environment of the Slovak Republic requests that these entities provide quarterly data enabling a comparison of packaging quantities under the rules in force prior to 12 August 2026 and under the current legislation, including a quantification of the difference. The Ministry also states that the provision of this data does not constitute a new legal obligation for packaging producers. The data is intended to compare the impact of the legislative change on the recorded quantities of packaging and to ensure the proper functioning of the extended producer responsibility scheme.
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Full text of the guidance (in Slovak language)