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HELPING PRODUCERS COMPLY WITH THEIR WASTE MANAGEMENT OBLIGATIONS
Extended producer responsibility obliges producers to take care of their products throughout their life cycle, including when they become waste. All producers of packaging and non-packaging products have this obligation.
The Waste Act allows each producer to comply with its obligations through a producer responsibility organisation, PRO for short.
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We will help you comply with your obligations in a convenient, transparent, and efficient way:
- waste collection, recovery, and recycling for all types of packaging and non-packaging (products made of glass, paper and cardboard and plastic),
- calculation of market and waste collection shares,
- registration of producers in the register of producers of packaging and non-packaging products and the notification of changes to the information contained in the registration application,
- keeping records and reporting aggregated data,
- information on the method of ensuring collection of packaging and non-packaging waste.
Our services to producers go beyond the Waste Act:
- granting the right to use the Green Dot registered trademark on packaging in the territory of the Slovak Republic,
- calculation of emission and CO2 savings (CO2 Certificate)
- social responsibility (Responsible Society project),
- cooperation and active assistance in the introduction of separate collection, recovery and recycling of waste from operations.
Expert advice on:
- eping initial records,
- registration according to the requirements of the Waste Act,
- submitting the required reports in accordance with the applicable legal provisions,
- labelling of packaging,
- ensuring compliance with statutory obligations concerning packaging waste in other EU countries when exporting products.
Practical services:
- electronic reporting,
- monitoring legislative changes and defending clients' interests,
- waste management audit directly at the client's company,
- free expert seminars and training.
Legal advice:
- on waste management, concerning both Slovak and international law,
- ensuring the collection and recovery of spent batteries and accumulators,
- ensuring separate collection, take-back and recovery of e-waste,
- in complying with obligations under the Environmental Damage Prevention and Remediation Act – risk analysis and drafting of an offer for financial coverage of liability for environmental damage.
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Register of producers
The producer of a specified product shall submit to the Ministry a written application for registration in the relevant register of producers before placing the specified product on the market.
Unless registered, the producer may not place the specified product on the market in the Slovak Republic.
Unless you are already registered in the register of packaging producers or the register of producers of non-packaging products, please contact us at customer@envipak.sk and we will arrange your registration and compliance with your statutory obligations.
If you want to find out whether you are registered in the register of packaging producers or the register of producers of non-packaging products, or to check that all your details are correct, you can do so on the website:
- List of packaging producers
- List of producers of non-packaging products
- List of electrical equipment producers
- List of battery and accumulator producers
- Waste management information system
References
"Since the portfolio of our Company’s products comprises mainly non-alcoholic beverages mostly bottled in Plastic and Tetrapak packages, we bear a greater responsibility for polluting the environment. Thanks to our cooperation with the authorized organization ENVI-PAK however, we are able to easily meet our duties under the applicable Slovak and EU legislation. Our cooperation with ENVI-PAK also helps to raise environmental awareness of our employees."
"We have been working with ENVI-PAK in the Slovak market for several years. We would like to use this opportunity to thank ENVI-PAK for their extraordinary professionalism that helps us meet one of our most important objectives – being an environmentally friendly player. Our Company operates vending machines in 24 European countries, and customer satisfaction is our priority in each country. We believe in providing our customers with products and services of the highest quality, but also in making sure that the generated waste shall be disposed of safely without damaging the environment. And in Slovakia we have been successful in doing so thanks to ENVI-PAK."
"Tetra Pak chose the ENVI - PAK system because we consider it to be the best in Slovakia. The GREEN DOT collection, recovery and recycling system in Slovakia is operated by the authorized organization ENVI - PAK . It is a guarantee to us of flawless compliance with our regulatory duties. This fact has been confirmed by the positive outcomes of audits conducted by the Slovak Environmental Inspection. We believe that one of the reasons is the fact that the system was founded and is operated by companies experienced in running similar schemes abroad. Membership of the authorized organization ENVI - PAK in the Pan-European PRO EUROPE association is a guarantee that international know-how and best practices of stable schemes in other countries shall be used also in Slovakia."
"Kofola is responsible in relation to its products in all stages of their life cycle, including disposal of packaging waste from our beverages. That is why we have been for many years a Client of the authorized organization ENVI-PAK that not only takes care of our statutory duties under the packaging legislation in a comprehensive manner, but has effectively developed a separate packaging waste collection system in Slovakia. We are happy to have such a strong partner on our side."
"Walmark imports and distributes nutritional supplements, drugs for human use and cosmetics. Under the Packaging Act we must meet several duties such as to register with the Slovak Ministry for the Environment, meet our recycling limits, duties in relation to prevention, labeling of packages, record-keeping of packages and of packaging waste and reporting to the Slovak Ministry for the Environment. We can handle some of these duties on our own. Since 2003 ENVI-PAK has been helping us in meeting our other duties. ENVI-PAK besides meeting the recycling limits keeps record of packaging waste quantities and completes the mandatory reporting to the Slovak Ministry for the Environment and requests data updates in the Register of obliged persons on our behalf. ENVI-PAK has assisted us during an audit by the Slovak Environmental Inspection and provided all the necessary documents and consulting. Last but not least, training is also important to us. ENVI-PAK always informs us about amendments to the packaging legislation. ENVI-PAK is indeed a reliable partner whom we can entrust compliance of our duties."
"Opavia – LU, s.r.o. in the framework of its environmental policy not only meets all the applicable standards under the European legislation, but in many areas exceeds with its environmental objectives the currently applicable legislation. We have been meeting our statutory duties in relation to packaging waste collection, separation and recycling limits with the help of the authorized organization ENVI-PAK. On top of the above duties, ENVI-PAK provides us with professional consulting, training for our staff, informs us about amendments to the legislation concerning packages and packaging waste. We appreciate mainly their expertise, flexibility and our partner’s positive attitude as well as the fact that ENVI-PAK has been actively promoting the packaging waste collection schemes directly with the people in the municipalities."
Frequently asked Questions
In 2004 we became the first authorized organization in Slovakia. On April 20, 2016, we were issued a decision on being granted the authorization to operate as a producer responsibility organisation for packaging, based on which from July 1, 2016 we operate as a producer responsibility organisation (PRO).
A producer of specified product is understood to be:
• producer of electrical equipment,
• producer of batteries and accumulators,
• packaging manufacturer,
• motor vehicle manufacturer,
• tyre manufacturer,
• manufacturer of non-packaging products.
Packaging producer is a private individual or legal entity, who:
a) packs or fill the goods in packaging and introduces them on the market under own brand name,
b) is a person/entity for whom goods are packed or filled and under whose trademark are marketed,
c) imports and places on the market packaged products,
d) distributes packaging (in exchange for a payment and free of charge) to end user for immediate packaging of goods (packaging used by customers to pack goods),
e) as a distributor uses packaging to wrap goods or to fill with merchandise (packaging, used by customer service personnel to pack goods),
f) provides empty packaging (in exchange for a payment and free of charge) to the end consumer.
Pursuant to § 27 par. 4 of the Act on waste producer of packaging must comply with obligations in the following areas:
• recovery and recycling of packaging waste at a minimum level of binding targets and limits for recovery and recycling,
• information obligation towards the public and the processor of specified waste stream,
• registration with the register of Producers of specified product,
• updating of information maintained by the register of Producers of specified product,
• organise the management of specified waste stream,
• maintain and archive records,
• reporting and archiving of summarized data,
• calculation of the collection and market share,
• ensure the collection of the entire volume of separately collected components of municipal waste.
The law allows producers of packaging to meet binding limits established for the recovery and recycling of two ways:
1. INDIVIDUALLY, the producer can meet these binding limits himself, with own resources without any contractual relationship with other entities (e.g. if it involves packaging waste from products which were used only inside the facilities of the producer).
2. THROUGH A PRODUCER RESPONSIBILITY ORGANISATION: the producer will enter into a contract with producer responsibility organisation for specified waste stream.
Producer responsibility organization can be establish only by producers of specified products. In der to be able to operate PRO requires to have a valid authorization granted by the Ministry of Environment SR. Without the authorisation, it can not operate. Authorized producer responsibility organization has the right to fulfil obligations on behalf of manufacturers, participating in its system.
The level of contributions to the ENVI - PAK system is derived from the amount of packaging, introduced by our clients onto the market. Subsequently we use these funds to finance, in accordance with legislation, separated collection in municipalities under contracts signed with municipalities and collection companies.
ENVI - PAK operates on a non-profit basis - all funds received from clients are re-invested back into the system, to achieve efficiency improvements.
We ensure the fulfilment of obligations, through agreements concluded with municipalities and collection companies. We provide long-term support for promotion and financing of sorted waste collection in towns and municipalities.
ENVI - PAK as a producer responsibility organisation for packaging and non-packaging products, discloses a model contract for the fulfilment of specified obligations together with a price list for the fulfilment of specified obligations pursuant to Section 28(4)(ac) of Act on Waste No. 79/2015 Coll.:
If a producer chooses to meet their obligations individually, in addition to all obligations specified in § 27 par. 4 of the Act, he must fulfil also the following obligations:
• to establish, operate and maintain a functioning system of individual handling of specified waste stream throughout the full term of individual compliance with obligations,
• comply with conditions of the authorization granted,
• to enter into a contract with co-ordination centre designated according to the specified waste stream originating from its specified product, if such centre has been established and to fulfil obligations arising therefrom;
• to carry out promotional and educational activities in the district, where it organises waste collection, focusing on the end-user, on handling specified waste stream, sorted waste and waste prevention,
• to submit, upon request, to the ministry and the co-ordination centre documents proving the veracity of the supplied data and information,
• to inform the Ministry without undue delays that facts have occurred that lead to the termination of its operations,
• to deliver to the ministry, each year latest by July 31, of the calendar year for the previous calendar year, a Report on the functioning of the individual handling system,
• to publish on its website, information from the report every year by July 31 of the calendar year for the previous year, within the prescribed scope as specified in letter g),
• to archive data that were the basis for the report under letter g), at least for a period of three years after its delivery to the ministry,
• to notify the ministry of any change in the system of individual handling of specified waste stream, within 30 days from the date of change and upon request, document this change to the Ministry,
• to comply with obligations arising from the split of responsibilities, as determined by the co-ordination centre in relation to the volume in excess and by being designated as entity responsible for arranging replacement collection,
• to report excess quantities to the co-ordination centre; based on the terms and conditions under letter c) it may grant these quantities to other co-ordination centre clients.
The obliged person/entity may delegate all of these obligations to the producer responsibility organization, which will fulfil all obligations applicable to the producer under the Act on Waste.
We are the exclusive partner of PRO EUROPE in Slovakia and we are the only company that can grant permission to use the GREEN DOT registered trademark to third parties. The contract between PRO EUROPE and ENVI - PAK has been concluded for an indefinite period.
Marking of packaging is not compulsory by law. If the producer marks the packaging, the packaging material composition must be labelled in accordance with special regulation (Decree on extended producer responsibility of specified products and on the management of specified waste stream no. 373/2015 Coll.).
The packaging may also be labelled to indicate the disposal method. The marking must be visible and easily legible, and at the same time it must be adequately durable and stable also after the opening of the packaging.
If it is unclear whether or not a particular product is packaging, a decision needs to be sought from the Ministry of Environment.
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