Authorised Representative for Packaging EPR in the Czech Republic
Your Local Partner for Packaging EPR in the Czech Republic
Foreign companies placing packaged products on the Czech market may have separate Czech Packaging EPR obligations, including registration, packaging reporting and ongoing administration. Depending on the sales model and applicable requirements, a company may also need to appoint an EPR Authorised Representative in the Czech Republic.
With over nine years of experience in packaging and waste management, we help foreign producers understand which compliance model applies to them and support the process from initial registration to ongoing reporting and communication with EKO-KOM.
Whether you need a formal EPR Authorised Representative or can operate under a Power of Attorney, our goal is to make Czech Packaging EPR clear, efficient and manageable, so you can focus on your business while we take care of the practical compliance administration.
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Common Questions About Czech Packaging EPR & PPWR
Whether you need to appoint an Authorised Representative for Extended Producer Responsibility in the Czech Republic depends on your specific sales model and the applicable Czech requirements.
- Under the PPWR, a company established in another EU Member State that supplies packaged products directly to end users in the Czech Republic through distance contracts falls within the cross-border producer framework.
- Recital 123 of the PPWR states that such a producer should appoint an EPR Authorised Representative in the Member State where the end user is located.
- Article 44(3) leaves the practical implementation of representation for registration and reporting obligations to the Member States. The Czech requirements therefore need to be assessed for each specific case.
- For producers established outside the EU, the PPWR expressly allows Member States to make the appointment of an EPR Authorised Representative mandatory under national rules.
Legal basis: Article 3(1), points 15(d) and 20, Article 44(3), and recital 123 of Regulation (EU) 2025/40.
Yes. The PPWR establishes an EU-wide framework, but it allows Member States to determine certain aspects of how EPR Authorised Representatives are used at national level.
Under Article 44(3) of the PPWR, a Member State may determine that the obligations set out in Article 44 may be fulfilled on behalf of a producer by an EPR Authorised Representative appointed in writing.
Recital 123 also states that a producer established in another EU Member State and supplying packaged products directly to end users through distance contracts should appoint an EPR Authorised Representative in the Member State where the end user is located. For producers established outside the EU, the PPWR allows Member States to make such an appointment mandatory.
In the Czech Republic, foreign producers may appoint an EPR Authorised Representative, while formal representation is mandatory in specific cases under the current Czech framework. This includes certain cross-border distance sales involving single-use plastic packaging and packaging products listed in Parts C and D of Annex 4 to the Czech Packaging Act.
Where a formal EPR Authorised Representative is not required, a foreign producer may remain directly responsible for its Czech Packaging EPR obligations and use a Power of Attorney for administrative representation.
Legal basis: Article 44(3) and recital 123 of Regulation (EU) 2025/40.
An Authorised Representative for Extended Producer Responsibility is a person or company established in the Czech Republic and formally appointed by a foreign producer to perform relevant EPR obligations on the producer’s behalf.
Depending on the applicable Czech requirements and the scope of the written mandate, the representative may perform activities relating to:
- producer registration;
- submission of required registration and reporting information;
- fulfilment of relevant Extended Producer Responsibility obligations;
- communication with the competent Czech authorities; and
- notification of changes to registered information.
The exact scope of representation depends on the written mandate and the applicable Czech EPR framework.
Legal basis: Article 3(1), point 20; Article 44, in particular paragraphs 3, 7–8 and 12; Article 45; and Annex IX of Regulation (EU) 2025/40.
No. EPR representation under the PPWR is country-specific.
An Authorised Representative for Extended Producer Responsibility must be established in the Member State for which the producer appoints the representative.
A company placing packaged products on the market in several EU Member States may therefore need a separate representation arrangement in each relevant Member State, depending on the applicable national requirements.
Where an EPR Authorised Representative is appointed for the Czech Republic, that representative must be established in the Czech Republic. A Czech appointment does not automatically cover Germany, Poland, Slovakia or other EU markets.
Legal basis: Article 3(1), point 20; Article 44(1)–(3); and recital 123 of Regulation (EU) 2025/40.
Where a formal EPR Authorised Representative is not legally required, the Power of Attorney model is usually the simpler and more flexible option.
Your company remains legally responsible for its Czech Packaging EPR obligations, while SUSCON manages the practical administration, including EKO-KOM registration, communication and packaging reporting.
A formal EPR Authorised Representative is required only in specific cases. Under the current Czech framework, this includes certain cross-border distance sales involving single-use plastic packaging listed in Parts C and D of Annex 4 to the Czech Packaging Act.
If you are unsure which model applies, SUSCON can assess your situation before registration.
The information required depends on whether SUSCON is appointed as an EPR Authorised Representative or acts under a Power of Attorney. In most cases, we will need:
- company identification details and registered office;
- VAT and company registration information;
- details of the authorised company representative and contact person;
- information about your sales model and activities in the Czech Republic;
- information on the products and packaging placed on the Czech market;
- the packaging data required for EKO-KOM registration and reporting; and
- the relevant appointment documentation or Power of Attorney.
For ongoing reporting, your company must provide complete and accurate packaging data for the relevant reporting period. SUSCON will guide you through the required documents and information depending on the representation model applicable to your company.
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