Following the announced changes in keeping records of packaging and non-packaging products placed on the market in connection with ecomodulation, we would like to inform you that on 1 July 2023 an amendment to the Decree of the Ministry of Environment of the Slovak Republic No. 371/2015 Coll., implementing certain provisions of the Waste Act, as amended, entered into force.

The amendment to Decree No. 259/2023 sets out new record-keeping requirements in Annex 10c. The producer of packaging and non-packaging products shall keep detailed data on the material composition of packaging and non-packaging products placed on the market for a period of a calendar year. The scope of the newly required data can be found here (Annex 10c). The full text of the amendment can be found here (259/2023).

At the same time, the keeping of new records according to the amendment to the Decree does not cancel the keeping of records according to Decree 366/2015 Coll., on the recording and reporting obligation (i.e. the existing record-keeping – the statement on packaging and non-packaging products), but provides for their simultaneous keeping.

At the same time, the transitional provision of the amendment to the Decree stipulates that the new registration obligation will be fulfilled by producers from 1 October 2023, i.e. for the first time in the report for 4Q 2023. In practice, this means that by 30 September it is necessary to introduce changes in the reporting in order to keep the records of packaging and non-packaging products in the new detailed structure from 1 October onwards.

On the topic of keeping new records in accordance with the amendment to the Decree, we are preparing a training session where we will thoroughly map the keeping of records on the material composition of packaging and non-packaging products placed on the market.

At the same time, we would like to inform you that in connection with this change, the contractual documentation will be updated and the quarterly statement on packaging and non-packaging products will be amended to comply with the requirements of the new legislation.