Czech packaging EPR: a data review before reporting

A packaging report should be traceable from actual Czech deliveries to the final EKO-KOM fields. Registration alone does not establish that those figures are correct.

Before submitting an EKO-KOM report, check that the Czech sales population is complete, each delivery uses the correct packaging version, materials and weights have evidence, and the calculated totals reach the right reporting fields. This review is useful for a business already registered in the Czech Republic as well as a foreign seller preparing its first Czech return.

For a larger portfolio, the most valuable result is a calculation that another person can reproduce. A summary of tonnes without the underlying deliveries, packaging specifications and decisions leaves the company dependent on one spreadsheet or employee.

This guide focuses on checking reporting data. For the earlier setup decisions, see Czech packaging EPR: from registration to quarterly reporting.

Establish the producer, period and rules being reviewed

Begin with a short scope statement: the legal entity, Czech sales routes, warehouses, packaging streams and reporting quarter. Specify whether the review covers the full population or selected samples.

Packaging duties can arise from B2C and B2B supplies. Under PPWR, a business can be an end user; a foreign seller supplying packaged goods directly to Czech end users must address the producer position for those deliveries. A sale to a Czech reseller needs its own assessment of the chain. The relevant definitions and EPR rules are in Regulation (EU) 2025/40, Articles 3 and 45.

The framework combines that EU regulation, the Czech Packaging Act, No. 477/2001 Coll., including Section 15 on records, and the applicable EKO-KOM agreement and reporting methodology. System instructions explain how its return operates; they are not a substitute for the legislation.

For an EU-established producer supplying directly to end users in another Member State, Article 45(3) requires a written EPR representative appointment in the destination country. Do not assume that low sales remove that duty. The Commission's small-business guidance distinguishes the current requirement from a proposed suspension and national operating arrangements.

PPWR generally applies from 12 August 2026, but individual requirements have different dates. Do not treat every later design or labelling requirement as already applicable. For a quarter spanning that August change, check the treatment of transactions before and after the change against the relevant methodology. EKO-KOM publishes separate instructions for records up to 11 August and from 12 August 2026 on its quarterly reporting page.

Request source records before the finished return

A useful review starts with the inputs, not just a copy of the report submitted last time.

Agree the data format and cut-off in advance. If the export has one row per order but the packaging catalogue uses individual products, the calculation needs a documented transformation between those units.

For a group with several entities, identify the legal owner of each record. A single warehouse export may contain movements for several producers; it should not silently become one producer's return.

Reconcile Czech deliveries and explain exclusions

As a practical control, compare the reporting population with another independent record, such as dispatch totals or accounting sales. Investigate differences rather than forcing the totals to match.

Check particularly:

• cancelled orders that never shipped;
• several shipments against one order;
• replacement deliveries and samples;
• marketplace orders absent from the main e-shop export;
• products sold in packs, sets or different units;
• goods supplied to another country;
• returns and movements between warehouses.

An invoice address, delivery destination and legally relevant market event can differ. Record the rule used to select the Czech population and investigate exceptions. Do not assume that every credit note automatically permits a packaging deduction: the physical flow and applicable reporting treatment still need evidence.

EKO-KOM describes completeness checks as a comparison of sales or statistical records with the calculation inputs, alongside examination of dispatch areas. Its audit overview explains that principle. The reconciliation procedure above is a practical way to prepare reviewable records.

Test packaging versions, weights and reporting categories

Select a useful sample: high-volume products, heavy packaging, recently changed specifications, new suppliers and unusual material combinations. Sampling can expose a recurring error, but it does not prove that every untested SKU is correct.

For each selected item, follow one transaction through the calculation:

1. Identify the product and shipment configuration actually used.
2. Find every associated packaging component.
3. Check its material and documented unit weight.
4. Confirm that the specification was valid on the relevant date.
5. Recalculate the packaging quantity independently.
6. Trace it to the reporting category and final field.

A product weight is not its packaging weight. A carton containing ten products should not be counted ten times at its full weight. A shipping box added by a fulfilment centre also needs to be considered, even if the product supplier has supplied an excellent retail-pack specification.

Keep the weight source, measurement basis and date with the record. If reliable information is missing, mark it as missing and agree how it will be obtained; zero would hide the gap. Do not retrospectively apply a new, lighter packaging specification to an earlier period.

These controls address recognised error types. EKO-KOM's published experience from packaging-record reviews, especially pages 41–44 discusses incorrect unit allocation, outdated weights, calculation errors and transfer into the return. The document describes audit experience up to 2022; use current instructions for today's reporting classifications.

Use a control total without losing the reporting distinctions

Consider this illustrative calculation, not a client case:

The selected components total 0.188 tonnes. That does not mean they all belong in one cell: product and transport packaging may need different reporting treatment, and other components remain outside this example.

For each number, the reviewer should be able to identify the source quantity, packaging version and conversion. Keep calculation precision until the appropriate reporting stage. The EKO-KOM reporting methodology, in its introductory instructions, specifies reporting in tonnes to kilogram precision, with three decimal places.

For a large catalogue, repeat the control by material, warehouse and reporting category. Large changes from the previous quarter are questions to investigate, not automatic errors: a new product mix can explain them.

Check the form version and submission evidence

As checked on 19 October 2026, EKO-KOM's current form is v. 2.77 for Q3 2026, with a filing window of 1–30 October 2026. That version should not become a permanent instruction for later quarters. Obtain the form relevant to the period from the official reporting page.

Before filing, compare the final workbook with the approved calculation. Check the producer identifier, period, units, totals and required fields. Keep the approved source-data version, calculation, submitted workbook and evidence of submission and processing together. An upload confirmation alone should not be described as acceptance unless that is what it confirms.

If a previous quantity was wrong, preserve the original report and establish the correction route. EKO-KOM's correction instructions require a complete corrected return for the quarter, rather than only the difference. They also set deadlines, including a special deadline for Q4. Confirm the applicable procedure before changing historical figures.

Separate a Kodo review from a formal inspection

Kodo can carry out an agreed advisory review of records and calculations. Its findings can help an existing registrant improve its inputs, prepare a return or respond to questions.

This is a private service with a defined scope. It is not an EKO-KOM-appointed audit, an authority inspection or an assurance that no further issue exists. A useful deliverable states what was reviewed, the evidence used, sampling limits, identified differences and the person responsible for each next step.

For example, the findings register can distinguish a missing supplier weight from a confirmed conversion error. The first requires evidence; the second may require recalculation across every affected SKU and quarter. Both need an owner and a recorded resolution.

What the client provides and what Kodo does

Kodo is already registered with EKO-KOM as an authorised representative for foreign packaging producers in Czechia. We represent the producer, not EKO-KOM. A particular producer's representation starts with the agreed written appointment and applicable onboarding; EKO-KOM explains that arrangement in its authorised representative procedure.

Within the agreed service, Kodo reviews source data, prepares packaging calculations and reports, and handles the relevant communication. The client supplies and confirms complete factual records, provides missing supplier information and signs the necessary documents.

You can also commission a data review while retaining your own registration or existing representative. Agree who is authorised to submit or correct a return; commissioning a review does not itself transfer that role.

The Kodo client portal keeps supplied documents, questions and review versions with the case. Registration is free and non-binding, with basic orientation on access, inputs and next steps. Detailed audits, reconstruction of historical records, integrations and representation are paid services agreed by scope. Kodo's fees are separate from EKO-KOM fees and packaging contributions.

For a proposal, send the legal entity, reporting period, existing registration, sales routes, approximate catalogue size and one example of your source data. Explore Czech packaging EPR services or request a reporting-data review.

The main conclusion

Before the next return, reconcile the Czech delivery population, test the packaging versions and trace the calculated totals into the period-specific form. If evidence or classifications are unresolved, assign the missing work before treating the report as ready.

Frequently asked questions

How Kodo can help

Kodo helps foreign sellers, manufacturers and existing Czech registrants organise packaging records and reporting. We provide scoped data reviews and, under the appropriate written appointment and onboarding, Czech packaging EPR representation. We can coordinate this with the commercial and operational work of selling in Czechia.

For legal, tax, regulatory, certification and investment-incentive matters, companies should work with qualified specialists and the responsible authorities.

Contact Kodo

Related reading

• Czech packaging EPR: from registration to quarterly reporting
• Selling to Czechia: PPWR and EPR before the first parcel
• Czech e-commerce operations: from order to EPR report

Sources and verification

Checked 19 October 2026: Regulation (EU) 2025/40, Articles 3, 44, 45 and 71; Czech Act No. 477/2001 Coll., e-Sbírka version effective from 1 December 2025, particularly Section 15; and the EKO-KOM pages and methodology linked above. The methodology read is version 26-2, effective from 12 August 2026. The form version and filing window are period-specific. The review sequence and example calculation are practical recommendations, not an additional statutory procedure.

• Regulation (EU) 2025/40, Articles 3 and 45
• Czech Packaging Act, No. 477/2001 Coll., including Section 15 on records
• small-business guidance
• quarterly reporting page
• audit overview
• experience from packaging-record reviews, especially pages 41–44
• EKO-KOM reporting methodology
• correction instructions
• authorised representative procedure

This article provides general information. The reporting treatment and review scope must be confirmed for the producer, sales route, packaging and period concerned.