Slovakia’s 100 kg packaging threshold: what remains
Less than 100 kg of packaging a year is a partial Slovak relief, not permission to ignore registration, records or reporting. Foreign online sellers must also address PPWR.
A small online store can have Slovak packaging duties. The threshold does not mean “no registration” or “no reporting”. Nor does it settle a foreign seller’s obligations after the EU Packaging and Packaging Waste Regulation, or PPWR, became generally applicable on 12 August 2026.
This guide separates the national relief from cross-border obligations. Legal position checked on 21 October 2026.
The threshold is strictly below 100 kg
Section 54(6) of Slovakia’s Waste Act, No. 79/2015, refers to an aggregate quantity of less than 100 kg of packaging placed on the Slovak market in a calendar year.
Exactly 100 kg does not qualify. The test concerns packaging mass, not product weight, sales revenue or the number of parcels. It is an annual total for the responsible producer, not a separate allowance for each SKU, marketplace or online store operated by that producer.
Identify the producer before calculating. For supplies after 12 August 2026, the Slovak Ministry’s PPWR guidance, version 1.4 directs businesses to the PPWR producer definition rather than relying on the old national definition alone.
What the national relief changes
Section 54(6) disapplies specified duties in Section 27(4)(b), (d)–(g), (i)–(l), and Section 27(6). Registration, applicable packaging requirements and record/reporting duties in Section 27(4)(a), (c) and (h) are not on that exemption list.
| Area | National position below 100 kg | Practical consequence |
|---|---|---|
| Registration | Remains; Section 30 requires registration before market placement | Small quantities do not postpone packaging registration in Slovakia |
| Records | Remain, including material-based records under Decree 366/2015 | Maintain evidence throughout the calendar year |
| Annual reporting | Remains for a small producer outside an OZV arrangement | Prepare the applicable annual return; do not assume silence is sufficient |
| Listed collection, recovery and target duties | Specified national duties are disapplied | This is not proof that PPWR responsibility or all costs disappear |
| Collective versus individual fulfilment | The normal Section 27(6) requirement is disapplied in the national text | The small-producer route is distinct from authorised individual fulfilment |
| Representative | The national representative duty is included in the exemption list | Check PPWR separately; do not infer that foreign sellers need no representative |
An OZV, or organizácia zodpovednosti výrobcov, is a producer responsibility organisation. Its contract, fees and data-submission schedule are distinct from legislation. The table describes the national provision, not a complete post-PPWR compliance route.
Foreign sellers need the PPWR check too
PPWR Article 45 establishes producer responsibility. Article 45(3) requires producers covered by Article 3(1)(15)(c)–(d) to appoint an EPR representative for relevant cross-border supplies. For example, an EU-established seller supplying packaged products directly to Slovak end users must address a Slovak appointment even at low volumes. Non-EU routes also require assessment of the applicable national and EU provisions.
The Commission’s small-business guidance distinguishes current obligations from a proposed suspension of representative requirements. A proposal is not an enacted exemption.
The Ministry’s September guidance acknowledges unresolved alignment between Slovak law and PPWR. It does not expressly confirm how the under-100 kg relief applies to every post-August cross-border arrangement. Consequently, do not assume the national exemption removes Article 45 obligations or guarantees that no OZV arrangement or contribution is needed. Obtain a case-specific position before relying on that conclusion.
Count the packaging that belongs to your route
Packaging protects, contains, handles and delivers products. Review retail packaging and the additional shipping carton, protective insert and filling, where the identified seller is the producer for those components. PPWR expressly recognises e-commerce transport packaging. PPWR Article 3
Hypothetical example: one seller makes 500 Slovak deliveries, each containing one product. Assume it is responsible for all four single-use components below and these are its only relevant Slovak packaging flows.
| Component | Weight per delivery | Weight across 500 deliveries |
|---|---|---|
| Retail carton | 20 g | 10 kg |
| Paper insert | 10 g | 5 kg |
| Shipping carton | 140 g | 70 kg |
| Paper filling | 10 g | 5 kg |
| Total | 180 g | 90 kg |
Counting only retail packaging and its insert would produce 15 kg, overlooking 75 kg of dispatch packaging. Another 60 identical deliveries add 10.8 kg, bringing the annual total to 100.8 kg.
Use documented weights and actual packaging versions. Reconcile channels and fulfilment records without duplicating orders. The example demonstrates aggregation; it does not establish entitlement to the relief for a particular seller.
Reporting below the threshold still takes preparation
The Ministry’s ISOH reporting page says that a producer below 100 kg outside an OZV arrangement files annually by 28 February of the following year. A producer fulfilling through an OZV does not itself submit that return; the OZV reports collectively.
Check the actual regulation when preparing the form. The ISOH summary mentions the introductory section and Table 1. However, the current Section 15(6) of Decree 366/2015 names the introductory section and Tables 1, 1a and 3 of Annex 16. Review the applicable fields rather than relying on the shorter website summary. Sections 15(4) and (7) require five-year retention of records and reports.
For the 2026 reporting year, the adopted Section 19(2) of Decree 89/2024 preserves the rules effective through 31 December 2026, despite the new decree starting in 2027. Recheck any subsequent amendments before filing.
Act before growth removes the relief
Track the running total and forecast the remaining year. If expected deliveries bring it to 100 kg or more, review the compliance arrangement before that happens; the annual test gives no automatic permission to wait until January.
Agree the required route, reporting period and registration changes with the appropriate Slovak specialist or organisation. Section 30(7) sets a 15-day notification period for a change to collective fulfilment, measured from that change. Do not treat this as a general grace period after crossing the threshold. Any treatment of earlier quantities or charges needs confirmation.
A marketplace or fulfilment provider does not automatically assume your obligations. Map who supplies each packaging component and what the contracts cover. A Czech EKO-KOM registration is not a Slovak registration.
The main conclusion
Establish the producer, total its Slovak packaging across channels, confirm registration and the reporting route, and assess PPWR separately. Document the basis for any relief before relying on it.
Frequently asked questions
Does exactly 100 kg qualify?
No. Section 54(6) says less than 100 kg, not 100 kg or less. Work from the underlying packaging records rather than using rounding to decide eligibility.
Must I report below the threshold?
The ISOH instructions require annual reporting from a producer below 100 kg outside an OZV arrangement. An OZV reports collectively for producers fulfilling through it. Confirm which route applies to your business.
Is the limit based on product or parcel weight?
It concerns packaging mass. Product weight and gross parcel weight are not substitutes for documented packaging component weights. Include the relevant dispatch packaging as well as retail packaging.
Can a foreign seller rely on the threshold to avoid a representative?
Do not draw that conclusion from the national relief. PPWR creates separate representative requirements for relevant cross-border producers. Establish your role, country of establishment and Slovak sales route.
Does each marketplace give us another 100 kg allowance?
No. The national test is the producer’s aggregate quantity on the Slovak market for the calendar year. Reconcile the producer’s channels together and exclude duplicate records.
What if we grow beyond the threshold during the year?
Review the arrangement before the forecast reaches the boundary. Confirm the applicable compliance route, notifications and treatment of the year’s quantities. Do not invent a next-year start date or assume a universal retrospective charge.
How Kodo can help
Kodo can help map the sales route, organise packaging evidence and prepare data for discussion with an appropriately qualified Slovak adviser, representative or OZV. Any coordination has an agreed scope. This does not establish a Slovak statutory mandate, authorisation or partnership for Kodo.
Contact Kodo with your country of establishment, sales route, packaging specifications and estimated Slovak annual quantities.
Sources
- Slovak Waste Act 79/2015, effective version from 1 January 2026: Sections 27, 30 and 52–54
- Decree 366/2015, effective through 2026: Section 15 and Annex 16
- ISOH: packaging reporting instructions
- Decree 89/2024, effective from 2027: Section 19(2), reporting-year transition
- Slovak Ministry PPWR guidance, version 1.4, 14 September 2026: Sections 1–3
- PPWR, Regulation (EU) 2025/40: Articles 3, 45–46 and 71
- European Commission: packaging EPR for small businesses
General information, not an individual legal assessment. Confirm the applicable Slovak and EU duties, reporting route and any claimed relief for your products and sales model with qualified specialists and the responsible authorities.