
In the new version of its guidance (published on 14 September 2026), the Ministry of the Environment of the Slovak Republic has reworked the section on penalties and added an entirely new point governing the conformity assessment of packaging. The following specific changes are the most important:
• Slovak inspections will not follow concessions from Brussels:
- In its published questions and answers (FAQ), the European Commission recommends that inspectors be more lenient and avoid jeopardising supply chains.
- However, the Ministry has added an explicit notice to the guidance that this Commission document is of a recommendatory nature only and is not legally binding on Slovak inspection authorities. The inspectorate in Slovakia will proceed in accordance with applicable national legislation.
• Classification of packaging as “designated products” (entirely new point 5):
- Packaging will be assessed under Act No. 56/2018 Coll. on conformity assessment.
- Full responsibility for the conformity assessment lies with the manufacturer (in the case of sale under its own brand or modification of the packaging, also the importer or distributor).
• EU declaration of conformity – machine translation is sufficient:
- The declaration of conformity for the Slovak market must be available in the official language (Slovak).
- A great relief is the confirmation that an ordinary machine translation is fully sufficient – an official (sworn) translation or notarial certification is not required.
• Strict rules for signing the declaration of conformity:
- If the declaration is bilingual, it is a single document signed by the manufacturer’s representative.
- If it is a translation of a foreign-language original, it must be clearly marked as a “translation of the EU declaration of conformity” and attached to the original, and it must not be signed by a local representative or managing director.
• Slovak language for QR codes and data carriers:
- Information about the manufacturer, the identification of the packaging, and instructions intended for users and the inspectorate – including those made available digitally via QR codes – must be available in Slovak for the Slovak market.
• Technical documentation during inspection:
- It is submitted by the manufacturer or, failing that, by the importer or distributor at the request of the inspection authority.
- The inspectorate may accept English, but if it requests a Slovak text, a machine translation with a visible “machine translation” label is again sufficient.
• Reference to the 2nd edition of the European Commission FAQ:
- The guidance reflects the newer edition of the European FAQ document, which expands the interpretation in particular with regard to transport and branded packaging.
We are continuously monitoring the PPWR situation. We will keep you updated with the latest information so that you are prepared for the new obligations. The full guidance is published in the Waste Management Information System (ISOH): Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste