Industry Statement on Slovakia’s Proposed Amendment to the Environmental Fund Act
The undersigned organisations strongly oppose the proposed Amendment to Slovakia’s Environmental Fund (EF) Act aiming to enable the Environmental Fund (EF) to act as a Producer Responsibility Organisation (PRO) within the Extended Producer Responsibility (EPR) system.
The proposed Amendment would reduce the effectiveness of the Slovak EPR system for packaging, risking to jeopardize the achievement of packaging recycling targets.
The purpose of Extended Producer Responsibility
Extended Producer Responsibility is mandatory for all packaging since 31st December 2024. It is the financial and organisational mechanism that closes the gap between the costs of separate collection, sorting and recycling and the market value of secondary materials.
Article 8a of the Waste Framework Directive (WFD), which sets out the general minimum requirements for EPR schemes, as well as the Packaging and Packaging Waste Regulation’s (PPWR), are very clear that the role of EU Member States in EPR systems is to authorise and supervise PROs. By taking on the role of a PRO, the State would be put in the conflicted and inappropriate position of having to police itself. Such an approach undermines the very concept of producer responsibility, is contrary to international best practice, and is cause for concern given the apparent trend towards the rise of State-run EPR schemes in Europe.
Risks to recyclability and packaging market access
The PPWR’s recycling and recycled-at-scale targets1 are set at a level of ambition that requires practically all used consumer and commercial / industrial packaging to be separately collected, sorted and recycled.
By assigning EPR responsibilities to a state-run body, the proposed Amendment risks to jeopardise progress towards recyclability at scale mandated under the PPWR. This could lead to the loss of market access for numerous packaging applications from 2035, even if they meet the PPWR’s Design for Recycling requirements, thus negatively impacting businesses and consumers alike.
In its 2023 Waste Early Warning Report2, the European Commission concluded that Slovakia was at risk of failing to meet the 2025 PPWD recycling targets (which have now been incorporated into the new PPWR). It recommended Slovakia to implement pay-as-you-throw systems and to improve the system for managing quality of recycling data. There were no concerns identified that would justify the intervention of the state in taking on the role of a producer. Nevertheless, on 1st October 2025, the Slovak government tabled in an expedited procedure an amendment to the national Waste Law that would enable the state Environment Fund to take on the role of a PRO.
Our call for action
The undersigned organisations urge members of the National Council to reject the government’s proposal to amend the Environmental Fund Act, and to ensure Slovakia’s EPR system remains aligned with the general minimum requirements of the Waste Framework Directive and supportive of the recyclability at scale objectives of the PPWR.