Industry association · Czechia
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Česká asociace odpadového hospodářství filed 5 positions between 16 Jan 2026 and 14 Sept 2026, across 5 of the 665 legislative files tracked here, attaching a full position paper 4 times.
Technical-environmental sustainability criteria (Article 7(9)) Logical basic role of mechanical recycling: For single-flow plastic (e.g.: Pet, PE, PP) mechanical recycling has the lowest specific energy consumption and the lowest CO2e emissions. Its place in terms of sustainability is unquestionable.
Filed in Czech · English published by the European Commission
Methodology for the calculation and verification of the PCR share (Article 7(8)) Post-consumer material definition (PCR): The actual terms of reference for the transposing legislation specify that they are to cover the requirements for the content of post-consumer waste materials. This means that post-industrial/pre-consumer technological waste should not be eligible.
Filed in Czech · English published by the European Commission
The proposal for an EC implementing regulation to end the waste regime for plastics is conceptually beneficial, but currently excessively administratively and procedurally burdensome. The scope of the documentation, certification and monitoring obligations does not correspond to the principle of proportionality and may lead to end-of-waste status being used in practice only by a limited number of large plants.
Filed in Czech · English published by the European Commission
Import conditions and third country verification (Article 7(10)) The lack of effective import controls, coupled with increasingly tighter conditions for the European market, pose a risk of declaratory fraud (mixing of primary plastic declared as recyclate due to price difference).
Filed in Czech · English published by the European Commission
(1) The introduction of the ALR methodology is not justified for the Czech Republic, as the Czech registration system (ISPOP) already works on the principle of digital traceability of specific material flows up to the final processor, thus meeting the objective to which the ALR is only theoretically heading in countries with insufficient data.
Filed in Czech · English published by the European Commission
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Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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