Comments of the Czech Republic on the Draft Implementing Regulation on Producer Registration and Reporting under Article 44(14) PPWR: General comments concerning clarity and consistency data consistency 1.) What does separate systems for the management of packaging waste referred to in Article 1(2) mean?
Ministry of Environment of the Czech Republic
Public authority · Czechia
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Their record over time
Ministry of Environment of the Czech Republic filed 8 positions between 12 Mar 2026 and 15 Sept 2026, across 8 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
The Czech Republic wishes to underline the critical importance of the benchmark revision for the period 20262030. Timely finalization of the revised benchmarks is essential to ensure legal certainty and the smooth allocation of free allowances already for 2026.
Czechia generally welcomes the simplification initiative and all efforts to lower the administrative burden. Already during public consultation before the submission of the current proposal, we pointed out to a broad range of legislative acts where we identified space for simplification and lowering administrative burden and we submitted detailed proposals.
Comments of the Czech Republic on the Proposed Delegated Act under Article 7(9) of Regulation (EU) 2025/40 on Packaging and Packaging Waste: The Czech Republic supports the establishment of sustainability criteria based on objective, transparent, and scientifically sound indicators.
Comments of the Czech Republic on the Proposed Delegated Act under Article 7(8) of Regulation (EU) 2025/40 on Packaging and Packaging Waste: The Czech Republic supports the development of a harmonised methodology for calculating and verifying the recycled plastic content in packaging, ensuring a uniform application of the PPWR requirements across the European Union while enabling effective verification of compliance…
Implementation of DNSH principle is problematic, as guidance essentially establishes a sustainability assessment, which may be extensive as well as streamlined to the current climate and environmental legislative framework. There are several methodologies which overlap in their objectives, the scope of application is not coherent between the EU funds legislation.
Comments of the Czech Republic on the Proposed Delegated Act under Article 7(10) of Regulation (EU) 2025/40 on Packaging and Packaging Waste: The Czech Republic considers it important that the requirements for the verification of recycled content in materials and products imported from third countries ensure a high level of credibility of declared information while maintaining a level playing field within the EU…
Czech Republic would like to point out that as a general principle, it is necessary not to raise administrative burden and not to raise excessive requirements to sorting and recycling facilities. The recycling industry is currently under pressure already in Europe and we must make sure that newly emerging rules will support its competitiveness and regrowth.
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