In the second half of 2026, several regulatory changes will take effect simultaneously for Czech companies. The Packaging and Packaging Waste Regulation (PPWR) will take direct effect on August 12, 2026, but the Czech Republic has not yet adopted an implementing amendment. This means that companies must comply with EU obligations without the support of national implementing legislation. At the same time, a revision of the Waste Framework Directive is underway, the ESPR Ecodesign Regulation is taking effect, and a proposal for the Circular Economy Act is expected in the fall, which is set to rewrite the rules on extended producer responsibility across the entire EU.
The practical impact is immediate, and it’s not primarily about fines. Pressure to provide documentation will come from the supply chain before it comes from regulatory authorities. Customers will begin requiring documentation on the recyclability and composition of packaging long before inspections focus on these issues. A company that does not have the necessary documentation prepared thus risks, above all, losing contracts.
The Regulation on Packaging and Packaging Waste takes effect directly on August 12, 2026. Therefore, the requirements are already in effect. The lack of an implementing amendment complicates the situation: the legislative process is scheduled to begin in the third quarter of 2026, and the Ministry of the Environment has stated that it intends to remain active in the area of secondary legislation as well.
This creates a period of legal uncertainty. Documentation requirements will very soon begin to affect business relationships. For example, retail chains and large manufacturers have their own compliance processes and will not wait for the Czech legislative process to be completed. For suppliers, this means they can expect their first “audit” from their customers.
The legislative process to revise the Waste Framework Directive (WFD) is expected to begin in the third quarter of 2026. This issue is being monitored, among other things, by a working group at the Ministry of the Environment focused on extended producer responsibility for textiles.
Sectors most affected: the textile and apparel industry, textile manufacturers and importers, and entities involved in the collection and processing of textile waste. Companies in these sectors should monitor the development of the EPR for textiles on an ongoing basis, as the system’s implementation will affect their cost structure starting in 2027.
The European Commission has opened registration for consultations on the methodologies of the Ecodesign Regulation (ESPR) and has made the product digital passport registry available, including a test user interface.
For companies, this presents two distinct opportunities. The first is the chance to familiarize themselves with the digital passport format before it becomes mandatory—the test interface allows them to try out the entire concept in a trial run. The second, and in the long term more significant, is the opportunity to influence the methodologies that will be used to assess specific product categories. Companies with a product portfolio in priority categories should therefore consider registering for these consultations.
An amendment to the Packaging Act (Parliamentary Print No. 193) is currently being debated in the Chamber of Deputies. The amendment aims to have authorized packaging companies serve as service providers and intermediaries for other collective systems; the stated goal is to simplify administrative procedures for municipalities.
However, some manufacturers, processors, recyclers, and industry associations point out that this move could pave the way for the gradual centralization of extended producer responsibility systems across different commodity categories. An open letter addressed to the Ministry of the Environment is being drafted in response to the proposal; it is expected to be sent in September 2026.
| Argument | Essence |
| Experience Abroad | In countries that have entrusted EPR to a single concessionaire, there has been repeated and difficult-to-predict increases in fees, which are ultimately borne by consumers. |
| Cost-Effectiveness | The consolidation did not lead to economies of scale, but rather to a shift in margins from the operators to the intermediary. |
| Conflict of Interest | An entity that processes reports from competing collective systems gains access to commercially sensitive data from companies with which it competes in the market. |
| Legal Uncertainty | The European Commission has been leading since the 11th. 6. 2024 Case AT.40775 concerning the functioning of the Czech packaging market (possible conflict with Articles 102 and 106 of the TFEU). |
| Timing | Any national legislation adopted now would have to be revised again in about two years due to the Circular Economy Act. |
For an ordinary company, one consequence is particularly important: the structure of EPR administration will directly affect future compliance costs. Therefore, even companies that do not normally deal with legislation should keep a close eye on developments regarding Parliamentary Document No. 193.
The release date for the draft Circular Economy Act (CEA) has changed repeatedly throughout the year. It is currently expected in the fourth quarter of 2026. The proposed content includes the harmonization of internal market rules in the area of circularity, the introduction of the so-called EPR One-Stop Shop (a unified digital interface for fulfilling EPR obligations across member states), and the expansion of mandatory EPR systems to additional commodities, with furniture being specifically mentioned.
The key sectors expected to be affected are packaging, electronics, chemicals, construction, transportation, and textiles. For exporting companies, a unified interface could mean a reduction in administrative burdens. At the same time, these are new rules for everyone, and it is important to monitor how the proposal can be influenced. Advocacy efforts regarding the CEA are shifting from the national level to the European Commission. Input must therefore be provided earlier and through different channels, typically via industry associations and European consultations.
A related topic is the financing of the transition. With regard to the Modernization Fund, new information has come to light—along with the ETS review—about its continuation beyond 2030. A shift toward financial instruments and a smaller share of direct subsidies is expected. Companies planning long-term investments in decarbonization should take this shift into account.
There has been mixed feedback regarding the current support for corporate self-consumption photovoltaic systems: while there is interest in continuing the program, there is also criticism that part of the support to date has gone to projects that would have been implemented even without it. Similarly, regarding the National Development Bank’s instruments, feedback from companies indicates that the current photovoltaic loan product primarily finances companies that would have been able to secure a standard loan anyway, and thus does not broaden access to financing. There is a lack of focus on higher-risk companies and less developed regions, an issue of direct relevance to the Moravian-Silesian Region and other structurally disadvantaged regions.
The Industry Acceleration Act (IAA) is a separate issue . The discussion focuses on how to structure the conditions for public support so that smaller and less-established firms can also benefit from it, rather than just large, well-established companies. This is precisely where feedback from small and medium-sized enterprises is most valuable—specific barriers to accessing support can serve as an important basis for the legislative process.
| Date | What’s Going On | Who is affected |
| 12. 8. 2026 | The PPWR has taken direct effect; the Czech Republic has not adopted an adaptation amendment. | Manufacturers and importers who place packaging on the market. |
| Q3 2026 | Launch of the legislative process for the amendment to the PPWR. | Packaging industry, fillers, retail. |
| Q3 2026 | Launch of the legislative process to revise the WFD. | Textile industry, waste sector. |
| On an ongoing basis | ESPR Consultation on Methodologies and Testing Interfaces for Digital Product Passports. | Manufacturers in priority product categories. |
| 11. 9. 2026 | Climate Week Prague – Climate Risks and Biodiversity; Seeking Speakers from Companies. | Companies with ties to the countryside, natural resources, and the financial sector. |
| 17. 9. 2026, 9:00 a.m.–12:00 p.m. | Climate Week Prague – IAA event (Deloitte): keynote address, position statement, roundtable discussion with the Ministry of Industry and Trade, companies, and city representatives. | Industrial companies, clean-tech firms, municipalities. |
| September 2026 | Planned submission of an open letter regarding the amendment to the Packaging Act to the Ministry of the Environment. | Manufacturers, processors, recyclers, collective management systems. |
| 13. 10. 2026 | Online Public Affairs: An Overview of the ” Change for the Better” Platform. | Membership Base and Partners. |
| Q4 2026 | The anticipated draft of the Circular Economy Act. | Packaging, electronics, chemicals, construction, transportation, textiles. |
| After 2030 | Modernization Fund – A Shift Toward Financial Instruments. | Companies planning to invest in decarbonization. |
Download this handy infographic with an overview of recommended steps and important deadlines for SMEs.
Feedback from small and medium-sized enterprises can influence the shape of European legislation. Through the SME Feedback channel of the Enterprise Europe Network, companies’ specific experiences are conveyed directly to the drafters of European regulations. Experiences with administrative burdens, unclear requirements, or a lack of support can thus serve as important input for amending these rules.
You can currently provide feedback on the draft implementing regulation for the Packaging and Packaging Waste Initiative —rules regarding national registers of producers. You may submit your comments by September 10, 2026.
Do you have any personal experience with this topic or suggestions that should be considered when drafting the rules? The EEN Czechia advisors will be happy to help you provide feedback.
This article is based on a regulatory overview prepared by the Moravian-Silesian Innovation Center as a partner of the EEN Czechia consortium. The text is based on a Public Affairs meeting of members of the “Change for the Better” business platform held on August 11, 2026. The information is current as of August 13, 2026—the timelines for legislative processes at both the EU and Czech Republic levels are subject to change. This article is for informational purposes only and does not constitute legal advice.
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