FAQ

Questions about the authorised representative

The authorized representative takes responsibility for all obligations resulting from the legal framework conditions of the foreign supplier.

All obligations can be found in Waste Management Act (OG 84/21), Ordinance on packaging and waste packaging, single-use plastic products and fishing gear containing plastic (OG 137/2023), Ordinance on the management of special categories of waste in the Fund system (OG 124/2023).

Waste Management Act (OG 84/21), Ordinance on packaging and waste packaging, single-use plastic products and fishing gear containing plastic (OG 137/2023), Ordinance on the management of special categories of waste in the Fund system (OG 124/2023).

The Extended Producer Responsibility system is a set of measures taken in the Republic of Croatia to ensure that product producers bear financial or financial and organizational responsibility for the “waste” phase in the product life cycle.

Obliged subjects are product producers  that place their product on the market of the Republic of Croatia.

Foreign mail order companies without a registered office in Croatia that deliver packaging, goods or packaged goods to private end consumers in Croatia within the framework of distance selling are obliged to appoint an authorized representative in Croatia for packaging placed on the market.

In Croatia, producers have legal obligations regarding EPR. According to EPR, the producer is obliged, among other things, to register and submit data to the Register of producers with extended responsibility.

There are no organizations in Croatia and everything is done through the Environmental Protection and Energy Efficiency Fund, which is legal entity with public powers. Interzero Croatia is the authorized representative of foreign companies in order for companies to fulfill their legal obligations to the Fund.

These regulations also apply to companies that sell electrical appliances and batteries in Croatia.

If you don’t sell directly to private end consumers in Croatia you don’t have to license the packaging. In this case, the obligation falls on your Croatian corporate customers. Please inform your (corporate) customers in Croatia that the packaging delivered to them is not licensed. Your customers must then decide for themselves how to proceed. They can either personally declare the waste of the transport packaging to the Environmental Protection and Energy Efficiency Fund, as their own import, or they can hand the packaging over to an EPR system like Interzero.

Yes, you do. Licensing of packaging, WEEE and batteries for a company without a registered office in Croatia is only possible by prior appointing an authorized representative in Croatia, this is independent of the actual quantity you put on the market. You have the option of choosing the flat rate if the yearly quantity is less than 1,500 kg (both in the household and commercial) in the packaging segment.

The authorized representative is a legal representative for your packaging, WEEE and batteries, who must assume your obligations. (You’ll find detailed information on the obligations in the next question.) Keeping in mind your obligations, we recommend that you choose your authorized representative carefully. Interzero is a partner you can trust.

In principle, any natural or legal person can be appointed as an authorized representative, as long as the following criteria are met:

  • Registered office in the Republic of Croatia (domestic VAT number)

No, no matter how high the quantity you place on the market is, in Croatia the licensing of packaging, waste electrical and electronic equipment and batteries is mandatory. If you are not based in Croatia, you must also appoint an authorized representative.

If you have already appointed one and are still looking for a collection and recycling system, you can also conclude a license agreement with us.

You have the option of choosing the all-inclusive solutions, which are also of interest to small-scale distributors.

All obligations can be found in the respective ordinances.

General: Waste Management Act (OG 84/21)

Packaging: Ordinance on packaging and waste packaging, single-use plastic products and fishing gear containing plastic (OG 137/2023)
Batteries: Ordinance on the management of special categories of waste in the Fund system (OG 124/2023).
Waste electrical and electronic equipment: Ordinance on the management of special categories of waste in the Fund system (OG 124/2023).

Yes. The regulations for the authorized representative stipulate that the authorized representative must be a legal person domiciled in Republic of Croatia.

Subsidiary branches that are established within Croatia, must be registered in the commercial register. However, they do not have their own legal personality. Instead, the legal entity remains the natural or legal person behind the main office.

The producer/importer who paid a fee to the Fund during import/production has the right to a refund of the fee in case of product export. For all management fees, in order to exercise the right to a refund, it is necessary to submit a completed prescribed form and attach to it the mandatory supporting documentation: invoice (if it is an bring out) or MRN customs declaration (if it is an export) and other necessary documentation on the basis of which it is possible to determine the data necessary for processing the case (certified specification and other documentation).

Please note that for some fees there is a clearly prescribed deadline for submitting a refund request, and it is necessary to take care of it.

Legally, a company should report retroactively everything they put on the market in Croatia since the period that they started placing/selling on this market.

Please upload your documents to your customer account, or send them to us via email as PDF files. Providing us with hard copies of contractual documentation will lead to a longer processing time. 

Croatian companies can register and report independently, but Interzero can help.

And non-Croatian companies must have an authorized representative in Croatia, for example Interzero.

In this case, you are obliged to register for WEEE, packaging and batteries, report the quantities within the prescribed period and pay the fee for the reported quantities. Since you are a foreign company, you are obliged to fulfill your obligations through an authorized representative, for example Interzero.

We offer our clients a service that covers your needs. Please contact us and we will assign you consultant to discuss your legal obligations.

Yes, as a foreign company, the authorized representative, like Interzero, will act as an intermediary between you and an Croatian EPR system.

The exact provisions on contract withdrawal and cancellation are set out in our Terms and Conditions. By law, there is no right of withdrawal in the B2B sector.

Please note: If you wish to cancel your order, we will charge you the processing fees incurred. You will be refunded the amount less the processing fees. After confirmation, it can take 5-10 business days for the refund to be processed.

The authorization fee can be paid in advance. Current payment methods is Stripe.

In addition, we offer purchase on account. You’ll find the terms of payment on the invoice sent to you.

Definitions: Who needs an authorized representative? 

A foreign manufacturer is any person who distributes packaging in Croatia to consumers others than private end consumers, or any person who sells disposable plastic products commercially in Croatia to other than private end consumers and (ii) has a registered office in another Member State of the European Union.

A foreign mail order company (packaging) is any  legal person without a registered office or branch in Croatia that delivers packaging, goods or packaged goods to private end consumers in Croatia within the framework of distance selling.

A foreign distance seller (disposable plastic products) is any person who sells disposable plastic products, excluding packaging, directly to private end consumers in Croatia on a commercial basis and by means of distance communication, and is established in another Member State of the European Union or in a non-member country.

Questions about packaging, WEEE and waste batteries obligations

Ordinance on packaging and waste packaging stipulates that producers/importers, when placing products packed in packaging on the market of the Republic of Croatia, pay compensation to the Fund namely:

  • waste packaging management compensation for the purpose of covering the costs of collecting and processing waste packaging in the system managed by the Fund
  • the return fee they pay as an incentive measure to encourage the owner to hand over the waste beverage packaging to the seller who has drinks in his offer or to the person who manages the recycling yard and receive the prescribed amount of the return fee.

The producer who is the first to put a product on the Croatian market is obliged to register/report. The business entity listed on the invoice is obliged to register/report. A foreign company cannot perform the above obligations independently, but an authorized representative is required. Interzero Croatia is an authorized representative for its clients.

The Fund has prescribed quarterly and annual reporting. Quarterly reports are submitted to us by the 9th of the current month for the previous quarter, and annual reports by February 15.

In Croatia, there are no threshold values for packaging placed on the Croatian market – obligors must report all quantities, no matter how small.

Currently, labeling obligations are valid in such a way that a producer who places beverages on the market in packaging covered by the refund system is obliged to mark such packaging with a GTIN code in accordance with the GS1 standard and the refund system label. A producer who places returnable (reusable) packaging on the market is obliged to mark such packaging with a mark for returnable packaging. In addition to the above, there are other cases in which there are certain labeling requirements.

Ordinance on the management of special categories of waste in the Fund system prescribes the fee for the management of waste batteries and accumulators as the fee for the management of a special category of waste that the producer is obliged to pay and which serves to finance the costs of the collection and processing of waste portable batteries and accumulators managed by the Fund.

A producer of batteries or accumulators is a legal or natural person – a craftsman, who on a professional basis develops, produces, processes, sells or imports and is the first person to put a battery or accumulator, including those found in devices and vehicles, to the market on the territory of the Republic of Croatia, regardless of the method of sale.

A battery or accumulator is any source of electrical energy produced by the direct conversion of chemical energy and consisting of one or more primary battery cells (which are not intended to be recharged) or one or more secondary battery cells (which are intended to be recharged). Types of batteries or accumulators are: portable batteries and accumulators, industrial batteries and accumulators and car batteries and accumulators (starters).

The invoice will be sent to the email address you provided. In case you have a different billing address, please let us know during the order process.

People paying a flat rate and annual reporters must pay the fee within 14 days of receipt of the invoice in order to be registered as a system participant.

After concluding a contract with Interzero Croatia, you will be requiered to pay 25% avans of your announced yearly quantities .

Monthly and quarterly reporters will receive their invoices within two weeks of submitting their last reports.

The producer of EEE is a legal or natural person – a craftsman who puts EEE on the market in the Republic of Croatia, that is, a person who, regardless of the method of sale:

  • has its business headquarters in the Republic of Croatia and on the territory of the Republic of Croatia resells equipment produced by other suppliers under its own name or trademark, whereby the reseller is not considered a producer if the producer’s name or trademark is on the equipment,
  • has its business headquarters in the Republic of Croatia and produces EE equipment under its own name or trademark, or had EE equipment designed or produced that it sells under its name or trademark within the Republic of Croatia,
  • has its business headquarters in the Republic of Croatia and in the Republic of Croatia on a professional basis puts EE equipment on the market from a third country or from another EU member state or
  • using remote communication, sells EE equipment directly to households or non-household users in the Republic of Croatia, and has its business headquarters in another EU member state or a third country.

A person who has a business seat in another EU member state or a third country, and places EE equipment on the market in the Republic of Croatia, is considered a producer and must authorize in writing a registered person in the Republic of Croatia, for example Interzero, who is responsible as an authorized representative to fulfill the obligations of that producer.

A battery or accumulator is any source of electrical energy produced by the direct conversion of chemical energy and consisting of one or more primary battery cells (which are not intended to be recharged) or one or more secondary battery cells (which are intended to be recharged). Types of batteries or accumulators are: portable batteries and accumulators, industrial batteries and accumulators and car batteries and accumulators (starters).

The Fund has prescribed quarterly and annual reporting. Quarterly reports are submitted to us by the 14th of the current month for the previous quarter, and annual reports by February 25.

WEEE = waste of electrical and electronic equipment that is waste in the sense of the law regulating sustainable waste management in the Republic of Croatia, including all components, sub-assemblies and consumables that form part of the product at the time of disposal.

Ordinance on the management of special categories of waste in the Fund system prescribes, among other things, the fee for WEEE management that is paid by producers and/or importers of EE equipment.

The WEEE management fee is a monetary amount paid by producers of EEE in order to cover the costs of separate collection and processing of WEEE in the system managed by the Fund for Environmental Protection and Energy Efficiency.

The Fund has prescribed monthly reporting. Monthly reports are submitted to us by the 4th of the current month for the previous month.

There are 6 categories with subcategories:

  1. Heat exchange equipment;
  2. Screens, monitors and equipment containing screens larger than 100 cm2;
  3. Light bulbs;
  4. Large equipment (any external dimension greater than 50 cm);
  5. Small equipment (no external dimension is greater than 50 cm) and
  6. Small information technology (IT) equipment and telecommunications equipment (no external dimension exceeding 50 cm).

The producer of EE equipment must ensure that it is clearly and visibly marked with the mandatory separate collection of EE waste. The sign for the separate collection of EE waste consists of a crossed wheelie bin and it must be displayed visibly, clearly and indelibly. If it cannot be shown on the product due to its size, it must be on the packaging, instructions and warranty card of that EE product. A record of the company producing the EE products must also be provided and indicated that it was placed on the market after August 13, 2005.