Croatia Packaging EPR and Deposit System Guide 2026

Croatia’s packaging compliance framework combines Extended Producer Responsibility, producer registration, packaging reporting, waste-management fees, technical packaging requirements, and a national Deposit Return System for beverage containers.

Businesses placing packaging or packaged products on the Croatian market may need to:

• Register in the Register of Producers with Extended Responsibility
• Report packaging placed on the Croatian market
• Pay waste-management fees
• Maintain material and weight records
• Appoint a Croatian representative for certain distance sales
• Register beverage packaging before market placement
• Apply a GTIN and the official deposit-system mark
• Pay the deposit amount for covered beverage containers
• Maintain technical and substance-compliance evidence
• Track reusable packaging separately
• Prepare for additional PPWR requirements

Croatia’s main national framework includes the Waste Management Act, the 2023 Ordinance on packaging and waste packaging, single-use plastic products and fishing gear containing plastic, and the 2024 Regulation on waste-management and deposit fees. The Environmental Protection and Energy Efficiency Fund, commonly referred to as FZOEU, operates the RPPO and plays a central role in packaging-fee and Deposit Return System administration.

Croatian packaging obligations now also operate alongside Regulation (EU) 2025/40, the EU Packaging and Packaging Waste Regulation. The PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026, although many individual requirements have later application dates.

For companies selling in Croatia, packaging compliance therefore requires both national EPR and deposit-system readiness and a wider EU PPWR compliance process.

These obligations are drawn from the Croatian packaging ordinance, the fee regulation, and current FZOEU implementation guidance.

Extended Producer Responsibility, or EPR, means that the producer placing packaged products on the Croatian market bears responsibility for contributing to the management of the resulting packaging waste.

Croatian producers and importers generally meet this responsibility by registering and reporting their packaging and paying a waste-management fee to FZOEU. The Fund then uses the system to support the collection and treatment of packaging waste and the achievement of national waste-management objectives.

Packaging EPR can therefore require a company to:

• Identify its producer role
• Register in the RPPO
• Maintain packaging records
• Report packaging by material and quantity
• Pay material-based waste-management fees
• Report exports and market withdrawals correctly
• Maintain evidence supporting packaging quantities
• Report reusable packaging separately
• Meet deposit-system requirements for covered beverages
• Retain technical compliance documents

The obligation is not limited to companies manufacturing empty packaging. It can also affect businesses that manufacture, import, introduce, distribute, or place packaged products on the Croatian market.

A producer assessment should focus on the legal entity and supply-chain activity that results in a packaged product being placed on the Croatian market.

Businesses that may have producer obligations include:

The Croatian ordinance defines import broadly to cover entry from another EU Member State or from a third country, whether the goods are obtained for commercial activity or for the business’s own use.

Companies should assess the actual movement of goods rather than relying only on contract terms. The producer role may differ depending on who imports, packs, sells, or supplies the product to the Croatian market.

A business established in another EU Member State or a third country can become a Croatian packaging producer when it sells packaged products directly to Croatian consumers exclusively through distance contracts.

In this situation, the foreign seller must appoint, in writing, a legal or natural person registered in Croatia to act as its authorised representative and fulfil the producer’s packaging obligations.

The representative arrangement should cover:

• RPPO registration
• Packaging quantity reporting
• Waste-management fee administration
• Deposit-fee reporting where relevant
• Authority and FZOEU communication
• Packaging-data access
• Record retention
• Reporting corrections
• Changes to the seller’s products or market activity

FZOEU requires representatives of foreign producers to upload evidence of their authority when registering through the RPPO. Where one representative acts for several foreign producers, registration must be completed separately for each producer.

A foreign seller should complete this process before beginning direct consumer sales into Croatia.

Croatian rules can also affect online platforms.

A platform that facilitates the sale of packaged products from producers not registered in the RPPO can, in defined circumstances, be treated as the producer for the relevant quantities and become responsible for fulfilling the unregistered seller’s obligations.

A platform without a Croatian establishment may also need to appoint a registered person in Croatia as its authorised representative.

Online marketplaces should therefore consider:

• Collecting sellers’ RPPO registration numbers
• Checking whether a foreign seller has a Croatian representative
• Mapping products to the Croatian destination market
• Maintaining packaging material and weight data
• Preventing sales by unregistered obligated producers
• Retaining seller declarations and registration evidence
• Including packaging compliance in seller onboarding
• Updating records when a seller changes its legal entity or supply model

This becomes particularly important where the platform controls fulfilment or adds e-commerce packaging to the product.

Croatian packaging obligations can cover packaging at multiple levels.

Packaging to include in the assessment

The packaging ordinance requires producers to maintain information about products in packaging, where those products were acquired or supplied, packaging quantities by material, and quantities exported, removed from Croatia, or withdrawn from the market.

A complete packaging inventory should therefore include more than the visible consumer container.

The Register of Producers with Extended Responsibility, or RPPO, is Croatia’s electronic database for producers, products, and quantities placed on the market.

FZOEU introduced mandatory digital RPPO reporting for relevant products and packaging from 1 January 2025, replacing the previous email and postal reporting process. The system covers single-use packaging, reusable packaging, and other regulated product streams.

The RPPO records:

• Producer identity
• Product and packaging information
• Quantities placed on the Croatian market
• Packaging materials
• Fee-related information
• Reusable packaging information
• Deposit-system packaging data
• Representative information for foreign producers

When a user first enters the RPPO, the system assigns a unique registration number after the user accepts the applicable conditions.

For single-use packaging, the accounting period is one month.

Producers must submit packaging data through the RPPO by the twentieth day of the current month for the previous month. Payment of the resulting waste-management fee is due by the end of that current month.

Example

Packaging placed on the Croatian market during July must generally be:

• Reported through the RPPO by 20 August
• Paid by the end of August

Reusable packaging follows a different schedule. It is reported annually by 20 January for the preceding calendar year.

Reporting calendar

FZOEU also requires annual information on recycled plastic used in relevant single-use beverage products by 1 March.

Companies should maintain packaging data monthly, even where a specific information set is submitted annually.

A compliant Croatian packaging dataset should link products, packaging components, materials, quantities, markets, and evidence.

Recommended packaging master data

The data should be version-controlled so the packaging weight and material used in an RPPO report match the packaging actually supplied during the relevant month.

A basic quantity calculation is:

Packaging weight per unit × units placed on the Croatian market

Example

Each material should be reported under the correct RPPO category.

Suitable weight evidence includes:

• Supplier packaging specifications
• Packaging bills of materials
• Technical drawings
• Controlled weighing records
• Packaging converter declarations
• Manufacturing specifications
• Approved engineering calculations

Where an estimate is used, the company should document the method, sample, packaging version, and review frequency.

Producers placing packaged products on the Croatian market must contribute to packaging waste management through material-based fees.

The fee is intended to support the collection and treatment of packaging waste in the EPR system managed by FZOEU. The current legal framework applies calculations based on packaging material and mass, together with the applicable eco-modulation and reporting coefficients.

The fee regulation contains material categories including:

• PET
• Glass
• Aluminium cans
• Steel cans
• Multilayer beverage packaging
• Other multilayer packaging
• Paper and cardboard
• Wood
• Textile packaging
• Other polymer materials
• Plastic bags

Current rates and FZOEU decisions should be checked before preparing financial forecasts because unit fees and eco-modulation rules may be updated. The producer remains responsible for maintaining the weight and material data needed to support the calculation.

A producer can request repayment of waste-management or deposit amounts where the product or packaging is subsequently exported, removed from Croatia, or withdrawn from the Croatian market.

The refund is based on an application to FZOEU, information recorded in the RPPO, and evidence proving the export, removal, or withdrawal.

Recommended export evidence

• Commercial invoices
• Delivery records
• Customer and destination information
• Customs records where applicable
• Product and packaging quantities
• Transport documents
• RPPO transaction records
• Credit notes or withdrawal records

The methodology should prevent the same packaging from being both deducted as an export and reported as placed on the Croatian market.

Croatia has operated a Deposit Return System for beverage packaging since 2006.

The system uses a refundable deposit to encourage consumers to return eligible empty beverage containers separately from other waste. Returned packaging is delivered to participating retailers or recycling yards, and the consumer receives the prescribed refund.

For businesses, DRS compliance can affect:

• Product registration
• Packaging artwork
• GTIN management
• Deposit charging
• Monthly reporting
• Fee payment
• Retail returns
• Packaging samples
• Import procedures
• Stock transition
• Export adjustments

During the current transitional period ending on 31 December 2026, the Croatian deposit system covers one-way beverage packaging:

• Made from PET
• Made from glass
• Made from aluminium or steel
• With a volume of at least 0.20 litres
• With a volume of no more than 3 litres
• Carrying the official Croatian Deposit Return System marking

This transitional scope is established by the 2024 fee regulation and is reflected in current FZOEU implementation information.

Businesses should assess the product and packaging combination rather than treating every bottle, jar, or can as deposit-bearing.

The transitional rule for PET, glass, and metal packaging of 0.20 to 3 litres applies only until the end of 2026.

Under the broader rule that applies after the transitional period, the Deposit Return System covers qualifying single-use beverage packaging made from:

• Plastic
• Glass
• Metal
• Multilayer composite material with a predominantly paper-cardboard component

The general upper capacity is 3 litres. Beverage cups and any packaging types specifically determined by FZOEU as unsuitable for collection are excluded.

Companies selling beverage cartons or packaging below 0.20 litres should prepare now for the post-2026 scope and monitor FZOEU instructions on registration, labelling, and system acceptance.

The refundable deposit is €0.10 per eligible beverage packaging unit.

The €0.10 amount took effect on 1 January 2025 under the Croatian Regulation on waste-management and deposit fees.

The deposit is separate from the producer’s packaging waste-management fee. A producer of a covered beverage package may therefore need to manage:

1. The material-based waste-management fee
2. The refundable deposit amount
3. Other applicable packaging or product-specific obligations

The producer must report the number of covered packaging units placed on the Croatian market and any quantities exported or removed from the Croatian market by the applicable monthly deadline.

A beverage producer must register a new covered product through the RPPO before placing it on the Croatian market.

The producer must submit information on:

• The producer
• The beverage product
• The packaging
• The product’s GTIN
• Relevant packaging characteristics

This information must be submitted no later than 14 days before market placement. The same obligation applies where the GTIN of an existing product changes.

After the electronic submission, the producer must provide FZOEU with:

• A physical sample of the packaging unit
• A printed list of the beverages submitted through the RPPO

FZOEU checks the packaging against the applicable marking requirements.

This registration period should be included in the product-launch timeline. Packaging should not be printed, imported in bulk, or distributed before the artwork, GTIN, and deposit marking have been validated.

Covered beverage packaging must carry:

1. A GTIN compliant with the GS1 standard
2. The official Croatian Deposit Return System mark

The same GTIN must not be used simultaneously for single-use and reusable versions of the packaging. The deposit mark must appear on the primary beverage packaging and not only on the secondary carton or grouped package.

Artwork-control checklist

A beverage that is not placed on the Croatian market under the DRS must not carry the Croatian deposit-system mark.

Croatia does not require general packaging material codes in the same way that it requires the DRS mark for deposit-bearing beverages.

A producer may voluntarily identify packaging materials using the European identification system under Decision 97/129/EC. When these material codes are used, they must follow that system.

This distinction is important:

Companies should not copy material codes or recycling symbols from similar packaging without confirming the actual material composition.

Retailers selling beverages in premises of 200 square metres or more must accept eligible waste beverage packaging.

Recycling-yard operators must also accept covered deposit packaging. A wholesaler offering beverages must enable its customers to return eligible beverage packaging regardless of the size of its sales area. Smaller retailers may participate voluntarily if they meet the necessary space and safety conditions.

Return-point obligations at a glance

The Croatian ordinance permits a retailer or recycling yard to limit mandatory acceptance to 80 packaging units per person per day, although it may choose to accept a greater quantity.

To support identification and refund, eligible packaging should normally be:

• Empty
• Not crushed or destroyed
• Not excessively contaminated
• Marked with the correct DRS symbol
• Marked with a readable barcode
• Identifiable as a registered Croatian deposit package

FZOEU return instructions state that the deposit mark and barcode must remain visible and readable.

Businesses should communicate these conditions clearly to consumers, retailer staff, and logistics partners.

Reusable or returnable packaging follows a separate compliance pathway.

A producer placing products on the Croatian market in reusable packaging must ensure its return and reuse through a deposit arrangement or another effective return mechanism. The producer must maintain records of:

• Reusable packaging placed on the market
• Packaging returned for reuse
• Reusable packaging exported for reuse
• Packaging reaching the end of its life and handed over for treatment

Reusable packaging must also carry the prescribed reusable-packaging mark.

Reusable packaging data is reported annually through the RPPO by 20 January for the previous calendar year. FZOEU may assume responsibility for collection and management at the producer’s cost where the producer does not ensure the required return and reuse.

A producer operating a return-and-reuse system must notify FZOEU and provide information about how the system operates.

Croatian EPR registration and fee payment do not replace the technical requirements applying to packaging.

Packaging placed on the Croatian market must meet essential requirements relating to:

• Manufacturing and composition
• Packaging minimisation
• Reuse suitability
• Recovery and recycling suitability
• Restricted substances
• Consumer information
• Applicable marking

The Croatian packaging ordinance requires packagers and producers to place only packaging that meets essential production, composition, reuse, and recovery requirements.

Companies should maintain technical evidence separately from their financial and RPPO reporting records.

The combined concentration of:

• Lead
• Cadmium
• Mercury
• Hexavalent chromium

must generally not exceed 100 mg per kilogram of packaging material, subject to specific legal exceptions for certain glass packaging and controlled-loop plastic crates and pallets.

The packaging supplier must provide an appropriate certificate in Croatian. For packaging sourced from another EU Member State, the producer may instead maintain a Croatian-language Declaration of Conformity supported by suitable documentation. This evidence must be available to the State Inspectorate on request.

Recommended evidence file

• Packaging material specification
• Packaging component list
• Heavy-metal certificate
• Croatian Declaration of Conformity where applicable
• Supporting test report
• Supplier identity
• Manufacturing site
• Effective date
• Packaging version
• Supplier change notification

The evidence should be reviewed whenever the material composition, supplier, pigment, coating, ink, or recycled input changes.

Croatian rules already contain recycled-content requirements for certain single-use beverage bottles.

PET beverage bottles within the applicable single-use-plastics category must contain an average of at least 25% recycled plastic from 2025. From 2030, relevant beverage bottles must contain an average of at least 30% recycled plastic.

Producers must also submit annual information on recycled plastic content by 1 March for the preceding year.

Data to maintain

• Bottle material
• Bottle weight
• Recycled plastic percentage
• Supplier declaration
• Calculation method
• Verification evidence
• Total bottles placed on the Croatian market
• Weighted annual average
• Reporting record

These Croatian obligations will need to be aligned with the broader calculation and verification methodology developed under the PPWR.

Croatian rules also require relevant single-use beverage containers with plastic caps or lids to be designed so the cap or lid remains attached during the intended use stage.

The requirement applies to the beverage-container categories specified in the national implementation of the EU Single-Use Plastics framework.

Beverage producers should therefore control:

• Bottle and cap design
• Closure supplier
• Applicable harmonised standard
• Packaging-line compatibility
• Technical drawings
• Supplier evidence
• Artwork and GTIN version

A closure redesign may affect packaging weight, RPPO reporting, recyclability, technical evidence, and DRS registration.

From 12 August 2026, Croatia’s existing EPR and DRS processes operate alongside the PPWR.

The PPWR introduces or strengthens requirements concerning:

• Packaging substances
• Recyclability
• Recycled content
• Compostable packaging
• Packaging minimisation
• Excessive empty space
• Harmonised labelling
• Restricted packaging formats
• Reuse and refill
• EU technical documentation
• EU Declarations of Conformity
• Producer registration
• Online marketplace checks

The PPWR regulates packaging throughout its life cycle, including production, use, and waste management.

Paying Croatian packaging fees does not automatically prove that the packaging meets PPWR design, labelling, recycled-content, or documentation requirements.

Companies should use the same controlled packaging dataset for both national EPR reporting and PPWR conformity work.

Step 1: Map the supply chain

Identify:

• Croatian entities
• Manufacturers
• Packers and fillers
• Importers
• Distributors
• Foreign distance sellers
• Online platforms
• Retailers
• Beverage producers
• Fulfilment providers

Step 2: Determine producer responsibility

Document which entity places each packaged product on the Croatian market and why it is considered responsible.

Step 3: Appoint a representative where required

Foreign distance sellers should establish the written Croatian representative mandate before beginning sales.

Step 4: Register in the RPPO

Complete producer registration and assign authorised users and reporting responsibilities.

Step 5: Build a packaging inventory

Include:

• Sales packaging
• Grouped packaging
• Transport packaging
• E-commerce packaging
• Service packaging
• Reusable packaging
• Labels, caps, sleeves, films, and pallets

Step 6: Create a packaging bill of materials

Record the material and weight of every packaging component.

Step 7: Create monthly reporting controls

Connect Croatian sales and import quantities to the approved packaging weights.

Step 8: Prepare the fee process

Confirm current material categories, applicable fee rules, internal approval, and payment deadlines.

Step 9: Identify DRS products

Review beverage type, packaging material, capacity, GTIN, market, and deposit-system marking.

Step 10: Register new beverage packaging

Submit the RPPO beverage record and packaging sample at least 14 days before market placement.

Step 11: Review retailer obligations

Confirm whether return points, staff procedures, storage, or reverse vending arrangements are required.

Step 12: Manage reusable packaging

Track quantities placed on market, returns, reuse, exports, and end-of-life treatment.

Step 13: Maintain technical evidence

Collect essential-requirement, heavy-metal, recycled-content, closure, and supplier documentation.

Step 14: Prepare for PPWR requirements

Assess recyclability, recycled content, minimisation, labelling, technical documentation, reuse, and future EPR registration requirements.

Step 15: Control changes

Reassess compliance whenever there is a change to:

• Packaging material
• Packaging weight
• Supplier
• GTIN
• Artwork
• Deposit status
• Sales route
• Legal entity
• Country placement
• Packaging version

Croatian packaging compliance requires connected information across producers, legal entities, packaging components, materials, suppliers, RPPO reports, fees, beverage registrations, deposit labels, and PPWR requirements.

ComplyMarket’s packaging compliance approach supports businesses in identifying market-specific obligations, linking requirements to packaging items and products, collecting supplier evidence, controlling documentation, and preparing structured compliance reports.

ComplyMarket can help companies manage:

• Croatia packaging EPR applicability assessments
• Producer and importer responsibility mapping
• Foreign distance-seller and representative requirements
• Packaging inventories and bills of materials
• Packaging component, material, and weight data
• Product-to-packaging mapping
• Supplier specifications and declarations
• RPPO registration records
• Monthly packaging reporting inputs
• Waste-management fee data
• Import, export, and market-withdrawal records
• Beverage DRS scope assessments
• GTIN and deposit-label evidence
• Beverage registration and packaging-sample records
• Reusable packaging data
• Heavy-metal and conformity documentation
• Recycled-plastic evidence
• Packaging version and change control
• PPWR readiness assessments
• Audit-ready compliance records

ComplyMarket’s EPR management framework also focuses on jurisdiction-based producer control, quantity and category management, standardised data collection, evidence management, reporting workflows, and country-specific market readiness.

For companies managing many products, suppliers, and European markets, this creates one controlled packaging-data process rather than separate spreadsheets for RPPO reporting, deposit registration, technical evidence, and PPWR assessments.