EPR in Slovenia: ARSO, MOPE & SPOT Registers
Where packaging and electronics part company between ARSO and MOPE, and how foreign sellers file
Sell physical goods to buyers in Slovenia and you inherit two separate registration duties, split across two authorities: the environment agency ARSO handles packaging, single-use plastics and fishing gear, while the environment ministry MOPE runs the electronics and battery registers through the SPOT business portal.

At a glance
EPR streams in Slovenia
Each stream carries its own producer duty, register and deadline here.
Active now
· 6- PackagingIn force
- WEEE / electronicsIn force since 4 July 2012
- BatteriesIn force since 18 August 2025
- Single-use plasticsIn force since 3 July 2021
- End-of-life vehiclesIn force since 21 October 2000
- Fishing gearIn force
Upcoming
· 1- TextilesFrom 17 April 2028
Facts last reviewed 17 July 2026
A mixed catalogue - say, a gadget shipped in a cardboard box with a battery inside - can put you in front of both. Underneath that split sits something more unusual: Slovenia has legislated a single national packaging scheme but has not yet switched it on, so the packaging market a seller registers into today is not the one the law now describes.
The single packaging scheme Slovenia legislated but has not switched on
For years, producers placing packaging on the Slovenian market chose among several competing compliance companies, each a druzba za ravnanje z odpadno embalazo (packaging-waste management company). The Environmental Protection Act, known as ZVO-2, replaced that with a single designated scheme. Two incumbent operators - Interzero, formerly Interseroh, and Surovina - challenged the model in the Constitutional Court. While the case ran, the Court referred a question to the Court of Justice of the EU, which answered in 2025, and issued an interim order that kept the existing multi-scheme system running in the meantime.
On 22 January 2026 the Court ruled. It found the single-scheme provisions of ZVO-2 - Articles 37 to 41, 43 and 321 - not unconstitutional. The Constitutional Court's January 2026 packaging ruling settled the legality of the model, but not its start date.
For a seller, the practical position is a split screen: the single scheme is upheld in law but not operational, so you still contract with one of the competing schemes running in parallel. Expect the counterparty you file with to change once the transition completes, and keep your compliance contract reviewable rather than locked for years.
Who the packaging duty reaches, and from what volume
The obligation falls on the producer, which here means the operator that first places packaged goods on the Slovenian market, not necessarily whoever manufactured them. A foreign online seller shipping directly to Slovenian buyers meets that definition as a distance seller. Extended Producer Responsibility works on a polluter-pays basis: whoever puts the material on the market funds its collection, sorting and recycling. If you are unsure where you sit, check which EPR duties apply to you across the common supply-chain models.
On thresholds, treat Slovenia as a register-from-the-start market: it is not understood to grant a small-seller volume exemption on packaging, so do not assume a de minimis allowance without confirming the current position. Foreign sellers also face an access step, since a company with no Slovenian establishment generally cannot file directly. For electronics, the producer or its authorised representative must be entered in the MOPE register before any equipment reaches the market; for packaging, a foreign seller typically works through a local representative or its chosen scheme.
ARSO: packaging, single-use plastics and fishing gear
ARSO (Agencija RS za okolje), operating under MOPE, is the counterparty for three streams.
Packaging is the heavily regulated one, governed by ZVO-2 and the packaging decree UL RS 54/21. There is no flat state levy: you join one of the approved packaging schemes and pay a fee set by the weight you place on the market, broken down by material - paper and board, plastic, glass, wood, metal - then file regular declarations. The fee already rewards recyclable materials and charges more for hard-to-recycle ones, a gap the PPWR will widen with harmonised recyclability grades across the EU. The official Slovenian waste-policy portal hosts the governing texts.
Single-use plastics duties apply under the EU Single-Use Plastics Directive, administered by ARSO with MOPE. The rules ban some items outright - plastic cutlery, plates, expanded-polystyrene food containers - and make producers of others, such as lightweight carrier bags and certain food containers, fund litter clean-up and awareness measures while meeting consumption-reduction targets.
Fishing gear containing plastic is a separate active duty under Article 8 of the same directive, again through ARSO: producers finance the collection, transport and treatment of waste gear delivered to port reception facilities. It rarely touches a general e-commerce catalogue, but it is a live scheme, not a future one.
MOPE and the SPOT portal: electronics, batteries and vehicles
For electronics and batteries you register through the SPOT national business portal, Slovenia's central gateway for corporate administrative procedures.
Electronics (WEEE) duties have applied since 4 July 2012 under decree UL RS 55/15, which transposes the EU WEEE Directive; registration sits in the MOPE-EEO register. You classify equipment by category - small IT, consumer electronics, large appliances - and separate household from commercial supply, because take-back and financing differ between the two. As noted above, the producer or its authorised representative must be registered before selling.
Batteries are governed by the directly applicable EU Batteries Regulation (Regulation (EU) 2023/1542); its producer duties under Article 55 have applied since 18 August 2025, with registration in the MOPE-Baterije register, again through SPOT. It covers every battery type - portable, industrial, automotive and light-means-of-transport packs such as e-bike batteries - with reporting on chemistry and weight, plus collection targets and recycled-content minimums to finance.
End-of-life vehicles carry a producer duty under the EU ELV Directive, applicable since 21 October 2000 and administered by MOPE; it reaches vehicle importers rather than most online sellers. Beyond these streams, Slovenia runs no active EPR scheme for furniture, tyres, graphic paper, toys, DIY and garden products, sports and leisure equipment, construction materials, waste oils or recreational boats, so you can leave those out of scope.
Scheme fees with no state tax, and ARSO and MOPE penalties
Slovenia hands you no single invoice. Packaging costs are the scheme fee, driven by material weight and recyclability, with no government flat tax on top. Electronics and batteries carry their own fee schedules inside the MOPE-EEO and MOPE-Baterije registers, set by category and weight. As a foreign seller you also pay a local representative to hold your mandate and file your declarations.
Enforcement runs on two tracks. ARSO and MOPE can impose administrative penalties for failing to register or report, but the faster pressure usually comes from the marketplaces: Amazon, eBay and comparable platforms ask for valid registration numbers and will suspend listings or block a seller from Slovenian buyers when those numbers are missing. In a market where the packaging counterparty may itself change mid-transition, a lapsed registration is an avoidable way to lose a sales channel.
Why Slovenia still has no beverage deposit scheme
A deposit-return system - a refundable deposit charged on beverage containers and reclaimed when the empty comes back - is a different mechanism from packaging EPR, and joining one would not replace your EPR filings. Several EU neighbours already run one. If and when Slovenia introduces a beverage deposit scheme to meet EU collection targets, you would take part in it on top of reporting your transit and secondary packaging to your packaging scheme, so confirm the current status with your representative rather than assuming either way.
The dates that set your Slovenian compliance calendar
The near-term calendar is driven by the EU packaging overhaul, but Slovenia's own packaging-scheme transition is the milestone to watch closely. These are the dates that fix your duties.
| Date | Milestone |
|---|---|
| 21 October 2000 | End-of-life vehicle producer duties apply under the EU ELV Directive. |
| 4 July 2012 | Electronics (WEEE) duties apply under decree UL RS 55/15. |
| 3 July 2021 | Single-use plastics duties apply under the EU SUP Directive. |
| 18 August 2025 | Battery producer duties apply under EU Regulation 2023/1542, Article 55. |
| 22 January 2026 | Constitutional Court upholds the single packaging-scheme provisions of ZVO-2. |
| 12 August 2026 | The EU packaging regulation (PPWR) applies directly in Slovenia. |
| 17 April 2028 | Mandatory textile EPR applies EU-wide under the revised Waste Framework Directive. |
Reporting the same packaging weights into a moving target - a scheme that may change counterparty mid-transition - is exactly where spreadsheets slip. You can put your EPR reporting on autopilot so your Slovenian filings stay accurate and your listings stay live.
Sources:
- Slovenian government waste-policy portal
- SPOT national business portal
- Constitutional Court packaging ruling (Uradni list RS)
- Revised Waste Framework Directive (EU) 2025/1892
- EU Batteries Regulation (EU) 2023/1542
- Single-Use Plastics Directive (EU) 2019/904
- Packaging and Packaging Waste Regulation (EU) 2025/40
Frequently asked questions
- Does Slovenia use one packaging compliance scheme or several?
- Several, for now. Slovenia has legislated a single designated packaging scheme, and the Constitutional Court upheld that model in January 2026, but it is not yet operational. Producers still contract with one of the competing schemes that continue to run in parallel while the transition completes.
- Do foreign online sellers need an authorised representative in Slovenia?
- For electronics, the producer or its authorised representative must be entered in the MOPE register before any equipment is placed on the market. A foreign seller with no Slovenian establishment generally cannot file directly and works through a local representative or its chosen compliance scheme.
- Is it ARSO or MOPE that runs EPR registration in Slovenia?
- Both. The environment agency ARSO is the counterparty for packaging, single-use plastics and fishing gear, while the environment ministry MOPE runs the electronics (MOPE-EEO) and battery (MOPE-Baterije) registers through the SPOT national business portal.
- Is there a minimum threshold before packaging EPR applies in Slovenia?
- Treat Slovenia as a register-from-the-start market. It is not understood to grant a small-seller volume exemption on packaging, so do not assume a de minimis allowance; confirm the current position before relying on one.
- Does Slovenia have a textile EPR scheme yet?
- Not yet. A mandatory textile extended producer responsibility scheme applies across the EU from 17 April 2028 under the revised Waste Framework Directive, which will bring Slovenian fashion and footwear sellers into scope.