Waste management for companies — complete guide under Act No. 79/2015 Coll. (2026)
A practical guide to waste management for companies: waste producer and waste holder, Waste Catalogue, records under § 14, reporting via ISOH and the change under Decree 89/2024 (postponed to 2027), extended producer responsibility, hazardous waste, SIŽP supervision and penalties.
What is waste management and who it applies to
Waste management is the set of activities aimed at preventing waste generation and at handling waste from the point of its creation through to final recovery or disposal. For businesses this is not a voluntary matter — the obligations flow directly from Act No. 79/2015 Coll. on waste and its implementing decrees. They apply to virtually every business operator: from a production facility, a construction company, a car-repair workshop and a restaurant to a small office that generates nothing more than a spent toner cartridge or worn-out electronics.
The logical backbone of the whole area is the waste management hierarchy under § 6 of Act No. 79/2015 Coll.: prevention of waste generation first, then preparation for re-use, recycling, other recovery (for example energy recovery) and only as a last resort disposal (landfilling). A company should embed this hierarchy in its internal procedures — not only because the law requires it, but also because higher steps in the hierarchy are generally cheaper.
Waste producer versus waste holder (§ 4)
Two concepts determine who bears the obligations. The waste producer is the party whose activity generates the waste (typically your company in its own operations). The waste holder is the waste producer or a person who has possession of the waste — the producer is therefore always also the first holder. The practical consequence: you cannot shed responsibility by simply “passing the waste on”. You may hand it over only to a person authorised to handle that type of waste; if you hand it to someone without an authorisation, the responsibility and the risk of a penalty remain with you.
Five core obligations of a company as waste producer
Regardless of company size, the obligations can be summarised under five pillars, derived primarily from § 14 of Act No. 79/2015 Coll.:
- Classify the waste correctly — assign it a catalogue number and category (non-hazardous O / hazardous N) in accordance with the Waste Catalogue.
- Collect waste separately by type, with hazardous waste kept separate from non-hazardous waste and secured against escape.
- Keep ongoing records of the types and quantities of waste and of its handling.
- Hand waste over only to an authorised person and retain proof of handover.
- Report the data from the records to the relevant authority (annual report, and in future on an ongoing basis to ISOH).
In specific cases these five are supplemented by further obligations: drawing up hazardous-waste identification sheets (ILNO), maintaining an operating rules document for the waste storage area, obtaining consents and registrations, and, when placing designated products on the market, complying with extended producer responsibility (RZV).
Waste classification and the Waste Catalogue
Every waste item must be assigned a six-digit catalogue number from the Waste Catalogue. The Catalogue is hierarchical: the first two digits indicate the group according to the sector or process of origin, further pairs narrow down the sub-group and the specific type. Correct classification is not a formality — it determines the category, the handling method, the records requirements and the collection price.
Waste is either non-hazardous (O) or hazardous (N). Some Catalogue entries are so-called mirror entries — they can be O or N depending on whether they contain hazardous substances above threshold values and on the so-called hazardous properties. Typical hazardous wastes in companies: used oils and lubricants, packaging contaminated with hazardous substances, solvents, batteries, fluorescent lamps, e-waste with hazardous components. Rule of thumb: if the input material had hazard pictograms and a safety data sheet, its waste or contaminated packaging will most likely be hazardous.
Waste records under § 14
Records are the “bookkeeping of waste”. They are kept on an ongoing basis — at every generation and every movement of waste, not just once a year at the time of reporting. The format and templates currently derive from Decree No. 366/2015 Coll.: for each type of waste a record sheet is maintained, in which the generation, quantity, handling method and the party to whom the waste was handed over are recorded. Recordkeeping also includes archiving — documents are generally retained for 5 years.
Practice is gradually moving to software tools (so-called ELO applications), which maintain records electronically and can export data in a format suitable for ISOH. Even though software eases the work, responsibility for the accuracy of the data remains with the company. The most common errors: an incorrect or missing catalogue number, incomplete handover records, missing documentation from the collection company, and backdating records retroactively just before an inspection.
ISOH and the major change 2025 → 2026 → 2027
This is a topic where most publicly available materials are out of date — and where a company most easily makes a mistake. ISOH (the Waste Management Information System) is the central state system of the Ministry of the Environment of the Slovak Republic, designed to digitalise waste management services, consolidate records and registers in one place and simplify reporting.
Decree 89/2024 versus 366/2015 — what was supposed to change
The new records and reporting decree is Decree No. 89/2024 Coll., which was to replace the existing Decree No. 366/2015 Coll. from 1 January 2026. The biggest announced change was the introduction of ongoing (quarterly) electronic records in ISOH: instead of a single annual summary report, companies would report every handover, receipt, recovery and disposal of waste on an ongoing basis — by the end of the month following the close of the quarter — and the records of hazardous-waste transport would be digitalised (electronic hazardous-waste consignment note, SLNO).
Postponement to 2027 (amendment Decree 369/2025) — what actually applies in 2026
The effective date of this "in-depth" change was postponed. Decree 89/2024 was amended by Decree No. 369/2025 Coll. (published in the Collection of Laws in December 2025), which shifts the launch of full ongoing electronic records and quarterly reporting to ISOH to 2027 at the earliest. The reason is that the ISOH system was not ready to receive ongoing data in full scope on a quarterly cycle.
- Until 31 December 2026 companies have no obligation to keep electronic records under the new Decree 89/2024, nor any obligation to make quarterly reports to ISOH.
- In 2026 the existing regime continues — records and reporting under the current regime (Decree 366/2015).
- Full transition to ongoing electronic records is expected from 2027 — the date and scope may still be refined based on official outputs from the Ministry of the Environment of the Slovak Republic.
Competitors' materials and older articles frequently state that ongoing records "from 2026" apply, or cite only 366/2015. The correct position for 2026 is: the 366/2015 regime continues and the full change has been postponed to 2027 by amendment Decree 369/2025. Up-to-date accuracy is precisely what distinguishes a reliable source from an outdated one.
Annual report on waste generation and handling
While the current regime remains in force, the key annual obligation is the report on waste generation and handling. It is submitted for the preceding calendar year, generally by 28 February, and in the current period is submitted electronically via ISOH.
The reporting obligation does not arise automatically for everyone — it is tied to exceeding a quantity threshold. Under § 3 of Decree No. 366/2015 Coll. the threshold is more than 50 kg of hazardous waste or more than 1 tonne of non-hazardous waste per year. Even if you do not have a reporting obligation at low quantities, the obligation to keep records always applies — the threshold relates to reporting, not to recordkeeping itself.
Canonical paragraphs, deadlines, thresholds and RZV streams
| Area | Regulation | Value / deadline / threshold |
|---|---|---|
| Waste Act (framework) | Act No. 79/2015 Coll. | umbrella regulation |
| Waste producer and waste holder | § 4 z. 79/2015 | definitions |
| Waste management hierarchy | § 6 z. 79/2015 | prevention → … → disposal |
| Basic obligations of the holder | § 14 z. 79/2015 | classification, records, handover |
| Keeping records (templates) | Decree 366/2015 Coll. | ongoing record sheet |
| Archiving records | Decree to Act 79/2015 | generally 5 years |
| Storage before disposal | § 14 ods. 1 písm. i) | maximum 1 year |
| Storage before recovery | § 14 ods. 1 písm. i) | maximum 3 years |
| Annual report + threshold | Decree 366/2015 § 3 | by 28 Feb; > 50 kg hazardous / > 1 t non-hazardous/year |
| New records decree | Decree 89/2024 Coll. | replaces 366/2015; effective date postponed |
| Postponement of ongoing records | Decree 369/2025 Coll. | quarterly records to ISOH deferred to 2027 |
| Extended producer responsibility | § 27 z. 79/2015 | designated streams (see below) |
| Supervision | z. 79/2015 | district office (env. dept.) + SIŽP |
| Penalties | § 117 z. 79/2015 | €500 – 50,000 for records violations |
Extended producer responsibility (RZV) and OZV
Extended producer responsibility (RZV) under § 27 of Act No. 79/2015 Coll. means that anyone who places so-called designated products on the Slovak market is also responsible for their entire life cycle, including the phase when they become waste — both financially and organisationally (collection, take-back, recovery, public awareness, meeting collection targets). RZV covers six designated streams:
- packaging,
- non-packaging products,
- electrical equipment and e-waste,
- batteries and accumulators,
- vehicles (end-of-life vehicles),
- tyres.
Beware of a common misconception: you are a producer of a designated product even when you import goods from abroad and place them on the Slovak market for the first time (including e-shops and the import of packaging). RZV obligations may be fulfilled individually or — in practice almost always — collectively through a producer responsibility organisation (OZV), with which the producer enters into a contract and pays recycling fees. This also requires registration in the Register of Producers of Designated Products and regular reporting of quantities placed on the market.
Hazardous waste in practice — ILNO, storage, transport
- ILNO (hazardous-waste identification sheet) — an identification sheet is drawn up for each type of hazardous waste and placed at its collection point. It contains the name, catalogue number, hazardous properties, instructions in the event of a spill and first-aid measures.
- Collection and storage — hazardous waste is collected separately, in labelled and secured containers, protected against escape. Deadlines: storage for a maximum of 1 year before disposal and a maximum of 3 years before recovery.
- Transport — recorded by means of a hazardous-waste consignment note (to be replaced in future by its electronic form, SLNO in ISOH). When transported outside Slovak territory, the cross-border waste transport regime applies, and ADR rules for the road transport of dangerous goods apply separately.
Hazardous waste is also the most common intersection with other company agendas — in particular with BOZP (chemical risks, personal protective equipment), fire protection (flammable waste) and the occupational health service (employee exposure).
Supervision and penalties — who inspects and what you face
State supervision in waste management is carried out by the district office (department of environmental protection) and the Slovak Environmental Inspection (SIŽP). They inspect records, reports, documentation and the actual handling of waste. Inspections most often focus precisely on the ongoing nature and verifiability of records and on proof of handover of waste to an authorised person.
Penalties are governed by § 117 of Act No. 79/2015 Coll. For failure to keep or incorrectly keeping records, a fine in the range of €500 to 50,000 is faced; for incorrect handling of hazardous waste and more serious breaches the ranges are higher. Beyond the direct fine, a loss of reputation, problems with public procurement and certifications (ISO 14001) and in extreme cases a restriction of operations are also at stake.
Most common myths about waste in companies
- "We don't generate waste, so this doesn't apply to us." A company becomes a waste producer for everything it discards — from a toner cartridge to electronics. The recordkeeping obligation arises regardless of quantity.
- "An external company takes away our waste — they deal with it." The collection company takes the waste, but generally does not keep your records or file your reports. The producer's responsibility remains with you.
- "It is enough to do the records once a year before reporting." Records are kept on an ongoing basis with every movement of waste. Retroactive compilation is a frequent reason for a penalty during an inspection.
- "Ongoing records to ISOH apply from 2026." Full ongoing records were postponed to 2027 by amendment Decree 369/2025. In 2026 the current regime under 366/2015 applies.
- "Fines are issued by the district office as in construction." In waste management, state supervision and the imposition of fines are carried out primarily by SIŽP and the district office, department of environmental protection.
Practical advice — what a company should do in 2026
The postponement of ongoing records to 2027 is not a reason to do nothing — it is time to prepare. Recommended course of action:
- Get waste classification and ongoing records in order under the current regime.
- Test a software tool for records with export to ISOH.
- Check access credentials and registration for ISOH and proof of waste handover.
- Map which waste streams will be most demanding under the ongoing regime from 2027 (particularly hazardous waste and its transport).
- Prepare documentation and ILNO and train the responsible person.
Companies that voluntarily switch to electronic records earlier will have a head start for the 2027 live launch. If you want to entrust the whole agenda to a specialist, see our waste management services — records, ISOH reports, documentation, RZV and representation during SIŽP inspections.
Súvisiace služby a zdroje
Odpadové hospodárstvo na kľúč
Prevezmeme evidenciu odpadov, ohlásenie cez ISOH, dokumentáciu, registrácie aj zastupovanie pri kontrole SIŽP.
BOZP — bezpečnosť a ochrana zdravia pri práci
Komplexné zabezpečenie BOZP pre vašu firmu — popri odpadovom hospodárstve pod jednou strechou.
Civilná ochrana
Dokumentácia a plán ochrany zamestnancov — ďalšia zákonná agenda pod jednou strechou.
GDPR — ochrana osobných údajov
Dokumentácia, DPO a zastupovanie pri kontrole ÚOOÚ — popri odpadoch z jedného miesta.
Kurzy a školenia
Školenie zamestnancov v oblasti bezpečnosti, ochrany a nakladania s odpadmi.
Slovník pojmov
Výkladový slovník kľúčových pojmov z BOZP, OPP, PZS a VTZ.
Stručná odpoveď
Waste management is governed by Act No. 79/2015 Coll. on waste. Every company whose activity generates waste is its producer and must correctly classify the waste, keep records, hand it over to an authorised person and report once a year. Full ongoing recording into the ISOH system is postponed to 2027; in 2026 the existing regime applies.
Časté otázky o odpadovom hospodárstve
Waste management is the set of activities in preventing the generation of waste and handling it from generation to recovery or disposal. The obligations arise from Act No. 79/2015 Coll. and concern practically every company whose activity generates waste, that is, is its producer.
Yes. The obligation to keep records of the types and quantities of waste arises for the producer regardless of the size of the company. What differs is mainly the extent of reporting, which depends on exceeding the statutory thresholds. Even a small office produces waste that must be recorded and properly handed over.
The waste producer is the one whose activity generates the waste. The holder is the producer or a person who physically has the waste in their possession. The producer is therefore always also the first holder. Both are subject to the obligations under § 4 and § 14 of Act No. 79/2015 Coll.
ISOH is the Waste Management Information System of the Ministry of the Environment. Annual reports on the generation of waste and its handling are submitted electronically precisely via ISOH. In future it is also to serve for the ongoing electronic recording of waste.
No. Full ongoing electronic recording with quarterly reporting into ISOH under Decree 89/2024 was postponed by an amendment — Decree No. 369/2025 Coll. — from 2026 to 2027. In 2026, the existing regime of Decree 366/2015 continues.
Decree 89/2024 Coll. moves towards fully electronic and ongoing recording of waste via ISOH and is to replace the older Decree 366/2015. However, its full effect was postponed to 2027, so it is important to follow the current state, not older guides.
The annual report is submitted for the previous calendar year as a rule by 28 February, electronically via ISOH. The deadline may exceptionally be postponed due to technical outages of the system. The reporting obligation is tied to exceeding the waste-quantity threshold.
Under § 3 of Decree 366/2015 Coll., the reporting obligation arises for more than 50 kg of hazardous waste or more than 1 tonne of other waste per year. Even if you have no reporting obligation at low quantities, the obligation to keep records always continues.
Under § 14 of Act No. 79/2015 Coll., waste may be stored for at most one year before its disposal and at most three years before its recovery. Waste must be handed over only to a person authorised to handle the given type of waste.
Waste-record documents must as a rule be kept for five years and be available in case of an inspection. The exact retention period is set by the implementing regulations to the Waste Act.
Hazardous waste is waste with hazardous properties that requires a stricter regime: a hazardous-waste identification sheet (ILNO), separate and secured storage, recorded transport with an accompanying sheet and handover to an authorised person. It includes, for example, oils, filters, solvents or contaminated packaging.
Extended producer responsibility under § 27 of Act No. 79/2015 Coll. means that whoever places packaging, electrical equipment, batteries, tyres or vehicles on the market is also responsible for their waste. It is fulfilled individually or through a producer responsibility organisation (OZV). You are also a producer when importing goods from abroad.
State supervision is carried out by the district office, environmental-care department, and the Slovak Environmental Inspectorate (SIŽP). For failing to keep records or keeping them incorrectly, a fine of 500 to 50,000 euros applies under § 117 of Act No. 79/2015 Coll., and more for more serious breaches.
The postponement to 2027 is time for preparation. It is recommended to put classification and recording in order under the existing regime, test the software with export to ISOH, check accesses and registration, and map the most demanding waste flows, especially hazardous waste and its transport.
No. The collection company takes the waste away, but it does not, as a rule, do the recording and reporting for you. The producer's responsibility for keeping records, reporting and handover documents remains with your company, regardless of who physically removes the waste.
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