The Czech Office for the Protection of Competition initiated an investigation based on received complaints regarding the market for collective fulfillment services for electronic devices. The aim was to determine whether any operators of collective systems hold a dominant position and if such a position is being abused.

Operators of collective systems fulfill obligations for manufacturers of electronic devices as stipulated by the Waste Act. They must have authorization from the Ministry of the Environment and meet other legal requirements. Electronic waste is categorized into six groups, with Group 4 further divided into 4a (large devices excluding solar panels) and 4b (solar panels). Currently, there are five operators in the Czech Republic for various groups of electronic devices, including ASEKOL, EKOLAMP, ELEKTROWIN, REMA Systém, and RETELA.

The authority defined the relevant market for services related to the collection, processing, and disposal of electronic devices, considering both broader and narrower definitions. The broader definition included services for all electronic devices (excluding Group 4b), while the narrower version considered separate markets for each group of electronic devices. Geographically, the authority focused on the national market encompassing the territory of the Czech Republic.

In assessing market power, market share was deemed the most significant criterion. The authority evaluated the market shares of the investigated operators from 2019 to 2024, also considering the market share trends of competitors. The data indicated that some collective systems hold significant market shares in certain relevant markets. However, there was a decline in the shares of the largest operators during the observed period, and there was not a significant gap from the nearest competitor, indicating market share instability.

The investigation found no evidence of a dominant position among the operators, as indicated by the movement of manufacturers between systems and the competitive discounts offered. These factors suggest that the operators cannot act independently of their competitors, which is a fundamental requirement for establishing a dominant position. The authority cannot rule out future changes in market conditions and will continue to monitor the situation.