Czech Environmental Inspectorate:

An inspection from the Czech Environmental Inspectorate (ČIŽP) is often one of the most stressful events for manufacturing companies. This isn't just a formal audit; it's a process that can result in liquidating fines. In this article, you will get clear answers on what inspectors focus on, what the most common errors in environmental law are that lead to sanctions, and how you can effectively defend yourself.  

Need advice on this topic? Contact the ARROWS law firm by email office@arws.cz or phone +420 245 007 740. Your question will be answered by "JUDr. Jakub Dohnal, Ph.D., LL.M.", an expert on the subject.

Why is a ČIŽP inspection a critical moment for your company?

Many companies perceive a ČIŽP inspection as a mere administrative formality. However, based on our two decades of practical experience, this is a fundamental and dangerous mistake. In reality, it is a highly formalized legal process that can have fatal consequences for your business.  

This isn't just a theoretical risk. Every year, fines in the tens or even hundreds of millions of crowns are imposed in the Czech Republic. The fine itself is often just the tip of the iceberg. The real costs are hidden elsewhere.  

The biggest threat isn't just the fines, but the "corrective measures." This can mean an order to invest millions in new technologies. 

In extreme cases, the ČIŽP can even issue a decision to limit or shut down operations. This has a catastrophic impact on cash flow, fulfilling contracts with customers, and the overall stability of the company.  

By law, ČIŽP inspectors have very broad powers. They can enter premises, demand any documents, take samples, and use your company's technical equipment. 

This imbalance of power requires you to have a partner with equal expertise on your side.  

Underestimating the situation is the first and biggest mistake. Our lawyers at ARROWS, who specialize in environmental law, handle disputes with the ČIŽP daily and are ready to level the playing field. 

For an immediate consultation on your situation, write to us at office@arws.cz.

What do inspectors focus on most often in manufacturing? (The Three pillars of risk)

An inspection is not random. It focuses on three key areas where fines are statistically the highest: waste, water, and air.  

Area #1: Waste management – A ticking time bomb

This area has long been in first place for both the number and total amount of fines imposed. The obligations of a waste generator are complex, and it is easy to make mistakes.  

The most common error is incorrect classification—mistaking hazardous waste for non-hazardous waste. 

An example is the CZK 3.5 million fine for the company FCC HP. The company used 95,880 tons of material as "certified products from waste" for the technical securing of a landfill. 

However, the ČIŽP proved that this was actually waste, and the company was thus avoiding fees and the creation of a financial reserve.  

Inspectors discovered that the company was actually being paid for the "purchase" of these "products." This is a clear signal that it is not a product, but hidden waste disposal.

A second common problem is storage and records. 

For instance, the company BMI received a fine of CZK 170,000 because it stored thousands of tons of technological waste on land not designated for that purpose. Furthermore, it had failed to report the production of this waste for three years.  

Properly setting up waste management is the foundation of prevention. 

ARROWS lawyers routinely provide clients with complete environmental audits and prepare internal directives and operating procedures that protect against fines. 

Do you need a legal audit of your waste management? Contact us at office@arws.cz.

Area #2: Water Protection – Permits and limits

Every manufacturing company that discharges wastewater (process, washing, or even just contaminated cooling water) must have a valid "permit for water management."  

For an inspector, checking this area is often very simple, and for the company, very risky. The questions are binary: Do you have a permit? Are you adhering to the limits set within it?

Discharging wastewater without a permit is one of the most serious offenses.

It carries a direct penalty of CZK 2–20 million and a real risk of an immediate shutdown of operations.  

Area #3: Air Protection – Emissions and Operational Records

This area concerns the operation of stationary sources of pollution—typically paint shops, boiler rooms, welding shops, or other technologies that produce emissions.  

Here, the devil is often in the data and operational records. An example is the case of the company UNICON, which received a fine of CZK 180,000. 

Not only did it exceed the annual limit of volatile organic compounds (VOCs) from the permitted 5 tons to 10 tons, but the inspection discovered this because the company "did not record the consumption of thinners and hardeners at the paint shop on a daily basis," but only monthly.  

Chaotic or insufficient records are a signal to inspectors that the company is trying to hide something, and it is a direct invitation for an in-depth inspection.

FAQ – Legal Tips on operational duties

1. Does even a small firm (e.g., an accounting office) need a waste contract? Yes, every waste generator, including small sole proprietors, must be able to prove how they managed their waste at any time. It cannot be mixed with regular municipal waste. This violation carries a fine of up to CZK 300,000 from the municipality. We handle contractual arrangements for companies of all sizes. For a review of your contracts, contact us at office@arws.cz.  

2. What if I only "occasionally" exceed the emission limit in water? "Occasionally" exceeding the limit is still a violation of the law. Exceeding emission limits carries a fine ranging from CZK 500,000 to 10 million and the imposition of expensive corrective measures. We will help you in negotiations with the water authority. Connect with us at office@arws.cz to get a tailored legal solution.  

The Most Common Operational Failures and Their Consequences

Risks and Sanctions	How ARROWS Helps
Incorrect waste classification (e.g., hazardous as non-hazardous). Risk of fines in the millions and back-payment of fees.	We will conduct an environmental legal audit and prepare internal directives. Need an audit of your documentation? Write to us at office@arws.cz.
Discharging wastewater without a valid permit. Risk of a CZK 2–20 million fine and immediate shutdown of operations.	We will secure the necessary permits and licenses and represent you before the water authority. Applying for a permit? Contact us at office@arws.cz.
Missing or incorrect operational records (air, waste). Risk of a fine and serves as a trigger for an in-depth inspection.	We will prepare template documentation and operational procedures that comply with the law. For legal assistance with documentation, write to us at office@arws.cz.
Storing waste outside of permitted areas or for longer than allowed. Risk of fines in the hundreds of thousands.	Legal review of operational procedures and storage management. Unsure if you are storing waste correctly? Contact our office – office@arws.cz.

IPPC and BAT: Do you understand integrated permitting? (For the big players)

If you operate a larger industrial enterprise, you are likely subject to the integrated prevention (IPPC) regime.

An integrated permit is the key permitting tool for large industrial and agricultural facilities.

 Its main principle is that one integrated permit replaces most of the individual "component" permits we discussed above—i.e., permits for water, air, and waste. 

Everything is contained in one "master" permit.  

Obtaining this permit, however, is directly tied to the obligation to use "Best Available Techniques" (BAT). 

BATs are not just recommendations; they are the "most effective and advanced" technologies that form the basis for setting emission limits in your permit. If your company is not using BAT, it is almost certain that you are violating your integrated permit.  

The impact is real. The aforementioned CZK 3.5 million fine for FCC HP was imposed precisely for "violation of the Act on Integrated Prevention." 

Their error in waste management was a direct breach of their IPPC permit conditions.  

Obtaining or changing an integrated permit is an extremely complex legal and technical process. ARROWS lawyers have experience representing clients in IPPC permitting procedures and will help you bring your operations into compliance with BAT requirements. 

For legal assistance with IPPC, contact us at office@arws.cz.  

Do you have international operations? Beware of transboundary waste shipments.

For companies with an international footprint, especially in logistics or manufacturing with an international supply chain, there is another significant risk: the transboundary shipment of waste. This is strictly regulated by an EU regulation.  

Inspections in this area don't just involve the ČIŽP. Data from the General Directorate of Customs is involved in planning inspections, cooperation takes place with the Police of the Czech Republic, and the international network of inspectorates, IMPEL, is utilized.  

An error in documentation (notification, accompanying documents) is not just a misdemeanor. It can be the trigger for an international investigation. 

A shipment detained at the border can be classified as an "illegal shipment," which often has criminal law implications and can lead to liability for creating an illegal dumping site abroad.

This is a key area where international legal expertise is necessary. Thanks to the ARROWS International network, built over ten years, we handle cases with an international element almost daily. 

Our lawyers will secure the necessary permits, conduct a legal analysis of the material's classification (whether it is waste or a secondary raw material), and protect you from the risks arising from contracts with international partners. 

Do not hesitate to contact our office – office@arws.cz.  

They've announced an inspection. What now? (The inspection process step-by-step)

This situation requires an immediate and correct response. Inspections are either planned or, more often, they come as a result of a tip-off—from a citizen, a competitor, or a former employee.  

The inspector's rights are broad: entry onto premises (excluding dwellings), verifying identity, demanding documents, and taking samples. 

Your key right is the right to choose an authorized representative (an attorney) to represent you throughout the entire process.  

Companies often make the mistake of trying to ignore the inspection. This is a costly error. The company ZB BUILDING received a CZK 50,000 fine just for "failing to create conditions for the inspection to be carried out." 

You must cooperate, but panicked and unstructured cooperation leads to providing information beyond your obligations, which will harm you.  

The key moment of the entire inspection is the "Inspection Protocol." It is the only legally relevant output. If you disagree with the findings in the protocol, it is absolutely essential to file qualified "objections." Passivity at this stage means an almost certain loss in the subsequent fine proceedings.  

FAQ – Legal Tips on the Inspection Process

1. The inspector wants to talk to my employees. Can I forbid it? No, the inspector has the right to speak with the physical persons present. However, you should ensure that your representative (an authorized person or attorney) is present to oversee the fairness of the questions. ARROWS provides accompaniment during the inspection directly at your company. Need a lawyer during an inspection? Write to office@arws.cz.  

2. Do I have to sign the protocol if I don't agree with it? You do not have to, but the signature itself does not mean agreement, only confirmation of receipt. Much more important is your legal right to file written, legally justified objections against the inspection findings within the specified deadline. We have extensive experience preparing objections. For an immediate solution to your situation, write to us at office@arws.cz.  

Mistakes During the Inspection

Risks and Sanctions	How ARROWS Helps
Ignoring requests or failing to provide cooperation. Risk of a fine for non-cooperation (up to CZK 50k) on top of the fine for the actual offense.	We will take over all communication with the authorities on your behalf. We ensure you meet your duty to cooperate without jeopardizing your rights. Need legal help? Contact us at office@arws.cz.
Providing informal "explanations" and chaotically handing over documents. You might unknowingly admit to a violation or reveal other problems.	We will ensure strategic management of communication. We will accompany the inspectors and insist that all requests are formal and recorded. Connect with us at office@arws.cz.
Passivity after receiving the inspection protocol. Missing the deadline for filing objections practically makes further defense impossible.	We immediately analyze the protocol and prepare qualified objections. Our lawyers are ready to help you – write to office@arws.cz.

How ARROWS ensures your smooth operations: From prevention to defense

Our approach to environmental law rests on three pillars that ensure full protection for your business:

1. Prevention (Audit and Compliance): The best inspection is one that finds nothing. We proactively identify risks before the ČIŽP does. We offer comprehensive environmental legal audits that review your documentation and real-world operations. Based on the audit, we prepare internal directives, emergency plans, and operating procedures that protect you from fines.  

2. Defense (Representation and Appeals): When a problem has already occurred. We provide immediate legal assistance and representation directly during the inspection at your company. If you receive a fine, we perform a rapid analysis and ensure the timely filing of an appeal. Our lawyers identify procedural flaws and factual inaccuracies and will represent you in proceedings before the Ministry of the Environment and administrative courts.  

3Training (Education and Certification): Investing in the knowledge of your management and employees provides the highest return. We provide expert, customized training for your operations, including a certificate of completion, which serves as proof during an inspection.  

We provide long-term services to our clients and pride ourselves on speed and high quality. Our portfolio includes more than 150 joint-stock companies, 250 limited liability companies, and 50 municipalities and regions. 

We can also connect clients with each other if they have interesting business opportunities.

For smooth operations and legal certainty in the environmental field, turn to our experts. Do not hesitate to contact our office – office@arws.cz.

FAQ – Frequently asked legal questions about ČIŽP inspections

1. What if I don't let the inspector into the premises? This is one of the biggest mistakes. Inspectors are authorized to enter. Actively obstructing an inspection is classified as "non-cooperation," and the ČIŽP will impose a separate fine for it, as happened to the company ZB BUILDING. If you are facing a similar problem, contact us at office@arws.cz.  

2. Can an inspection come from a tip-off from a competitor or former employee? Yes. The ČIŽP handles a large number of tip-offs from citizens and legal entities. The inspectorate is obliged to investigate the tip-off, even if it turns out to be unfounded. If you want legal assistance in handling a tip-off, write to us at office@arws.cz.  

3. Do I have to sign the protocol if I don't agree with it? You do not have to, but refusing to sign does not solve the situation. By signing, you are only confirming receipt of the protocol. Much more important is your legal right to file written and reasoned objections against the inspection findings. Clients turn to us daily for help with objections. Need help with objections? Write to office@arws.cz.  

4. Does ČIŽP also inspect chemicals (REACH/CLP)? Yes, "chemical safety" is one of the main competencies of the ČIŽP. Inspectors check, for example, the correct labeling of chemical mixtures (H-statements) during sales, as shown by inspections of e-shops (Alza, Mall.cz) with fines of CZK 60-100k. We also ensure compliance in the area of REACH and CLP. Connect with us at office@arws.cz.  

5. What is a "corrective measure" and why is it worse than a fine? A fine is a one-time financial penalty. A corrective measure is an obligation imposed by the ČIŽP for you to bring your operations into compliance with the law at your own expense (e.g., building a new wastewater treatment plant). These costs often exceed the fine itself many times over. Our lawyers will help you negotiate reasonable and economically viable conditions for corrective measures. For an immediate solution to your situation, write to us at office@arws.cz.  

6. I've already received a fine decision. Is it too late? It is not, but you must act immediately. From the delivery of the decision, there is a deadline of only 15 days to file an appeal. Missing this deadline means the decision is final and you must pay the fine. Contact us immediately; we will conduct an analysis and take over your defense. Our lawyers are ready to help you – write to office@arws.cz.  

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