Czech Republic | BCH-NR3-CZ-109073 | Third National Report on the Implementation of the Cartagena Protocol on Biosafety | Biosafety Clearing-House

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Third National Report on the Implementation of the Cartagena Protocol on Biosafety (NR3)
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BCH-NR3-CZ-109073-1   |   PDF   |   Print   |  
last updated: 23 Oct 2015
General Information


Czech Commission for the Use of Genetically Modified Organisms and Genetic Products - advisory body to the Ministry of the Environment; Ministry of Agriculture; supervisory authorities; universities and research institutions;  NGOs
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01 Oct 2011
30 Sep 2011
Party to the Cartagena Protocol on Biosafety
Yes
EN
Article 2 – General provisions
A domestic regulatory framework is fully in place
EN
2001 or earlier
EN
  • One or more national biosafety laws
  • One or more national biosafety regulations
  • One or more sets of biosafety guidelines
  • Other laws, regulations or guidelines that indirectly apply to biosafety
Yes
EN
Yes
EN
Less than 5
EN
Yes
EN
The Czech Republic is a member state of the European Union, therefore the Czech legislative framework has been harmonised with the European Union legislation. The EU legislation is listed and described in the parallel 3rd National Report of the European Union.<br />In the Czech Republic, the first basic national legal instrument regarding the use of GMOs was adopted already in 2000. Since February 2004, the Act 78/2004, on the Use of Genetically Modified Organisms and Genetic Products, as amended, with an implementing Decree 209/2004 have been in force. The Act transposes EU Directives 2001/18/EC and 2009/41/EC, therefore it covers the contained use, deliberate release of GMOs into the environment (e. g. field trials) and placing on the market of GMOs as or in products. It has been in force since February 2004. <br />General rules on the co-existence of genetically modified crops with conventional and organic farming are set by the Act 252/1997, on Agriculture, as amended, and specified by the Decree 89/2006, on detailed conditions for growing a genetically modified variety, as amended.<br />Re Q16: Amendments of some Acts and corresponding Decrees related to biosafety are under way, on the basis of recent developments and knowledge and in compliance with the new EU legislation.<br />More information is available through the Czech national node of the BCH at http:<a href="http://www.mzp.cz/biosafety">http://www.mzp.cz/biosafety</a><br />The EC Regulations 1829/2003 and 503/2013 concerning the authorisation of GM food and feed, Regulation 1830/2003 on traceability and labelling of GMOs and GM food and feed, Regulation 1946/2003 implementing the Cartagena Protocol and relevant implementing decisions have been directly applicable in the Czech Republic since its accession to the EU in May 2004. For more information on EU legislation, please refer to the EU report.
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Article 5 - Pharmaceuticals
Yes
EN
Yes
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According to the EU Regulation 726/2004, a medicinal product containing LMOs may only be placed on the market in the European Union after it has received a marketing authorisation granted by the centralised EU procedure. The assessment preceding the registration must include an environmental risk assessment in line with the requirements of Directive 2001/18/EC. <br />EU Regulation 1946/2003 reflects the provisions of the Protocol as regards the export of LMOs, including pharmaceuticals.
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Article 6 – Transit and Contained use
Yes
EN
Yes
EN
Yes
EN
- Contained use: <br />Act 78/2004, on the Use of Genetically Modified Organisms and Genetic Products, as amended, and its implementing Decree 209/2004, on Detailed Conditions for the Use of Genetically Modified Organisms and Genetic Products, as amended, transpose Directive 2009/41/EC on the contained use of genetically modified micro-organisms, and covers contained use of other GM organisms (plants and animals) as well.<br />- Transit:<br />Act 78/2004, on the Use of Genetically Modified Organisms and Genetic Products, as later amended and its implementing Decree 209/2044, on Detailed Conditions for the Use of Genetically Modified Organisms and Genetic Products, as amended, apply also for export, import and transit of GMOs and genetic products.<br />EU Regulation 1946/2003 that is directly applicable in the Czech Republic, addresses transboundary movement of GMOs, and specifically sets requirements for exports of GMOs to third countries.
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Articles 7 to 10 – Advance Informed Agreement (AIA) and intentional introduction of LMOs into the environment
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
No
EN
None
EN
None
EN
Since its accession to the European Union in May 2004, the Czech Republic has applied the EU legislative framework as described in the EU National Report. <br />Notifications for placing GMOs on the market are processed at EU level. The EU legislation sets requirements for the information to be contained in notification dossiers. The authorisation procedure involves all EU Member States, as authorised products are granted free movement throughout the EU territory. The final decision is adopted by voting of all Member States.<br />Applications for intentional introduction of GMO into the environment for other purposes than placing on the market (experimental release, field trials) are submitted and processed at the national level. The authorisations are issued by the Czech Competent Authority. These cases have not involved transboundary movements so far.<br />Re Q37: It is not quite clear whether this question concerns intentional introduction into the environment generally or only the cases regarding intentional transboundary movements (covered by Q35). The answer of corresponding Q40 in the Czech Republic 2nd national report referred to approvals of field trials, that is intentional introduction into the environment not involving transboundary movements. If the Q37 in this report covers only LMOs subjected to transboundary movements, the answer is none.<br />Data on experimental releases of GMOs are available in the Czech node of BCH<br /><a href="http://www.mzp.cz/Biosafety/decisiones.html">http://www.mzp.cz/Biosafety/decisiones.html</a><br />
EN
Article 11 – Procedure for living modified organisms intended for direct use as food or feed, or for processing (LMOs-FFP)
Yes
EN
Yes
EN
Yes
EN
Yes
EN
No
EN
Yes
EN
More than 10
EN
More than 10
EN
More than 10
EN
Yes, always
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Yes, always
EN
It has to be noted that the import of GMOs intended for direct use for food or feed or for processing, is covered by the directly applicable EU Regulations. Decisions for placing GMOs-FFP on the market in the European Union are taken at the EU level by all the Member States. The authorisations apply for the whole EU territory, the transport within the Union is not considered as import or export. The Czech Republic as a Member State participates in the assessment and decision-making procedures.<br />All decisions are subsequently published by the European Commission in the European Biosafety Clearing-House (BCH) and not in the individual Member States' BCHs.
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Article 12 – Review of decision
Yes
EN
No
EN
No
EN
None
EN
Article 13 – Simplified procedure
No
EN
No
EN
None
EN
Article 14 – Bilateral, regional and multilateral agreements and arrangements
Yes
EN
One or more
EN
Yes, always
EN
The Czech Republic has been a Member State of the European Union since 2004. EU is a regional arrangement with common market rules, including transboundary movements of goods.
EN
The Czech Republic as a Member State of the European Union implements the EU legislative framework. Transport of goods within the EU is not considered as import or export.
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Articles 15 & 16 – Risk Assessment and Risk Management
Yes
EN
Yes
EN
10 or more
EN
10 or more
EN
One or more
EN
Yes
EN
Yes
EN
Yes
EN
No
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
  • Commercial production
  • Field trial
  • LMOs for Contained use
  • LMOs for direct use as food
  • LMOs for direct use as feed
  • LMOs for processing
Yes, always
EN
Yes, always
EN
More than 10
EN
Yes
EN
Yes
EN
Yes
EN
Risk Assessment<br />The European Union legal framework, based on a prior risk assessment before authorisation for the use of GMOs is given, and is applicable in the Czech Republic. The overarching aim of the environmental risk assessment is, on a case-by-case basis, to identify and evaluate potential adverse effects of the GMO, direct and indirect, immediate or delayed, on human health and the environment. Notifications for the use of GMOs must include a full assessment of the risks to human and animal health and to the environment, which is than reviewed by EU and/or national Authorities and experts.<br />In case of placing the GMOs on the market, the review of the risk assessment is conducted at the EU level by the European Food Safety Authority (EFSA) and EU Member States. Special procedure is applied in cases when the notification includes commercial cultivation. The Czech Ministry of Agriculture in close cooperation with its advisory body - the Scientific Committee for Genetically Modified Food and Feed - regularly participates in the European authorization procedure for genetically modified crops intended for direct use as food or feed, or for processing, under EU Regulation 1829/2003.<br />As regards the contained use and intentional introduction into the environment for experimental testing or field trials, the risk assessment is conducted at national level. Environmental risks are dealt with by the Czech Commission for the Use of GMOs and Genetic Products&nbsp; (expert advisory body to the Ministry of the Environment). Health risks are reviewed by the Ministry of Health.<br />The risk assessment should be performed in a scientifically-sound and transparent manner, based on up-to-date knowledge. Its results have to be reevaluated if new information on the GMO and its effects is obtained.<br />For training of experts and for the risk assessment, the Czech Competent Authorities and their advisory bodies use the methodology set by the EU legislation (e.g. Commission Implementing Regulation 503/2013) and EFSA guidelines, as well as manuals and guidance documents developed by the CPB AHTEG on RA/RM. <br />Re Q83: Technical guidance on specific topics should be further developed, namely as regards organisms resulting from the use of new gene techniques.<br />Risk Management<br />The authorisation decisions always set conditions for the use of GMOs, based on the risk assessment results. These conditions include requirements for monitoring - observations of potential effects of GMOs on health and environment. The monitoring is conducted both by the authorisation holder and by the supervision authorities.<br />The Czech Environmental Inspectorate is the main Competent Authority on state supervision of the use of GMOs (contained use, intentional introduction into environment and unauthorised GMOs). It cooperates with other supervision Authorities responsible for various agendas related to biosafety: Czech Agriculture and Food Inspection Authority in charge of food inspections and control; Central Institute for Supervising and Testing in Agriculture in charge of seeds, phytosanitary regulations, plant protection products and quality of feed; State Veterinary Administration as to animal related supervision; State Institute for Drug Control as medicinal products are concerned;&nbsp; Customs Administration in charge of export and import supervision.
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Article 17 – Unintentional transboundary movements and emergency measures
Yes
EN
Yes
EN
Yes
EN
Never
EN
Article 14 of Regulation (EC) 1946/2003 that is directly applicable in the Czech Republic provides for measures to prevent unintentional transboundary movements of GMOs and appropriate responses, including emergency measures.<br />However, transfer within the European Union is not considered as a transboundary movement according to the relevant EU legislation - Regulation (EC) 1946/2003 states that "transboundary movement" means the intentional or unintentional movement of a GMO between one Party or non-Party and another Party on non-Party, excluding intentional movements between Parties within the Community. The Czech Republic is an inland country, not on the border of EU, so it does not serve as a point of entry into EU for commodities and seeds.
EN
Article 18 – Handling, transport, packaging and identification
Yes
EN
Yes
EN
Yes
EN
Existing types of documentation
EN
Yes
EN
Existing types of documentation
EN
Yes
EN
Existing types of documentation
EN
Yes
EN
Yes
EN
One or more
EN
Yes
EN
10 or more
EN
Yes
EN
5 or more
EN
5 or more
EN
The Czech Republic follows the EU comprehensive legal framework on GMOs, which also addresses the issues of handling, transport, packaging and identification covered by Article 18. <br />However, transfer within the European Union is not considered as a transboundary movement. The Czech Republic is an inland country, not on the border of EU, so it is not a point of entry into EU for seeds and commodities from third countries. The only GMOs that are imported / exported directly to or from the Czech Republic are GMOs intended for contained use. In these cases, the entry point is the airport.<br />The Czech Act No 78/2004 Coll., on the Use of GMOs and Genetic Products, sets in Art. 25 the requirements for the import and export of GMOs intended for contained use.<br />The certified laboratories for the detection of GMOs, serving also for the Competent Authorities, are:<br />National Reference Laboratory for GMOs Testing and DNA Fingerprinting, Crop Research Institute, Prague<br />Laboratory of the Centre for Health, Nutrition and Food in Brno, National Institute of Public Health<br />Laboratory of the Department of Biochemistry and Microbiology, Institute of Chemical Technology, Prague<br />Laboratory of Central Institute for Supervising and Testing in Agriculture, Brno<br />Laboratory of State Veterinary Administration, Jihlava
EN
Article 19 – Competent National Authorities and National Focal Points
n/a
EN
Yes
EN
State administration:<br />The Competent Authority for the use of GMOs in the Czech Republic is the Ministry of the Environment. The Ministry of the Environment is the Competent Authority for the Cartagena Protocol on Biosafety and for the EU Regulation 1946/2003 as well.<br />The Ministry of Agriculture of the Czech Republic is the Competent Authority for genetically modified food and feed. <br />Detailed information including contacts is available in BCH.
EN
Article 20 – Information Sharing and the Biosafety Clearing-House (BCH)
Information available and in the BCH
EN
Information available and in the BCH
EN
Information available and in the BCH
EN
Information available and in the BCH
EN
Information available and in the BCH
EN
Information not available
EN
Information not available
EN
Information not available
EN
Information available and in the BCH
EN
Information available and in the BCH
EN
Information available and in the BCH
EN
Information available and in the BCH
EN
Information not available
EN
Information not available
EN
Information not available
EN
Information not available
EN
Information available and in the BCH
EN
Yes, to some extent
EN
Yes
EN
Yes, in some cases
EN
No
EN
Yes
EN
10 or more
EN
One or more
EN
  • National website
  • 5B6177DD-5E5E-434E-8CB7-D63D67D5EBED (Meetings of the Czech Commission on the Use of Genetically Modified Organisms and Genetic Products; workshops for decision-makers, experts or general public.)
Question 126: Part of the information is available at the European Union BCH, including harmonised EU legislation (126 c). The Czech node of BCH provides links to this website.<br />Question 126 i: Only final decisions on contained use and experimental introduction of GMOs into the environment are issued at the national level in the Czech Republic. Final decisions on commercial release are made at the European Union level and are available at the EU BCH.<br />Questions 126 j: Any information according to Article 14, paragraph 4 published at the European level in the EU BCH would be valid also for the Czech Republic.<br />Question 126 k, l: Decisions according to the Article 11, paragraph 1 and 4 are taken at the European Union level and are obligatory also for the Czech Republic. All these decisions are made available in the EU BCH.<br />Questions 126 m: Article 11, paragraph 6 is not relevant for the Czech Republic as it is neither a developing country nor Party with an economy in transition.<br />Question 128: One person has been appointed both the BCH National Focal Point and Cartagena Protocol National Focal Point in the Czech Republic. This person also works for the Czech competent authority for CPB. Coordination with other authorities involved in biosafety issues has been established.<br />Question 132: Special workshops were organized for decision-makers at the highest level, for specialists as well as for general public (Ministry of the Environment, Ministry of Agriculture), international and regional events see Capacity-building activities. The Czech Commission for the Use of Genetically Modified Organisms and Genetic Products is an important body for cooperation of specialists and coordination among responsible authorities, it serves for sharing topical information as well and its open meeting once a year aims to inform the public about biosafety activities. Radio broadcasting special programmes are focused on the general public. <br />Question 133: Numerous publications were prepared and issued within the UNEP/GEF Projects, both in Czech and in English. During the last year, the Ministry of Agriculture re-edited publications distributed during specialized workshops, and Ministry of the Environment prepared topical information for national and international authorities and for the interested public. <br />Question 134: Besides the national BCH, operated by the Ministry of the Environment,&nbsp; information on the LMOs intended for direct use as food or feed is available at the website focused on food safety, operated by the Ministry of Agriculture.
EN
Article 21 – Confidential information
Yes
EN
In some cases only
EN
The Czech Act 78/2004, paragraph 9, as well as the relevant European legislation, listed in the EU report, define which information can be identified and treated as confidential.<br />It has to be noted that the confidentiality provisions make clear what information should never be identified as confidential, namely a general description of the GMO, name and address of the notifier, risk assessment and emergency response plans.
EN
Article 22 – Capacity-building
Yes
EN
Yes
EN
Multilateral channels
EN
Yes
EN
Regional channels
EN
Yes
EN
Average
EN
  • Development of national biosafety frameworks
  • Implementation of national biosafety frameworks
  • Building Capacity for Effective Participation in the BCH (Phase I)
Yes
EN
  • Institutional capacity
  • Human resources capacity development and training
  • Risk assessment and other scientific and technical expertise
  • Public awareness, participation and education in biosafety
  • Information exchange and data management including participation in the Biosafety Clearing-House
  • Scientific, technical and institutional collaboration at subregional, regional and international levels
  • Identification of LMOs, including their detection
  • Implementation of the documentation requirements under Article 18.2 of the Protocol
  • Handling of confidential information
  • Scientific biosafety research relating to LMOs
Yes
EN
No
EN
Yes, a few
EN
  • Risk assessment and other scientific and technical expertise
  • Public awareness, participation and education in biosafety
  • Identification of LMOs, including their detection
  • Implementation of the documentation requirements under Article 18.2 of the Protocol
  • Scientific biosafety research relating to LMOs
  • Taking into account risks to human health
No
EN
Yes
EN
5 per year or more
EN
Yes
EN
Questions 142-143: Special workshops were held in the Czech Republic for countries demanding support on bilateral basis. Series of regional training workshops were organized in cooperation with FAO and Ministry of Agriculture, with expert support of the Ministry of the Environment. Czech experts assisted in the EU workshops in some EU accession countries.<br />Questions 144-146: UNEP/GEF Projects contributed greatly to the development of NBF, especially to enhancement of&nbsp; institutional and authorities cooperation, to capacity-building and public awareness.<br />Questions 147-154: In spite of a number of experienced specialists in the Czech Republic, the country still has need for its own capacity-building, especially due to recent scientific development in biosafety. The need is monitored for inner purposes and therefore it was not submitted to the BCH. Capacity-building strategy is a part of broader national strategies (such as environmental education) and their action plans. <br />Question 155: Biotechnology and biosafety issues are included in educational programmes of universities. E.g. Charles University Prague organizes a special course on biotechnology in general and its use in various branches with high participation of students, in spite of its optional character. Agricultural University Prague, Faculty of Natural Sciences - Hradec Kralove University, Pharmaceutical Faculty Brno and South Bohemian University Ceske Budejovice have biotechnology and its safe handling included in their compulsory programmes. Other universities range these issues in their broader curricula.
EN
Article 23 – Public awareness and participation
Yes
EN
Yes
EN
Yes
EN
Biosafety strategy forms a part of broader national strategies (e.g. Strategy for Sustainable Development, National Biodiversity Strategy, State Programme on Environmental Education and Public Awareness, Food Safety Strategy, Action Plan on Health and the Environment)<br />Biosafety focused programmes are developed through:<br />Czech Commission on the Use of Genetically Modified Organisms and Genetic Products (especially its open meeting for the public once a year), meetings with the public, media, websites of authorities (Ministry of the Environment, Ministry of Agriculture).
EN
Yes
EN
10 or more
EN
Yes
EN
Yes
EN
Yes
EN
Yes
EN
  • National website
  • Public hearings
  • 5B6177DD-5E5E-434E-8CB7-D63D67D5EBED (As to field trials, local boards and media.)
National website
EN
Yes
EN
5 or more
EN
25 or more
EN
Yes
EN
Yes
EN
More than 5
EN
Biosafety issues are included in broader national strategies and legislation, such as those on environmental education. Awareness programmes are developed in cooperation with educational institutions, nature conservation organizations, centres for environmental education, muzea, some NGOs.<br />The right to information is based on national legislation, namely the Act 106/1999 on Free Access to Information, ammended in 2006, and the Act 123/1998 on the Right to Environmental Information, ammended through the Act 132/2000 and Act 6/2005. As a Party to the Aarhus Convention and to its Ammendement on Public Participation in Decisions on the Deliberate Release in the Environment and Placing on the Market of Genetically Modified Organisms, the Czech Republic implements the obligations of this Convention.<br />The public is always consulted during the authorisation process of field trials, by means of the Ministry's website and official boards of relevant regional authorities. In case of objections or negative comments made by the public, a public hearing must be organised by the Ministry of the Environment.<br />Public consultations regarding the notifications for placing LMOs on the market are organised at the EU level.
EN
Article 24 – Non-Parties
No
EN
Yes
EN
No
EN
Yes
EN
No
EN
Act 78/2004 Coll., which is in line with the EU legislation on GMOs, applies to all imports / exports of LMOs, whether these originate from parties or non-parties to the Protocol. The LMOs imported from non-party were intended for contained use.
EN
Article 25 – Illegal transboundary movements
Yes
EN
Yes
EN
Never
EN
It has to be noted that transfer within the European Union is not considered as a transboundary movement according to the relevant EU legislation - Regulation (EC) 1946/2003 states that "transboundary movement" means the intentional or unintentional movement of a GMO between one Party or non-Party and another Party on non-Party, excluding intentional movements between Parties within the Community. The Czech Republic is an inland country, not on the border of EU, so it does not serve as a point of entry into EU for commodities and seeds.<br />No illegal transboundary movements have been recorded during the current reporting period. Besides general surveillance, the Czech Environmental Inspectorate has monitored for possible occurrence of LMOs that have been detected in other countries, e.g. GM ornamental fish.
EN
Article 26 – Socio-economic considerations
No
EN
Not applicable
EN
5 or more
EN
Socio-economic considerations are relevant at national level as regards the co-existence between conventional, organic and GM crops. The Czech Republic adopted its rules for co-existence in 2006 by the amendment of the Act 252/1997 on Agriculture. The details are set by the implementing Decree&nbsp; 89/2006, on detailed conditions for growing of genetically modified variety, as amended by Decree 58/2010. <br />The Czech Republic participated in discussions and information exchange on socio-economic issues at the European Union level.
EN
Yes, to some extent
EN
The Czech Republic as a Member State of the European Union follows EU guidelines and recommendations related to GM crops cultivation and possible impacts of this activity on various areas, including socio-economic aspects. Based on the 2010 European Commission Recommendations on guidelines for the development of national strategies and best practices to ensure the co-existence of genetically modified crops with conventional and organic farming, the Czech Republic has developed its national legislation on co-existence measures for GM maize, soybean and potato. Already from the first GM crop cultivation in 2005 (Bt-maize MON810), the co-existence rules have been applied. Since 2006 the general co-existence rules for GM crops cultivation became part of the Czech Act 252/1997, on Agriculture, as amended. For selected crops (potato, maize, soybean) details are further specified by Decree 89/2006, on Detailed Conditions for GM Crop Cultivation, as amended.<br />In spite of the fact that there is ten years experience with GM maize cultivation in the Czech Republic, data on socio-economic implications of GMO cultivation are rather scarce to become statistically significant and assessable. It is due to a low cultivation area of Bt-maize, which did not exceed 9 000 hectares even in the best year 2008. Since 2010 the cultivation area of MON 810 has gradually decreased, falling to less than 1 000 ha in 2015. Behind this data are numerous aspects, beginning from the generally negative attitude of the EU public to GM crops, higher administration requirements for GMO growers, problems with selling the harvest, high GM seed cost, up to a limited interest of leading seed distributors to import GM seed into EU nowadays. The situation with GM crops cultivation may get even worse following the recent Directive 2015/412, which gives the possibility to the Member States to restrict or prohibit the cultivation of GMOs in their territory. Under this new Directive, Member States may adopt opt-out decisions on GMO cultivation based on compelling grounds distinct from the environmental risk assessment undertaken in the context of the authorisation procedure at EU level. <br />On the other hand the European Commission in 2013 established a technical working group named the "European GMO Socio-Economics Bureau - ESEB" to organise and facilitate the exchange of technical and scientific information regarding the socio-economic implications of the cultivation and use of GMOs between Member States and the Commission. This team is composed of experts from the Member States (the Czech Republic did nominate its own bureau member but Czech experts take part in the working groups activities) and the Commission. The ESEB has compiled topics, indicators, methodological guidelines and potential data sources to carry out analyses of socio-economic effects in the Member States and across the EU. Thus, detailed guidelines to perform analyses of socio-economic effects of relevant crops will be useful soon also for the Czech Republic.
EN
Article 27 – Liability and Redress
Yes
EN
No
EN
Yes
EN
The Czech Republic ratified the Nagoya - Kuala Lumpur Supplementary Protocol on Liability and Redress to the CPB in February 2012. <br />The Czech Republic as a member of the EU has already relevant legislation in place:<br />At the EU level: <br />Directive 2004/35/EC of the European Parliament and of the Council on environmental liability with regard to the prevention and remedying of environmental damage<br />At the national level: <br />Act 167/2008, on prevention of ecological damage and its remedies and on amendments of some acts, that transposes the Directive 2004/35/EC into the domestic legislation<br />Regulation of the Government 295/2011 on the way of risk assessment of environmental damage and detailed conditions of financial security – provides further details on financial aspects in relation to environmental liability <br />Act 89/2012, Civil Code
EN
Article 28 – Financial Mechanism and Resources
5,000 USD or more
EN
Article 33 – Monitoring and reporting
Yes
EN
Yes
EN
Yes
EN
Other information
It has to be noted that as far as the EU and its Member States are concerned, there are two levels of implementation of the Protocol, the EU level and national level.<br />Therefore this national report refers to the EU report where relevant.
EN
Comments on reporting format
Some questions concern different reporting periods: At the very beginning of this report, it is written that the reporting period is 2011 - 2015. In spite of that, Q132 requires data for two last years and Q133 for the last year.
EN