Extended Producer Responsibility in Estonia
EPR applies to anyone selling the following products to consumers in Estonia:
- electrical and electronic equipment, lamps
- batteries and accumulators
- packaging that is placed on the market together with products
- motor vehicles and parts
- tyres
- agricultural plastic
- fishing gear containing plastic and their components
- wet wipes
- balloons
- tobacco products with filters and filters marketed for use in combination with tobacco products
Who is subject to Extended Producer Responsibility?
Manufacturers, importers, distance sellers and packers of product are subject to extended producer responsibility.
Producer is a person who designs, plans, manufactures, processes, sells or imports products on professional basis.
The term 'producer' includes a natural or legal person who, irrespective of the selling technique, including through distance communication (i. e online marketplaces), sells products directly to Estonian households or other users, even if the person is established in another European Union Member State or outside the European Union.
Producer responsibility requirements have been applied and apply to producers of products irrespective of the selling method, i.e. distance selling through digital platforms.
How to manage Extended Producer Responsibility?
The easiest way to manage Extended Producer Responsibility is to join a producer responsibility organization.
In Estonia tyres, electrical and electronic equipment, portable batteries and accumulators, light means of transport batteries, electric vehicle batteries and industrial batteries producers are required to organise waste collection and treatment through producer responsibility organisation. Producers of these products are required to have a written contract with a producer responsibility organisation.
Producer responsibility organisations are non-profit organisations and are set up and managed by producers.
Producer organisations organise:
- collection, transport, treatment, and disposal of end-of-life products
- ensuring that collection and recycling targets are met
- ensuring that awareness rising campaigns are done
Information on distance selling
The distance seller is also a producer!
Producer responsibility requirements have been applied and apply to producers of products irrespective of the selling method, i.e. distance selling threw digital platforms.
According to Waste Act online platform has the right to register as a producer and fulfil extended producer responsibility organisations on behalf of their traders. When registering, the online platform must provide the names of the traders on whose behalf the extended producer responsibility obligations are fulfilled. The list is submitted to the PRO and the authority. The list must be kept up to date. If a digital platform fulfils EPR obligations on behalf of traders, this provision applies to all traders operating exclusively on that platform.
Authorised representative
A producer during its commercial or professional activity, places its products on the market in another Member State where it does not have a seat, appoints an authorised representative who is a natural or legal person with residence or seat in that Member State who performs the obligations imposed on the producer on its behalf.
A producer whose place of business is outside Estonia and who places products of concern on the market in Estonia shall be registered in the register of products of concern through an authorised representative having a place of business in Estonia.
An authorised representative can also be producer responsibility organisation.
Producer responsibility organisations for packaging
A packaging producer, an importer or exporter of empty packaging, a packaging undertaking who places packaged goods on the market are obliged to keep consistent records on the mass of packaging material by the types of packaging and packaging material.
A packaging undertaking who places packaged goods on the market and has not transferred its obligations to a recovery organisation is obliged to submit verified data per calendar year by the types of packaging and packaging material in the Packaging register
Producer responsibility organisations are:
- Eesti Taaskasutusorganisatsioon MTÜ (www.eto.ee/en)
- Tootjavastutusorganisatsioon OÜ (www.tvo.ee/en)
- OU Eesti Pakendiringlus (pakendiringlus.ee/en)
- Eesti Pandipakend OÜ (eestipandipakend.ee/en) - for packages with a deposit.
Authorised representative for packaging producer
An authorised representative within the meaning of Packaging Act is a person who performs the obligations of a packaging undertaking in the territory of a Member State in relation to extended producer responsibility schemes where the packaging undertaking does not have a seat in the Member State. The authorities are valid only if they have been approved in writing by the authorised representative. The authorised representative performs the tasks specified in the authorisation received from the packaging undertaking.
Producer responsibility organisations for electrical and electronic equipment, lamps, and batteries and accumulators
From 2022 all producers of household electrical and electronic equipment, and portable batteries are required to be a member of a producer responsibility organisation (PRO). The PRO must establish and manage a country-wide collection network for both electrical and electronic equipment, and batteries.
All distributers who sell portable batteries must have a collection spot in their place of business irrespective of whether the user buys a new device or not.
The distributor of electrical and electronic equipment is obliged to take back free of charge, at his point of sale and on the basis of a quantitative equivalence, waste of the same type and from the same use as the equipment being marketed.
In Estonia there are two producer responsibility organisations for electrical and electronic equipment, lamps, and batteries and accumulators.
These are:
- EES-Ringlus (http://eesringlus.ee/ (electronic equipment, batteries, lamps))
- Elektroonikaromu (http://www.elektroonikaromu.ee/web/?cat_ID=2 (electronic equipment, batteries))
Producer responsibility organisations for tyres
For a producer it is not possible to perform the collection point requirement, where producer shall establish collection points for waste tyres in each Estonian county, therefore starting from 2022 tyre producer is obliged to transfer performance of obligations by written contract to a producers' responsibility organisation.
In Estonia we have two producer responsibility organisations for tyres.
- Rehviringlus MTÜ ( Rehviringlus)
- Estonian Tire Recycling MTÜ (Estonian Tire Recycling - vanarehvide taaskasutus Eestis)
Producer responsibility for motor vehicles
Producer of motor vehicles and parts of motor vehicles may choose to fulfil the obligations individually. Our producers have to transfer them by written agreement to an authorized waste treatment managers.
The obligations for collection and treatment of end-of-life vehicles are fulfilled by MTÜ ELV Autolammutusliit, Kuusakoski AS, Metruna OÜ.
Legislation
Estonian Waste Act establishes the principles of producer responsibility and requirements.
§ 25-1 - Producer is required to fulfil the extended producer responsibilities. The producer is required to ensure the collection of waste resulting from products of concern placed on the market thereby and the recovery or disposal of the waste and shall have a sufficient guarantee for the performance of such obligations.
§ 25-1 (6) Starting from 2022 the producer is obliged to transfer performance of obligations by written contract to a producers' responsibility organisation.
§ 26-1 (1) The producer is required to register themselves in the register of products of concern and to submit data to the register
§ 26-1 (13) Producer whose place of business is outside Estonia and who places products of concern on the market in Estonia shall be registered in the register of products of concern through an authorised representative having a place of business in Estonia. An authorised representative shall be appointed by a written authorisation.
Packaging extended producer responsibility principles are set in the Packaging Act.
Packaging producer is an importer or exporter of empty packaging, a packaging undertaking who places packaged goods on the market.
A packaging producer that does not meet the recycling target set for packaging must pay excise duty on packaging waste. Excise duty rates and conditions for exemption from excise duty are established by the Packaging Excise Duty Act.
Penalties
Meeting Extended Producer Responsibility obligations is not voluntary.
Violations of the EPR requirements can result in fines. If a company which has responsibility as a producer neglects its registering responsibility, the Environmental Board may impose a fine or start an administrative procedure.
Violation of the obligation to fulfil extended producer responsibility is punishable by a fine of up to 200,000 euros.
Upon failure to comply with an administrative procedure precept, the non-compliance levy pursuant is 32,000 euros. The non-compliance levy pursuant shall be imposed until the extended producer responsibility requirements are complied.
Whistleblowing
You can notify the Estonian Environmental Board of a company you believe is active in the Estonian market and not fulfilling extended producer responsibility obligations.
Estonian Environmental Board will handle all the notifications and carries out supervision.
Before submitting a notification, you can check the register of products of concern to see if the company has fulfilled its Extended Producer Responsibility obligations.
You can make the notification by sending email to [email protected]
FAQ
- electrical and electronic equipment, lamps
- batteries and accumulators
- packaging that is placed on the market together with products
- motor vehicles and parts
- tyres
- agricultural plastic
- fishing gear containing plastic and their components
- wet wipes
- balloons
- tobacco products with filters and filters marketed for use in combination with tobacco products
You can check which companies meet their Extended Producer Responsibility obligations from register of products of concern.
You can check take-back points at: Kuhuviia
Under the Waste Act, the producers, i.e. the manufacturers, importers, distance sellers have the primary right to arrange waste management for the products under their responsibility.
Other operators may set up parallel systems only in cooperation with the producer.
Statistics on Extended Producer Responsibility and other waste statistics are collated in the environmental agency webpage and in the register of product of concern and packaging register.
Yes, Extended Producer Responsibility must be taken care of, even if import activity or the amount of product sold through distances selling is minimal.
Usually, the easiest and most cost-effective way is to join a producer organisation.
The costs of producer responsibility are covered by recycling fees paid by producers. Payments vary by sector and by producer organisation. Current prices are published on the websites of the organisations.
Costs for electric and electronic equipment and batteries:
Elektroonikakäitlus OÜ Lisa 1. Hinnakiri EUR 2022
Costs for tyres:
Estonian Tire Recycling - liitu tootjavastutusorganisatsiooniga
Distance Selling
An online store is a distance seller and must fulfill Extended Producer Responsibility obligations.
Distance sellers registered in Estonia must organise their Extended Producer Responsibility obligations in each destination country in accordance with the laws of that country. Distance sellers are undertakings or other operators who sell products that come under Extended Producer Responsibility directly to users in other countries.
Distance sellers of electrical and electronic equipment, batteries, tyres, vehicle parts, motor vehicles, SUP-products or fishing gear containing plastic must always appoint an authorised representative who is based in the EU member state in question to manage their Extended Producer Responsibility obligations in accordance with the legislation of that country
Packaging
Extended producer responsibility applies to all types of packaging that protect the product, including reusable boxes, bottles, rollers, pallets, etc. Here are some examples of packaging materials that come under extended producer responsibility:
- Glass (e.g. jars, bottles)
- Metal (e.g. cans, drums, canisters, cable ties, rollers)
- Plastic (e.g. film, sheeting, bags, caps, canisters, boxes, cable ties, styrofoam, foam)
- Paper and paperboard (e.g. boxes, bags, wraps, rolls, shells)
- Wood (e.g. pallets, cable reels)
- A disposable beverage cup that is filled with a drink at the point of sale upon consumer order.
- A disposable packaging that is filled with product at the point of sale upon consumer order.
The extended producer responsibility applies to all professionally operating companies that place packaging on the market.
Extended producer responsibility for packaging applies to the following operators who professionally place packaging on the Estonian market:
- packers, i.e. companies that pack or package their products for the Estonian market (excluding service and farmer packaging),
- importers, i.e. companies that import packaged products to Estonia,
- distance sellers, i.e. foreign companies that sell remotely packaged products directly to Estonian users.
Beverage packaging and DRS
Mandatory inclusion in the deposit system applies to:
- Reusable glass and plastic packaging for beer, low-alcohol beverages, cider, perry, and soft drinks.
- Single-use glass, metal, and plastic packaging for beer, low-alcohol beverages, cider, perry, and soft drinks.
Voluntary inclusion in the deposit system applies to:
- deposit may also be applied to non-reusable and reusable packaging of strong alcoholic beverages, low-alcohol beverages and syrup.
- deposit may also be applied to other packaging (also to e-commercial packages).
The amount of the deposit is established by the regulation of the Minister of the Environment "Packaging Deposit Amount".
For single-use and reusable packaging for which a deposit amount has not been established by a regulation of the Minister of the Environment, the packaging producer may independently establish the amount of the deposit if the packaging producer has a packaging return system in place, based on which the quantities of packaging placed on the market and taken back can be monitored.
Estonia registers
Packaging register -Pakendiregister
Product of concern register - Probleemtooteregister
Member State registers
Register for electrical and electronic equipment: EWRN - European WEEE Registers Network: National Registers
Register for packaging National Members
Last updated: 18.03.2026
