Estonia

Extended Producer Responsibility (EPR) for Packaging in Estonia

Extended producer responsibility for packaging in Estonia
Estonia transposed the EU Packaging Directive through the Packaging Act (Pakendiseadus), first in force on 1 June 2004 and most recently over-hauled on 10 January 2025. The scheme—commonly called EPR Estonia—makes every “packaging undertaking” finance collection, recovery and auditing of packaging waste. Oversight is shared by the Climate Ministry, the Estonian Environmental Board (Keskkonnaamet) and the Packaging Register run by the Estonian Environment Agency (Keskkonnaagentuur).

Who must register for EPR in Estonia

• Estonian manufacturers/packers that first place packaged goods on the market.

• Importers or distributors bringing packaged goods from abroad.

• Distance-selling companies without an Estonian establishment (must act via an authorised representative; see §10² of the Act).

What the package includes

• Paper & cardboard
• Plastics (incl. PET, HDPE, films)
• Glass
• metals (steel, aluminium)
• Wood
• Composites

Thresholds

There is no exemption from registration or reporting, but two light-duty rules apply:

• ≤ 20 t per year → annual report may be filed without costly external audit.

• Micro-entities (< 10 employees and turnover ≤ €2 million) are still expected to register, yet their audit duty rarely arises.

EPR registration procedure in Estonia

• Open a Packaging Register account (pakis.envir.ee) using an Estonian e-ID or Smart-ID.

• Choose and contract a recovery organisation (PRO)—e.g., Eesti Pakendiringlus, Eesti Taaskasutusorganisatsioon (ETO), Tootjavastutus­organisatsioon or Ragn-Sells.

• Submit a yearly quantity forecast and pay the membership fee.

• Keep weight records & source documents for seven years (§24 Packaging Act).

• PRO uploads your data; the Register issues an EPR number required by marketplaces—completing EPR registration Estonia.

Authorized representative

Reporting Deadline

• Annual declaration: packaging quantities for the previous calendar year must reach the Packaging Register and your PRO by 1 September.

• Interim reports: many PRO contracts require quarterly or monthly weight statements—the timetable is agreed in the membership agreement

Who Assumes Responsibility?

• Estonian manufacturers / packers: carry full responsibility for their packaging as soon as the product is first placed on the Estonian market.

• Importers / distributors: become fully liable at customs clearance, provided the packaging is not already licensed upstream.

• Foreign distance sellers: assume liability—through an authorised representative—when they make a direct B2C sale to an Estonian customer.

• Producer Responsibility Organisations (e.g., Eesti Pakendiringlus): handle the operational tasks of collection, recycling, and data transfer.

• Keskkonnaamet / the Packaging Register: oversee enforcement and registry duties, including audits and the imposition of penalties.

Duties of Each Group Who Is Responsible

• Producers / importers: join a PRO, pay eco-fees, file accurate data, retain documents seven years, and commission an audit if > 20 t packaging placed on market.

• Authorised representative: hold local mandate, sign PRO contract, submit reports and fees, receive official correspondence.

• PROs: meet Estonia’s material-specific recycling targets, operate nationwide collection points, audit member data and forward compliance reports.

• Keskkonnaamet / Environment Agency: maintain producer register, carry out inspections and can fine non-compliant firms up to €400 000