Guide: Extended Producer Responsibility (EPR) for Packaging in Estonia
Since January 1, 2020, Estonia has taken a significant step forward in environmental stewardship by implementing an Extended Producer Responsibility (EPR) system aligned with the Directives Act (Riigikogu, 2004a) for packaging. Under this progressive framework, producers bear the responsibility for their products throughout their lifecycle, with a particular focus on packaging materials.
Responsibility in Estonia
The Packaging Act, together with its accompanying regulations, holds various entities accountable for compliance, including:
- Online seller
Definition of Packaging under the Packaging Act
The Packaging Act of the Republic of Estonia classifies the following materials as packaging:
- Paper, carton, corrugated board
- Beverage carton
- Glass and ceramics
- Ferrous metal
There are no lower quantity minimum quantities. Thresholds to exempt anyone introducing packaged products from their obligations. Even sending a single parcel or a solitary product item obliges compliance.
Producer’s Responsibilities under EPR in Estonia
Producers dealing with EPR products must undergo registration with the relevant authority to acquire a packaging registration number. This process entails:
- Producers are obliged to diligently report various types of packaging to the Ministry of Climate.
- Producers must sign a contract with eco-operators (Extend organization responsibility) required to levy eco-contributions corresponding to each material type and establish contracts with eco-operators.
2. Fee Payments
- The fee depends on the EPR for each type of material; the producers are required to make eco-contributions as specified by the PRO.
- VAT will be added to the service fees in the amount of 20%.
Producers must submit annual reports detailing their packaging quantities.
Producers must designate an authorized proxy situated in Estonia to perform the tasks specified in the authorization received from the packaging company.
In Estonia, the deadline for submitting yearly reports is no later than the 10th of January of the calendar year.
Sanctions for Violation
In cases of non-compliance:
- Failure to fulfill the obligation to take back packaging and packaging waste or violation of the take-back requirements shall be punished with a fine of up to 300 fine units.
- Violation of the requirements for keeping records of packaging and packaging waste or failure to implement a self-checking system shall be punished with a fine of up to 200 fine units.
- The delayed payment of the amounts provided for in the Contract with extended organization responsibility, the producer undertakes to pay late interest 0.05% of the amount delayed for a day upon the request.