Manufacturer and importer

Principle of Producer Responsibility

The Waste Act in force in Estonia establishes the principle of producer responsibility for so-called problem products, which means that the producer is obliged to ensure the collection and recycling or disposal of waste generated from the problem product manufactured, sold, or imported by them. Since 2006, used tires have also been included in the category of problem products.

Producer responsibility applies to entrepreneurs, including manufacturers, importers, wholesalers, and retailers, who are responsible for the substances, ingredients, and the product as a whole, from its production to its transformation into waste.

The principle of producer responsibility applies to tires in European Union member states, whereby tire importers and manufacturers are required to finance a system for collecting and recycling used tires.

In practice, this means that the manufacturer or importer adds a recycling fee to the price of a new tire and pays the collected money to the producer responsibility organization, which organizes the collection and recycling of tires.

The manufacturer or importer is obligated to join the producer responsibility organization according to Section 25¹, paragraph 6 of the valid Waste Act (https://www.riigiteataja.ee/akt/131122010029?leiaKehtiv). Tire retailers have an obligation to accept one-to-one old tires at their workshop when a customer purchases new tires from them or to provide the address of the nearest collection point.

The requirements for joining and the collection network are regulated by Regulation No. 80, also known as the Tire Regulation, adopted on June 17, 2010 (https://www.riigiteataja.ee/akt/13335801?leiaKehtiv)

For additional questions, please contact us.

National Problem Product Register

The National Problem Product Register (abbreviated as PROTO) is established to keep records of producers of problem products, problem products themselves, waste generated from them, as well as the recycling and disposal of waste, including waste exported from Estonia.

The goal of PROTO is to maintain accounting for the fulfillment of recycling targets set in Estonian legislation and to provide waste-related information to the European Commission based on the data registered in the system. All problem product importers operating in Estonia, including tire importers, must be registered in PROTO. Tire importers can add themselves to the register through a producer responsibility organization (e.g., MTÜ Estonian Tire Recycling) by using the organization's waste plan.

If the problem product importer has joined a producer responsibility organization (PRO), they have delegated their obligations arising from the law and regulation to the PRO, who takes full responsibility for complying with the laws and regulations.

When registering as an individual company, the problem product importer must submit a waste plan to PROTO, specifying how the company intends to collect old problem products.

The company must also submit quarterly reports to PROTO on the quantities of problem products imported into Estonia, sold in Estonia, exported from the country, and produced in Estonia, both in tons and pieces. The company also needs to provide PROTO with the quantities of problem products collected and recycled. If the company has joined a producer responsibility organization (PRO), the data is transmitted to PROTO by the PRO.

For more information, visit PROTO's website at: https://proto.envir.ee/