As a rule, a company is required to register in PROTO if all of the following conditions are met:

• the product is a battery or accumulator, or contains one;
• the company places it on the Estonian market;
• the obligation is not fulfilled by an Estonian supplier, a PRO, or another responsible party.
  
  If all conditions are met, the method of fulfilling the obligation depends on the type of battery or accumulator. For portable batteries and accumulators, light means of transport batteries, electric vehicle batteries, and industrial batteries and accumulators, you must join an appropriate PRO. For motor vehicle batteries, the company can choose whether to register independently or through a PRO. If necessary, read about the next steps in the section on fulfilling obligations.
  
  If it is unclear whether a product belongs to this category or whether the obligation has already been fulfilled, request confirmation from your supplier or the Environment Agency.

This category includes:

• portable batteries and accumulators, such as standard batteries, button cells, power banks, and small rechargeable batteries;
• light means of transport batteries, such as electric scooter or electric bicycle batteries;
• electric vehicle batteries;
• motor vehicle batteries;
• industrial batteries, such as energy storage batteries and other batteries intended for industrial use.
  
  A battery or accumulator may be sold as a standalone product or be contained within another product.

A company places a battery, accumulator, or a product containing them on the Estonian market, for example, when they make it available on the Estonian market for the first time:

• manufactures batteries, accumulators, or products containing them in Estonia;
• brings them to Estonia from another European Union country;
• orders the product from outside the European Union and sells it to an Estonian customer;
• sells them to Estonian customers;
• leases them out in Estonia;
• sells them to Estonian customers via an online store or other means of distance communication;
• uses batteries, accumulators, or products containing them ordered from abroad to provide its service;
• sells them under its own name or trademark – it may bear producer responsibility even if it does not manufacture the product itself.
  
  The obligation does not depend on the quantity. The determining factor is whether the product is placed on the Estonian market.

Based on this category, a company does not have an obligation to register in PROTO if it purchases batteries, accumulators, or products containing them from an Estonian supplier who has already placed them on the Estonian market and fulfilled the producer responsibility obligation.

Check with the supplier:

• whether the supplier has placed the product on the Estonian market;
• whether the producer responsibility obligation has been fulfilled;
• what type of battery or accumulator it is;
• whether the company from which the purchase is made is registered in PROTO, for example, for accumulators and batteries.
  
  Depending on the situation, the supplier may also bear the obligation. In such cases, it must be determined who first placed the product on the market in Estonia – that party must comply with the requirements.

Regarding motor vehicle batteries, the producer has the option to fulfill the requirements independently. To organize the collection and recovery or disposal of waste generated from portable batteries and accumulators, light means of transport batteries, electric vehicle batteries, and industrial batteries and accumulators, producers of these products of concern are required to conclude a written contract with a producer responsibility organisation.

Batteries and accumulators FAQ
 
Eesti Elektroonikaromu OÜ

MTÜ Eesti Elektri- ja Elektroonikaseadmete Ringlus

• Waste Act

EU Batteries Regulation 2023/1542