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

• The product is a piece of electrical or electronic equipment or a component of it;
• The company places the product on the Estonian market;
• The obligation is not fulfilled by an Estonian supplier, a producer responsibility organisation (PRO/TVO), or another responsible party.

If all conditions are met, the method of fulfilling the obligation depends on the type of equipment. For household electrical and electronic equipment, you must join an appropriate producer responsibility organisation (PRO). In other cases, it is also possible to register independently in PROTO. If the equipment contains a battery or an accumulator, additionally check the batteries and accumulators category. If necessary, read more 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 Estonian Environment Agency.

This category includes, for example:

• Large household appliances, such as refrigerators, washing machines, and stoves;
• Small household appliances, such as kettles, toasters, and vacuum cleaners;
• Computers, laptops, monitors, printers, and other IT equipment;
• Telephones, routers, headphones, and other telecommunication equipment;
• Lamps, luminaires, and other lighting equipment;
• Electrical and electronic tools;
• Electrical toys, sports, and leisure equipment;
• Medical devices, monitoring and control instruments;
• Automatic dispensers and other automated devices;
• Equipment containing a battery or an accumulator.

Electrical and electronic equipment can be sold as a standalone product or be part of a larger product. If the device contains an accumulator or a battery, also check the category for batteries and accumulators; in this case, the obligations for both the device and the accumulator or battery must be assessed.

A company places electrical and electronic equipment or their components on the Estonian market, for example, when they make it available on the Estonian market for the first time:

• Manufactures electrical and electronic equipment or its components in Estonia;
• Imports them to Estonia from another European Union country;
• Orders the product from outside the European Union and sells it to a customer in Estonia;
• Sells them to customers in Estonia;
• Leases or rents them out in Estonia;
• Sells them to customers in Estonia via an online store or other means of distance communication;
• Uses electrical and electronic equipment or their components ordered from abroad to provide its services;
• Sells them under its own name or trademark – the company may carry 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.
If the device contains a battery or an accumulator, it must be verified separately whether an obligation also arises regarding the batteries and accumulators.

Based on this category, a company does not have an obligation to register in PROTO if it purchases the electrical or electronic equipment or its component from an Estonian supplier who has already placed it on the Estonian market and fulfilled the producer responsibility obligations. Check with the supplier to confirm:

• Whether the supplier has placed the product on the Estonian market;
• Whether the producer responsibility obligation has been fulfilled;
• Whether the battery or accumulator inside the device is also covered by the obligation.

Depending on the situation, the obligation may rest with the supplier. In such cases, it is necessary to determine who placed the product on the Estonian market for the first time – that party must comply with the requirements.

Household equipment includes all devices typically used at home. This also includes equipment used in commerce, industry, or institutions that is similar in nature to household appliances. If a device is likely to be used both at home and elsewhere, it is always classified as household equipment, for example: solar panels, coffee makers, heating appliances, and power tools.

No. To organise the collection and recovery or disposal of waste generated from household electrical and electronic equipment, producers are required to conclude a written contract with a producer responsibility organisation (PRO).

FAQ on Electrical and Electronic Equipment

Eesti Elektroonikaromu OÜ

MTÜ Eesti Elektri- ja Elektroonikaseadmete Ringlus

• Waste Act

WEEE Directive - 2012/19/EL