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 fishing gear containing plastic 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, register your company in PROTO. A producer of fishing gear containing plastic must conclude a contract with a waste management company to organise waste management and meet recovery targets through them. Additionally, the company must arrange for user awareness initiatives, including awareness campaigns. 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:

• Nets;
• Fyke nets;
• Traps;
• Fishing lines and monofilaments;
• Ropes;
• Floats;
• Other fishing gear and components containing plastic used in fishing or aquaculture.

If the material composition of the product is unclear, verify it with the supplier or check the product's technical documentation.

A company places fishing gear containing plastic on the Estonian market, for example, when they make it available on the Estonian market for the first time:

• Manufactures these products 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 products 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.

Based on this category, a company does not have an obligation to register in PROTO if it purchases the product 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 product belongs to this category of products of concern;
• Whether you have a confirmation or document to rely on if necessary.

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.

FAQ on fishing gear

• Waste Act

SUP Directive 2019/904