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

• the product is a motor vehicle or a part thereof;
• the company places the product on the Estonian market;
• the obligation is not fulfilled by an Estonian supplier, a PRO, or another responsible party.
  
  If all conditions are met, register the company in PROTO. A manufacturer of motor vehicles and their parts must conclude a contract with a waste management operator to arrange waste handling and meet recovery targets. The company must also organize user awareness efforts independently, including nationwide awareness campaigns. 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:

• Category M1 motor vehicles (vehicles with no more than eight seats in addition to the driver's seat) and their parts;
• Category N1 motor vehicles (vehicles with a maximum mass not exceeding 3.5 tonnes) and their parts
• Category L2e motor vehicles and their parts, which are divided into subcategories:
  - Category L2e-P motor vehicles (three-wheeled mopeds designed for passenger transport) and their parts;
  - Category L2e-U motor vehicles (three-wheeled mopeds designed as utility vehicles) and their parts.
  
  A vehicle-related product may also belong to another category of products of concern. For example, separate extended producer responsibility obligations apply to tyres and motor vehicle batteries, which should be checked under the respective category.

A company places motor vehicles and their parts on the Estonian market, for example, when they make it available on the Estonian market for the first time:

• manufactures these products 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 motor vehicles and their parts 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 a motor vehicle or a part thereof from an Estonian supplier who has already placed it 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;
• 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 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.

No, for category M1, N1, and L2e motor vehicles, a separate contract must be concluded with a PRO regarding tyres, and for batteries, you must either register independently or conclude a contract with a PRO. Other motor vehicles themselves are not products of concern, but the tyres, batteries, and accumulators attached to them are also subject to producer responsibility. To fulfill producer responsibility obligations for tyres, a contract must be concluded with a producer responsibility organisation. Regarding motor vehicle batteries, the producer has the option to fulfill the requirements independently.

FAQ on Motor Vehicles and Their Parts

• Waste Act

End-of-Life Vehicles Directive (ELV Directive) - 2000/53/EÜ