Based on this category, a company is generally required to register in PROTO if all three of the following conditions are met:

• The product is a pre-moistened wipe containing plastic;
• The company places it on the Estonian market;
• The obligation is not fulfilled by an Estonian supplier or another responsible party.

If all conditions are met, register your company in PROTO. If necessary, read more about the next steps in the section on fulfilling obligations.

If it is unclear whether a product contains plastic, 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 pre-moistened wipes containing plastic that are intended for personal hygiene or household use. This includes, for example:

• Baby wipes;
• Makeup remover wipes;
• Intimate hygiene wet wipes;
• Pre-moistened household cleaning wipes;
• Other similar pre-moistened wipes containing plastic.

If the product does not contain plastic, it does not belong to this category. If the material composition is unclear, verify it with the supplier or check the product's technical documentation.

If your company does not handle wet wipes containing plastic, no obligation to register in PROTO arises based on this category.

A company places wet wipes 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;
• 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 wet wipes from an Estonian supplier who has already placed them 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 contains plastic;
• 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.

• Waste Act

SUP Directive 2019/904