Obligations can be affected by changes such as, for example:

• The company begins selling a new category of products of concern;
• The company stops selling a certain product of concern;
• The company begins purchasing products from abroad instead of an Estonian supplier;
• The company begins selling to Estonian customers via an online store or other means of distance communication;
• The company begins selling products under its own name or trademark;
• A product begins to contain an accumulator, batteries, electronics, components of electronic equipment, or tyres;
• The quantities of products placed on the Estonian market change;
• The company joins a PRO or ceases fulfilling obligations through a PRO;
• The contact person or the individual responsible for reporting within the company changes.

If the change concerns whether the company is an obligated party at all, clarification should be requested from the Estonian Environment Agency or the PRO for the respective product category.

If a company terminates its activities involving products of concern, it must submit an application to the Estonian Environment Agency to delete its PROTO registration. If the business has transferred its obligations to a PRO, the contract with the PRO must be terminated in accordance with the terms of the contract, and the PRO will notify the Estonian Environment Agency. If operations are discontinued mid-year, the obligation to submit reports for that period remains.

It is advisable to ask for help when it is not clear:

• Whether a product belongs to a category of products of concern;
• Whether the company is the party placing the product on the Estonian market;
• Whether the obligation rests with the company, the supplier, or another party;
• Whether obligations can or must be fulfilled through a PRO;
• Whether PROTO-related procedures are performed by the company itself or by the PRO;
• What data needs to be collected;
• How to handle more complex cases, such as ordering from abroad, online sales, large batteries, equipment with batteries or electronics, or products moving onward out of Estonia.

If the question concerns a specific product or supply chain, it is useful to gather the product description, origin, sales channel, target market, and information on whether the product remains in Estonia for use before seeking assistance.

The obligation is to register in PROTO before placing products of concern on the market. If a company later discovers that it has a registration obligation, it must do so as soon as possible. Contact an appropriate PRO or the Estonian Environment Agency to agree on the next steps.

Waste Act

Probleemtooteregistri määrus