Producer responsibility
TVO provides a complete compliance solution for international companies placing packaging on the Estonian market. From registration and reporting to producer responsibility and Authorised Representative services, we help you meet your legal obligations efficiently and with confidence.
Producer responsibility in Estonia
Extended Producer Responsibility (EPR) obligations in Estonia
are primarily based on the Estonian Packaging Act and the EU Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR). EPR obligations apply to all businesses that meet the definition of a producer under the PPWR.General principles for determining who is a PRODUCER:
- A manufacturer or importer that places empty packaging or packaged products on the market of an EU Member State for the first time is a producer.
- A brand owner is the producer where packaged products are marketed under its name or trademark.
- An e-commerce seller is the producer where it sells packaged products directly to an end user in another EU Member State.
- For transport packaging, service packaging, and primary production packaging, the producer is generally the business that first places the empty packaging on the market, rather than the business using the packaging.
- A company that exports packaged goods directly to an end user in another EU Member State (whether a business using the product in its activities or a private consumer) is considered the producer in the destination Member State and must comply with all producer obligations applicable in that country.
Key obligations
Registration and reportingFulfilment of EPR obligations through a Producer Responsibility Organisation (PRO)
Authorised Representative
Audit of financial records and the data submitted to the Packaging Register (> 20 ton/per year)
Concluding a cooperation agreement with TVO
- TVO is producer responsibility organization (PRO) in Estonia
- TVO provides compliance services for all packaging types and materials, except beverage packaging covered by Estonia's deposit return system.
- To transfer your EPR obligations, a cooperation agreement must be signed with TVO.
- Once the cooperation agreement has been concluded, TVO submits all required agreement details to the Estonian Packaging Register (PAKIS). We also prepare and submit your annual packaging report to the Register on your behalf.
- You will receive access to the TVO reporting portal to report your packaging quantities. An overview of the reporting requirements and level of detail is available in FAQ (LINK).
- All ongoing communication and support are available in English. We have a dedicated contact person for international clients
- TVO has the right to conclude an agreement retroactively from the beginning of the current quarter.
- Please fill out the form below and we will send a pre-filled contract for review and, if suitable, for signing.
Services and fees
The service fees cover the following services provided by TVO:- Guidance on the interpretation of packaging legislation and ongoing advice on all matters related to packaging and packaging waste compliance.
- Assistance with preparing and verifying packaging reports.
- Organisation of the collection, recovery and recycling of packaging waste placed on the market, in accordance with legal requirements.
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Submission of the annual packaging report to the Estonian Packaging Register (PAKIS) on your behalf.
By concluding a cooperation agreement with TVO, a company is released from the obligation to pay packaging excise duty arising from the Packaging Excise Duty Act.
The packaging undertaking remains responsible for maintaining accurate records of the packaging placed on the Estonian market and, where required by law, arranging an independent audit of its packaging report. By joining TVO, the producer transfers the fulfilment of its extended producer responsibility (EPR) obligations to TVO, which carries out the statutory collection, recovery and recycling obligations on the producer's behalf.
Principles of Service Fee Application:
- TVO's service fees are public and equal for all Producers.
- The final amount payable to TVO depends on the quantities of packaging waste placed on the Estonian market by the Producer.
- The service fee depends on the type of packaging and packaging material.
- The service fee is calculated per unit of weight.
- No additional charges apply beyond the agreed service fees. This includes no minimum fees, fixed annual fees, administrative charges, notification fees, or registration costs.
Sales packaging
Packaging material | Collection and recycling service fee, €/ton |
| Glass | 91 |
| Plastic (mono) | 225 |
| Plastic (composite) | 360 |
| Paper- and paperboard (mono) | 80 |
| Paper- and paperboard (composite) | 135 |
| Beverage carton | 140 |
| Metal (ferrous/aluminium) | 162 |
| Wood | 20 |
| Other | 270 |
Transport- and grouped packaging
| Packaging material | Collection and recycling service fee, €/ton |
| Glass | 91 |
| Plastic | 60 |
| Paper- and paperboard | 65 |
| Metal (ferrous/aluminium) | 77 |
| Wood | 18 |
| Other | 270 |
No Estonian VAT is charged to foreign companies, where applicable under VAT legislation.
Registration and reporting
Under the PPWR, producers are required to register in each Member State where they qualify as a producer. At present, no dedicated producer register has yet been established in Estonia. Currently, information on companies that have joined a producer responsibility organisation, as well as data on the packaging they place on the Estonian market, is managed through the Estonian Packaging Register (PAKIS).For companies that have concluded a cooperation agreement with TVO, TVO submits the required agreement details and annual packaging reports to the Estonian Packaging Register (PAKIS) on the producer's behalf, in accordance with the requirements of Estonian legislation.
How to report
Packaging reports on the quantities of packaging placed on the Estonian market are submitted to TVO on a monthly or quarterly basis, as agreed. Companies that have concluded a cooperation agreement with TVO receive access to the TVO reporting portal for submitting their packaging data.
Packaged product → Identify packaging type → Identify material → Report weight (tonnes) → TVO calculates the fee
An overview of the required reporting detail is available in the link below:
Packaging reporting principles
Packaging Reporting Portal
Authorized representative
Companies that are not established in Estonia but place packaging on the Estonian market, regardless of the sales channel used, are required to appoint an Authorised Representative established in Estonia. The Authorised Representative fulfils the producer's obligations under the Estonian Packaging Act on the company's behalf.
TVO can provide Authorised Representative services under a separate Authorised Representative Agreement for additional fee. If you require this service, please contact us for further information.
Audit requirement
Companies placing more than 20 tonnes of packaging on the Estonian market per calendar year are required to have their packaging report and the underlying financial records independently audited.A company whose audit report summary is submitted unmodified (i.e., received a positive assessment) is exempt from conducting an audit for the next three calendar years.
TVO submits the auditor's report to the Estonian Packaging Register (PAKIS) on the producer's behalf.
TVO can assist you in finding a statutory auditor in Estonia who is authorised to carry out the required audit.
Legislation
PPWRPackaging Act
Packaging Excise Duty Act
Statute of the Packaging Register
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