Principle of producer responsibility

Requirements for the collection, recovery, and treatment of waste generated from electrical and electronic equipment (EEE) have been established at the EU level by EU Directive 2002/96/EC, more widely known as the WEEE Directive.

In Estonia, the requirements set out in the WEEE Directive are reflected in the Waste Act and the regulations of the Government of the Republic and the Minister of the Environment adopted on the basis of the Waste Act.

The Waste Act introduces the principle of producer responsibility, according to which producers must ensure the collection and the recovery or disposal of waste generated from EEE manufactured, resold, or imported by them. The related costs must be borne by the producer, which means that producers must arrange for the acceptance, collection, recovery, and treatment of waste generated from their products.

It is important to note here that ‘producer’ does not refer only to producers in the traditional sense of the word: within the meaning of the relevant legislation, ‘producers’ also means all importers of electrical and electronic equipment.

The principle of producer responsibility has been applicable to EEE in Estonia since 13 August 2005 and involves the following obligations:

• Producers must ensure the collection and recovery of waste generated from EEE manufactured or imported by them, and must bear the related costs.
• Producers shall be jointly responsible for the collection and recovery of waste generated from EEE placed on the market before 13 August, and the related costs shall be distributed between them according to each producer’s market share in the sale of the corresponding type of EEE.
• Final consumers must be able to deliver any generated WEEE free of charge to a collection system set up by the producer(s).

In the operation of the system of collection and recovery of EEE it is important to have an overview of the producers, the EEE they have placed on the Estonian market, and data on the collection and treatment of the waste generated from this.

All producers of EEE operating in Estonia are required to register in the National Register of Products of Concern (PROTO) and submit data to the register on a regular basis in accordance with the established procedure. Based on the data in the register, the state can check how each producer is fulfilling the obligation placed on them to treat waste generated from EEE.

Which types of EEE are subject to producer responsibility?

Equipment listed in the annex to Regulation No. 65 of the Government of the Republic of 20 April 2009 establishing the requirements and procedure for the collection, return to the producer, and recovery or disposal of waste generated from electronic equipment, and the targets and deadlines for achievement thereof. Please note that this list is not exhaustive.

CATEGORIES OF ELECTRICAL AND ELECTRONIC EQUIPMENT

1. Heat exchange equipment

For example: refrigerators, freezers, medical freezers, air conditioners, air conditioning and cooling equipment; stationary centrally controlled air conditioning, freezing, refrigeration, and cooling equipment etc.

2. Screens, monitors, and devices with a screen larger than 100 cm²

For example: laptops; displays (glass / CRT / liquid crystal (LCD) / plasma); television sets (with or without built-in additional unit); other telecommunication products or equipment for transmission of images or other information, etc.

3. Lamps

For example: LED luminaires, LED light bulbs and other LED products; Straight fluorescent tubes; Energy-saving lamps, other gas-discharge lamps, etc.

4. Large appliances (with any external dimension greater than 50 cm)

For example: microwave ovens; vacuum cleaners, carpet sweepers, other electric cleaning appliances; sewing, weaving, and knitting machines and other textile processing machines; other electric motor-driven domestic appliances not elsewhere specified; personal computers, including keyboard and mouse (excluding monitor); printers, all types (dot matrix, laser, inkjet), copiers, duplicators, scanners, fax machines; other products and equipment for electronic collection, storage, processing, presentation, or transmission of data; other equipment (radio, video/DVD, CD player, cassette player, turntable, amplifiers, speakers, TV boxes, SAT systems); fixtures for work and home use (ceiling-, floor-, desk-mounted, etc.); electric current generating equipment; lawn mowers and other electrical garden tools, high-pressure washers, compressors, etc. for home use; electric tools; coin-operated slot machines, large vending machines and ATMs; sports equipment with electrical or electronic components; large musical equipment; devices for detecting, preventing, monitoring, treating, or alleviating disease, injury, or disability; other monitoring and surveillance equipment used in industrial plants (e.g., control panels); washing machines; clothes dryers; cookers (full height); hobs and ovens (including electric hobs); dishwashers; other large appliances used for storing, cooking, and other processing of food; electric fans and other ventilation and exhaust equipment; electric heaters (boilers, radiators, etc.); solar panels, solar heating systems and the accompanying equipment and accessories.

5. Small appliances (with no external dimensions exceeding 50 cm)

For example: clothes irons and other equipment for ironing or rolling laundry or other clothing care procedures; toasters, deep fryers; coffee grinders, coffee machines and apparatuses for opening containers or packaging; electric knives; hair clippers, hair dryers, toothbrushes, shavers, massagers, and other personal care appliances; clocks, watches, and equipment for measuring or recording time; scales; other electrical motor-driven domestic appliances not elsewhere specified; consumer equipment, fixtures (ceiling-, floor-, table-mounted, etc.); other equipment (radio, video/DVD, CD player, cassette player, turntable, amplifiers, speakers, clock radios, portable radios / CD players / music players, digital TV boxes); other products or equipment for recording or reproducing sound or images, including equipment for transmitting sound, images, and signals other than those for telecommunication technologies; equipment with integrated solar panels; electric tools (for screwing, drilling, grinding, sawing, welding, spraying, etc.); lawn mowers and other electrical garden tools, high-pressure washers, compressors, etc. for home use; video games and electrically powered or battery-powered games and toys; sports equipment with electrical or electronic components; small musical equipment; d for detecting, preventing, monitoring, treating, or alleviating disease, injury, or disability; smoke detectors, heating resistors, thermostats; measuring, weighing, or regulation equipment for home or laboratory use; other monitoring and surveillance equipment used in industrial plants (e.g., control panels).

6. Small information technology and telecommunication equipment (with no external dimensions exceeding 50 cm)

For example: Personal computers, PDAs, tablet computers; mobile phones; wireless phones, telephones, telephone exchanges, modems and answering machines together with accessories; transformers and battery chargers (sold separately); other telecommunication products or equipment for transmitting sound, images, or other information.

BATTERIES AND ACCUMULATORS

Explanation.

Pursuant to the statutes of the National Register of Products of Concern, the following procedure must be followed when declaring batteries and accumulators.

• First, identify the category of the battery or accumulator:

Portable and installed in electrical and electronic equipment. Designation: PATk (neither an industrial nor automotive battery or accumulator). The battery or accumulator inside the sold EEE must be declared separately from the EEE.

Automotive. Designation: PATa (accumulator used for automotive starter, lighting, or ignition power).

Industrial. Designation: PATt (accumulator designed for exclusively industrial or professional uses or used in any type of electric vehicle).

• Then, identify the type of the battery or accumulator:

1. Other types – Muu
2. Nickel–metal hydride – NiMH
3. Nickel–cadmium – NiCd
4. Lithium–ion – Li-ioon
5. Mercury oxide – Hg
6. Silver oxide – Ag2O
7. Liitium – L
8. Lead – Pb

When preparing a declaration, different types of batteries and accumulators must be indicated separately. Examples: A company that imports laptops with, for example, lithium–ion batteries, must declare the weight of the laptop (identifier: 201) and the weight of the battery (identifier: PATk Li–ion) separately. If the company also sells laptop batteries separately, they must be declared using the identifier PATk Li–ion.

For batteries sold separately, note that PROTO does not require separate declaration for the three best-selling battery types (alkaline batteries, zinc–carbon (ZnC) batteries, and magnesium (Mg) batteries), and these classify under the identifier PATk Muu.

Silver oxide batteries (button cells used mainly in electronic clocks and calculators) must be declared separately. Here, too, it is important to consider whether they are sold separately or installed in EEE, and the identifier would be PATk Ag2O. The same principle applies to mercury oxide batteries (button cells used in hearing aids and photography equipment) – PATk Hg. Lithium batteries (button cells used in clocks and photography supplies) must be declared using the identifier PATk L.

Categories of batteries and accumulators

PATk – portable batteries and accumulators (incl. those sold separately)