About Estonian Register of Products of Concern.

On 30 January 2006, the Government of the Republic adopted Regulation No. 26 establishing the National Register of Product of Concern (official abbreviation PROTO). Text of the regulation: https://www.riigiteataja.ee/ert/act.jsp?id=988587

The data controller of the National Register of Products of Concern is the Ministry of the Environment and the data processor is the Information Technology Centre of the Ministry of the Environment.
 
All producers of products of concern operating on the Estonian market must register in the register. PROTO keeps records of the quantities of products of concern placed on the market in Estonia and imported to Estonia, as well as of the recovery and disposal of waste generated from these products of concern.

PROTO provides an overview of the import of products of concern to the Republic of Estonia, as well as the sale of products of concern and the treatment of waste generated from this. 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 products of concern.

The register enables the possibility to identify the quantities of products of concern imported to Estonia, as well as the share of products placed on the market in Estonia by both product type and producer.

This makes it possible to establish the percentage of products placed on the market by each producer and to demand that they cover waste management costs in proportion to their market share. It also makes it possible to establish the extent to which waste generated from products of concern is collected, recovered, disposed of, and exported.

Persons who import or manufacture products of concern (i.e. producers within the meaning of section 23 of the Waste Act) are required to submit the data provided for in the regulation to PROTO.

The information required to be submitted to the register includes the following:

1. Name, commercial register code, postal address, EHAK code, EMTAK code, name of authorised representative, telephone and fax number, e-mail address.

2. Name and trademark of the products of concern, and a description of the activity related to the products (manufacture, import, export, placing on the market of the products of concern).

3. A declaration that the products of concern conform to the requirements set out in Regulation No. 158 of the Government of the Republic of 29 April 2004 establishing a detailed list of hazardous substances prohibited in products of concern and imposing prohibitions and restrictions on products of concern.

4. A description of the waste-related activity (waste treatment plan indicating the expected quantity of waste generated or treated, and indicating the national waste collection network, information on the financing of the treatment of the waste, other persons treating the waste, and the methods of recovery, disposal, and export).

5. Information on the existence of a financial or other guarantee to ensure the collection and treatment of waste generated from the products of concern.

6. The weight of imported products of concern, the weight of manufactured products of concern, the weight of exported products of concern, the weight of products of concern placed on the market.

7. The weight of waste collected, the weight of waste reused, the weight of waste recycled, the weight of waste recovered for energy generation, the total weight of waste recovered, the weight of waste disposed of.

8. The weight of waste treated in Estonia, the weight of waste sent for treatment in another Member State, the weight of waste sent for treatment outside the European Community, the weight of recyclable waste exported to another Member State, the weight of disposable waste exported to another Member State, the weight of disposable waste exported outside the European Community, the weight of recyclable waste exported outside the European Community.

The quantities of products of concern reported to the register by a producer indicate the extent of the liability and obligations of that producer. Producers may report data to the register independently or via the respective producer association.

Most of the producers operating in Estonia have chosen to fulfil their obligations through a producer association, because compliance with the established requirements is relatively complicated and impractical for companies when acting alone (requirement of a national collection network, arrangement for waste treatment, etc.). It is easier (and cheaper) to delegate your responsibilities to a producer association, as this allows you to focus on your core activities with peace of mind.

Eesti Elektroonikaromu is a producer association (ID = 10175) registered with PROTO which represents its member producers in their relations with the National Register of Products of Concern and manages the submission of all data required from its member producers.

Additional information: National Register of Products of Concern