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Packaging EPR in Estonia
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Checked 2026-09-03 · 4 sources · 4 open questions
- Register
- Riiklik pakendiregister (PAKIS)
- Authority
- Kliimaministeerium; register operated by Keskkonnaagentuur
- Law
- Pakendiseadus (PakS); Pakendiaktsiisi seadus; riikliku pakendiregistri põhimäärusif the packaging undertaking has handed its collection and recovery duty to a recovery organisation (taaskasutusorganisatsioon), the organisation files to the register on its behalf; only those who have NOT handed it over file themselves.
- Who registers
- You register yourself in the national system
- Threshold
- 20 t a yearAUDIT threshold, not a registration threshold: the packaging report must be audited by a sworn auditor once more than 20 t of packaging is placed on the market in a year (was 5 t until 15 May 2021).
- Reporting
- Annually, by 30 Junedata for the previous calendar year, by packaging and material type, incl. reusable packaging mass, mass placed on the market, recovery data, recycled content of plastic drink bottles and single-use plastic quantities. ⚠️ two dates found: the register statute says 30 June, the ministry page mentions 31 March — see conflicts.
- Household packaging schemes
- Eesti Pakendiringlus; TVO; ETO
- Industrial packaging schemes
- Eesti Pakendiringlus; TVO; ETO
What is not settled
- Authority The authority contradicts itself\ud83d\udd34 THE AUTHORITY CONTRADICTS ITSELF. Our row says the register is operated by Keskkonnaagentuur. EUNR names the Ministry of Climate and the Environmental Board of Estonia as the participating bodies.
- Reporting The authority contradicts itselfTHE AUTHORITY CONTRADICTS ITSELF. Two official sources give two deadlines: the register statute says 30 June, the ministry page says 31 March.
- Authorised representative Not established at sourceThe pages read do not address the authorised representative.
- Authorised representative Sources disagreeThe authorised-representative duty is under review. On 10 December 2025 the Commission published COM(2025) 982, part of the Omnibus VIII environmental simplification package, whose Article 2 would suspend Art. 45(3) until 1 January 2035; COM(2025) 983 proposes the same for the Single-Use Plastics Directive. The suspension as drafted covers producers ESTABLISHED IN THE UNION selling cross-border directly to end users. Producers established in third countries are not covered — member states may still require a representative or ensure traceability by other means. European Parliament committee reports of May 2026 would narrow the relief to micro and small enterprises. PROPOSAL, AND NOW LARGELY STOPPED: on 24 June 2026 the Council decided not to proceed with the suspension, opposed by a large majority of member states. A Parliament committee vote is expected around October 2026, and even the Parliament's narrower approach would keep the framework for producers outside the EU. Article 45(3) applies as written today, and for a producer established in a third country nothing in this proposal ever applied.
The same in every EU country
- PPWR Art. 44 — registration is a precondition for placing packaging on that market
- PPWR Art. 45(3) — a producer under Art. 3(1)(15)(c)/(d), i.e. one making packaging available in another Member State DIRECTLY TO END USERS, must appoint an authorised representative there. From 12 Aug 2026.
- set nationally, Art. 68; national rules due by 12 Feb 2027
- Art. 44(14) implementing act still pending; central EU register not before 1 Jan 2029
Sources
Countries with the same answer
We do not register you, we are not your authorised representative, and we do not pay a scheme. This is public information gathered in one place and checked on the date shown. Confirm with the national authority before acting.
Tarafex
The number these registers ask for is kilograms by material for one year of deliveries. If your shipments are recorded as they go out, that number already exists.
See what Tarafex does →
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