Estonia's register of products of concern
Estonia files its producer duties under a phrase of its own. PROTO is the Estonian EPR producer register, the Register of Products of Concern, holding the goods the Waste Act calls probleemtoode.
It is administered under the Ministry of Climate. You register, receive a producer number, and meet your duties on your own or through a producer responsibility organisation. Under the Waste Act wording in force from 1 January 2026, a contract with a producer organisation is required for household electronics, tyres and portable, LMT, EV and industrial batteries. Packaging is handled separately, in PAKIS.
What PROTO covers
- Electronics: a producer organisation contract is required for household electronics, through PROs such as EES-Ringlus and Eesti Elektroonikaromu.
- Batteries: a producer organisation contract is required for portable, LMT, EV and industrial batteries, with the EU Battery Regulation from 18 August 2025.
- Vehicles: motor vehicles and parts are products of concern, with take-back through ELV operators.
- Tyres: a producer organisation contract is required.
- Agricultural plastic: a product of concern, with producer responsibility since 2013.
- Single-use plastics and fishing gear: cost-coverage duties, with systems required by end of 2024.
Who must register
Producers that first place products of concern on the Estonian market, importers and distance sellers included.
Getting a PROTO number
- Confirm your goods are products of concern under the Waste Act.
- If you have no Estonian place of business, appoint an Estonian authorised representative (see below).
- Apply in PROTO before you start selling. The Environment Agency registers you within 12 weeks of a complete application and issues your producer number.
- Sign with a producer organisation where the law requires it: household electronics, tyres and portable, LMT, EV and industrial batteries.
- Report the previous calendar year's data to PROTO by 31 January. A producer organisation reports for its members.
Your producer number
PROTO issues a producer number in the format "PRO" followed by six digits, for example PRO260151.
Foreign producers and the representative
Producers without a place of business in Estonia register in PROTO through an authorised representative established in Estonia. Non-EU distance sellers must appoint one.
Estonian terms you will meet
- Probleemtooteregister (PROTO): the register of products of concern.
- Probleemtoode: a product of concern.
- Jäätmeseadus: the Estonian Waste Act.
Estonia's other register
Packaging has its own Estonian register, PAKIS. This page is PROTO, the register of products of concern covering electronics, batteries, vehicles, tyres, agricultural plastic, single-use plastics and fishing gear.
Frequently asked questions about PROTO
Short answers to what producers ask most.
Who must register in PROTO?
Any producer, importer or distance seller placing products of concern on the Estonian market. Packaging is separate, in PAKIS.
What is a product of concern?
A probleemtoode: the Waste Act's category for electronics, batteries, vehicles, tyres, agricultural plastic, fishing gear and certain single-use plastics that carry producer duties.
What is my PROTO number?
A producer number in the format "PRO" plus six digits, issued when you register.
Do foreign producers need a representative?
Producers with no Estonian place of business register through an Estonian authorised representative, and non-EU distance sellers must appoint one.