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 through a producer responsibility organisation, which has been mandatory for most streams since 2022. Packaging is handled separately, in PAKIS.
What PROTO covers
- Electronics: through PROs such as EES-Ringlus and Eesti Elektroonikaromu.
- Batteries: mandatory PRO membership since 2022, 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: mandatory PRO membership since 2022.
- 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).
- Register in PROTO and receive your producer number.
- Join the relevant producer responsibility organisation for your stream.
- Report put-on-market data as required.
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 and single-use plastics.
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 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.