WEEE and battery registration in Estonia

What PROTO covers

PROTO is the Estonian register of products of concern, known in Estonian as the probleemtoodete register. It was created under § 26¹ of the Waste Act (Jäätmeseadus) as a data collection system holding the quantities of products of concern brought into the country by producers, together with data on collection, reuse and recycling of the resulting waste.

All producers of electrical and electronic equipment operating in Estonia are required to register in PROTO and to submit data on a regular basis under the established procedure.

Who counts as the producer

The producer is whoever manufactures, imports or resells the equipment onto the Estonian market. Producers are responsible for the collection, recycling and recovery of waste from the equipment they place on that market.

As with packaging, this follows the party that puts the goods on the Estonian market. If you sell to an Estonian company that resells to consumers, that company is the producer for PROTO purposes.

The definition in Waste Act § 23(1³) applies irrespective of the selling technique, including sale by means of distance communication, and its fourth limb catches a party who sells electrical and electronic equipment by distance communication directly to Estonian households or other users while being established in another member state or outside the EU. Shipping direct to Estonian consumers from Germany makes you the producer under Estonian law.

What a producer responsibility organisation does

Producer responsibility organisations organise the reporting to PROTO on behalf of producers and arrange collection of waste equipment, appliances, batteries and accumulators through nationwide collection points. Eesti Elektroonikaromu is one such organisation operating in Estonia.

The practical effect is that a producer signs one contract, declares tonnage by category, pays a fee, and the organisation handles registration, reporting and collection infrastructure.

The register itself names the organisations, in the guidance documents it publishes for each stream.

For household appliances, joining one is not optional. The register states that for household equipment a contract with a producer responsibility organisation is compulsory, and producers of portable, light-transport, electric-vehicle and industrial batteries are likewise required to contract with one, which then files the registration application on their behalf.

What it costs

Waste Act § 23(4)5) requires every producer responsibility organisation to publish, on its own website, the contribution producers make per tonne of products of concern placed on the market. So the rate is always checkable rather than a matter for negotiation in the dark. Under § 23(4¹) the charge must take account of product durability, reparability, re-usability, recyclability and the presence of hazardous substances, on a life-cycle basis.

Eesti Elektroonikaromu publishes its recovery tariffs in euro per kilogram. A representative selection:

Batteries are priced separately, again per kilogram: 0.60 for ordinary portable batteries and for nickel-metal-hydride and nickel-cadmium cells, 0.76 for portable lithium batteries, 0.80 for lithium-ion accumulators including those in light transport vehicles, and 0.065 for lead accumulators. Invoices carry a minimum of 10 euros plus VAT.

How this interacts with packaging registration

They are separate obligations in separate registers, and a single product can trigger both.

Frequently asked questions

What is PROTO?

PROTO is the Estonian register of products of concern (probleemtoodete register), created under § 26(1) of the Waste Act. It holds data on the quantities of products of concern placed on the Estonian market and on the collection, reuse and recycling of waste from them.

Do I need to register if I sell an LED lamp to Estonia once?

The Waste Act sets no minimum quantity. § 26(1)(1¹) states flatly that producers are required to register themselves in the register of products of concern and to submit data to it, and neither a threshold nor a de minimis quantity appears anywhere in the Act. What the obligation does attach to is professional activity: § 23(1⁸) defines placing on the market as making a product available on the Estonian market for the first time on a professional basis. A genuine one-off private sale is not that. A trial shipment as part of your business is, however small.

Does a battery supplied inside a product need separate registration?

It needs separate declaration, which is the practical question. Batteries and accumulators are their own category of products of concern under § 25(2)1), distinct from equipment under § 25(2)4), and the rule the recovery organisations apply is that a battery inside a device being sold must be declared separately from the device. The worked example they give: an importer of laptops containing lithium-ion cells declares the laptop weight under the screens category and the battery weight under the portable lithium-ion battery code. Batteries sold on their own carry the same battery code. So the treatment does not change with how the battery arrives, and the EU definition agrees, since a producer under Regulation (EU) 2023/1542 is one who supplies batteries including batteries incorporated into appliances.

If I sell to an Estonian distributor, who registers?

The Estonian distributor, as the party placing the equipment on the Estonian market.

Is WEEE registration the same as packaging registration?

No. They are separate registers with separate reports. Packaging goes in the packaging register, electrical equipment and batteries go in PROTO. A boxed appliance triggers both.

Can I register directly instead of joining an organisation?

Only if you are established in Estonia, and not at all for household appliances. PROTO accepts direct registration from Estonian producers only; a producer established abroad must work through an Estonian branch or an authorised representative established in Estonia. For household equipment, and for portable, light-transport, electric-vehicle and industrial batteries, contracting a producer responsibility organisation is compulsory rather than merely convenient, and the organisation then files the registration.

When is the report due?

By 31 January for the previous calendar year. Note that this is two months earlier than the packaging register deadline of 31 March, so a producer carrying both obligations has two separate reporting dates.

What changed for batteries in December 2025?

Estonian battery rules moved to EU law. From 13 December 2025 the Waste Act defines a battery by reference to Article 3 of Regulation (EU) 2023/1542, and § 26(3¹) provides that collection, return, recovery and the collection and recovery targets for waste batteries are set out in Chapter VIII of that Regulation. The national definition of a battery producer was repealed at the same time. Supervision of Chapter VIII compliance sits with the Environmental Board.

Sources

• Waste Act (Jäätmeseadus) §§ 23, 25, 26, 26¹, consolidated text in force 01.07.2026, Riigi Teataja. Checked 2026-08-28.
• Register of products of concern (PROTO), proto.envir.ee, and its published guidance on electrical and electronic equipment (09.05.2026) and on batteries and accumulators (18.05.2026). Checked 2026-08-28.
• Recovery tariffs, Eesti Elektroonikaromu. Checked 2026-08-28.
• Regulation (EU) 2023/1542 concerning batteries and waste batteries, Chapters III and VIII.
• Extended producer responsibility, Ministry of Climate.

Seekor is the trading name of Mervantis OÜ, an Estonian distribution company (register code 14412321). We sell electrical equipment in Estonia, so when we take on a powered range the PROTO registration is ours to arrange rather than yours. How it works.