Extended Producer Responsibility

Producer responsibility applies to approximately 50,000 Finnish manufacturers, importers and packers as well as distance sellers.

 

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EXTENDED PRODUCER RESPONSIBILITY IN GENERAL

When was extended producer responsibility put in place?

Extended Producer responsibility in waste management was encoded in the Waste Act in 2004, but a number of government resolutions concerning producer responsibility had been passed before that. For example, there have been extended producer responsibility obligations for paper and tyres since the late 1990s. The EU Packaging and Packaging Waste Directive entered into force in 1994 and was implemented in Finland in 1997 by a corresponding government decision.

Which products are included in Extended Producer Responsibility?

  • accumulators and batteries 
  • vehicles 
  • packaging 
  • paper and paper products 
  • tyres 
  • electrical and electronic equipment 
  • single-use plastic products (SUP-products) 
  • fishing gear containing plastic
     

Where can I check which businesses manage their Extended Producer Responsibility?

You can check which companies meet their Extended Producer Responsibility obligations from the Waste Management Compass:    


The Waste Management Compass allows you to check whether a company has met their Extended Producer Responsibility obligations by joining a producer organisation. You can also see which product groups are included.   

The Waste Management Compass information service is maintained by the Finnish Environment Institute (SYKE).  The information in the Waste Management Compass is based on the producer register maintained by the Pirkanmaa ELY Centre.  

To search the Waste Management Compass, please use the company's business ID number or the corresponding VAT number, as these codes identify the company. In addition to the official name, the same business ID may have several secondary names, which may not necessarily appear in the Waste Management Compass. You can check the company's business ID and any auxiliary names in the Business Information System maintained by the Finnish Patents and Registration Office and the Finnish Tax Administration at ytj.fi/en.  

 

Where can I find the nearest take-back points for waste under producer responsibility?

You can check take-back points at: kierratys.info
Tyre take-back points are listed at: rengaskierratys.com
Car take-back points are listed (in Finnish) at: autokierratys.fi
 

Who can collect and accept waste under producer responsibility?

Under the Waste Act, the producers, i.e. the manufacturers, importers, distance sellers or packers, have the primary right to arrange waste management for the products under their responsibility. Other operators may set up parallel systems only in cooperation with the producer.
 

Where can I find statistical information on recycling and Extended Producer Responsibility?

Statistics on Extended Producer Responsibility and other waste statistics are collated in the environmental administration's online service (in Finnish):

What is the difference between reuse, preparing for re-use, recycling and recovery of waste?

Reuse means using products or their parts again for the original purpose. Preparing for re-use means recovery operations, where products classified as waste or their parts are prepared so that they can be re-used without other pre-processing. Recycling means that waste material is used as raw material in another product. For example, the production of plastic bags from used plastic is recycling. Waste recovery includes both recycling and recovery as energy.


MANAGING EXTENDED PRODUCER RESPONSIBILITY

Why should Extended Producer Responsibility be managed?

Managing Entented Producer Responsibility is part of businesses’ statutory social responsibility. Extended Producer Responsibility enables consumers to recycle products easily and free of charge. Recycling has positive environmental impacts. When old products are reused or recycled, fewer new products and virgin raw materials are needed.

What kind of companies does Extended Producer Responsibility apply to? 

The Extended Producer Responsibility applies to companies that manufacture, import or distance sell: 

  • accumulators and batteries 
  • vehicles 
  • packaging 
  • paper and paper products 
  • tyres 
  • electrical and electronic equipment 
  • single-use plastic products (SUP-products) 
  • fishing gear containing plastic
     

In addition, Extended Producer Responsibility applies to all packers and importers of packaging products.
 

Does Extended Producer Responsibility need to be managed if the business has minimal import activity?

 Yes, Extended Producer Responsibility must be taken care of, even if import activity or the amount of product sold through distances selling is minimal. 
 

My business’s waste management is in order, and the waste is sent via contractors to appropriate processing. Do I have to do anything else?

Merely procuring waste containers for the company's premises or handling the waste generated in the company's operations is not managing the Extended Producer Responsibility. Extended Producer Responsibility means that manufacturers, importers, distance sellers and packers of certain products have an obligation under the Waste Act to arrange for the waste management and recycling of the products they have placed on the market, at their own expense, when the end-users dispose of the products. Extended Producer Responsibility applies not only to packers and importers of packaged products but also to manufacturers, importers and distance sellers of the following products: 

  • batteries and accumulators 
  • cars 
  • paper 
  • tyres 
  • electrical and electronic equipment 
  • single-use plastic products (SUP-products) 
  • fishing gear containing plastic
     

The easiest way to manage Extended Producer Responsibility for your business is to join a producer organisation. For instructions on managing Extended Producer Responsibility, see: 

The collection network alone is subject to fairly stringent national requirements, which means that very few companies are able to manage Extended Producer Responsibility independently without a producer organisation. 
 

How do I manage Extended Producer Responsibility?

Usually the easiest and most cost-effective way is to join a producer organisation for your sector. For instructions on organising producer responsibility, see:

Another company in the same sector has not joined a producer organisation and is not paying recycling fees. How is fairness among businesses ensured?

From the point of view of fair competition, it is important that the costs and obligations of Extended Producer Responsibility are distributed equally among producers. The Pirkanmaa ELY Centre, which oversees producer responsibility, carries out regular monitoring to ensure that all manufacturers, importers, distance sellers and packers of products that are subject to Extended Producer Responsibility manage their responsibilities, instead of leaving the work and costs for others to bear. 

You can notify the Finnish Extended Producer Responsibility Authority (Pirkanmaa ELY Centre) of a company you believe is active in the Finnish market and neglecting its Extended Producer Responsibility. Read more: 

How much does it cost to manage producer responsibility?

The costs of producer responsibility are covered by recycling fees paid by producers. Payments vary by sector and by producer organisation. Current prices are published on the websites of the organisations. Check the product organisations of your sector:

Does a business have to manage Extended Producer Responsibility if it imports products that are subject to producer responsibility into Finland from within the EU?

Yes. Extended Producer Responsibility applies to products that are placed on the Finnish market for the first time, including from within the EU.

Our company operates in Åland. How do we manage Extended Producer Responsibility?

The Province of Åland has its own Extended Producer Responsibility system. Companies operating in Åland must join the system even if they manage Extended Producer Responsibility in mainland Finland. Read more:

 

DISTANCE SELLING

My company has an online store and we distance-sell products to users in other countries. Do I have to manage Extended Producer Responsibility?

Distance sellers who are in Finland must organise their Extended Producer Responsibility obligations in each destination country in accordance with the laws of that country. Distance sellers are undertakings or other operators who sell products that come under Extended Producer Responsibility directly to users in other countries.

Distance sellers of electrical and electronic equipment must always appoint an authorised representative who is based in the EU member state in question to manage their Extended Producer Responsibility obligations in accordance with the legislation of that country.

Do distance sellers who are based in other countries participate in the organisation of waste management in Finland, or do the costs fall on Finnish companies?

Extended Producer Responsibility applies throughout the European Union to operators who distance sell products covered by Extended Producer Responsibility directly to users in other countries. Distance sellers who are not based in Finland must organise their Extended Producer Responsibility obligations in Finland in accordance with the Waste Act of Finland and the supplementary decrees.

If your business is based in another country and distance-sells products that are subject to Extended Producer Responsibility directly to users in Finland, you can manage your business's Extended Producer Responsibility in Finland in two ways:

  1. by joining a producer organisation; or
  2. by appointing an authorised representative who is based in Finland to assume Extended Producer Responsibility obligations on your behalf in accordance with Finnish legislation.

The easiest way is to seek advice from the Finnish producer organisation for the product group in question.

The exception is distance sales of electrical and electronic equipment within the EU. An operator selling electrical and electronic equipment directly to Finnish users from another EU country can manage Extended Producer Responsibility only by appointing an authorised representative based in Finland.

 

SELLERS’ OBLIGATIONS

Which products that come under Extended Producer Responsibility are sellers required to accept?

Sellers of batteries, accumulators, tyres and electrical and electronic equipment must accept decommissioned products at their point of sale free of charge. For detailed instructions, see:

As a seller, where do I send products I have collected under Extended Producer Responsibility?

The seller must hand over accepted products only to transporters or processors which have been contracted by the producer organisation or producer. Handing products over to other parties is prohibited under the Waste Act. Producers are responsible for the waste management of products and the associated costs after the waste product leaves the seller’s premises.

 

REPORTING

Where can I find instructions and forms for reporting the monitoring data?

Monitoring data is reported via the online service of the regional administration. For instructions, see:

 

BATTERIES AND ACCUMULATORS

Our company imports electrical and electronic equipment that contains batteries. We are already managing Extended Producer Responsibility for electrical equipment. Do we have to manage Extended Producer Responsibility separately for batteries?

Yes, producer responsibility is handled separately for each product group. This ensures that companies are equally involved in the organisation of waste management and recycling for all products that come under producer responsibility. It also ensures that statistics on products placed on the market, collected and recycled are as detailed and accurate as possible.

Producer organisations are currently developing a one-stop service to enable companies to easily join producer organisations in different sectors.

Our company imports/manufactures large industrial batteries that cannot be moved. How can Extended Producer Responsibility be managed in this case?

Companies importing and manufacturing large industrial batteries can join Recser Oy. The producer organisation organises data collection, reporting, communications and cooperation with authorities as required by law. However, the producer is responsible for organising waste collection and recycling in accordance with the Waste Act. See also Recser Oy's website for more information about large industrial batteries and accumulators:


Does the Battery Regulation bring changes to the definition of a producer?

Yes, the definition of a producer expands. In the future, the definition of producer is in accordance with the Battery Regulation: 

Producer means any manufacturer, importer or distributor or other natural or legal person that, irrespective of the selling technique used, including by means of distance contracts, either: 

a) is established in a Member State and manufactures batteries under its own name or trademark, or has batteries designed or manufactured and supplies them for the first time under its own name or trademark, including those incorporated in appliances, light means of transport or other vehicles, within the territory of that Member State; 

b) is established in a Member State and resells within the territory of that Member State, under its own name or trademark, batteries, including those incorporated in appliances, light means of transport or other vehicles, manufactured by others, on which the name or trademark of those other manufacturers does not appear; 

c) is established in a Member State and supplies for the first time in that Member State on a professional basis, batteries, including those incorporated in appliances, light means of transport or other vehicles, from another Member State or from a third country; or 

d) sells batteries, including those incorporated in appliances, light means of transport or other vehicles, by means of distance contracts directly to end-users, whether or not they are private households, in a Member State, and is established in another Member State or in a third country;

In addition, an economic operator that makes available on the market for the first time within the territory of a Member State a battery that results from preparation for re-use, preparation for repurposing, repurposing or remanufacturing operations are considered as the producer (article 56 point 2.)

Are the requirements the same for producers of consumer and business market batteries in terms of Extended Producer Responsibility?

Yes, in terms of Extended Producer Responsibility is concerned, the requirements are the same regardless of whether it is a product intended for consumers or businesses.

How is the category of each battery defined?

According to the definitions of the Battery Regulation and the purpose of use defined by the manufacturer, each battery belongs to the battery categories as defined by the Battery Regulation. If the battery manufacturer produces e.g. starting batteries, the batteries are classified as SLI batteries, regardless of what the consumer can use the battery for. If a professional economic operator is preparing batteries for repurposing, the repurposer’s intended future use of the battery may alter its category.

Does the Battery Regulation bring changes regarding the appointment of an authorised representative?

Yes, in the future it is mandatory for distance sellers to appoint an authorised representative for Extended Producer Responsibility in each Member State in which it sells batteries (article 56 point 3).
Where can I get more information about other changes in the Battery Regulation?
You can find more information about other upcoming changes in the Battery Regulation from the Regulation itself, which can be found on the website of the European Union and on the website of the Finnish Safety and Chemicals Agency (Tukes) at:

You can find other frequently asked questions and answers regarding the entire Battery Regulation at: 

VEHICLES

We import used cars to Finland. Do importers of used cars have producer responsibility?

Yes. Producer responsibility also applies to imports of second-hand cars. The Waste Act obligates the company to assume producer responsibility when the cars first enter the Finnish market.

Does producer responsibility apply to an individual citizen who buys a car from abroad?

Producer responsibility applies only to commercial imports, i.e. it does not apply to private persons who import cars for their own use.

Does producer responsibility apply to mopeds, work machines, motorcycles or caravans?

Producer responsibility does not apply to these types of vehicles. However, it does apply to tyres and batteries that are part of the vehicles.

We import cars and have organised our producer responsibility by joining Suomen Autokierrätys. Do we also have to take producer responsibility for batteries, tyres or electrical and electronic equipment supplied with cars?

Yes, producer responsibility is handled separately for each product group. This ensures that companies are equally involved in the organisation of waste management and recycling for all products that come under producer responsibility. It also ensures that statistics on products placed on the market, collected and recycled are as detailed and accurate as possible.

You can organise your producer responsibility for certain batteries and electrical and electronic equipment via Suomen Autokierrätys, but separate arrangements are required for e.g. tyres and lead batteries. Read more:

 

PACKAGING

What kind of packaging does extended producer responsibility apply to?

Extended producer responsibility applies to all types of packaging that protect the product, including reusable boxes, bottles, rollers, pallets, etc. Here are some examples of packaging materials that come under extended producer responsibility:

  • Glass (e.g. jars, bottles)
  • Metal (e.g. cans, drums, canisters, cable ties, rollers)
  • Plastic (e.g. film, sheeting, bags, caps, canisters, boxes, cable ties, styrofoam, foam)
  • Paper and paperboard (e.g. boxes, bags, wraps, rolls, shells)
  • Wood (e.g. pallets, cable reels)

Who has extended producer responsibility for packaging?

The extended producer responsibility applies to all professionally operating companies that place packaging on the market. In addition, extended producer responsibility applies to the manufacturers and importers of the so-called service and farmer packaging.

Extended producer responsibility for packaging applies to the following operators who professionally place packaging on the Finnish market:

  • packers, i.e. companies that pack or package their products for the Finnish market (excluding service and farmer packaging), 
  • importers, i.e. companies that import packaged products to Finland, 
  • distance sellers, i.e. foreign companies that sell remotely packaged products directly to Finnish users, 
  • manufacturers of service or farmer packaging, i.e. companies that manufacture said packaging for the Finnish market and 
  • importers of service or farmer packaging, i.e. companies that bring said packaging to the Finnish market.

Our company imports products that have no packaging other than the packaging in which they are transported. Does our company have extended producer responsibility for the packaging?

Yes. The extended producer responsibility for packaging applies to sales packaging, multi-packaging and transport packaging.

Are public-sector operators subject to extended producer responsibility for packaging? Should municipal actors such as catering services take care of extended producer responsibility?

The extended producer responsibility applies to all companies with a business ID that package or import packaged products into Finland. The above criteria also apply to municipal actors.

Why are collection containers for plastic and glass packaging restricted to only packaging materials?

Packers and importers of packaged products have extended producer responsibility for packaging and the associated costs. That is one reason why the collection of packaging materials organised by producers must not include other materials. The only exception is metal: both metal packaging and other small metal items can be collected in the same container.

Unusual types of plastic and glass can be difficult to handle by recycling systems in practice and cause poorer recycling outcomes.

 

BEVERAGE PACKAGING

Can the retail trade sell soft drinks without a deposit?

Yes, it can. If the packaging does not have a deposit marking, it is subject to a tax.

Our company's beverage packaging is managed by a deposit and return scheme, and thus not subject to the beverage packaging tax. How do we prove to the tax administration that our products are part of a scheme?

The operator of the return scheme can request an extract from the producer register maintained by the Pirkanmaa ELY Centre on behalf of the producer. The extract can be sent to the tax administration as proof that the packaging is part of an approved return scheme. Any changes to the return scheme must be reported without delay. If the change results in changes in taxation, it will apply from the first calendar month following the notification. Read more:

Is it sufficient for beverage packaging to be part of a return scheme in any country?

No. The operator of a return scheme must demonstrate that the scheme meets the requirements of Finnish legislation and annually report the requested information to the Pirkanmaa ELY Centre.

 

PAPER AND PAPER PRODUCTS

Do we have to have a paper collection container in our housing company? Does the housing company have other obligations regarding paper collection?

Housing companies have an obligation to provide a space and a container for the collection of paper. In practice, the obligation applies to all terraced properties and apartment blocks. The company is responsible for the costs of organising the container and space (e.g. the rent for containers), and producer organisations are responsible for the transport and recycling costs of the paper.

Paper collection must be arranged regardless of the amount of paper produced at the property. However, it is a good idea to discuss with the collection service provider to determine the appropriate container size and collection frequency. It may also be possible to organise a shared collection facility with neighbouring properties.

Can the housing company choose the collection service provider?

Yes, the housing company can choose the provider. However, the provider must be a contracted partner of a producer organisation. There are two producer organisations for paper in Finland: Suomen Keräyspaperi tuottajayhteisö Oy and Suomen Keräystuote Oy. Paper can be collected only by transport and collection service providers that have a contract with a producer organisation. This ensures that paper waste management is carried out in accordance with the Waste Act.


 
TYRES

Our company does not generate tyre waste, because we sell tyres to users. Do we still have producer responsibility?

Yes, if the company has imported the tyres. The company must organise waste management for any tyres it imports at its own expense when the tyres are decommissioned by the final user. The final user is usually a customer to whom the tyres were sold. The easiest way to manage producer responsibility is to join a producer organisation:

What happens to tyres when they are recycled?

Tyres are recycled for further uses. From collection facilities, the tyres are transported to regional terminals where they are sorted. The tyres are then cut into strips, broken up or ground for various uses, such as road and earth construction, water treatment, surfacing applications (riding arenas, artificial grassland, sports and playing fields) and binding agent for asphalt. Intact tyres can be retreaded.

Can rimmed tyres be handed in for recycling?

Yes, but there may be a charge for the removal of rims. Only rimless tyres must be accepted without a charge.

 

ELECTRICAL AND ELECTRONIC EQUIPMENT

Our company manufactures/imports electrical equipment. How do I know which equipment comes under producer responsibility?

Producer responsibility applies to all electrical and electronic equipment manufactured in or imported to Finland which is intended for consumers or for professional use, unless a separate derogation is provided for. European authorities have harmonised policies on these exceptions. The guidelines can be found in English in the European WEEE Registers Network (EWRN) publication under New WEEE2 Exclusions.

Because an extensive collection network is required, joining a producer organisation is almost always the only way to manage producer responsibility for electrical and electronic equipment. Read more about managing producer responsibility:


SUP PRODUCTS

 

The content of this section will be updated soon.

 

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ely-updated 13.09.2024