How to manage Extended Producer Responsibility

There are three different ways to manage Extended Producer Responsibility (EPR). The easiest way is to join an existing producer organisation. You can also set up a new producer organisation. In exceptional cases, you can fulfil your EPR obligations by applying directly to the producer register. 

Join a producer organisation

Producer organisations are non-profit organisations set up and managed by producers. Producer organisations carry out the statutory obligations on behalf of the company:  

  • collection, transport, management and recycling of end-of-life products.  
  • reporting monitoring data to the supervisory authority on an annual basis  
  • ensuring that recycling targets are met.
     

See the list of Producer Organisations and become a member

Setting up a new Producer Organisation

Extended Producer Responsibility can also be met by setting up a producer organisation with other producers to carry out the statutory obligations on their behalf. You can set up a producer organisation with other producers to handle your statutory obligations. Only producers can establish a producer organisation, and all members must be producers in the sector in question.  

The producer organisation must submit an application to the producer register of the Finnish Supervisory Agency. Finnish Supervisory Agency oversees producer responsibility nationwide, excluding Åland.  

Deposit and return schemes for beverage packaging should apply to the producer register in the same way as producer organisations. Once the scheme has been approved, the member businesses and their product packaging will be exempted from beverage packaging tax.  

Fees for founding a producer organisation

Finnish Supervisory Agency approves a producer organisation in the producer register if it meets the requirements set out in the Waste Act. The approval is made by a formal decision. Both approved and rejected applications are subject to a fee based on the Act on Criteria for Charges Payable to the State and the Government Decree on chargeable services of the Centres for Economic Development, Transport and the Environment; the Employment and Economic Development Offices, and Development and Administration Centres. Submissions which are withdrawn or otherwise expired are subject to a proportional processing fee based on the decree and the amount of work incurred. No fee is charged for recording changes reported by a registered producer organisation. 

Forms for founding a producer organisation (in Finnish)

Applications to the producer register should preferably be made by using the online form. If it is not possible, please print and complete a PDF form and send it to the registry of the Finnish Supervisory Agency: [email protected].  

In the application, provide details about the activities of the producer organisation, including waste management arrangements, the organisation’s rules and  nancial standing. The rules or other equivalent documents must describe how the obligations are shared between producers and how new producers can arrange the management of producer responsibility with the producer organisation, and state that the owner, shareholder and member of the producer organisation must be a producer in the sector in question. Furthermore, the producer organisation’s  nancial standing must enable it to meet the assumed obligations for a continuous period of at least six months.  

In exceptional cases, you can apply directly to the producer register

 

In exceptional cases, you can apply directly to the producer register

In exceptional cases, Extended Producer Responsibility can also be met by applying directly to the producer register. In exceptional cases, your company may be accepted in the register of producers if:  

  • joining a  producer organization is distinctly unnecessary in view of the nature and scale of the company’s activities  
  • it collects, prepares for re-use, recycles and recovers discarded products in accordance with the requirements of each product group  
  • it meets collection, recycling and recovery targets  
  • it has contracts for the treatment of waste with a party holding the necessary permits and qualifications for the treatment  
  • it informs end-users how and where they can return end-of-life products to a collection point organised by the company.  
  • from 1.1.2023, it will regularly and systematically monitor the implementation of the obligations and develop the reliability of the information in this respect (self-monitoring). The company will draw up a written plan for self-monitoring. If necessary, an independent and qualified person must carry out a regular inspection to support the self-monitoring.  
  • it keeps records of the type, quality and quantity of products it places on the market and of discarded products it receives, and of the waste generated by each type of product. The company also reports annually to the Finnish Supervisory Agency.  
  • it publishes annually on the public information network information on the fulfilment of its obligations concerning the separate collection and recovery of waste.  
     

All of the above conditions must be met in order for a company to be accepted as an individual producer in the producer register. In addition, the Finnish Supervisory Agency may require producers who are not members of a producer organisation to submit a report on their financial arrangements and an action plan for re-use and waste management to ensure that they have sufficient financial resources to meet their Extended Producer Responsibility obligations.  

If a company joins a producer organisation, the producer organisation will carry out all Extended Producer Responsibility obligations on its behalf. 

Fees for applying to the producer register

Finnish Supervisory Agency charges the producer a fee for the registration application and for the annual processing and inspection of monitoring data. A fee is also charged for negative decisions. The fee is based on the State Fees Act and the Government Decree on Fees payable to the Centres for Economic Affairs, Transport and the Environment, the Employment and Economic Development Offices and the Development and Administration Centres. The fee for processing a cancelled or otherwise expired notification is equal to the amount of work performed, in accordance with the Fee Decree. No fee shall be charged when a producer accepted in the register of producers notifies of changes.

Forms for applying to the producer register (in Finnish)

Print and fill in the pdf form and send it to the Finnish Supervisory Agency: [email protected].  

Please provide information about the company and the products subject to Extended Producer Responsibility, as well as a description of how the waste management of the products is organised. Please provide all the information requested in the application, without which the application cannot be processed and the company cannot be accepted in the register of producers. If the business name of your company accepted in the register changes, please submit a new application. 
 

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