Who is subject to Extended Producer Responsibility?
Every company has a responsibility to act for the environment and to promote a circular economy. The company is responsible for the whole lifecycle of the product.
Producers of certain products are responsible for the waste management of the products they place on the market. Producers are e.g. manufacturers, importers, packers and distance sellers. The producer is the one who places the product on the Finnish market for the first time. This makes recycling efficient and easy.
Extended Producer Responsibility applies to these products:
The Extended Producer Responsibility (EPR) applies to all batteries and accumulators except those that are incorporated or designed to be incorporated into products specifically for military purposes or equipment designed to be sent into space (the Battery Regulation article 1). Businesses with EPR include:
- Importers, manufacturers, distance sellers and distributors of batteries and accumulators,
- those who resell batteries under their own name or trademark,
- those who sell batteries together with or incorporated in other products (such as vehicles or electrical appliances),
- economic operators who make available on the market batteries that results from preparation for re-use, preparation for repurposing, repurposing or remanufacturing.
EPR for batteries is based on the Waste Act (2011) and the Battery Regulation (EU 2023/1542). The easiest way to manage EPR is to join your sector’s producer organisation. The acceptances of producer organisations vary by battery category and chemistry.
Portable batteries and accumulators
Portable batteries and accumulators are sealed and weigh 5 kg or less. They include e.g. button cell batteries, finger batteries (such as AA and AAA batteries), and other batteries and accumulators used by consumers or professionals in electrical and electronic equipment.
The easiest way to manage EPR is to join a producer organisation for portable batteries and accumulators:
LMT batteries
LMT batteries (light means of transport batteries) are sealed, weighs 25 kg or less and is
specifically designed to provide electric power for the traction of wheeled vehicles. For example, LMT batteries include batteries for electric bicycles and electric scooters.
The easiest way to manage EPR is to join a producer organisation for LMT batteries:
SLI batteries
SLI batteries are used in vehicles, other means of transport or machinery for starting, lighting and ignition. Electric and hybrid cars use two types of batteries; one is typically a lead battery that is classified as a SLI battery, and the other is a lithium-ion or nickel metal hydride battery that is classified as an EV battery (see Electric vehicle batteries). For example, in the starting systems of mopeds, motorcycles, quadricycles, scooters and ride-on lawnmowers, so-called portable lithium SLI batteries can also be used instead of lead batteries.
The easiest way to manage EPR is to join a producer organisation for SLI batteries:
- Akkukierrätys Pb Oy (akkukierratyspb.fi) (lead-based SLI and industrial batteries)
- ERP Finland ry (erp-recycling.org) (excluding lead-based SLI batteries, only in Finnish)
- Recser Oy (paristokierratys.fi) (excluding lead-based SLI batteries)
Electric vehicle batteries
Electric vehicle batteries (EV batteries) weighs more than 25 kg and is specifically designed to provide electric power for traction in vehicles of categories L, M, N or O.
The easiest way to manage EPR is to join a producer organisation for EV batteries:
Industrial batteries
An industrial battery is designed specifically for industrial use or is any other battery that weighs more than 5 kg and that by definition does not fall under any other battery category. Industrial batteries are used in products such as: emergency or backup power sources, energy storage, batteries used for traction in rail, waterborne and aviation transport vehicles or off-road machinery and intended to be used for industrial activities, communication infrastructure, agricultural activities, or generation and distribution of electric energy.
The easiest way to manage EPR is to join a producer organisation for industrial batteries:
- Akkukierrätys Pb Oy (akkukierratyspb.fi) (lead-based industrial batteries)
- ERP Finland ry (erp-recycling.org) (excluding industrial batteries weighing more than 25 kg and lead-based industrial batteries, only in Finnish)
- Recser Oy (paristokierratys.fi) (excluding lead-based industrial batteries)
The Extended Producer Responsibility (EPR) concerns passenger cars, vans and recreational vehicles. EPR applies to businesses operating in Finland that commercially import new or used cars and businesses that import cars on behalf of Finnish residents. EPR also applies to distance sellers.
EPR for vehicles is based on the Waste Act (2011) and the Government decree on end-of-life vehicles and restrictions on the use of hazardous substances in vehicles (2015).
The easiest way to manage EPR is to join your sector’s producer organisation for vehicles:
Almost all products include packaging which comes under The Extended Producer Responsibility (EPR). Waste management's EPR applies to all professionally operating companies that place packaging on the market. In addition, EPR applies to the manufacturers and importers of the so-called service and farmer packaging.
EPR 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.
Such businesses carry EPR for the following materials:
- carton, board and paper
- glass
- metal
- plastic
- wood
Packages are single-use or reusable products that are used to store or protect a substance or object, to facilitate its display or to enable its handling or transportation. In addition to sales packaging, packaging also includes group and transport packaging.
Service packaging is packaging that is used at the point of sale to pack food and other products directly for the consumer. These include e.g. carrier bags, packaging for takeaway portions and other packaging used in service operations.
Farmer's packages are packages that are used to package unprocessed agricultural and horticultural products that are sold off the farm.
EPR for packaging materials is based on the Waste Act (2011) and the Government Decree on packaging materials and waste (2021).
The easiest way to manage EPR is to join the sector-specific producer organisation for packaging.
Producer organisations in the packaging sector:
- Finnish Packaging Producers Ltd, whose membership is obtained through the service company Rinki Oy.
- Sumi Oy (sumi.fi)
EPR for beverage packaging (see the following section) can be managed by joining the deposit and return scheme for beverage packaging. Non-deposit beverage packaging not covered by the return scheme is subject to a tax on beverage packaging, and EPR in this area can be managed by joining the producer organisation.
Producers of certain single-use plastic packaging are also responsible for clean-up costs. This means that producers pay municipalities for the costs of cleaning up litter caused by their products and for litter prevention.
Like other packaging materials, beverage packaging is also subject to The Extended Producer Responsibility (EPR). If the products come under the deposit and return scheme for beverage packaging, EPR does not have to be addressed separately, and the products are not subject to a tax on beverage packaging. Beverage packaging that does not come under the return scheme, and the producer’s other packaging, are subject to the normal EPR.
No tax is payable on beverage packaging if:
- The packer or importer of the product has joined a deposit and return scheme for beverage packaging
- The product in question has been approved for the scheme, and
- The return scheme has been approved to the producer register maintained by the Finnish Supervisory Agency.
The return schemes for beverage packaging are regulated by the Waste Act (2011) and the Government Decree on return schemes for beverage packaging (2013). Taxation is regulated by the Act on Excise Tax on Certain Beverage Packages (2004). The deposit of beverage packaging must be at least:
- EUR 0.15 for metal drink cans
- EUR 0.20 for plastic packaging with a capacity above 0.35 litres but less than 1 litre
- EUR 0.40 for plastic packaging of 1 litre and above
- EUR 0.10 for other beverage packages
The packer or importer of beverages may join an existing deposit and return scheme or set up a new scheme and apply for its registration to the producer register. For details on which types of beverage packaging are suitable for deposit and return schemes, and on memberships, see the websites of approved schemes that are accepting new members:
The Extended Producer Responsibility (EPR) applies to professional importers of paper products and to manufacturers and importers of paper that is used in the manufacture of paper products. It applies to e.g. the following products:
- Newspapers and magazines
- Office paper, note pads, journals, envelopes and postcards
- Commercial catalogues and direct mail publications
Products that do not come under EPR include e.g. tissue paper, books, calendars, and instructions for use or assembly which are supplied with products. EPR for paper is based on the Waste Act (2011) and the Government Decree on the separate collection and recycling of paper waste (2013).
The easiest way to manage EPR is to join one of the sector-specific producer organisations:
- Suomen Keräyspaperi Tuottajayhteisö Oy (suomenkerayspaperituottajayhteiso.fi)
- Suomen Keräystuote Oy (suomenkeraystuote.fi)
Tyre producers include commercial tyre manufacturers, importers and retreaders. Importers of new and used vehicles and machines that are fitted with tyres are also tyre producers. Only tyres, not wheels, are covered by Extended Producer Responsibility (EPR). EPR applies to the tyres of the following vehicles and machines:
- Cars, vans and lorries
- Mopeds, motorcycles, scooters, quad bikes and quadricycles
- Caravans and trailers
- Non-road mobile machinery
EPR does NOT apply to the following tyres:
- Tyres of bicycles and bicycle trailers
- Tyres of wheelbarrows, golf carts, rollators and wheelchairs
- Tyres of push lawnmowers
- Aircraft tyres
EPR for tyres is based on the Waste Act (2011) and the Government Decree on the separate collection and recovery of decommissioned tyres (2013).
The easiest way to manage EPR is to join your sector’s producer organisation:
The Extended Producer Responsibility (EPR) applies to all electrical and electronic equipment intended for consumers or for professional use unless a separate derogation is set. Producers are:
- Manufacturers and importers
- Traders selling equipment under their own name or trademark and
- Distance sellers.
The easiest way to manage EPR is to join your sector’s producer organisation:
- Flip ry (elker.fi), ICT Producer Co-operative (elker.fi) ja SELT ry (elker.fi) (Membership matters are handled by the service company Elker Oy (elker.fi))
- ERP Finland ry (erp-recycling.org)
- SER-Tuottajayhteisö ry (serty.fi)
Distance sellers who sell electrical and electronic equipment directly to end-users (private individuals or businesses) in another EU country must appoint an authorised representative in each country of destination. The authorised representative assumes EPR in the country in question in accordance with the legislation of that country. Distance sellers of electrical and electronic equipment established in another EU country must therefore appoint an authorised representative in Finland, while Finnish distance sellers of electrical and electronic equipment must appoint an authorised representative in other EU countries.
EPR for electrical and electronic equipment is based on the Waste Act (2011) and the Government Decree on electrical and electronic equipment waste (2014).
The Extended Producer Responsibility (EPR) applies to producers of certain single-use plastic (SUP) products, i.e. manufacturers, importers and packers. The SUP products covered by EPR are:
- cups for beverages sold empty to the end-userand their caps and lids;
- wet wipes for personal hygiene and consumer use;
- balloons for consumer use, and
- tobacco products with filters.
Certain single-use plastic packaging (SUP packaging) in accordance with Annex of the Waste Act. The producers of these products are responsible for the cleaning costs. Producers pay municipalities for the costs of cleaning up litter caused by their products and for the prevention of littering.
In addition, the producers of tobacco products with filters are separately responsible for the costs incurred for municipalities for the acquisition of litter bins for tobacco waste and for the awareness raising measures concerning littering caused by tobacco products and tobacco waste.
The easiest way to manage EPR of tobacco products with filters, wet wipes and balloons is to join a producer organisation:
The easiest way to manage EPR of SUP packaging is to join a producer organisation.
Producer organisations in the packaging sector:
- Finnish Packaging Producers Ltd, whose membership is obtained through the service company Rinki Oy.
- Sumi Oy (sumi.fi)
EPR is based on the Waste Act (2011) and the Government Decree 1318/2022 (the Government Decree is available only in Finnish and Swedish.)
A distance seller selling SUP products directly to an end-user (individual or business) in another EU country must appoint an authorised representative established in that EU country. The authorised representative will assume EPR in that country in accordance with the legislation of that country. Distance sellers of SUP products established in another EU country must therefore appoint an authorised representative in Finland, while Finnish distance sellers of SUP products must appoint an authorised representative in other EU countries.
The Extended Producer Responsibility (EPR) applies to manufacturers, importers and distance sellers of fishing gear containing plastic.
Fishing gear means any item or piece of equipment that is used in fishing or aquaculture to target, capture or rear marine biological resources or that is floating on the sea surface, and is deployed with the objective of attracting and capturing or of rearing such marine biological resources. The definition of fishing gear excludes electrical and electronic equipment included in fishing gear. Fishing gear waste means fishing gear including all separate components, substances or materials that were part of or attached to such fishing gear when it was discarded. Examples of waste include lost and abandoned fishing gear.
The easiest way to manage EPR is to join your sector’s producer organisation:
EPR is based on the Waste Act (2011) and the Government Decree 1319/2022 (the Government Decree is available only in Finnish and Swedish.)
What is considered as professional activity?
Extended Producer Responsibility (EPR) applies to producers who place products on the Finnish market on a professional basis. Producers include e.g. manufacturers, importers and packers of products, as well as distance sellers selling directly to users.
Especially small businesses may wonder what professional activity means. An activity is not considered professional if the entrepreneur established in Finland is not liable for VAT. Currently, the turnover threshold for VAT liability is €20 000 per year. If the trader does not have a VAT identification number, the activity is not considered professional.
For packaging, there is no more a minimum number of kilograms of packaging to which professionalism applies. A packer is considered to be a professional if they are subject to VAT.
Check whether the company has met its EPR obligations
Extended Producer Responsibility (EPR) for waste management applies to around 50 000 manufacturers, importers and packers, as well as international distance sellers. The majority of companies fulfil their EPR as required by law. It is fair that all companies with EPR share the costs of waste management equally.
Are you wondering whether a company is meeting their EPR obligations? Check through this link:
The Waste Management Compass allows you to check whether a company has met their EPR 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 Finnish Supervisory Agency.
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.
You can also check the membership lists of various producer organisations to see if the company is a member of the producer organisation.
Contact information
Customer service for environmental affairs
Ask our customer service by using service form (coming soon)
By e-mail: [email protected]
By calling: +358 295 256 920 (Monday–Friday 9:00–15:00)