FAQ

PRODUCERS GUIDANCE

• Packaging Report Audit

  Do I need a packaging report audit?

  
  

  Under the Estonian Packaging Act, companies placing more than 20 tonnes of packaging on the Estonian market during a calendar year must have their annual packaging report audited by a sworn auditor as a limited assurance engagement under the Auditing Activities Act.

  
  

  When calculating the 20-tonne threshold, deposit packaging must also be included, even if it is reported separately to Eesti Pandipakend.

  
  

  How do I complete the audit?

  
  

  1. Appoint a sworn auditor.
     A list of licensed auditors is available from the Estonian Board of Auditors.
  2. Download your annual packaging report from the TVO Client Portal (aruanne.tvo.ee).
  3. Prepare the report for the auditor.
     Reusable packaging that has permanently left circulation must be reported separately from single-use packaging. If these quantities were reported together during the year, they should be separated for the audit.
  4. Inform TVO immediately if corrections are required.
     If the auditor identifies errors, please notify TVO before the audit is finalised so that the packaging report can be corrected. The audit opinion should always be based on the final, accurate report.
  5. Submit the audit report to TVO by 1 August of the following year.
     You can upload it via the TVO Client Portal or send it by e-mail to info@tvo.ee.

  
  

  Important deadlines

  Deadline	Action
  1 August	Submit the audited packaging report to TVO.
  1 September	TVO submits the audit information to the Estonian Packaging Register (PAKIS).

  
  
  

  To ensure sufficient processing time, TVO asks clients to submit their audit reports no later than 1 August.

  
  

  Audit exemption

  If your packaging report receives an unmodified (positive) audit opinion, your company is exempt from the audit requirement for the following three calendar years, unless the legal conditions change.

  
  

  Need assistance?

  If you have any questions about the audit process, our specialists are happy to help.

  E-mail: info@tvo.ee
  Phone: +372 681 1481

  
  
  
  
• Packaging Reporting Principles
  Packaging placed on the Estonian market must be reported according to:
  
  

  1. Packaging type
  2. Packaging material

  
  1. Packaging Type
  
  

  Packaging type	Description
  Sales packaging	Packaging intended for the end user or consumer.
  Group packaging	Packaging used to group together one or more sales units.
  Transport packaging	Packaging used to handle and transport goods without becoming part of the sales packaging.

  
  2. Packaging material
  
  

  Sales Packaging	Group & Transport Packaging
  Glass	Glass
  Plastic (mono material)	Plastic
  Plastic (composite)	Paper and cardboard
  Paper and cardboard (mono material)	Ferrous metal
  Paper and cardboard (composite)	Non-ferrous metal
  Beverage carton	Wood
  Ferrous metal	Other (textiles, ceramics, etc.)
  Non-ferrous metal
  Wood
  Other (textiles, ceramics, etc.)

  
  Report the total weight of packaging placed on the Estonian market during the reporting period by packaging type and material. Packaging weights should be reported in tonnes.
  
  

  Reusable Packaging Reporting

  
  

  What is reusable packaging?
  
  

  Reusable packaging is packaging that is designed, manufactured and placed on the market to be used multiple times for the same purpose throughout its lifecycle.

  Examples include:

  • returnable transport pallets;
  • reusable crates and containers;
  • reusable takeaway food packaging;
  • refillable packaging systems.
    
    

  If packaging is returned by customers and used again for packaging the same type of products, it is considered reusable packaging.
  
  

  What information must be reported?

  Where reusable packaging is placed on the Estonian market, the following information must be reported separately by packaging type (sales or transport/group packaging) and material:

  
  

  Reporting information	Description
  Reusable packaging placed on the market for the first time	Total weight (tonnes) of reusable packaging introduced during the reporting year.
  Reusable packaging in circulation	Total weight (tonnes) of reusable packaging in use.
  Average annual rotations	Average number of times each reusable packaging unit is reused during the calendar year.
  Reusable packaging withdrawn from use	Weight (tonnes) of reusable packaging removed from circulation due to damage, loss or other reasons.

  
  Companies using reusable packaging must maintain separate records for reusable packaging and report the required information at least once per year. Reusable packaging must always be reported separately from single-use packaging.
  
  
  

  Single-Use Plastic (SUP) Packaging Reporting

  
  

  Certain single-use plastic (SUP) packaging must be reported separately for statistical purposes in addition to the regular packaging report.

  
  

  SUP quantities do not replace standard packaging reporting. They must also be included in the relevant packaging material categories (e.g. plastic, beverage cartons) in the regular packaging report.

  
  

  SUP Packaging Categories

  The following single-use plastic packaging categories are subject to separate reporting:

  
  

  SUP category	Examples
  Beverage cartons	Beverage cartons with a capacity of up to 3 litres.
  Plastic beverage bottles	Plastic beverage bottles with a capacity of up to 3 litres, including caps and lids.
  Plastic beverage cups	Cups intended for beverages, including lids.
  Plastic food containers	Ready-to-eat food containers intended for immediate consumption.
  Flexible plastic food packaging	Wrappers and other flexible packaging intended for ready-to-eat food.
  Lightweight plastic carrier bags	Lightweight plastic shopping bags.

  
  

  SUP packaging quantities must be reported in addition to the regular packaging report. Companies should:

  • include the packaging in the relevant packaging material category (e.g. plastic or beverage cartons);
  • report the applicable SUP category separately for statistical reporting.

  
  
  
• Where and when do I submit my packaging report?

  Packaging reports are submitted through the TVO Client Portal at aruanne.tvo.ee according to the reporting frequency agreed in your contract (monthly or quarterly).

  
  

  First-time login
  After signing the client agreement, TVO creates a user account for your designated contact person. To activate your account:

  1. Open the login page.
  2. Under "Register as a user", enter your e-mail address.
  3. Click "Send password".
  4. An initial password will be sent to your e-mail. You can change it after logging in.

  
  

  Reporting deadlines

  • Submit your packaging report to TVO by the 10th day of the month following the reporting period.
  • The reporting period is agreed in your contract and is either monthly or quarterly.

  
  

  Corrections
  Reports can be amended during the calendar year and until 31 March of the following year.

  
  

  Year-end reporting
  To allow TVO to submit the required consolidated report to the Estonian Packaging Register (PAKIS), the final report for the previous calendar year must be submitted to TVO by 28 March.

  
  

  If your company is not a member of a producer responsibility organisation, you must submit your packaging report directly to PAKIS by 31 March.

  
  Submit your report