Producers responsibility

Services and Fees

TVO's task is to be a cooperation partner for packaging undertakings in fulfilling obligations arising from the Packaging Act, including:

1. to offer assistance in interpreting legislation, providing advise and support in all challenges related to packaging and packaging waste;
2. to help with compiling the packaging report;
3. to advise on finding the best packaging waste collection solution;
4. to organize the collection and recycling of packaging waste placed on the market;
5. to submit the packaging report to the Packaging Registry on behalf of the company;
6. to provide advice on packaging design and the selection of environmentally friendly materials.

By concluding a cooperation agreement with TVO, a company is released from the obligation to pay packaging excise duty arising from the Packaging Excise Duty Act.

The packaging undertaking remains responsible for keeping records of the quantities of packaging placed on the Estonian market and, if necessary, commissioning an audit of the packaging report. TVO assumes the obligation for the collection and recycling of packaging and packaging waste upon concluding the cooperation agreement.

Principles of Service Fee Application:

• TVO's service fees are public and equal for all clients.
• The final amount payable to TVO depends on the quantities of packaging waste placed on the Estonian market by the client.
• The service fee depends on the type of packaging and packaging material.
• The service fee is calculated per unit of weight.

What are the service fees used for?

The collection and recycling of packaging waste, including:

• Developing, maintaining, and servicing a nationwide packaging waste collection network, sorting the collected packaging waste, and directing it to recycling.
• Informing the public and consumers about the procedures and requirements for returning packaging and packaging waste, including nationwide advertising campaigns to draw attention to packaging sorting,
• Participating in various public events,
• Providing explanations through media outlets,
• Conducting training sessions in schools and kindergartens.

Sales packaging

Packaging material	Collection and recycling service fee, €/t
Glass	91
Plastic (mono)	225
Plastic (composite)	360
Paper- and paperboard (mono)	80
Paper- and paperboard (composite)	135
Beverage carton	140
Metal (ferrous/aluminium)	162
Wood	20
Other	270

*Prices exclude VAT

Transport- and tertiary packaging

Packaging material	Collection and recycling service fee, €/t
Glass	91
Plastic	60
Paper- and paperboard	65
Metal (ferrous/aluminium)	77
Wood	18
Other	270

*Prices exclude VAT

ENGLISH

FAQ

What is packaging?

Packaging is everything that remains after the product has been consumed.

According to the Packaging Act, packaging is any product made of any material used to contain, protect, handle, deliver, or present goods from raw materials to finished goods and from the manufacturer to the consumer. Single-use packaging used for the same purpose is also considered packaging.

A product designed and intended to be filled at the point of sale, and a single-use product that is sold, whether filled or intended to be filled at the point of sale, is considered packaging if that product performs the function of packaging.

Packaging components and additional elements permanently attached to the packaging are considered parts of the packaging to which they are attached.

An additional element that hangs directly on or is attached to the product and performs a packaging function is also considered packaging, unless that element is an integral part of the product and is intended to be consumed or discarded with the product.

See also the annex to the directive, which helps classify more complex products as packaging or not.

Packaging material is the material from which the main part of the packaging is made. If the packaging consists of several different materials (e.g., plastic-metal, cardboard-plastic, or other), the packaging material is considered to be the material with the largest mass fraction in the packaging composition (this explanation comes from § 4 subsection 4 of the Packaging Excise Duty Act).

What is a packaging report and how to fill it?

A packaging report provides an overview of the quantities of packaging of goods placed on the Estonian market by a company. In the packaging report, a packaging company reports the quantities of packaging of goods placed on the market by it during a calendar year.

Placing on the market is considered to be:

• the sale, exchange, free transfer, and use for own consumption of goods packaged by the packaging company, acquired from another Member State, and imported packaged goods.

Key principles:

• records must be kept with kilogram accuracy;
  
• the accounting period is the calendar year;
  
• the packaging report is the basis for the application of TVO service fees.
  

CALCULATING PACKAGING QUANTITIES FOR IMPORTED GOODS
To prepare a packaging report, it is necessary to determine what goods have been imported by the company and how they are packaged. For regularly imported and similarly packaged goods, it is simpler – the packaging around the goods should be weighed once, and in the future, only the quantities of imported goods need to be counted and multiplied by the weight.
However, if the imported goods are very different, the data on the delivery notes – net and gross weights – can be helpful. Suppliers themselves can also be helpful, as they most likely know exactly how much different packaging is around the goods they sell.
If all the imported goods remain within the company and are used in the company's own activities, the packaging waste should be collected separately from other waste, handed over to a waste handler who weighs it and sends it for recycling. A packaging report can also be prepared based on the quantities of waste. At this point, it is very important to distinguish between packaging waste from imported goods and packaging waste from goods purchased in Estonia. The latter is not the company's responsibility and should not be reflected in the company's packaging report.

CALCULATING PACKAGING QUANTITIES FOR PACKAGING ACTIVITIES
If a company packages goods in its operations and sells them on the Estonian market or uses them for its own needs, the company must keep records of the quantities of packaging used and reflect this information in the packaging report. As a rule, the company knows how much packaging material is used per product. Here, too, the help of suppliers can be used and the weights of empty packaging purchased from them can be requested.
Anything placed around a product that is not integral to it is considered packaging and must be accounted for.

If a company packages goods in its operations but exports all or part of the packaged goods from Estonia, the quantities of these packages must also be recorded. These quantities do not need to be declared, i.e., reflected in the packaging report, but they are part of the company's mandatory internal accounting.

Once the system for packaging quantity data has been established, the information must be submitted to TVO at the agreed frequency (monthly or quarterly).

Important deadlines

TVO expects the company's packaging report no later than the 10th of the month following the reporting period (the reporting period can be either a month or a quarter and this is fixed in the contract).

Changes can be made to the packaging report during the current year and until the end of the first quarter of the following calendar year (until March 31st).

A company whose report must also undergo an audit must submit the audit decisions no later than August 1st.

ENGLISH

What are the different types of packaging?

Packaging is classified according to its intended use, number of uses, type of material, and whether a deposit is charged.

Sales packaging or primary packaging – the part of a sales unit intended to be handed over to the end-user or consumer at the point of sale.

Group packaging or secondary packaging – intended for grouping a certain number of sales units at the point of sale, regardless of whether the group packaging is sold with the goods to the end-user or consumer or is only used to facilitate handling, protect or present the goods, whereby the group packaging can be removed without altering the properties of the product.

Transport packaging or tertiary packaging – intended for handling and transporting a certain number of sales units or goods in group packaging to prevent physical damage to the goods during transport; this does not include road, rail, sea, and air freight containers.

By number of uses:

• single-use packaging;
• reusable packaging.

By type of material:

• glass, plastic, ferrous metal, non-ferrous metal (aluminium), paper and papaerboard, wood, other materials;
• monomaterial and composite material packaging.

By deposit status:

• deposit packaging;
• non-deposit packaging.

Specific types:

• plastic carrier bags;
• single-use plastic product.

The next step is to create a system for collecting data on the packaging materials and their intended use for different products, classified by type and also by quantity (in tons), as easily and accurately as possible.

Where and when to submit the packaging report to TVO?

The packaging report is submitted through the TVO client portal at the agreed frequency in the reporting portal aruanne.tvo.ee.

After signing the client agreement, a user account linked to an e-mail is created for the agreed employee representing the company. Upon the first login, in the window that opens from the "Log in" button, enter the e-mail address in the field under "Register as a user" on the right and click the "Send password" button. An initial password will then be sent to the entered e-mail address, which can later be changed in the settings when logging into the portal.

Submitting the packaging report:

• The packaging report is submitted to TVO at the agreed frequency, either monthly or quarterly.
• TVO expects the company's packaging report no later than the 10th of the month following the reporting period (the reporting period is agreed upon in the contract as either a month or a quarter).
  
• Changes can be made to the packaging report during the current year and until the end of the first quarter of the following calendar year (i.e., until March 31st).
• Before March 31st, TVO submits consolidated reports of all clients to the Packaging Register (PAKIS).
  
• Packaging companies must send their report for the last period of the calendar year to TVO no later than March 28th.
  
• If a packaging company has not entered into a cooperation agreement with any recovery organization, it must submit its packaging report to PAKIS itself also before March 31st.
  
• Reports for the completed calendar year can be submitted or corrected until March 31st of the following year.
  

Guide for conducting an audit

What is a packaging report audit?
According to § 241 of the Packaging Act, a packaging company that places packaged goods on the market with a packaging mass of more than 20 tons per year must have its packaging report audited as a limited assurance engagement within the meaning of the Auditing Activities Act.

It is important to include in the packaging quantities also those packages that are subject to a deposit and for which a report is submitted to Eesti Pandipakend OÜ.

To do this:

• Find a suitable sworn auditor. Information about all sworn auditors can be found on the website of the Estonian Board of Auditors.
  
• Download the consolidated packaging quantity report submitted to TVO by logging into the portal aruanne.tvo.ee.
  
• It is important to distinguish between the quantities of reusable packaging that have left the circulation and single-use packaging. Even if you have declared these quantities together in the packaging report, they must be distinguished in the packaging report submitted for auditing.
  
• If it turns out during the audit that corrections need to be made to the packaging report, TVO should be notified immediately. It is important that the audit opinion is on a correct report, and TVO also has an agreement to add or reduce additional obligations.
  
• We expect audited packaging reports no later than August 1st of the following year! They can be uploaded to the aruanne.tvo.ee page or sent by e-mail to info@tvo.ee.
  

NB! A packaging company whose audit report summary is submitted unmodified (i.e., received a positive assessment) is exempt from conducting an audit for the next three calendar years.

We provide guidance and answer questions by e-mail at info@tvo.ee or by phone at 681 1481.

Audit decisions must be submitted to the National Packaging Register no later than September 1st of the following calendar year.

TVO does this itself, but in order to do everything on time, we expect our clients' audit decisions no later than August 1st!