The Estonian Recovery Organization (ERO) came into force on July, 2004. ERO is a non-profit organization and does not share profit among its owners. All profit is reinvested to the collection and recovery for decreasing total costs.

ERO’s mission is to help packaging operators to fulfill Packaging Act economically reasonable, socially acceptable and environmentally effective way.

ERO’s aim is to transfer packaging operator’s obligation to organization. ERO represents the interests of its members/clients in cooperation with public institutions.

The scope of responsibility is to collect and recover its clients’ packaging waste and to guarantee reporting for Packaging Register. ERO is not responsible for packaging circling in the deposit system.


The highest decision making body is General Meeting which nominates board for 2 years. Board is responsible for fulfilment of ERO’s targets. The Board consists of 6 members. To achieve its goals, board has formed office and hired Managing Director. Managing Director runs ERO with 6 employees.

ERO is a collaborative industry body through which businesses work together to achieve the recovery and recycling of packaging waste. Membership is open to all types of obligated companies including manufacturers, converters, packer/fillers, sellers and also all sectors of industry. It aims to take the pressure away from businesses that would find it difficult and time consuming to comply with any legislation on an individual basis.

System Description

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Non-Profit Organisation Eesti Taaskasutusorganisatsioon (ETO) is the first accredited producer responsibility organisation in Estonia engaged in the selective collection and recycling of packaging waste since 2004.

ETO is connecting obliged industry from several fields of business activities: producers of packaging products, importers, retail trade and producers of packaging.

ETO is a member of the Packaging Recovery Organisation Europe PRO EUROPE and the Extended Producers Responsibility Association EXPRA.

ETO customers have the right to use The Green Dot (der Grüne Punkt) marking on packaging in Estonia. The Green Dot on the packaging means that for such packaging a financial contribution has been paid to a qualified national packaging recovery organisation that has been set up in accordance with the principles defined in European Packaging and Packaging Waste Directive 94/62 and the respective national law.

The Estonian Packaging Act stipulates a definition of packaging obliged industry as following:  packaging undertaking means any person who packages, imports, or sells packaged goods within their economic or professional activities.

Producers and importers have to keep in-house records on packaging materials and their quantities. Producers and importers are responsible for taking back and recovering their packaging waste according to the required amounts in packaging and packaging excise tax legislation.
Packaging companies can fulfill the take-back and recovery obligations individually or join an accredited packaging organisation MTÜ Eesti Taaskasutusorganisatsioon (ETO). ETO is collecting packaging waste nationwide in cooperation with waste operators.

ETO service fees cover all costs of collection, sorting, transport and recovery costs.

Packaging Act stipulates packaging as all products made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of goods, from raw materials to processed goods, from the producer to the user or the consumer. Non-returnable items used for the same purpose are also considered to constitute packaging.

The types of packaging material are the following:
1) glass means all fused inorganic glass types which belong to Chapter 70 of the Combined Nomenclature pursuant to Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff (OJ L 256, 7.9.1987, p. 1–675);
2) plastic means all natural and artificial polymer-based materials in both single and multi-layer embodiment which belong to Chapter 39 of the Combined Nomenclature pursuant to Council Regulation (EEC) No 2658/87;
3) metal means steel which belongs to Chapter 73 of the Combined Nomenclature, aluminium which belongs to Chapter 76 of the Combined Nomenclature, and other metals which are used as packaging materials and belong to Section XV (Base metals and articles of base metal) of the Combined Nomenclature pursuant to Council Regulation (EEC) No 2658/87;
4) paper and paperboard, including composite paperboard, which belongs to Chapter 48 of the Combined Nomenclature pursuant to Council Regulation (EEC) No 2658/87;
5) wood;
6) other material.

Classes of packaging:
1) sales packaging or primary packaging means part of a sales unit designated to be handed over to the end-user or consumer at the place of sale.
2) grouped packaging or secondary packaging is meant for grouping a certain number of sales units at the place of sale regardless of whether the grouped packaging is sold as such to the end-user or consumer or whether it serves only as a means to facilitate the handling of goods, or protection or presentation of goods, whereas grouped packaging can be removed from the product without affecting its characteristics;
3) transport packaging or tertiary packaging is meant for handling and transport of a certain number of sales units or goods in grouped packaging in order to prevent transport damage, whereas transport packaging does not include road, rail, sea and air containers.

Depending on the possibility of reusing packaging, the subclasses of packaging are as follows:
1) reusable packaging is intended and designed to pass at least several rotations or circles in the reuse system during its life cycle, depending on the intended use, possibility, and fitness for the use of the packaging;
2) non-reusable packaging is meant only for single use.


Communication activities

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ETO is organizing collection and recycling of packaging waste by acting as follows:

– establishing nationwide publicly accessible selective collection system – bins with different colours;
– tendering, by procedure of competition, services of packaging collection and recovery;
– subcontracting handling, sorting, transportation and recycling of collected packaging waste;
– providing reporting on behalf of packaging companies to the Packaging Register;
– cooperating with municipalities to ensure inhabitants with convenient way to return packaging waste;
– communication towards consumers in order to increase  awareness of packaging waste sorting habits;
– collection of service fee from the packaging companies according to packaging legislation;


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Calculation of packaging mass is imposed on the production of packaging goods placed on the market in Estonia or acquired and imported in the event of the sale, exchange, transfer without charge or use for self-consumption of the packaging.


For determination of packaging mass there should be counted together mass of packaging along with any components and additional elements attached to the packaging such as lids, caps, corks, seals, labels, safety strips, clips, etc., without the goods contained therein.

The total mass of the packaging placed to the market shall be determined to the nearest 1 kg.

If the packaging consists of various materials and these materials can be manually separated, the mass of packaging shall be determined separately for every type of packaging material to be separated, except if the parts to be separated constitute less than 10% of the total mass of packaging. In this case, the mass of the components and additional elements of packaging shall be counted among the mass of the class of the dominant packaging material.

Reusable packaging is not subject of reporting as long as reused.


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Eesti Taaskasutusorganisatsioon MTÜ

Mustamäe tee 24
10621 Tallinn

Phone: +372 5663 8831