Introduction

Finland is one of those EU markets where EPR requirements have been significantly tightened in recent years — and where the consequences of non-compliance are quickly felt in sales practice. Online sellers focused on VAT and order fulfillment often learn about waste management obligations only when a marketplace platform restricts their offers due to lack of EPR registration confirmation.

It is worth noting that Finland introduced an important change from 1 January 2024: the annual turnover threshold of one million euros, below which some entities were exempt from EPR obligations in the area of packaging, was abolished. From that moment, these obligations may apply to all entities placing packaging on the Finnish market, regardless of turnover size. This change covered a wide group of enterprises, including foreign online sellers.

This guide is addressed to producers, importers, and online stores serving customers in Finland.

What is EPR

Extended Producer Responsibility (EPR) is a regulatory system in which entities placing goods on the market bear financial responsibility for the collection, recycling, and proper management of waste generated from those goods after the end of their use.

In practice, this means that if a company ships products in cartons, films, or other packaging materials or places electronics or items containing batteries on the market, it may be subject to obligations related to financing their collection and recycling systems. This obligation does not end at the moment of sale — it is “extended” over the entire life cycle of the product.

In Finland, the EPR system covers several regulated waste categories. For e-commerce sellers, the key ones are primarily:

• packaging,
• waste electrical and electronic equipment (WEEE),
• batteries and accumulators.

The Finnish system also covers other product groups, including:

• tires,
• motor vehicles,
• printed paper materials,
• selected single-use plastic products.

The fulfillment of EPR obligations generally includes three elements: registration in the appropriate system, reporting the quantities of products or packaging placed on the market, and paying fees related to financing waste management. In practice, many enterprises fulfill these obligations through producer responsibility organizations (PRO), which support operational and reporting processes.

Scope of entities — who the regulations apply to

Each EPR system asks the same question: who first places the product on the Finnish market? These obligations may rest on:

• Finnish producers and packers that manufacture or package products for the local market,

• importers and entities acquiring goods from other EU countries and introducing them into Finland,

• distributors selling products under their own brand,

• foreign online sellers shipping goods directly to Finnish consumers.

The Finnish system explicitly includes distance selling in its regulations and supervisory practice. In the case of foreign e-shops, the assessment of obligations depends on the type of product. It is also crucial whether the applicable regulations classify a given entity as a producer for a specific waste stream.

Finland also provides for the possibility of appointing an authorized representative (AR). The law explicitly indicates this solution for entities from another EU country that sell electronic equipment to users in Finland. The issue of using an AR is also relevant for packaging or batteries. However, companies should assess this need separately, based on the legal basis and their business model.

Legal basis for obligations

The Finnish EPR system is based on several key legal acts. The main document is the Waste Act No. 646/2011 (Jätelaki). It establishes the framework of the extended producer responsibility system. It also defines general principles of waste management and obligations of entities placing products on the market.

Detailed rules for packaging are contained in Government Decree No. 518/2014. In the area of electrical and electronic equipment, national regulations implementing the WEEE Directive apply, including Decree No. 519/2014. The battery market is regulated by EU Regulation 2023/1542. These provisions apply directly in all Member States, although specific requirements enter into force gradually.

The Finnish system additionally applies fee modulation mechanisms. These depend on the properties of packaging materials, specifically their recyclability. This means that packaging design directly affects the level of contributions. Such a solution encourages companies to use more environmentally friendly solutions.

Competent authority and Producer Register

Supervision over the EPR system in Finland is exercised by state authorities at the national level. A key role is played by the Pirkanmaa Centre for Economic Development, Transport and the Environment (Pirkanmaan ELY Centre). This authority maintains the producer register and supervises the fulfillment of obligations. It also enforces regulations concerning extended producer responsibility.

Finland has a network of regional ELY centres, but EPR-related tasks are highly centralized. As a result, businesses, including foreign entities, primarily deal with one competent authority. At the operational level, approved producer responsibility organizations (PRO) operate. They carry out tasks related to collection, recycling, and data reporting on behalf of companies.

The main administrative tool of the system is the Producer Register (tuottajarekisteri). It is maintained by the Pirkanmaa ELY Centre. Registration is carried out electronically. Obtaining an entry is a condition for legally placing products on the Finnish market.

After registration and joining a compliance system, the enterprise receives official confirmation or an identification number. This document may be required in business relations, especially by sales platforms. Entities covered by the system must additionally maintain documentation regarding goods and packaging. Companies store this data for a specified period for the purposes of potential inspections.

Main EPR obligations in Finland

Registration

The first step is to determine which waste streams apply to a given activity. Systems in other EU countries operate similarly. Most online stores begin with the analysis of packaging. Then they check electrical and electronic equipment (WEEE) and batteries, depending on the offered assortment.

Companies usually register in the Producer Register maintained by the Pirkanmaa ELY Centre. However, the method of fulfilling obligations depends on the chosen model. Enterprises may choose an individual model or cooperation with a producer responsibility organization (PRO).

The collective model consists of concluding an agreement with an approved PRO organization. It takes over part of the operational tasks, including organizing collection and recycling. This organization also fulfills reporting obligations to a certain extent. Sellers commonly use this solution because it simplifies administrative processes.

Individual fulfillment of obligations remains an alternative. However, it involves a greater organizational burden. The company must then independently meet all system requirements.

Some product categories are subject to additional national and EU requirements. This applies particularly to electrical equipment and batteries. Regulation (EU) 2023/1542 imposes on battery producers an obligation to register in the countries where they make their goods available. Detailed rules for applying this act are phased in.

Authorized representative (AR) — Finnish specificity

The issue of appointing an authorized representative (AR) plays an important role in the Finnish EPR system. This particularly concerns cross-border sales.

Foreign sellers without a seat or branch in Finland may be required to appoint a local representative. Sometimes they use the services of an entity acting on their behalf. Everything depends on the type of product and the definition of producer in specific regulations.

Regulations concerning electrical and electronic equipment (WEEE) explicitly provide for such a possibility. Entities engaged in distance selling widely use this solution in practice.

The issue of appointing a representative for packaging and batteries requires separate assessment. The legal basis and business model should be taken into account. Regulation (EU) 2023/1542 imposes on battery producers without a seat in a given country an obligation to appoint a representative. These rules enter into force in stages.

For this reason, many foreign e-commerce sellers cooperate with a local supporting entity, even when the regulations do not impose a clear obligation.

Confirmation of Registration (EPR Number)

An enterprise receives confirmation of entry into the register after completing the procedure. The authority then assigns an identification number to a given waste stream. These documents constitute proof of fulfilling the registration obligation in the EPR system. Their form may vary depending on the product category.

Confirmation of registration is of great operational importance. Sales platforms increasingly require such proof during seller verification. It is often a condition for maintaining active offers on the Finnish market.

The registration process takes varying amounts of time. It may include establishing a representative or joining a collective system. It is recommended to start these activities in advance. It is best to do this before the actual start of sales in Finland.

Reporting and recording

Producers covered by the EPR system in Finland are, as a rule, required to maintain records concerning the quantities and types of products and packaging placed on the Finnish market. This data also includes a breakdown by materials and — depending on the case — a distinction between single-use and reusable packaging.

Reporting rules, including frequency and deadlines for submitting data, may vary depending on the waste stream and the adopted compliance model. In practice, in many cases reporting is carried out through producer responsibility organizations (PRO), which submit reports on behalf of their members based on the data provided.

Entities covered by the system should also ensure the storage of documentation regarding introduced products and packaging for a specified period, which is important in the event of inspections by the competent supervisory authority.

Charges 

Contributions related to fulfilling EPR obligations in Finland are, as a rule, dependent on the quantity and type of packaging materials or products placed on the market. In practice, when using the collective system, these fees are paid to producer responsibility organizations (PRO), which manage collection and recycling systems.

In addition to variable fees, enterprises may also incur other costs related to participation in the system, such as registration fees or administrative contributions, depending on the chosen compliance model.

An important feature of the Finnish system is the application of fee modulation mechanisms depending on the properties of packaging materials, in particular their recyclability (so-called eco-modulation). In practice, this means that packaging that is easier to process may be subject to lower rates, while materials that are more difficult to recycle may involve higher fees.

The scope of application of these mechanisms and detailed criteria may vary depending on the material category and the rules adopted in a given system, therefore their impact on costs should be assessed individually. For e-commerce sellers, this may be an important factor when selecting and designing packaging.

Product and packaging labelling requirements

Entities placing products on the Finnish market are subject to specific labeling requirements, resulting mainly from EU regulations and their implementation into national law. The scope of these obligations depends on the type of product and relevant sectoral regulations. Most often they concern:

• packaging: markings with material identification symbols in accordance with EU Decision 97/129/EC; Finland also applies mandatory labeling in this respect,
• electrical and electronic equipment — the crossed-out wheeled bin symbol, indicating the need for selective collection, in accordance with WEEE regulations,
• batteries and accumulators — markings including the crossed-out wheeled bin symbol and, in certain cases, additional chemical markings, in accordance with EU regulations.

Detailed requirements regarding the form, size, and placement of markings may result from specific regulations and are introduced gradually, particularly in relation to battery regulations.

Markings are generally placed on the product, packaging, or — in justified cases — in accompanying documentation. In online sales, this information may also be provided digitally.

Information obligations towards buyers

An important change in the Finnish EPR system was the abolition, from 1 January 2024, of the turnover threshold below which some entities were exempt from packaging obligations. As a result, obligations related to registration and reporting may now apply to all entities placing packaging on the Finnish market, regardless of the scale of activity.

In practice, this information should include in particular:
• an indication that the product should not be disposed of together with unsorted municipal waste,
• information on the availability of selective waste collection systems,
• general information on the environmental impact of improper disposal.

In the e-commerce model, this information may be provided in various ways, e.g. in the user manual, on the product page, in post-transaction communication, or in materials attached to the shipment. The method of providing it should be adapted to the nature of the sale and the target market.

Waste streams and obligation thresholds

An important change in the Finnish EPR system was the abolition, from 1 January 2024, of the turnover threshold below which some entities were exempt from packaging obligations. As a result, obligations related to registration and reporting may now apply to all entities placing packaging on the Finnish market, regardless of the scale of activity.

In practice, this means that even relatively small online sales — if they involve placing packaging on the Finnish market — may generate EPR obligations. This is an important difference compared to some other EU countries where quantitative or turnover thresholds still exist.

In the case of electrical and electronic equipment (WEEE) and batteries, regulations generally do not provide for general exemption thresholds, which means that obligations may arise already when these products are placed on the market.

The Finnish EPR system is also gradually being extended to new product categories, including selected single-use plastic products and other waste streams. The scope and timing of introducing new obligations may result from specific regulations and legislative changes at national and EU level, therefore they should be monitored on an ongoing basis.

Consequences of non-compliance

Failure to meet EPR requirements in Finland may lead to both administrative consequences and operational risks. The competent supervisory authority — the Pirkanmaa ELY Centre — has the power to conduct inspections and take actions against entities that do not fulfill obligations arising from waste management regulations. The type and amount of potential sanctions depend on the nature of the infringement and the circumstances of the specific case.

From a business perspective, the consequences may be equally significant. Sales platforms increasingly require proof of compliance with EPR obligations, and the lack of appropriate registration or documentation may result in reduced visibility of offers, additional verification procedures, or suspension of sales.

In the case of cross-border activity, the issue of establishing an entity acting on behalf of the seller (e.g. a representative or operational partner) may also be of particular importance, if required in a given business model. The lack of an appropriate organizational structure may hinder proper fulfillment of registration and reporting obligations.

Summary

Finland stands out among other EU countries in several respects important for e-commerce. First of all, the abolition of the turnover threshold in 2024 means that EPR obligations for packaging now apply to a wide range of entities, regardless of the scale of their activity.

Another important element is the issue of establishing an entity acting on behalf of the enterprise (e.g. an authorized representative). The role of such a representative depends on the type of product and the specific business model. In addition, fee modulation mechanisms, including eco-modulation, introduce additional factors affecting costs. For this reason, it is worth taking these guidelines into account already at the packaging design stage.

Enterprises selling to Finland should in particular assess which waste streams apply to their activity, ensure appropriate registration in relevant systems, choose a model for fulfilling obligations (e.g. individual or collective), and — if necessary — consider support from a local entity. Implementing these actions at an early stage of sales allows reducing regulatory and operational risk related to activity on the Finnish market.

Support in fulfilling EPR obligations

Rulity Consulting supports sellers entering the Finnish market in organizing compliance with the EPR system in a clear and operationally efficient manner. The starting point is an analysis of the product portfolio and sales model, which allows determining which waste streams may apply under Finnish regulations. For most online stores, these will primarily be packaging, and depending on the assortment, also electrical and electronic equipment (WEEE) and batteries.

On this basis, it is possible to select an appropriate compliance model, including registration in the appropriate system, selection of a producer responsibility organization (PRO), and — if necessary — support in organizing the compliance structure, including cooperation with a locally operating entity.

Proper planning of compliance before starting sales on the Finnish market allows reducing the risk of later corrections and ensuring business continuity, including limiting operational risks related to the lack of required registrations or documentation.

FAQ

Need support with registration in the Finnish market? Rulity Consulting will help you through the verification process and ensure correct reporting.