What is Finland EPR EEE

Finland's EEE EPR framework is governed by the Waste Act 646/2011 (as amended) and implementing decrees setting out requirements for collection, treatment, and recycling of end-of-life EEE. These transpose the EU WEEE Directive (Directive 2012/19/EU) into Finnish national law. The national supervisory authority for EEE producer responsibility is the Pirkanmaa Centre for Economic Development, Transport and the Environment (Pirkanmaa ELY Centre), which manages the national producer register, carries out audits, and enforces compliance. The Ministry of Environment defines the legal framework and environmental targets. Finland has five approved producer organisations (PROs) for EEE, with Elker Oy acting as a service company handling membership, reporting, and administrative functions for three of them — SELT ry, ICT Producers Co-operative-TY, and Flip ry. Finland was included in Zalando's first wave of EEE EPR verification, active from January 2026.

Does This Apply to E-Commerce & Online Sales

Yes. Distance-selling companies without a Finnish branch or establishment that sell EEE directly to Finnish consumers are explicitly captured as producers under Finnish waste legislation. Distance sellers must fulfil EPR obligations via an authorised representative domiciled in Finland. The Pirkanmaa ELY Centre has published official guidance specifically for distance sellers (May 2024) confirming that foreign companies selling EEE to Finnish consumers online are subject to Finnish producer responsibility obligations. Zalando activated EEE EPR number verification for Finland from January 2026.

Who is the "Producer" under Finland EPR?

Under the Waste Act 646/2011, the following entities are considered producers of EEE:

1. Manufacturers or brand owners established in Finland that first place EEE on the Finnish market under their own name.
2. Importers or intra-EU acquirers bringing EEE into Finland from other EU Member States or from outside the EU.
3. Distance-selling companies without a Finnish establishment that sell EEE directly to Finnish consumers — must comply via an authorised representative.
4. Retailers marketing own-brand EEE products.
5. Private label owners whose brand name appears on EEE manufactured by third parties.
6. Economic operators who prepare EEE for re-use where applicable.

Who Must Register for EPR EEE in Finland

All producers placing EEE on the Finnish market must join one of the five approved producer organisations (PROs) for EEE in Finland. Membership in a PRO constitutes registration in the producer register maintained by the Pirkanmaa ELY Centre. In exceptional cases, producers may fulfil obligations by applying directly to the producer register without joining a PRO, but this requires individual approval. The five approved PROs for EEE in Finland are:

• SELT ry — membership handled by Elker Oy (elker.fi)
• ICT Producers Co-operative-TY — membership handled by Elker Oy (elker.fi)
• Flip ry — membership handled by Elker Oy (elker.fi)
• ERP Finland ry (erp-recycling.org)
• SER-Tuottajayhteisö ry (serty.fi)

Producer responsibility must be handled separately for each product group — EEE and battery obligations require separate registrations and PRO memberships.

Finland EPR EEE Registration Threshold

Finland does not publish a de minimis threshold for EEE EPR registration. The Waste Act applies to all producers placing EEE on the Finnish market regardless of volume, turnover, or size.

EEE Categories Covered (and Excluded)

Finland applies the open scope approach of the revised WEEE Directive. All EEE falls within scope unless specifically excluded. The Finnish system classifies EEE by the nature of products and end-users (B2C household versus B2B professional use). Main categories include: Large household appliances Refrigerators, washing machines, dishwashers, cookers, electric heaters, air conditioners. Small household appliances Vacuum cleaners, toasters, coffee machines, irons, hair dryers, electric clocks. IT and telecommunications equipment Computers, laptops, tablets, smartphones, printers, routers. The ICT Producers Co-operative-TY specifically covers consumer electronics and IT equipment producers. Consumer electronics Televisions, radios, audio and video equipment, cameras. Lighting equipment Fluorescent lamps, LED lamps, and luminaires (excluding filament bulbs). Electrical and electronic tools Power tools and similar equipment. Toys, leisure and sports equipment Video game consoles, electric toys, and sports equipment with electrical components. Medical devices Medical equipment (excluding implanted and infected devices). Monitoring and control instruments Smoke detectors, thermostats, measuring instruments. Automatic dispensers Vending machines and cash dispensers. Other EEE (open scope) All remaining EEE within voltage parameters. Key exclusions:

• EEE specifically designed and installed as part of another type of equipment that can only function as part of that equipment
• Large-scale fixed installations
• Military or space equipment
• Implanted and infected medical devices

B2B (professional use only) EEE has a simplified fee structure — the ICT Producers Co-operative-TY charges an annual fee of €300 for producers of only B2B equipment, compared to quarterly recycling fees for B2C products.

Producer Responsibility Organization (PRO)

Finland operates with five approved PROs for EEE, coordinated through two service structures: Elker Oy (elker.fi) — a non-profit service company managing membership, reporting, and administrative functions for three PROs: SELT ry, ICT Producers Co-operative-TY, and Flip ry. Elker is part of the European cooperation network Pronexa AG (formerly weee Europe), allowing central reporting across multiple EU countries. SELT ry covers household appliances and white goods EEE. ICT Producers Co-operative-TY covers consumer electronics and IT equipment. Connection fees range from €500 (sales under €1 million) to €1,500 (sales under €10 million). B2C producers pay quarterly recycling fees per device reported. B2B-only producers pay an annual fee of €300. Flip ry covers luminaires and lighting equipment. ERP Finland ry (erp-recycling.org) covers multiple EEE categories. SER-Tuottajayhteisö ry (serty.fi) covers multiple EEE categories. From 1 April 2026, reporting of EEE placed on the Finnish market moved to the Elrepo digital reporting system for Elker-managed PROs (SELT ry, ICT, Flip ry). The first reporting period in Elrepo covers Q1 2026, with the reporting window 1–30 April 2026.

EPR Registration in Finland

The registration process for EEE producers in Finland is as follows:

1. Confirm whether your products qualify as EEE and identify the correct PRO based on your product category — SELT (household appliances), ICT (consumer electronics/IT), Flip (lighting), ERP Finland, or SER-Tuottajayhteisö.
2. If established outside Finland, appoint an authorised representative domiciled in Finland before registering.
3. Join the appropriate PRO through Elker Oy (elker.fi) for SELT, ICT, or Flip; through erp-recycling.org for ERP Finland; or through serty.fi for SER-Tuottajayhteisö.
4. Sign the membership agreement and pay any applicable connection or joining fee.
5. PRO membership constitutes registration in the national producer register with the Pirkanmaa ELY Centre.
6. From 1 April 2026, report EEE placed on the Finnish market through Elrepo on a quarterly basis (for Elker-managed PROs).
7. Pay recycling contributions based on the weight and type of EEE placed on the Finnish market.
8. Maintain records for audit by the Pirkanmaa ELY Centre.

Authorized Representative

Distance-selling companies established outside Finland must appoint an authorised representative domiciled in Finland to fulfil all EPR obligations. The Pirkanmaa ELY Centre has confirmed this requirement in its official guidance for distance sellers (May 2024). The AR handles registration with the PRO, quarterly Elrepo reporting, fee payment, and communication with the Pirkanmaa ELY Centre. The AR must be domiciled in Finland. Important development: In December 2025, the European Commission proposed suspending the authorised representative requirement for EU-established companies until 2035 under Proposal COM(2025) 983. This proposal has not been formally adopted as of May 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers must report the following data through the PRO and Elrepo (from 1 April 2026 for Elker-managed PROs):

• Total number of devices and weight (kilograms) of EEE placed on the Finnish market during the reporting period, by product category and end-user type (B2C household versus B2B professional)
• Weight of end-of-life EEE collected and treated during the reporting period
• Brand names under which EEE was placed on the market
• Collection and recycling performance data compiled and reported by the PRO to the Pirkanmaa ELY Centre on behalf of members

Reporting is quarterly for B2C EEE through Elrepo. B2B-only producers report annually.

First Reporting Period & EPR Reporting Deadlines

Finland's EEE EPR has been in place for many years. Key dates:

• January 2026: Zalando activated EEE EPR verification for Finland — sellers without a valid Finnish EEE registration face listing restrictions.
• 1 April 2026: Elrepo reporting system launches for Elker-managed PROs (SELT, ICT, Flip). Replaces the old Prime system.
• 1–30 April 2026: First Elrepo reporting period, covering Q1 2026 (January–March 2026).
• Quarterly: EEE placed-on-market declarations through Elrepo for B2C producers.
• Annual: B2B-only producers report annually through the PRO.

Labels & Marketing Claims

Crossed-out wheeled bin symbol All EEE placed on the Finnish market must carry the crossed-out wheeled bin symbol, indicating separate collection. The symbol must be visible, legible, and indelible. Where not possible on the product, the symbol must appear on packaging or documentation. CE marking Mandatory for applicable EEE categories under EU product safety legislation. RoHS compliance EEE must comply with Directive 2011/65/EU (RoHS) restricting hazardous substances. RoHS compliance is maintained separately from EEE EPR registration. Language requirements Consumer-facing information on EEE sold in Finland must be provided in Finnish and/or Swedish where required under Finnish consumer protection law. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Finland.

EPR Eco Fees & Eco-Modulation

Finland's EEE EPR fee structure varies by PRO and product category: ICT Producers Co-operative-TY (via Elker):

• Connection fee: €500 (EEE sales under €1 million) to €1,500 (sales under €10 million)
• B2C producers: quarterly recycling fees per device reported, based on the equipment and recycling fee list
• B2B-only producers: annual fee of €300

Other PROs (SELT, Flip, ERP Finland, SER-Tuottajayhteisö) publish their own fee schedules — confirm rates directly with the chosen PRO at time of membership. Finland does not currently apply a formal eco-modulation framework adjusting EEE contributions based on product repairability or recyclability. As the Ecodesign for Sustainable Products Regulation (ESPR) implementing regulations develop, eco-design criteria may influence future contribution structures.

Risks, Penalties & Common Mistakes

1. Failing to join a PRO before placing EEE on the Finnish market. The Pirkanmaa ELY Centre carries out audits and can impose fines for non-compliance. Zalando has activated EEE EPR verification from January 2026 — sellers without a valid Finnish registration number face listing restrictions.
2. Choosing the wrong PRO. Each PRO has specific accreditations by EEE category. Joining a PRO that does not cover your product type does not fulfil your obligations. Producers should confirm accreditation scope with the Pirkanmaa ELY Centre or chosen PRO before signing.
3. Failing to appoint an authorised representative. Distance sellers must comply through a Finnish-domiciled AR. The Pirkanmaa ELY Centre has specifically confirmed this in guidance for distance sellers.
4. Confusing EEE and battery registration. Producer responsibility must be handled separately for each product group. EEE and battery registrations are separate obligations with separate PROs.
5. Missing the Elrepo transition. From 1 April 2026, Elker-managed PROs (SELT, ICT, Flip) moved reporting to Elrepo. Historical data from the old Prime system is available on request from the PROs after this date.
6. Missing quarterly reporting deadlines. B2C EEE producers must report quarterly through Elrepo. Missing submissions attract enforcement by the Pirkanmaa ELY Centre.
7. Missing the crossed-out wheeled bin symbol. Mandatory on all EEE — missing or inadequate marking is independently actionable.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products qualify as EEE and identify the correct Finnish PRO based on your product category.
2. If established outside Finland, appoint an authorised representative domiciled in Finland.
3. Join the appropriate PRO through Elker Oy (elker.fi) for SELT, ICT, or Flip; through ERP Finland ry (erp-recycling.org); or through SER-Tuottajayhteisö ry (serty.fi).
4. Complete membership registration and confirm your registration in the Pirkanmaa ELY Centre's producer register.
5. Set up quarterly Elrepo reporting for B2C EEE from 1 April 2026.
6. Provide your Finnish EEE registration number to Zalando and other marketplaces.
7. Ensure all EEE products carry the crossed-out wheeled bin symbol, comply with RoHS restrictions, and include Finnish/Swedish-language consumer information where required.
8. Handle battery EPR separately through the appropriate Finnish battery PRO if your EEE products contain batteries.

FAQ

Is EEE EPR mandatory in Finland?

• Yes. Finland's EEE EPR has been mandatory for many years under the Waste Act 646/2011. All producers placing EEE on the Finnish market must join one of the five approved PROs and comply with collection, reporting, and recycling obligations. The Pirkanmaa ELY Centre supervises compliance and carries out audits. Zalando activated EEE EPR verification for Finland from January 2026.

Do foreign brands selling online into Finland need to register?

• Yes. Distance-selling companies without a Finnish establishment are explicitly captured as producers under Finnish waste legislation. The Pirkanmaa ELY Centre published specific guidance for distance sellers in May 2024 confirming their obligations. Foreign companies must appoint an authorised representative domiciled in Finland and join a Finnish EEE PRO.

Which PRO should I join for EEE in Finland?

• Finland has five approved PROs: SELT ry (household appliances), ICT Producers Co-operative-TY (consumer electronics and IT), Flip ry (lighting), ERP Finland ry, and SER-Tuottajayhteisö ry. SELT, ICT, and Flip are managed through Elker Oy (elker.fi). The correct PRO depends on your specific EEE product category — confirm accreditation scope before signing.

What is Elrepo and when did it apply?

• Elrepo is Finland's new digital reporting system for EEE and batteries placed on the market, launched on 1 April 2026, replacing the old Prime system for Elker-managed PROs (SELT, ICT, Flip). The first reporting period covers Q1 2026 (January–March), with the reporting window 1–30 April 2026. Historical data from Prime is available on request after this date.

Is there a minimum volume threshold for EEE EPR in Finland?

• No. The Waste Act does not establish a minimum volume or turnover exemption. All producers placing EEE on the Finnish market must register and comply regardless of size. Producer responsibility for EEE and batteries must be managed separately — joining a battery PRO does not cover EEE obligations and vice versa.

What is Finland EPR Batteries

Finland's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States. The Regulation has applied in stages since 18 February 2024, with EPR and waste management obligations fully in force from 18 August 2025. At national level, Finland implements battery EPR through its Waste Act and subordinate legislation governing producer responsibility. The national supervisory authority is the Pirkanmaa Centre for Economic Development, Transport and the Environment (ELY Centre), which oversees compliance and accredits producer organisations. Producers register and report through approved producer organisations, and from 1 April 2026 through the new Elrepo digital reporting system. The EU Battery Regulation replaced the previous Batteries Directive 2006/66/EC in full from 18 August 2025. Finland was included in the first group of countries where Zalando activated battery EPR verification, with the Finnish register operational from January 2026.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation explicitly captures distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Finnish consumers via an online store — with no physical establishment in Finland — is treated as a producer and must comply with Finnish battery EPR obligations. Online marketplaces are required under the EU Battery Regulation to verify that sellers on their platforms are EPR-registered. Finland was in the first wave of countries where Zalando activated battery EPR number verification from January 2026 — sellers without a valid Finnish battery EPR registration number have had battery-containing product listings blocked on Zalando since August 2025.

Who is the "Producer" under Finland EPR?

Under Regulation (EU) 2023/1542 and Finnish waste legislation, a producer is any person who, in the course of commercial activity, makes batteries available on the Finnish market for the first time. This covers:

1. Manufacturers established in Finland who produce and sell batteries domestically under their own brand.
2. Importers bringing batteries into Finland from non-EU countries for the first time under their own name.
3. Companies introducing batteries from another EU Member State into Finland for the first time.
4. Private label owners whose brand name appears on batteries manufactured by third parties.
5. Distance sellers and online retailers established outside Finland who sell batteries or battery-containing products directly to Finnish consumers.
6. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Who Must Register for EPR Batteries in Finland

All producers placing batteries on the Finnish market must join an approved producer organisation and register through that organisation. Finland has four approved producer organisations for batteries, accredited by the ELY Centre, each covering different battery categories and chemistries:

• ERP Finland ry (erp-recycling.org) — covers portable batteries and other categories
• Recser Oy (paristokierratys.fi / recser.fi) — covers batteries including portable batteries and accumulators
• Akkukierrätys Pb Oy — covers lead-acid batteries
• Finnish Car Recycling Ltd (autokierratys.fi) — covers automotive batteries and automotive traction batteries; members are importers and professional distributors of automotive and automotive traction batteries

Note: The accreditations of producer organisations vary by battery category and chemistry. Producers must join the organisation that covers their specific battery type. Producer responsibility must be handled separately for each product group.

Finland EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Finnish market must register and comply regardless of size or volume. The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely. For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in Finland: Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. The most commonly encountered category for e-commerce sellers. Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles. Managed through Finnish Car Recycling Ltd and its members. Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027. Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Subject to carbon footprint declarations, battery passports from 2027, and detailed collection obligations. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

Finland operates with four approved producer organisations for batteries, each accredited by the ELY Centre for specific battery categories and chemistries: Recser Oy operates the national Paristokierrätys (battery recycling) service and manages collection, recycling, and reporting for portable batteries and accumulators. Recser Oy uses the Elrepo system for reporting placed-on-market quantities. ERP Finland ry is part of the pan-European ERP network and covers portable batteries and other categories, providing compliance services including reporting and fee management. Akkukierrätys Pb Oy specialises in lead-acid batteries. Finnish Car Recycling Ltd manages automotive and automotive traction batteries through its membership of importers and professional distributors. From 1 April 2026, the reporting of batteries placed on the Finnish market has moved to Elrepo — a new digital reporting system used by Elker Oy (SELT ry, ICT Producer Cooperative–TY, Flip ry), Recser Oy, and Akkukierrätys Pb Oy. The first reporting period in Elrepo covers Q1 2026 (January–March), with the reporting window 1–30 April 2026.

EPR Registration in Finland

The registration process for battery producers in Finland is as follows:

1. Determine whether your business qualifies as a producer under the EU Battery Regulation and Finnish waste legislation.
2. Identify the correct approved producer organisation based on your battery category and chemistry — ERP Finland ry, Recser Oy, Akkukierrätys Pb Oy, or Finnish Car Recycling Ltd.
3. If established outside Finland, appoint an authorized representative established in Finland before registering.
4. Apply for membership with the appropriate producer organisation.
5. Register battery volumes and brand names through the producer organisation.
6. From 1 April 2026, report placed-on-market quantities through Elrepo (for Recser Oy, Akkukierrätys Pb Oy, and Elker Oy members). The first reporting period covers Q1 2026.
7. Pay applicable contributions to the producer organisation based on battery category and volume.
8. Retain records for audit by the ELY Centre.

Authorized Representative

Under Regulation (EU) 2023/1542 (Article 57), producers established outside Finland must appoint an authorized representative — a legal or natural person established in Finland — to fulfill EPR obligations on their behalf. The authorized representative handles registration with the producer organisation, Elrepo reporting setup, fee payment, and contact with the ELY Centre. The representative must be appointed in writing. Important development: In December 2025, the European Commission proposed suspending the authorized representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of May 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers registered through Finnish producer organisations must report the following data through Elrepo (from 1 April 2026):

• Total weight (kilograms) of batteries placed on the Finnish market during the reporting period, broken down by battery category (portable, LMT, SLI/automotive, industrial, EV)
• Battery chemistry type where relevant to contribution calculations
• Brand names under which batteries were placed on the market
• Collection and recycling performance data, compiled and reported by the producer organisation to the ELY Centre on behalf of members
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been in place in Finland for many years. The new EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

• 18 August 2025: EPR registration, waste management, and labelling obligations fully in force.
• January 2026: Finnish battery EPR register operational — Zalando activated EPR number verification for Finland from this date.
• 1 April 2026: Elrepo reporting system launches. Replaces the old Prime reporting system.
• 1–30 April 2026: First reporting period in Elrepo, covering Q1 2026 (January–March 2026).
• Until 31 March 2026: Historical reports (2025 and older) accessible in the old Prime system. After this date, available on request from Recser.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries.
• 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory from 18 August 2024. Language requirements Consumer-facing information on batteries sold in Finland must be provided in Finnish and/or Swedish where required under Finnish consumer protection law. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Finland.

EPR Eco Fees & Eco-Modulation

Finnish producer organisations set contribution rates for their members based on the weight and category of batteries placed on the Finnish market. Specific fee schedules should be confirmed directly with the chosen producer organisation at the time of membership registration. Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required across all Member States. Finland's specific eco-modulation framework under the new Regulation has not been separately published as of May 2026.

Risks, Penalties & Common Mistakes

1. Placing batteries on the Finnish market without producer organisation membership. The ELY Centre oversees compliance and has authority to enforce producer responsibility obligations. Operating without a PRO arrangement is a breach of both Finnish waste law and the EU Battery Regulation.
2. Choosing the wrong producer organisation. Finland has four approved PROs with different accreditations by battery category and chemistry. Joining an organisation that does not cover your battery type does not fulfil your obligations.
3. Failing to appoint an authorized representative. Non-EU and non-Finnish producers must appoint a Finnish-established representative before registering.
4. Assuming one EU registration covers Finland. Battery EPR registration is national. Membership in a PRO in another EU member state does not fulfil Finnish obligations.
5. Missing Zalando's EPR number requirement. Finland was in the first wave of countries where Zalando activated battery EPR verification from January 2026. Sellers without a valid Finnish registration number have listings blocked.
6. Missing the Elrepo transition. Reporting has moved from the old Prime system to Elrepo from 1 April 2026. Historical reports from 2025 and earlier are only accessible in Prime until 31 March 2026.
7. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries and whether they are being sold to Finnish consumers.
2. Identify the correct Finnish producer organisation based on your battery category — ERP Finland ry, Recser Oy, Akkukierrätys Pb Oy, or Finnish Car Recycling Ltd.
3. If established outside Finland, identify and appoint an authorized representative established in Finland.
4. Apply for membership with the appropriate producer organisation and complete registration.
5. Set up reporting through Elrepo (from 1 April 2026) for quarterly placed-on-market declarations.
6. Provide your Finnish battery EPR registration number to marketplaces including Zalando where you sell battery-containing products.
7. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, and capacity information as required from August 2025.
8. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

Is battery EPR mandatory in Finland?

• Yes. Battery EPR has been mandatory in Finland for many years. From 18 August 2025, the new EU Battery Regulation (2023/1542) fully replaced the former Batteries Directive. All producers placing batteries on the Finnish market must join an approved producer organisation, register, report quarterly through Elrepo (from 1 April 2026), and comply with collection and recycling obligations.

Do foreign brands selling online into Finland need to register?

• Yes. Distance sellers and e-commerce operators selling batteries or battery-containing products to Finnish consumers are captured as producers. Non-Finnish companies must appoint an authorized representative established in Finland. Finland was in the first wave of countries where Zalando activated battery EPR verification from January 2026 — sellers without a valid registration number have listings blocked.

Which producer organisation should I join?

• Finland has four approved PROs with different accreditations by battery category and chemistry: ERP Finland ry, Recser Oy, Akkukierrätys Pb Oy, and Finnish Car Recycling Ltd. Producers must join the organisation that covers their specific battery type. Contact the ELY Centre or individual PROs to confirm which organisation is accredited for your battery category.

What is Elrepo and when does it apply?

• Elrepo is Finland's new digital reporting system for batteries and electrical and electronic equipment placed on the market. It replaced the old Prime system from 1 April 2026. The first reporting period in Elrepo covers Q1 2026 (January–March), with the reporting window 1–30 April 2026. Producers should log in to Elrepo and verify their company information before the first reporting deadline.

Is there a minimum volume threshold below which registration is not required?

• No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Finnish market must register and comply regardless of size.

Textile EPR law in Finland: None enacted

Finland is not among the countries with enacted textile EPR legislation.