The supervicing authority of producer responsibility has stated that, starting from January 1, 2025, importing products for own use will be considered an activity subject to producer responsibility, in Finland. This applies when a company manufactures or commissions the manufacture of products, subject to producer responsibility, for its own use. In this context, “import” refers to bringing goods into Finland from another country.
The Pirkanmaa ELY Centre (Centre for Economic Development, Transport and the Environment) states in its guidance:
“For all products subject to producer responsibility imported for own use—when it is not a case of distance selling—the import is considered to fall under producer responsibility. Products imported for own use are considered to have been placed on the Finnish market, and since they become waste in Finland, importers (professional operators) must have extended producer responsibility for the products they import.” The obligation of extended producer responsibility does not cease, even if the company collects or recycles the products itself, at the end of their life cycle.
Correct reports retrospectively
If a company has imported electrical and electronic equipment into Finland for its own use, starting from 1 January 2025, and has not reported the equipment to the producer organizations, the report must be corrected or the unreported quantities must be added to the next report. To correct a report, log in to Elker’s reporting portal and select the report you wish to modify. Detailed instructions for correcting a report can be found in the Member Company Manual.
Example Company: Solar Panel Ltd.
The company commissions the manufacture of solar panels for its own use and imports the equipment into Finland to establish a solar power plant. The company must report the equipment to the producer responsibility organization. Device packaging, pallets, and any potential energy storage systems must also be taken into account.
Example Company: Data Center Ltd.
The company manufactures servers in another country and transfers them to Finland to establish a data center. Defective servers are either repaired or recycled within the company’s own process. The company must report the servers and peripheral devices transferred to Finland to the producer responsibility organization. Device packaging and pallets must also be taken into account.