Insufficient supervision and limited awareness of population are obstacles to packaging recovery

Toomas Mattson | 12/8/2010 | 4:06 PM

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TALLINN, 8 December 2010 - The National Audit Office finds that the state has been unable to guarantee that packaging companies collect and recover the packaging brought to the market to the required extent. The main reason for this is insufficient supervision of packaging companies, the recovery organisations that represent them and persons who recover packaging waste, and the population’s limited awareness of the collection of packaging waste.

Estonia failed to meet the packaging waste recovery rates of the European Union in 2009 due to insufficient supervision. The approximate calculations made by the National Audit Office show that last year the state could have collected almost one billion kroons in packaging excise from companies, because the quantity of collected and recovered packaging was smaller than required. However, the state has forfeited this money, as its supervision authorities have been unable to identify the offenders and it is unknown which companies have failed to perform their obligations.

The reports of the recovery organisations that represent companies show that the share of packaging these organisations have recovered is as large as stipulated in the Packaging Act. However, the data of the Ministry of Environment show that the proportion of recovered packaging is smaller, as the quantity of packaging brought to the market is 45% higher than indicated by recovery organisations. This means that the quantity of packaging waste that ends up in landfills is impermissibly high. The difference in data usually results from the fact that not all companies have declared all of the packaging they have brought to the market.

Insufficient supervision means that packaging companies have not had to take responsibility for their failures. The Environmental Inspectorate, the Tax and Customs Board and the Environmental Information Centre that keeps the Packaging Register have been unable to guarantee that packaging companies and recovery companies provide accurate information about the quantities of packaging brought to the market in Estonia and how much of this packaging is recovered. The analysis carried out by the National Audit Office indicated that supervision authorities have not checked the data submitted by packaging companies belonging to recovery organisations (which is an estimated 80-90% of all packaging companies) at all.

The National Audit Office advises that packaging excise be collected immediately when the package is brought to the market in order to ensure that packaging excise meets its goal i.e. forces companies to collect and recover its packaging to the required extent. However, this means that packaging companies and the data submitted by them must be more efficiently checked.

Another reason behind the failure to meet the target rate of packaging recovery is the limited awareness of people and the inconvenience of returning packaging. The audit conducted by the National Audit Office indicated that 54% of people living in Estonia do not know that package waste can be returned free of charge. Sorting one’s waste would considerably reduce the amounts paid for waste removal, as packaging waste often forms almost half of the waste in a container.

The National Audit Office believes that people’s motivation to collect packaging waste according to type and to return it is reduced by the inconvenience and complexity of sorting. Different types of packaging must be collected separately and then taken to a packaging container or waste station, or their removal must be ordered from a waste removal company. The audit showed that the public packaging containers installed by recovery organisations are often far from residential areas, different types of packaging must be taken to different places, the number of containers has been cut in recent years, they are marked differently, and in many cases the openings in them are too small. Insufficient control and coordination by the state, and local authorities in particular, is also one of the main causes of this problem. The audit indicated that recovery organisations often dictate their own terms and conditions to local authorities in the manner of ‘take it or leave it’, and local authorities are unable to make the organisations work to improve the collection network.

Both the Minister of the Environment and the Minister of Finance support the National Audit Office’s suggestion to collect some packaging excise from companies at the moment the packaging is brought to the market. Both ministers agree that supervision of packaging waste, including the relevant cooperation between the Tax and Customs Board and the Environmental Inspectorate, must be made more efficient.

The Minister of Environment feels that local authorities have a major role to play in improving the collection of packaging waste.


According to the principles of the environmental policy of the European Union, the person responsible for collection and recovery of packaging waste is the manufacturer. The manufacturer has to guarantee that the waste resulting from the products made, distributed or imported by them is collected and recovered or safely discharged. All of the costs of these activities are covered by the manufacturer. Companies are obliged to pay the state packaging excise on packaging waste not recovered as required.

Estonia failed to meet the target rate of recovery in both 2008 and 2009, when 45% (target 50%) and 51% (target 60%) of packaging waste was recovered respectively. The state is responsible to the European Union for meeting the target rates of recovery.

The quantity of packaging waste has doubled since 2001 and attempts to separate it from economic growth (increase in consumption) have been unsuccessful. The quantity of packaging waste created in Estonia in 2008 was a record 214,000 tonnes (160 kg per person). Only deposit packaging (mainly bottles) is generally separated from other everyday waste, and the majority of recoverable packaging waste is sent to landfills (about 100,000 tonnes in 2008).

Packaging waste must be recovered, as it helps reduce the quality of waste sent to landfills or burnt in households, and recycling packaging material as a raw material helps save natural resources.

The amount of packaging excise paid to the state in 2009 was 500,000 kroons.

The National Audit Office checked whether the state’s activities support the collection and recovery of packaging waste in such a manner that packaging companies recover as much packaging waste as possible and the recovery goals set out in the packaging directive of the European Union are met.


Toomas Mattson
Head of Communication Service
National Audit Office
Telephone: +372 640 0777
Mobile: +372 51 34 900
E-mail: [email protected]


  • Posted: 12/8/2010 4:06 PM
  • Last Update: 11/10/2015 6:07 PM
  • Last Review: 11/10/2015 6:07 PM


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