Renewable energy projects need to take into account Extended Producer Responsibility (EPR) obligations. In solar power and grid energy storage projects, electrical equipment and batteries are key products covered by EPR.
In a nutshell, EPR lies with the company that is the first to place the product on the market in Finland.
For batteries as well as electrical and electronic equipment, EPR applies to manufacturers, companies importing products from within or outside the EU, distance sellers and companies selling products under their own name or trademark.
EPR also applies to companies that place batteries incorporated into other products on the market, and to economic operators that prepare for re-use or for repurposing or remanufacture batteries.
Fingrid is not a producer within the meaning of the Waste Act.
Fingrid is not a producer within the meaning of the Waste Act, but it requires its contractual partners to comply with up-to-date legislation on EPR.
”We can communicate the requirements of EPR in a number of different contexts to make operators aware of them,” says Environmental Specialist Nina Nordblad from Fingrid.
Producer organisations carry out the legal obligations on behalf of their members
In Finland, the easiest way to manage EPR is to join an approved producer organisation.
”Producer organisations are non-profit organisations established and managed by the producers themselves. They carry out the legal obligations on behalf of their members,” says Jaana Mäenpää, Senior Officer at the Finnish Supervisory Agency.
The producer organisation is responsible for organising the waste management for discarded products, including collection, transport and recycling. It also collects and reports annual statistics to the authorities and ensures that the collection, recycling and recovery targets for the products are met.
Alternatively, EPR can be fulfilled by establishing a producer organisation with other producers. In exceptional cases, it can also be managed by applying directly to the producer register, but this is rare.
Nationwide supervision
EPR is guided and supervised nationally by the Finnish Supervisory Agency. Supervision focuses on both producers and producer organisations.
”Often, non-compliance can be due to lack of information, but that does not remove the responsibility. That is why we highlight the importance of proactive guidance and information sharing,” says Mäenpää.
The Finnish Supervisory Agency may impose a negligence penalty for failing to comply with EPR or to report annual monitoring data.
