COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019 Country Report - ESTONIA Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2019: A Europe that protects its citizens and enhances their quality of life
Date: 2019-07-31
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Estonia, application of EU law, climate change policy, environmental law, environmental protection, governance, green economy, public health, quality of the environment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 31.7.2019  SWD(2019) 135 final/2  CORRIGENDUM This document corrects document SWD(2019) 135 final of 04.04.2019 Old footnote 43 deleted and footnote 75 modified The text shall read as follows: COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019      Country Report - ESTONIA             Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2019:  A Europe that protects its citizens and enhances their quality of life  {COM(2019) 149 final} - {SWD(2019) 111 final} - {SWD(2019) 112 final} - {SWD(2019) 113 final} - {SWD(2019) 114 final} - {SWD(2019) 115 final} - {SWD(2019) 116 final} - {SWD(2019) 117 final} - {SWD(2019) 118 final} - {SWD(2019) 119 final} - {SWD(2019) 120 final} - {SWD(2019) 121 final} - {SWD(2019) 122 final} - {SWD(2019) 123 final} - {SWD(2019) 124 final} - {SWD(2019) 125 final} - {SWD(2019) 126 final} - {SWD(2019) 127 final} - {SWD(2019) 128 final} - {SWD(2019) 129 final} - {SWD(2019) 130 final} - {SWD(2019) 131 final} - {SWD(2019) 132 final} - {SWD(2019) 133 final} - {SWD(2019) 134 final} - {SWD(2019) 136 final} - {SWD(2019) 137 final} - {SWD(2019) 138 final} - {SWD(2019) 139 final}  
 
 
This report has been written by the staff of the Directorate-General for Environment, European Commission. Comments 
are welcome, please send them to ENV-EIR@ec.europa.eu 

More information on the European Union is available at http://europa.eu. 

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For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

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Reproduction is authorised provided the source is acknowledged. 

1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

EXECUTIVE SUMMARY ................................................................................................................................... 3 

PART I: THEMATIC AREAS .............................................................................................................................. 4 

1. 

TURNING  THE  EU  INTO  A  CIRCULAR,  RESOURCE-EFFICIENT,  GREEN  AND  COMPETITIVE  LOW-
CARBON ECONOMY .............................................................................................................................. 4 

Measures towards a circular economy ................................................................................................. 4 
Waste management .............................................................................................................................. 7 
Climate change ...................................................................................................................................... 8 

2. 

PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL .................................................. 11 

Nature and biodiversity ....................................................................................................................... 11 
Maintaining and restoring ecosystems and their services .................................................................. 12 
Estimating natural capital ................................................................................................................... 12 
Invasive alien species .......................................................................................................................... 13 
Soil protection ..................................................................................................................................... 13 
Marine protection ............................................................................................................................... 14 

3. 

ENSURING CITIZENS' HEALTH AND QUALITY OF LIFE ........................................................................ 15 

Air quality ............................................................................................................................................ 15 
Industrial emissions ............................................................................................................................. 16 
 ................................................................................................................................................. 17 
Noise 
Water quality and management ......................................................................................................... 17 
Chemicals ............................................................................................................................................ 19 
Making cities more sustainable ........................................................................................................... 20 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................... 23 

4. 

GREEN  TAXATION,  GREEN  PUBLIC  PROCUREMENT,  ENVIRONMENTAL  FUNDING  AND 
INVESTMENTS ..................................................................................................................................... 23 

Green taxation and environmentally harmful subsidies ..................................................................... 23 
Green public procurement .................................................................................................................. 24 
Environmental funding and investments ............................................................................................ 25 

5. 

STRENGTHENING ENVIRONMENTAL GOVERNANCE ......................................................................... 28 

Information, public participation and access to justice ...................................................................... 28 
Compliance assurance ......................................................................................................................... 29 
Effectiveness of environmental administrations ................................................................................ 30 
International agreements ................................................................................................................... 32 
Sustainable development and the implementation of the UN SDGs .................................................. 32 

2 

 
 
 
 
Environmental Implementation Review 2019 – Estonia 

Executive summary 

Estonia and the Environmental Implementation Review 
(EIR) 

In  the  2017  EIR,  the  main  challenges  identified  with 
regard  to  implementation  of  EU  environmental  policy 
and law in Estonia were: 

 

 

reducing the intensity of resource use, which  would 
improve industrial resilience; 
creating a  greater capacity in recycling to offset  the 
overcapacity  in  incineration  and  the  mechanical 
biological treatment of waste. 

In  March  2017,  Estonia  organised  an  EIR  dialogue 
focusing  on  waste  management  and  the  circular 
economy. 

Also  in  2017,  the  Commission  launched  the  TAIEX-EIR 
peer-to-peer instrument (EIR P2P) as a new practical tool 
allowing  peer-to-peer 
learning  among  environmental 
authorities.  Estonia  participated  in  EIR  P2P  workshops 
on  air  quality  (both  on  effective  measures  and  good 
practices  aiming  to  reduce  emissions  from  domestic 
heating)  and  on  exchanging  experiences  and  good 
practices  related  to  reducing  air  pollution  in  zones  or 
agglomerations where the levels of pollutants in ambient 
air exceed limit or target values. 

Progress on meeting challenges since the 2017 EIR 

show 

room 

for  more 

Estonia’s  performance  in  terms  of  resource  efficiency  of 
SMEs  as  well  as  its  low  score  on  the  Eco-Innovation 
improvement, 
Scoreboard 
especially  given  the  country’s  strong  overall  innovation 
potential.  There  is  strong  public  support  in  Estonia  for 
increasing resource efficiency through for example Green 
Innovation  Estonia  and  the  Environmental 
Industry 
Investment Centre. Thus, the challenge appears to be to 
engage SMEs in circular economy activities. 

For  resource  productivity,  Estonia  remains  among  the 
worst  performing  in  the  EU,  although  it  has  improved 
slightly since 2015. 

Some  progress  on  waste  is  underway  thanks  to  the 
national waste management plan for 2014-2020, and the 
adoption of a circular economy action plan scheduled for 
2020.  However,  according  to  the  Commission’s  2018 
Early  Warning  Report,  Estonia  is  considered  at  risk  of 
non-compliance with the 2020 municipal waste recycling 
target  of  50 %.  No  progress  has  been  made  in  dealing 
with  excess 
incineration  and  mechanical  biological 
treatment  (MBT)  capacities,  as  these  facilities  are  now 
installed and are hard to upgrade. This makes investment 
in  separate  collection  and  recycling  capacity  crucial  to 
reach  the  targets.  The  recent  administrative  reform 

(which reduced the number of municipalities) could help 
increase  coordination  and  efficiency  in  delivering  waste 
collection services. 

On economic instruments, significant progress was made 
with  the  Estonian  government’s  decision  taken  on  17 
March  2017,  to  introduce  a  vehicle  registration  tax 
dependent  on  the  vehicle’s  power  and  CO2  emissions. 
However,  a  new  subsidy  has  been  put  in  place  for  peat 
and  this  is  a  step  backwards.  In  addition,  Estonia  still 
lacks a national action plan for green public procurement 
but  intends  to  cover  this  in  their  action  on  circular 
economy. 

Examples of good practice 

frameworks 

Investment  Centre 
in 
investment 

The  National  Environmental 
provides  good  opportunities  for 
environmental projects. 
Estonia  has  one  of  the  most  complete  prioritised 
action 
in  the  EU,  and  this  was 
successfully  used to secure funding for Natura 2000 
sites from various EU funds. 
The  Ministry  of  Environment  organises  an  annual 
‘partnering event’, a good example of how to involve 
stakeholders and the public in environmental issues. 

 

 

 

3 

 
 
Environmental Implementation Review 2019 – Estonia 

Part I: Thematic areas 

1. Turning the EU into a circular, resource-efficient, green and 

competitive low-carbon economy 

Measures towards a circular economy 

The  Circular  Economy  Action  Plan  emphasises  the  need 
to  move  towards  a  life-cycle-driven  ‘circular’  economy, 
reusing  resources  as  much  as  possible  and  bringing 
residual  waste  close  to  zero.  This  can  be  facilitated  by 
developing  and  providing  access  to  innovative  financial 
instruments and funding for eco-innovation. 

Following  the  adoption  of  the  Circular  Economy  Action 
Plan in 2015 and the setting up of a related  stakeholder 
platform  in  2017,  the  European  Commission  adopted  a 
new  package  of  deliverables  in  January  20181.  This 
included  additional  initiatives  such  as:  (i)  an  EU  strategy 
for plastics; (ii) a Communication on how to address the 
interplay  between  chemical,  product  and  waste 
legislation; (iii) a report on critical raw materials; and (iv) 
a  framework  to  monitor  progress  towards  a  circular 
economy2. 

Estonia’s  performance  in  terms  of  circular  economy 
varies.  The  circular  (secondary)  use  of  material  was 
11.8 % in 2016 (EU-28 average 11.7 %), while the number 
of people employed in the circular economy in Estonia is 
above the EU-28 average (2.01 % of total employment in 
2016, against an EU-28 average of 1.73 %). 

In  the  2017  Special  Eurobarometer  468  on  attitudes  of 
EU  citizens  towards  the  environment,  89 %  of  Estonian 
people  said  they  were  concerned  about  the  effects  of 
plastic  products  on  the  environment  (EU-28  average 
87 %).  85 % said they  were  worried about  the impact of 
chemicals  (EU-28  average  90 %)3.  There  appears  to  be 
general  support  for  circular  economy  initiatives  and 
environmental protection actions in Estonian society. 
Estonia’s  resource  productivity4  (how  efficiently  the 
economy uses material resources to produce wealth) has 
slightly  decreased  in  2017,  and  now  stands  at  0.494 
EUR/kg compared to the EU average of 2.04 EUR/kg (see 
Figure  1,  preliminary  estimate).  It  remains  among  the 

1 European Commission, 2018 Circular Economy Package. 
2 COM(2018) 029. 
3 European Commission, 2017, Special 486 Eurobarometer, ‘Attitudes of 
European citizens towards the environment’. 
4 Resource productivity is defined as the ratio between gross domestic 
product (GDP) and domestic material consumption (DMC). 

lowest  in  the EU,  together  with  that  of  Bulgaria  and 
Romania. 

The  Ministry  of  Rural  Affairs,  the  Ministry  of  the 
Environment,  and  the  Ministry  of  Economic  Affairs  and 
Communication are all in principle responsible for setting 
and 
implementing  circular  economy  policies.  This 
fragmented  responsibility  makes  it  harder  to  implement 
comprehensive circular policies. 

During  the  second  half  of  2018,  Estonia  announced  the 
preparation  of  a  circular  economy  action  plan  and 
strategy.  The  action  plan  takes  a  long-term  strategic 
approach, with different actions envisaged for the short- 
and  medium  term,  including  green  public  procurement, 
voluntary instruments and economic measures. 

In  2019,  the  Estonian  government  plans  to  open  the 
proposal  for  consultation.  Adoption  is  planned  for  2020 
at the earliest. 
Figure 1: Resource productivity 2010-20175 

The most recent waste-related policy initiative, Estonia’s 
national  waste  management  plan  for  2014-2020,  has 
already adopted the underlying principles of the circular 
economy. 

In the context of the multiannual financial framework for 
2014-2020, Estonia has decided to invest EUR 111 million 
in more resource-efficient  solutions, mainly in small and 
medium-sized  enterprises  (SMEs)  in  the  manufacturing 
industry.  Funding  went  to  raising  awareness  (events 

5 Eurostat, Resource productivity. 

4 

 
 
 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

started  in  2016),  training  resource  specialists/auditors, 
supporting  resource  audits  and  investing  in  resource-
efficient solutions.  

the  private 

in  a  country  can  give  a 

The number of EU Ecolabel products and EMAS-licensed 
organisations6 
rough 
measurement  of  the  circular  economy  transition.  These 
two  indicators  show  to  what  extent  this  transition  is 
sector  and  other  national 
engaging 
stakeholders.  These  two 
indicators  also  show  the 
commitment of public authorities to policies that support 
the circular economy. As of September 2018, Estonia had 
311  products  and  13  licences  registered  in  the  EU 
Ecolabel  scheme,  out  of  71 707  products  and  2 167 
licences  the  EU.  This  shows  significant  take-up  of  these 
licences7. Moreover, as of May 2018 5 organisations from 
Estonia were registered in EMAS8. 

SMEs and resource efficiency 

Estonian SMEs continue to perform in line with the EU-28 
average on environmental aspects (see Figure 2). There is 
significant  divergence  among  indicators,  however.  The 
percentage  of  SMEs  that  have  taken  up  resource-
efficiency  measures  is  the  lowest  in  the  EU,  despite  the 
fact  that  nearly  50 %  of  Estonia’s  SMEs  benefited  from 
public support measures for such actions. In contrast, the 
proportion of SMEs whose main income is generated by 
green  products  or  services  is  above  the  EU  average. 
However,  the  proportion  of  companies  offering  green 
products and services below the EU average. 

There has been considerable policy action in this area in 
recent  years,  for  example  Green  Industry  Innovation 
Estonia  and  support  grants  for  agricultural,  processing 
and  non-farming  rural  businesses  to  use  renewable 
energy, organic raw materials and eco-friendly processes. 
The 
Centre 
(Keskkonnainvesteeringute Keskuse  — KIK) also  supports 
eco-friendly business. 

Environmental 

Investment 

The  latest  Eurobarometer  on  ‘SMEs,  resource  efficiency 
and green markets’9 asked companies about both recent 
resource-efficiency actions they had taken and additional 
resource-efficiency  actions  they  planned  to  take  in  the 
next  2  years.  The  Eurobarometer  then  compared  these 
responses with responses given to the same questions in 
2015.  50 %  of  Estonian  companies  expressed  the 
intention  to  not  take  any  resource-efficiency  actions  – 

6 EMAS is the European Commission’s Eco-Management and Audit 
Scheme – a programme to encourage organisations to behave in a more 
environmentally sustainable way. 
7 European Commission, Ecolabel Facts and Figures. 
8 European Commission, Eco-Management and Audit Scheme. 
9 Flash Eurobarometer 456 ‘SME, resource efficiency and green 
markets’ January 2018. The 8 dimensions were Save energy; Minimise 
waste; Save materials; Save Water; Recycle by reusing material 
internally; Design products easier to maintain, repair or reuse; Use 
renewable energy; Sell scrap materials to another company. 

5 

this  is  the  3rd  highest  number  in  the  EU  (EU  average 
19 %). There is no significant  increase in ambition in any 
of the eight areas covered by the Eurobarometer. Energy 
(21 % compared to 59 % in EU) and material saving (16 % 
compared to 51 %) are the main areas where companies 
are planning future actions . 
Figure 2: Environmental performance of SMEs10 

Only 4 % of Estonian companies (compared to 22 % in the 
EU on average, Member State range 3 %-38 %) relied on 
external  support  in  their  efforts  to  be  more  resource 
efficient.  Because  of  the  low  number  of  Eurobarometer 
respondents,  however,  it  is  impossible  to  specify  the 
most used types of external assistance, except to say that 
none  of  the  respondents  mentioned  having  relied  on 
external consulting services. 

The  companies  surveyed  regard  grants  and  subsidies  as 
the  most  significant  source  of  support  for  becoming 
resource  efficient 
In  addition,  20-23 %  of 
surveyed  companies  mention  technical  or  financial 
technology  demonstration  or  better 
consultancy, 
cooperation among companies as useful assistance. 

(36 %). 

Estonia is known for its excellent approach to supporting 
ambitious  innovation  among  new  entrepreneurs.  This 
might  explain  the  good  performance  of  companies  that 
generate  more  than  50 %  of  turnover  from  green 
products and services. 

10 European Commission, 2018 SBA fact sheet - Estonia, p. 12.  

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

investing 

it  comes  to 

in  resource 
However,  when 
efficiency,  this  good  performance  does  not  spill  over  to 
SMEs.  They  are  highly  individualistic,  do  not  rely  on 
external assistance and lack motivation to invest in their 
resource efficiency. Awareness raising and pressure from 
peers at local level could motivate them to engage more 
in resource efficiency and the circular economy. 

Eco-innovation 

Estonia  ranked  17th  on  the  2018  European  Innovation 
Scoreboard,  being  the  3rd  worse  innovator  in  terms  of 
performance  evolution  (3.2 %  decrease  since  2010)11. 
Estonia’s  eco-innovation  performance  does  not  fully 
reflect  the  country’s  potential. 
Its  composite  eco-
innovation  score  of  60  lies  40 %  below  the  EU  average 
(see Figure 3). 
Figure 3: 2017 Eco-innovation index (EU=100)12 

Estonia has been performing well below the EU average 
for several years (see Figure 4). 

Resource  efficiency  outcomes  stands  out  as  the  most 
alarming  indicator  of  the  index,  as  Estonia  is  lagging 
behind any other Member State. 

One  significant  initiative  in  this  area  is  Estonia’s  smart 
specialisation  strategy,  which  focuses  specifically  on 
Information  and  Communication  Technologies  (ICT).  It 
could help further diversify the country’s strong industrial 
base,  which  could  potentially  be  a  burden  on  eco-
innovation  and  the  circular  economy,  as  R&D  intensity 

and added value in industries appear to be rather low. 
Figure 4: Estonia’s eco-innovation performance13 

On  the  other  hand,  Estonia’s  strong  start-up  and 
entrepreneurial  culture,  well-functioning  labour  market, 
and  highly  advanced,  digitised  processing  of  public  and 
governmental services support eco-innovation. 

The  country’s  focus  on  and  interest  in  ICT  is  clear  in  its 
cleantech 
shown  considerable 
advances  in  the  development  and  commercialisation  of 
cleantech solutions. 

sector,  which  has 

The  main  driver  behind  Estonia’s  progress  on  eco-
is  foreign  demand,  which  means  that, 
innovation 
is  highly 
ultimately,  Estonia’s  eco-innovation  scene 
dependent  on  foreign  support.  This  creates  a  barrier  to 
entry  for  new  and  small  companies  with  low  project 
management capabilities, and results in a general lack of 
funding  opportunities  for  start-ups  and  established 
companies to engage in eco-innovative solutions. 

In  2016,  the  Estonian  government  put  in  place  several 
measures that support R&D. The most important of these 
are: i) a specific development programme for companies 
with distinctively high growth potential; ii) more tailored 
and  effective  support 
for  public  procurement  of 
innovation;  iii)  a  more  active  engagement  of  financial 
instruments; and iv) an industrial policy green book’14. 

The EIR dialogue held in Estonia in March 2017 included a 
panel discussion on eco-innovation. Participants included 
representatives  of 
the  Commission,  an  Estonian 
designer/software  company  that  upcycles  waste  from 
garment  production  in  Bangladesh/India  to  designer 
clothing,  a  Professor  at  Tallinn  Technological  University, 
and  a  sustainability  specialist  from  Team  Resource 
Jyväskylä, 
Wisdom,  a  municipality-led 
Finland. 

initiative 

in 

Eco-innovation  was  also  one  of  the  priorities  for  the 
Estonian  EU  presidency  in  2017.  Estonia  is  looking  for 
ways to engage young software programmers across the 

11 European Commission, European innovation Scoreboard 2018. 
12 European Commission, The Eco-Innovation Scoreboard and the Eco-
Innovation Index. 

13 European Commission, The Eco-Innovation Scoreboard and the Eco-
Innovation Index. 
14 European Commission, Eco-Innovation Observatory: Eco-innovation 
Country Profiles 2016-2017 

6 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

in  a  coding  competition  (hackathon)  specifically 

EU 
addressing eco-efficiency/circular economy challenges. 

Figure 5: Municipal waste by treatment in Estonia 2010-
201717 

2019 priority action 

  Stregthen  the  policy  framework  to  speed  up  the 
transition  towards  the  circular  economy  by  all 
economic sectors. 

Waste management 

Turning waste into a resource is supported by: 
(i)  fully 
legislation,  which 
implementing  EU  waste 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets, etc.; 
(ii) reducing waste generation and waste generation per 
capita in absolute terms; and  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  the  management  of  municipal 
waste  for  which  EU 
law  sets  mandatory  recycling 
targets.15. 

As  shown  in  Figure  5,  the  amount  of  municipal  waste 
generated  in  Estonia  kept  increasing  from  280  kg  per 
capita  in  2012  and  amounted  to  390  kg  per  capita  in 
201716.  It  remained  below  the  EU  average  of  487  kg, 
however.  In  addition,  Estonia  uses  an  index  to  measure 
the growth rate of municipal waste per capita in relation 
with  the  growth  rate  of  the  Gross  Domestic  Product 
(GDP)  where  the  trend  was  more  positive,  as  waste 
generation grows slower than GDP. 

Figure 5 shows Estonia’s municipal waste by treatment in 
terms of kg per capita, revealing a shift from landfilling to 
incineration.  Strong  conclusions  on  trends 
in  waste 
treatment methods in Estonia are difficult to make due to 
adjustments  made  to  waste  data 
for  2010-2015. 
However,  it  is  clear  that  Estonia  made  progress  in 
reducing  landfilling  of  municipal  waste,  which  was  at 
19 %  in  2017,  below  the  EU  average  of  around  24 %. 
Most  of  this  waste  was  however  shifted  towards 
incineration,  which 
is  now  the  predominant  waste 
treatment method in Estonia (42 % in 2017).  

15 See Article 11.2 of Directive 2008/98/EC. This Directive was amended 
in 2018 by Directive (EU) 2018/851, and more ambitious recycling 
targets were introduced for the period up to 2035. 
16 This important increase as compared to previous years results from a 
correction of data to also include the relevant fraction of packaging 
waste. 

7 

As shown in Figure 6, Estonia’s municipal waste recycling 
rate is at 28 %, below the EU average of 46 %. This is well 
below the 50 % recycling target set for 202018. 
Figure 6: Recycling rate of municipal waste, 2010-201719 

Therefore, in its Early Warning Report’20 the Commission 
considered that Estonia is at risk of non-compliance with 

17 Eurostat, Municipal waste by waste operations. 
18 Member States may choose a different method than the one used by 
ESTAT (and referred to in this report) to calculate their recycling rates 
and track compliance with the 2020 target of 50% recycling of municipal 
waste. 
19 Eurostat, Recycling rate of municipal waste. 
20 European Commission, Report on the implementation of waste 
legislation, including the early warning report for Member States at risk 
of missing the 2020 preparation for re-use/recycling target on municipal 
waste, SWD(2018)416 accompanying COM(2018)656. 

 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

in  the  country, 

for  municipalities 

the  2020  municipal  waste  recycling  target  of  50 %. 
Furthermore,  it  stated  that  Estonia  will  need  to  make 
even  more  efforts  to  comply  with  the  recycling  targets 
set  for  the  post-2020  period21.  The  report  identified  the 
structural problems leading to slow progress in recycling. 
This  refers  to  a  number  of  regulatory  barriers  that  are 
causing  uncertainty 
including  the 
possibility 
to  choose  between 
tendering for the market and competition in the market, 
which  has  also  slowed  down  investment  in  the  sector. 
Separate collection is not yet efficient, with lack of focus 
on door-to-door services and generous derogations from 
the  obligation  to  organise  food  waste  collection,  which 
may  be 
limiting  the  system’s  overall  performance. 
Extended  producer  responsibility  schemes  for  packaging 
are  not  integrated  in  municipal  collection  services.  The 
incentives  for  households  to  separate  waste  are  not 
sufficient,  with  waste  fees  being  too  low.  There  are  no 
effective  instruments  to  force  municipalities  to  comply 
with  the  recycling  targets.  Moreover,  there 
is  no 
incineration  tax  to  shift  waste  management  towards 
recycling. 

There  have  been  some  positive  developments  since  the 
2017 EIR and these are likely to improve the situation in 
Estonia.  They  include  an  administrative  reform  reducing 
the  number  of  municipalities  which  could  bring  more 
coordination and more efficiency in delivering services. In 
addition,  mandatory  audits  of  producers  placing 
packaging  on  the  market  have  already  led  to  positive 
corrections of the data on packaging put on the market. 
This  translates  into  higher  financial  contributions  to  the 
system  and  puts  more  pressure  on  producers  to  meet 
their packaging recycling targets. 

The  EIR  dialogue  held  in  March  2017  addressed  waste 
issues.  Estonia 
further  reducing 
incineration  and  increasing  recycling,  and  to  working  on 
all areas that were identified as needing improvement. 

is  committed 

to 

2019 priority actions 

 

 

instruments, 

including 
Introduce  new  policy 
economic ones, to promote waste prevention, make 
reuse  and  recycling  more  economically  attractive 
and  shift  reusable  and  recyclable  waste  away  from 
incineration and landfilling. 
Set  mandatory  targets  for  recycling  and  generation 
of  residual  waste  at  the  municipal 
level,  with 
financial  penalties  for  non-compliance.  Develop  and 
run 
for 
municipalities  to  help  support  their  efforts  to 

support  programmes 

implementation 

21 Directive (EU) 2018/851, Directive (EU) 2018/852, Directive (EU) 
2018/850 and Directive (EU) 2018/849 amend the previous waste 
legislation and set more ambitious recycling targets for the period up to 
2035. These targets will be taken into consideration to assess progress 
in future Environmental Implementation Reports. 

8 

 

 

 

organise  separate  collection  and  improve  recycling 
performance. 
Improve  and  extend  separate  collection  of  waste, 
including  for  bio-waste.  Establish  minimum  service 
standards  for  separate  collection  (e.g.  frequency  of 
collections, types of containers etc.) in municipalities 
to ensure high capture rates of recyclable waste, and 
put  in  place  civic  amenity  sites.  Use  economic 
instruments such as pay-as-you-throw. 
Shift  reusable  and  recyclable  waste  away  from 
incineration. 
Improve  the  functioning  of  extended  producer 
line  with  the  general 
in 
responsibility  systems, 
minimum  requirements  on  extended  producer 
responsibility22. 

Climate change 

The EU has committed to undertaking ambitious climate 
action internationally as well as in the EU, having ratified 
the Paris Climate Agreement on 5 October 2016. The EU 
targets are to reduce greenhouse gas (GHG) emissions by 
20 % by 2020 and by at least 40 % by 2030, compared to 
1990.  As  a  long-term  target,  the  EU  aims  to  reduce  its 
emissions  by  80-95 %  by  2050,  as  part  of  the  efforts 
required by developed countries as a group. Adapting to 
the adverse effects of climate change is vital to alleviate 
its  already  visible  effects  and  improve  preparedness  for 
and resilience to future impacts. 

The EU emissions trading system (EU ETS) covers all large 
greenhouse  gas  emitters  in  the  industry,  power  and 
aviation  sectors  in  the  EU.  The  EU  ETS  applies  in  all 
Member States and has a very high compliance rate. Each 
year,  installations  cover  around  99 %  of  their  emissions 
with the required number of allowances.  

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  the  effort  sharing 
legislation.  Estonia’s  emissions  were  below  its  annual 
emission  allocations  (AEAs)  in  each  of  the  years  2013-
2016. According to preliminary data, emissions exceeded 
the  AEA  for  2017  by  1  percentage  point.  For  2020, 
Estonia’s  national  target  under  the  EU  Effort  Sharing 
Decision  is  to  avoid  increasing  emissions  by  more  than 
11 %  compared  to  2005.  For  2030,  its  national  target 
under  the  Effort  Sharing  Regulation 
is  to  reduce 
emissions by 13 % compared to 2005. 

The  Estonian  low-carbon  strategy,  ‘General  Principles  of 
Estonian Climate Policy until 2050 (Climate Policy 2050)’ 
was  adopted  by  the  Parliament  in  April  2017.  The 
strategy  presents  a  long-term  vision  of  Estonia’s  climate 
policy and actions to be implemented by 2050. According 
to the guidelines, Estonia will aim to create a competitive 

22 Directive (EU) 2018/851. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

Figure 8: Targets and emissions under the Effort Sharing 
Decision and Effort Sharing Regulation 24 

in 

reduce  greenhouse  gas 
low-carbon  economy  and 
emissions 
industry, 
transportation, 
the  energy, 
agriculture,  forestry  and  waste  management  sectors  by 
at  least  80 %  by  2050,  compared  to  1990  levels.  This 
would mean a reduction of Estonia’s current greenhouse 
gas emissions to the level of 8 million tonnes of CO2eq by 
2050 (MoE, 2016). Estonia also has interim goals for 2030 
(reduction  by  70 %  compared  to  1990  levels)  and  for 
2040  (reduction  by  72 %  compared  to  1990  levels).  The 
strategy’s  targets  and  guidelines  will  be  implemented 
with the help of sector-specific developments plans. 

Figure  7:  Change  in  total  GHG  emissions  1990-2017 
(1990=100 %)23.  

The  accounting  of  GHG  emissions  and  removals  from 
forests and agriculture is governed by the Kyoto Protocol. 
For  the  land  use  sector,  Estonia’s  reported  quantities 
under  the  Kyoto  Protocol  show  net  removals  of  on 
average  -3.6  Mt  CO2-eq  for  2013-2016.  This  means  that 
Estonia contributes with 0.9 % to the annual average sink 
of  -384.4  Mt  CO2-eq  in  the  EU-28.  Accounting  for  this 
period  shows  net  credits  of  on  average  -0.8  Mt  CO2-eq, 
which corresponds to 0.7 % of the EU-28 accounted sink 
of  -115.7  Mt  CO2-eq.  Reported  net  removals  and 
accounted net credits show a continuous increase. 

The  EU  Strategy  on  adaptation  to  climate  change, 
adopted  in  2013,  aims  to  make  Europe  more  climate-
resilient, by promoting action by Member States, better-
informed  decision  making,  and  promoting  adaptation  in 
key vulnerable sectors. By adopting a coherent approach 
and  providing  for  improved  coordination,  it  seeks  to 
enhance the preparedness and capacity of all governance 
levels to respond to the impacts of climate change.  

The  Estonian  national  strategy  on  climate  change 
adaptation  was  adopted  in  2017.  It  calls  for  eight  sub-
goals  in  the  following  priority  areas:  human  health  and 
rescue  preparedness,  land  use  and  spatial  planning, 
natural  environment,  bio-economy,  economy,  society, 
infrastructure  and  buildings,  and  energy  and  energy 
supply  systems.  The  action  plan  to 
implement  the 
adaptation  strategy  was  developed  in  parallel  with  the 
strategy  itself  and  supports  its  goals  and  sub-goals. 
Sectoral  mainstreaming 
is  monitored  and  reported 
annually  through  a  centralised  National  Adaptation 

24 European Environmental Agency, Annual European Union greenhouse 
gas inventory 1990–2016. Proxy GHG emission estimates for 2017, 
Member States national projections. 

Starting from 2019 and at least once every four years, the 
government  will  present  the  Estonian  parliament, 
Riigikogu, with a report considering the main principles of 
climate policy in the preparation and implementation of 
cross-sectoral  and  sectoral  strategies  (NECP  Survey, 
2017). 

(fluorinated  greenhouse  gases), 
Regarding  F-gases 
Member  States  had  to  put 
in  place  training  and 
certification  programmes  and  rules  for  penalties  and 
notify  the  Commission  of  them  by  2017.  Estonia  has 
notified both measures. 

23 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 

9 

 
 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

(NAS)  /  National  Adaptation  Plan  report 
Strategy 
published  by  the  Ministry  of Environment.  Furthermore, 
the Ministry of Environment presents an overview of the 
execution of the NAS to the government once a year. 

Figure  9:  GHG  emissions  by  sector  (Mt.  CO2-eq.) 
(historical data 1990-2016; projections 2017-2030)25.  

from 

revenues 

Total 
the  auctioning  of  emission 
allowances  under  the  EU  ETS  over  2013-2017  were 
EUR 110 million in Estonia. National legislation states that 
50 %  of  the  revenues  must  be  used  for  energy  and 
climate  purposes.  47 %  of  the  auctioning  revenues  have 
so far been spent, or are planned to be spent, on climate 
and energy purposes. 

A  good  practice,  taking  place  in  Tallinn,  is  the  ‘fix  the 
façade’ programmes to combat climate change26. 

2019 priority action 

In this report, no priority actions have been included on 
climate action, as the Commission will first need to assess 
the  draft  national  energy  and  climate  plans  which  the 
Member  States  had  to  send  by  the  end  of  2018.  These 
plans  should  increase  the  consistency  between  energy 
and climate policies and could therefore become a good 
example  of  how  to  link  sector-specific  policies  on  other 
interlinked themes  such as agriculture-nature-water and 
transport-air-health.  

25 Annual European Union greenhouse gas inventory 1990–2016 (EEA 
greenhouse gas data viewer). Proxy GHG emission estimates for 
2017Approximated EU greenhouse gas inventory 2017 (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 
26 European Commission, Good Practice Report, European Green Capital 
2018, p.64. 

10 

 
 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

2. Protecting, conserving and enhancing natural capital 

About  25 %  of  forests  located  on  Estonia’s  Natura  2000 
sites  are  on  privately  owned  land.  A  recent  study28 
concluded that the connectivity of forest protected areas 
should be improved. 

Progress 
restoring 
in  maintaining  or 
conservation status of species and habitats 

favourable 

The 2017 EIR was based on the latest (2012) report from 
Member  States  on  the  conservation  status  of  habitats 
and  species.  New  data  will  be  available  for  the  next  EIR 
reporting cycle. 

2019 priority actions 

 

 

for 

the 

and 

objectives 

Complete  the  designation  process  for  special  areas 
of  conservation  and  put  in  place  clearly  defined 
conservation 
necessary 
the  sites.  Provide 
conservation  measures 
adequate  resources  for  their  implementation 
in 
order  to  maintain/restore  species  and  habitats  of 
community  interest  to  a  good  conservation  status 
across their natural range. 
Ensure  that  Natura  2000  management  plans  are 
being effectively implemented. 

  Develop and promote smart and streamlined ways of 
implementation,  in  particular  as  regards  site  and 
species  permitting  procedures,  ensuring  necessary 
knowledge  and  data  availability  and 
improving 
communication with stakeholders. 

Nature and biodiversity 

The  EU  biodiversity  strategy  aims  to  halt  the  loss  of 
biodiversity  in  the  EU  by  2020.  It  requires  the  full 
implementation  of  the  Birds  and  Habitats  Directives  to 
achieve  favourable  conservation  status  of  protected 
species and habitats. It also requires that the agricultural 
and  forest  sectors  help  to  maintain  and 
improve 
biodiversity. 

Biodiversity strategy 

The  Estonian  government  approved 
the  national 
biodiversity  strategy  and  action  plan  (NBSAP)  in  2012, 
with a timeline extending until 2020. 

Setting up a coherent network of Natura 2000 sites 

By  late  2017,  17.9 %  of  Estonia’s  national  territory  was 
covered  by  Natura  2000  sites  (EU  average  18.2 %),  with 
Birds  Directive  Special  protection  Areas  (SPAs)  covering 
13.7 %  (EU  average  12.4 %)  and  Habitats  Directive  Sites 
of  Community  Importance  (SCIs)  covering  17.3 %  (EU 
average 13.9 %)27. 

Altogether,  there  are  567 Natura  2000  sites  in  Estonia. 
The latest assessment of the Natura 2000 network shows 
that  the  SCI  part  of  Estonia’s  Natura  2000  network  is 
almost complete in the Marine Baltic region and close to 
being complete in the Boreal region. 

Designating Natura 2000 sites and setting conservation 
objectives and measures 

Estonia  has  designated  most  of  its  Natura  2000  sites  as 
special  areas  of  conservation.  348  of  them  have 
management  plans  in  place;  representing  86.3 %  of  the 
total  number  of  Estonian  sites.  Action  plans  for  semi-
natural  habitats,  protected  marshes  and  a  number  of 
threatened species have also been established.  

Estonia’s number of nature-related complaints to the EU 
is  low  compared  to  that  of  many  other  countries. 
Complaints  are  mainly  linked  to  public  participation  and 
assessment  of  infrastructure  projects.  Estonian  NGOs 
often  manage  to  handle  the  complaints  at  national  or 
local level. 

frameworks 

Estonia  has  provided  one  of  the  most  complete 
It  was 
prioritised  action 
successfully used to ensure funding for Natura 2000 sites 
from various EU funds e.g. rural development plan (RDP) 
and  the  Cohesion  Fund.  Estonia  has  also  been  active  in 
applying for LIFE funding to manage its Natura 2000 sites. 

in  the  EU. 

27 EEA, Natura 2000 Barometer. 

28 Institute of Ecology and Earth Sciences, University of Tartu, 
Alategevuse LOORA teadusaruanne.  

11 

 
                                                                 
 
 
 
 
 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

Maintaining  and  restoring  ecosystems  and 
their services 

The EU biodiversity strategy aims to maintain and restore 
including  green 
ecosystems  and  their  services  by 
infrastructure  in  spatial  planning  and  restoring  at  least 
15 %  of  degraded  ecosystems  by  2020.  The  EU  green 
infrastructure  strategy  promotes  the  incorporation  of 
green infrastructure into related plans and programmes. 

The EU has provided guidance on the further deployment 
of  green  and  blue  infrastructure  in  Estonia29  and  a 
country page on the Biodiversity Information System for 
Europe  (BISE)30.  This  information  will  also  contribute  to 
the  final  evaluation  of  the  EU  Biodiversity  Strategy  to 
2020. 

Estonia  views  spatial  planning  as  the  appropriate 
mechanism through which to create ecological networks. 
Green  infrastructure  is  developed  through  the  Estonian 
Green  Network,  based  on  a  national  spatial  plan  and 
county-level  thematic  spatial  plans.  The  Green  Network 
was  set  up  in  2000  and  covers  about  half  of  Estonia’s 
territory. 

there 

While the principle of the ecosystem approach has been 
into  all  major  national  programmes, 
introduced 
strategies  and  development  plans, 
is  no 
methodology  for  how  it  should  be  implemented  in 
practice.  Furthermore,  the  implementation  of  county 
plans  remains  a  challenge.  In  larger  cities,  especially 
Tallinn, the area, cohesion and biodiversity of the Green 
Network  is  decreasing  and  the  pressure  on  protected 
areas  is  growing.  There  is  therefore  room  to  improve 
Tallin’s  Green  Network.  The  Estonia  2030+  national 
spatial  plan31  envisages  national  guidelines  that  would 
improve  the  quality  of  space  while  taking  into  account 
public interest. 

Several  LIFE  projects  that  include  green  infrastructure 
elements  are  ongoing.  They  relate  to  the  conservation 
and 
restoration  of  Mire  habitats,  Estonian  alvar 
grasslands,  and  petrifying  spring  habitats.  EU  funds  are 
the  main  source  of  funding  for  green  infrastructure  in 
Estonia. 

29 The recommendations of the green infrastructure strategy review 
report and the EU Guidance on a strategic framework for further 
supporting the deployment of EU-level green and blue infrastructure. 
30 Biodiversity Information System for Europe. 
31 Regionaalministri Valitsemisala, Estonia 2030+ national spatial plan. 

12 

Estimating natural capital 

The  EU  biodiversity  strategy  calls  on  Member  States  to 
map  and  assess  the  state  of  ecosystems  and  their 
services 32 in their national territories by 2014, assess the 
economic  value  of  such  services  and  integrate  these 
values  into  accounting  and  reporting  systems  at  EU  and 
national level by 2020. 

The mapping of Estonian ecosystem services was started 
in 2017 and will be finalised  in early 2019. National and 
local spatial planners and the environmental assessment 
integrate  the 
community  are  working  in  groups  to 
mapping  and  assessment  of  ecosystem  services  into 
decision-making tools at national and local level by 2020. 
The  project  is  managed  by  the  Estonian  Environment 
Agency. 

Methods  that  help  assess  and  map  the  ecosystem 
services of  marine and inland waters  were developed in 
201633. 

At  the  MAES  (mapping  and  assessment  of  ecosystems 
and  their  services)  working  group  meeting  held 
in 
Brussels  in  September  2018,  it  was  shown  that  Estonia 
has  made  some  progress  in  implementing  MAES.  It  was 
noted that progress has been communicated through the 
BISE 
for  Europe) 
platform  (Figure  9).  However,  last  updates  from  Estonia 
were  received  in  September  2016,  making  the  progress 
insufficient.  This  assessment  was  made  by 
the 
ESMERALDA  project34  and  based  on  27  implementation 
questions. The assessment is updated every 6 months. 

Inforamtion  System 

(Biodiversity 

Figure 10: Implementation of MAES (September 2018) 

Estonia  has  not  yet  set  up  a  business  and  biodiversity 
platform3536,  a  key  tool  for  promoting  and  facilitating 
natural capital assessments among business and financial 
service  providers.  Such  a  platform  would  help  Estonia 

32 Ecosystem services are benefits provided by nature such as food, 
clean water and pollination on which human society depends. 
33 BISE, Estonia. 
34 Esmeralda Project. 
35 Natural Capital Coalition, Natural Capital Protocol 
36 Business and Biodiversity, The European Business and Biodiversity 
Campaign aims to promote the business case for biodiversity in the EU 
Member States through workshops, seminars and a cross media 
communication strategy. 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

achieve the goals of the EU biodiversity strategy. 

2019 priority action 

 

Strengthen support for the mapping and assessment 
of ecosystems and their services, and valuation work 
and develop natural capital accounting systems. 

Invasive alien species 

Under the EU biodiversity strategy, the following are to 
be achieved by 2020:  
(i) invasive alien species are identified; 
(ii) priority species controlled or eradicated; and 
(iii) pathways managed to prevent new invasive species 
from disrupting European biodiversity.  
This is supported by the Invasive Alient Species 
Regulation, which entered into force on 1 January 2015. 

The  report  on  the  baseline  distribution  (Figure  10),  for 
which  Estonia  could  only  review  its  country-level  data 
(there was a delay in reviewing the grid level data due to 
format incompatibilities), shows that of the 37 species on 
the first EU list, seven have been observed in Estonia. Of 
these,  four  are  established:  Persian  and  sosnowsky’s 
hogweed  (Heracleum  persicum  and  sosnowskyi),  signal 
crayfish  (Pacifastacus 
leniusculus)  and  amur  sleeper 
(Perccottus  glenii).  Sosnowsky’s  hogweed  seems  to  be 
the most widespread. 

Figure  11:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Estonia37 

Between  the  entry  into  force  of  the  EU  list  and  18 May 
2018,  Estonia  has  submitted  one  early  detection 
notification  to  the  Commission,  for  spiny-cheek  crayfish 

37 Tsiamis K; Gervasini E; Deriu I; D`amico F; Nunes A; Addamo A; De 
Jesus Cardoso A. Baseline Distribution of Invasive Alien Species of Union 
concern. Ispra (Italy): Publications Office of the European Union; 2017, 
EUR 28596 EN, doi:10.2760/772692. 

13 

(Orconectes  limosus).  Estonia  subsequently  notified  its 
decision not to apply eradication measures. Based on the 
evidence  provided  by  Estonia,  the  Commission  did  not 
reject this decision. 

With  regard  to  the  IAS  Regulation,  Estonia  has  notified 
the Commission of its competent authorities responsible 
for  implementation,  as  well  as  of  its  national  provisions 
on penalties applicable to infringements. It has therefore 
fulfilled its notification obligations. 

Soil protection 

The  EU  soil  thematic  strategy  underlines  the  need  to 
ensure a  sustainable use of soils.  This  entails preventing 
further  soil  degradation  and  preserving  its  functions,  as 
well as restoring degraded soils. The 2011 Roadmap to a 
Resource Efficient Europe states that by 2020, EU policies 
must  take  into  account  their  direct  and  indirect  impact 
on land use. 

Soil  is  an  extremely  fragile  finite  resource  and  it  is 
increasingly degrading in the EU. 

Estonia  ranks  below  the  EU  average  as  regards  artificial 
land  (EU-28 
land  coverage,  with  1.9 %  of  artificial 
average: 4.1 %). Its population density is 30.3/km2, which 
is below the EU average of 11838. 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  A  recent 
report  of  the  European  Commission39  estimated  that 
potentially  polluting  activities  have  taken  or  are  still 
taking place on approximately 2.8 million sites in the EU. 
At EU level,  650 000 of these sites have been registered 
in national or regional inventories. 65 500  contaminated 
sites  have  already  been  remediated.  Estonia  has 
registered 300 sites where potentially polluting activities 
have  taken  or  are  taking  place,  and  has  already 
remediated or applied aftercare measures on 110 sites.  

Soil erosion by water is a natural process, but this natural 
process can be aggravated by climate change and human 
activities  such  as  inappropriate  agricultural  practices, 
deforestation,  forest  fires  or  construction  works.  High 
levels  of  soil  erosion  can  reduce  productivity 
in 
agriculture  and  can  have  negative  and  transboundary 
impacts  on  biodiversity  and  ecosystem  service.  High 
levels  of  soil  erosion  can  also  have  negative  and 
lakes  (due  to 
transboundary  effects  on  rivers  and 
increased 
transport  of 
and 
volumes 
contaminants).  According  to  the  RUSLE2015  model40, 

sediment 

38 Eurostat, Population density by NUTS 3 region. 
39 Ana Paya Perez, Natalia Rodriguez Eugenio Status of local soil 
contamination in Europe: Revision of the indicator “Progress in the 
management Contaminated Sites in Europe”,2018). 
40 Panagos, P., Borrelli, P., Poesen, J., Ballabio, C., Lugato, E., 
Meusburger, K., Montanarella, L., Alewell, C., The new assessment of 

 
                                                                 
                                                                 
 
Environmental Implementation Review 2019 – Estonia 

Estonia  has  an  average  soil  loss  rate  by  water  of  0.21 
tonnes per hectare per year (t ha−a yr−y), compared to the 
EU  mean  of  2.46    t ha−a yr−y.  This  indicates  that  soil 
erosion in Estonia is low on average. 
Figure 12: Proportion of artificial land cover, 2015 41 

must develop a marine strategy for their marine waters, 
and cooperate with the EU countries that share the same 
marine  (sub)region.  In  Estonia’s  case,  the  Baltic  Marine 
Environment 
(Helsinki 
Protection 
Commission) plays an important role here.  

Commission 

The  marine  strategies  comprise  different  steps  to  be 
developed  and  implemented  over  six-year  cycles.  The 
latest  step  required  Member  States  to  develop  their 
programme of measures and report it to the Commission 
by 31 March 2016. 

The  Commission  could  not  assess  whether  the  Estonian 
measures were appropriate to reach GES because Estonia 
reported  its  measures  too  late  for  the  Commission  to 
include them in the assessment exercise 43. 

2019 priority action 

 

Ensure  timely  reporting  on  the  various  elements 
under  the  Marine  Strategy  Framework  Directive  so 
that  Estonia  can  be  part  of  future  Commission 
assessments. 

These  figures  are  the  output  of  an  EU  level  model  and 
can  therefore  not  be  considered  as  locally  measured 
values.  The  actual  rate  of  soil  loss  can  vary  strongly 
within a Member State depending on local conditions.Soil 
organic  matter  plays  an  important  role  in  the  carbon 
cycle and in climate change. Soils are the second largest 
carbon sink in the world after the oceans. 

Marine protection 

The EU coastal and marine policy and legislation require 
that  by  2020  the  impact  of  pressures  on  marine  waters 
be  reduced  to  achieve  or  maintain  good  environmental 
status  and  ensure  that  coastal  zones  are  managed 
sustainably. 

The Marine Strategy Framework Directive (MSFD)42 aims 
to  achieve  Good  environmental  status  (GES)  of  the  EU’s 
marine  waters  by  2020.  To  that  end,  Member  States 

soil loss by water erosion in Europe, (2015) Environmental Science and 
Policy, 54, pp. 438-447. 
41 Eurostat, Land covered by artificial surfaces by NUTS 2 regions. 
42 Directive 2008/56/EC. 

43 Estonia reported its programme of measures to the Commission on 
24 April 2017 whereas the due date was 31 March 2016. 

14 

 
                                                                                                        
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

3. Ensuring citizens' health and quality of life 

Air quality 

EU clean air policy and legislation require the significant 
improvement  of  air  quality  in  the  EU,  moving  the  EU 
closer to the quality recommended by the World Health 
Organisation.  Air  pollution  and  its  impacts  on  human 
health,  ecosystems  and  biodiversity  should  be  further 
reduced with the long-term aim of not exceeding critical 
loads  and  levels.  This  requires  strengthening  efforts  to 
reach full compliance with EU air quality legislation and 
defining strategic targets and actions beyond 2020. 

The  EU  has  developed  a  comprehensive  body  of  air 
legislation44,  which  establishes  health-based 
quality 
standards  and  objectives 
for  a  number  of  air 
pollutants.However, according to the European Court of 
Auditors  (ECA)45,  EU  action  to  protect  human  health 
from air pollution has not delivered its expected impact. 

The  emissions  of  several  air  pollutants  have  decreased 
in  Estonia46.  The  emission  reductions 
significantly 
between 1990 and 2014 mentioned in the previous EIR 
continued  between  2014  and  2016.  Emissions  of 
sulphur  oxides  (SOx)  fell  by  26.9 %,  emissions  of 
ammonia  (NH3)  fell  by  1.24 %,  emissions  of  volatile 
organic compounds (NMVOCs) fell by 2.98 %, emissions 
of  fine  particulate  matter  (PM2.5)  fell  by  5.67 %  and 
emissions  of  nitrogen  oxides  (NOx)  fell  by  10.16 %  (see 
also Figure 13 on the total PM2.5 and NOx emissions per 
sector). 

Air  quality  in  Estonia  is  reported  to  be  generally  good, 
with  exceptions.  Despite  the  reduction  in  emissions, 
Estonia  needs  to  make  additional  efforts  to  meet  its 
emission reduction commitments (compared with 2005 
levels)  set  by  the  new  National  Emissions  Ceilings 
Directive 47 for 2020 -2029 and for any year from 2030. 

For  2017,  Estonia  did  not  report  any  values  that 
standards48.  However, 
exceeded  EU  air  quality 
the European  Environment  Agency49  estimated  that  in 
than  560  premature  deaths  were 
2015  more 
attributable to air pollution. 

44 European Commission, Air Quality Standards, 2016. 
45 European Court of Auditors, Special report no 23/2018: Air 
pollution: Our health still insufficiently protected. 
46 See EIONET Central Data Repository and Air pollutant emissions 
data viewer (NEC Directive) 
47 Directive 2016/2284/EU 
48 EEA, EIONET Central Data Repository. . 
49 EEA, Air Quality in Europe – 2018 Report, p.64. Please see details in 
this report as regards the underpinning methodology. 

Figure  13:  PM2.5  and  NOx  emissions  by  sector  in 
Estonia50 

See  also  Figure  13  on  the  number  of  air  quality  zones 
that exceed limit values of NO2, PM2.5, and PM10. 

Figure  14:  Air  quality  zones  exceeding  EU  air  quality 
standards in 201751  

In a TAIEX-EIR P2P workshop held in Bratislava, Slovakia 
on  2–3 July  2018,  experts  from  Slovakia,  Hungary, 
Czechia,  Estonia,  Latvia,  Lithuania,  Germany,  Belgium, 
Poland,  Ireland,  the  United  Kingdom,  Denmark  and 
Bulgaria  exchanged  knowledge  and  experience  on 
effective  measures  and  good  practices  related  to 
reducing emissions from domestic heating. 

A  TAIEX-EIR  P2P  workshop  held  in  Graz,  Austria  on  10-
11  September  2018  brought  together  environmental 
authorities,  regions  and  cities  from  Austria,  Croatia, 

50 2016 NECD data submitted by Member State to the EEA. 
51 EEA, EIONET Central Data Repository. Data reflects the reporting 
situation as of 26 November 2018. 

15 

 
 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

Estonia,  Germany,  Hungary,  Italy,  Lithuania,  Poland, 
Romania, the Slovak Republic, Spain and Sweden. They 
exchanged  experiences  and  good  practice  on  reducing 
air pollution. They also discussed the effectiveness of air 
quality  plans  in  zones  or  agglomerations  where  the 
levels of pollutants in ambient air exceed limit or target 
values. 

2019 priority action 

 

Take  action,  in  the  context  of  the  forthcoming 
national  air  pollution  control  programme  (NAPCP), 
to  reduce  the  main  emission  sources,  including 
through the tax system. 

Industrial emissions 

The main objectives of EU policy on industrial emissions 
are to:  
(i) protect air, water and soil;  
(ii) prevent and manage waste; 
(iii) improve energy and resource efficiency; and  
(iv) clean up contaminated sites.  
To achieve this, the EU takes an integrated approach to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial Emissions Directive52 (IED). 

The below overview of industrial activities regulated by 
the  IED  is  based  on  the  ‘industrial  emissions  policy 
country profiles’ project 53. 

In Estonia, around 135 industrial installations must have 
a  permit  according  to  the  IED.  In  2015,  the  industrial 
sectors  in  Estonia  with  the  most  IED  installations  were 
‘other activities’ (55 % of total - mainly intensive rearing 
of  poultry  or  pigs),  energy-power  and  waste 
management (see Figure 14). 

The energy-power sector was identified as contributing 
the  most  emissions  to  air  in  Estonia,  with  pollutants 
including  sulphur  oxides  (SOx),  nitrogen  oxides  (NOx), 
particulate matter (PM2.5) and heavy metals. The ‘other 
activities’  sector  (mainly  intensive  rearing  of  poultry  or 
pigs)  significantly  contributes  to  emissions  of  non-
methane  volatile  organic  compounds  (NMVOCs)  and 
ammonia (NH3). The breakdown is shown in Figure 15. 

52 Directive 2010/75/EU covers industrial activities carried out above 
certain thresholds. It covers energy industry, metal production, 
mineral and chemical industry and waste management, as well as a 
wide range of industrial and agricultural sectors (e.g. intensive rearing 
of pig and poultry, pulp and paper production, painting and cleaning). 
53 European Commission, Industrial emissions policy country profile – 
Estonia. 

16 

Figure  15:  Number  of  IED  industrial  installations  by 
sector, Estonia (2015)54 

The 
‘other  activities’  and  energy-power  sectors 
contributed  the  most  emissions  to  water.  The  energy-
power,  intensive  rearing  of  poultry  or  pigs  and  waste 
management sectors were identified as contributing the 
most to waste generation. 

Figure  16:  Emissions  to  air  from  IED  sectors  and  all 
other national total air emissions, Estonia (2015) 

The enforcement approach under the IED creates strong 
rights for citizens to have access to relevant information 
and  to  participate  in  the  permitting  process  for  IED 
installations.  This  empowers  NGOs  and  the  general 
public to ensure that permits are appropriately granted 
and their conditions respected. 

Best  available  techniques  (BAT)  reference  documents 
and  BAT  conclusions  are  developed  through  the 
exchange  of 
information  between  Member  States, 
industrial associations, NGOs and the Commission. This 
ensures  a  good  collaboration  with  stakeholders  and  a 
better application of the IED’s rules. 

Thanks to the national competent authorities’ efforts to 
apply the legally binding BAT conclusions and associated 

54 European Commission, Industrial emissions policy country profile – 
Estonia. 

 
 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

BAT emission levels in environmental permits, pollution 
has decreased considerably and continuously in the EU. 

For  example,  by  applying  the  recently  adopted  BAT 
emission  levels  for  large  combustion  plants,  emissions 
of  sulphur  dioxide  will  be  cut  on  average  by  between 
25 %  and  81 %,  nitrogen  oxide  by  between  8 %  and 
56 %,  dust  by  between  31 %  and  78 %  and  mercury  by 
between 19 % and 71 %. 

2019 priority actions 

  Review permits to ensure that they comply with the 

 

newly adopted BAT conclusions. 
Strengthen  control  and  enforcement  to  ensure 
compliance with the BAT conclusions. 

  Address  water  and  air  pollution  from  the  power 
sector and intensive rearing of poultry or pigs.  

Noise 

The  Environmental  Noise  Directive  provides  for  a 
common approach to avoiding, preventing and reducing 
the harmful effects of exposure to environmental noise. 

Excessive noise from aircrafts, railways and roads is one 
of the main causes of health problems in the EU 55. 

Based  on  a  limited  set  of  data  calculated  by  the 
European Environment Agency in 201756, environmental 
noise causes at least 100 premature deaths per year in 
Estonia  and  is  responsible  for  around  300  hospital 
admissions.  Noise  also  disturbs  the  sleep  of  roughly 
1 200  people  in  Estonia.  The  noise  mapping  for  the 
is 
previous  reporting  round  (reference  year  2011) 
complete, as are the action plans (reference year 2013). 

is  traffic,  which 

Tallinn’s  main  source  of  noise 
is 
significant due to the high  commuting levels caused by 
urban  sprawl.  Tallinn  monitors  compliance  with 
environmental  noise  requirements  when  planning  new 
noise-sensitive  projects;  it  is  mandatory  to  carry  out  a 
noise  survey  during  the  planning  stage  for  new  sites 
that  could  potentially  cause  a  noise  disturbance.  Noise 
maps and noise reduction action plans are available on 
Tallinn’s  website.  Tallinn  displays  real-time  noise  levels 
on noise boards. 

The  noise  reduction  action  plan  prepared  for  Tallinn  in 
2013 defined quiet areas. Quiet areas have been divided 
into  two  categories  based  on  noise  level:  quiet  areas 
(noise level Lday ≤ 55 dB) and critical quiet areas (noise 
level  Lday  ≥  55  dB).  In  the  last  10  years,  Tallinn  has 

55 WHO/JRC, Burden of disease from environmental noise, Fritschi, L., 
Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), World 
Health Organization, Regional Office for Europe, Copenhagen, 
Denmark, 2011. 
56 European Environment Agency, Noise Fact Sheets 2017. 

several  quiet  areas  and  has  made  them  accessible  to 
citizens. In 2015, just under 70 % of Estonians reported 
to  be  satisfied  with  the  level  of  noise  in  their  city57. 
These  instruments,  adopted  after  a  public  consultation 
had  been  carried  out,  should  include  the  measures  to 
keep noise low or reduce it.  

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive will ensure that EU citizens benefit 
from good quality and safe drinking and bathing water. 
It  will  further  ensure  that  the  nutrient  cycle  (nitrogen 
and phosphorus) is managed in a more sustainable and 
resource-efficient way. 

The  existing  EU  water  legislation58  puts  in  place  a 
protective  framework  to  ensure  high  standards  for  all 
water bodies in the EU and addresses specific pollution 
sources (for example, from agriculture, urban areas and 
industrial  activities).  It  also  requires  that  the  projected 
impacts  of  climate  change  are  integrated  into  the 
corresponding  planning 
instruments  e.g. flood  risk 
management  plans  and  river  basin  management  plans, 
including  programme  of  measures  which  include  the 
actions  that  Member  States  plan  to  take  in  order  to 
achieve the environmental objectives. 

Water Framework Directive 

reported 

the  second 
Estonia  has  adopted  and 
generation of River Basin Management Plans under the 
the  European 
Water  Framework  Directive  and 
Commission  has  assessed 
the 
development since the adoption of the first River Basin 
Management  Plans,  including  suggested  actions  in  the 
EIR report 2017. 

status  and 

the 

The most significant pressures on surface water bodies 
were  unknown  anthropogenic  pressure  (71%  of  water 
bodies)  and  dams,  barriers  and  locks  affecting  25%  of 
water bodies.  

For  groundwater  bodies,  “no  significant  pressure”  was 
reported  for  77%  of  groundwater  bodies.  The  most 

57 European Commission, The 7th Report on Economic, Social and 
Territorial Cohesion, 2017, p.120. 
58 This includes the Bathing Waters Directive (2006/7/EC), the Urban 
Waste Water Treatment Directive (91/271/EEC) (on discharges of 
municipal and some industrial wastewaters), the Drinking Water 
Directive (98/83/EC) (on potable water quality), the Water Framework 
Directive (2000/60/EC) (on water resources management), the 
Nitrates Directive (91/676/EEC) and the Floods Directive 
(2007/60/EC). 

17 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

significant  pressures  were  contaminated  sites  or 
abandoned  industrial  sites  (point  sources  15%  and 
diffuse  polution  13%),  waste  disposal  sites  (13%)  and 
discharges not connected to sewerage network (13%)  

The  most  significant  impact  on  surface  water  bodies 
was  classified  as  an  “unknown  impact  type”  (58.4%  of 
water  bodies),  followed  by  altered  habitats  due  to 
morphological changes (21%). The situation was similar 
in  groundwater  bodies,  with  77%  of  water  bodies  with 
reported impacts classified as unknown.  

The  proportion  of  water  bodies  in  good  or  better 
ecological status or potential is 60%  for rivers, 67%  for 
lakes and 13% for coastal waters as illustrated in Figure 
16  but  there  is  a  risk  that  the  proportion  of  water 
bodies 
is  overestimated 
because  of  the  low  confidence  in  the  classification  of 
most of those water bodies.  

in  good  ecological  status 

Figure  17:  Ecological  status  or  potential  of  surface 
water bodies in Estonia59 

of  the  assessment  of  status  as  well  as  increase  in  the 
monitoring data available explain the large decrease in 
the  proportion  of  surface  water  bodies  with  good 
chemical status. 5% of the total groundwater body area 
is in poor chemical status.  

38  out  of  39  groundwater  bodies  (97%)  were  in  good 
quantitative  status  and  1  (3%)  was  failing  good  status. 
In  terms  of  area  this  means  that  1%  was  failing  good 
quantitative status. 

The  implementation  of  the  measures  identified  in  the 
first  Programme  of  Measures  has 
started  but 
unexpected  planning  delays,  lack  of  finance,  and  the 
lack  of  a  mechanism  for  implementing  measures  were 
identified as obstacles to the implementation. Pressures 
causing  failure  of  objectives  in  the  Water  Framework 
Directive have been identified in the second River Basin 
Management  Plans  and  it  is  reported  that  measures 
have been put in place for most of these. 

Bathing Water Directive 

Figure  16  shows  that  in  2017,  out  of  Estonia’s  54 
bathing  waters,  63 %  were  of  excellent  quality,  16.7 % 
of  good  quality  and  5.6 %  of  sufficient  quality 
(compared to 66.7 %, 16.7 % and 11.1 % respectively in 
2016).  However,  four  bathing  waters  were  of  poor 
quality60.  Detailed  information  on  Estonia’s  bathing 
waters is available on a national web portal 61 and on an 
interactive  map  viewer  designed  and  hosted  by  the 
European Environment Agency 62. 

Figure 18: Bathing water quality 2014-2017 63 

A significant proportion of monitoring sites are used for 
assessment  of  ecological  status  (100%,  98%,  80%  and 
78%  of  sites  for  lakes,  rivers,  territorial  and  coastal 
lower 
respectively)  with  a  considerably 
waters 
proportion  of  sites  used  for  monitoring  of  chemical 
status (26%, 38%, 70% and 30% of sites for lakes, rivers, 
territorial and coastal water respectively). 

Between the first  and second River Basin Management 
Plans  there  was  a  large  decrease  in  the  proportion  of 
surface water bodies with good chemical status from 99 
to 10% and a significant increase in the proportion with 
unknown status from 0 to 88%. Methodological changes 

59 EEA, WISE dashboard. 

60 European Environment Agency, European bathing water quality in 
2016, 2017,  p. 17. 
61 Health Board. 
62 EEA, State of bathing waters. 
63 European Environment Agency, European bathing water quality in 
2017, 2018, p. 21. 

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Environmental Implementation Review 2019 – Estonia 

Urban Waste Water Treatment Directive  

Overall,  Estonia  shows  a  high  level  of  compliance  with 
the Urban Waste Water Treatment Directive, with close 
to 97 % of waste water collected and around 90.4 % of 
it  subject  to  secondary  and  more  stringent  treatment. 
However,  a  few  agglomerations  remain  non-compliant 
and  the  Commission  is  following  up  on  them  with 
infringement  procedures.  The  estimated  investment 
needed to ensure adequate collection and treatment of 
waste  water  in  Estonia’s  remaining  agglomerations  is 
EUR 56 million64. 

Nitrates Directive 

The  last  report  on  the  implementation  of  the Nitrates 
Directive,  referring  to  the  period  2012-2015,  showed 
stability  in  nitrate  concentrations  in  groundwater,  as 
well  as  in  surface  waters.  However,  between  the 
reporting  periods  2008-2011  and  2012-2015,  44.4 %  of 
groundwater  stations 
in  nitrate-vulnerable  zones 
showed an increase in average nitrate concentrations. 

The  Commission’s  assessment  found  that  good  efforts 
were  made  with  positive  results  in  setting  objectives 
and  devising  measures 
focusing  on  prevention, 
protection  and  preparedness.  The  assessment  also 
showed that, as was the case for other Member States, 
Estonia’s  Flood  Risk  Management  Plans  do  not  yet 
include  a  baseline  to  assess  the  progress  achieved  in 
implementing  measures  (by  extension  the  objectives, 
too)  and  an  as  complete  as  possible  estimation  of  the 
cost  of  measures.  In  addition,  there 
is  scope  for 
clarifying  the  method  for  selecting  measures,  including 
the use of cost/benefit analysis. 

2019 priority actions 

 

should  provide 

Step  up  efforts  to  assess  the  status  of  all  water 
bodies, increasing the confidence in the assessment 
of  status  and  reducing  the  proportion  of  unknown 
status.  Monitoring 
sufficient 
temporal resolution and spatial coverage (including 
in biota). 
Further  prevent  and  reduce  nitrate  pollution  from 
agricultural  sources  by  effectively  implementing 
and enforcing the Water Act adopted in 2017. 
  Resolve  the  last  remaining  issues  related  to  the 

 

 

Urban Waste Water Treatment Directive. 
Take  steps  to  clarify  the  method  for  selecting 
measures, including the use of cost/benefit analysis 
in relation to the Flood Risk Management Plans. 

Chemicals 

The  EU  seeks  to  ensure  that  by  2020  chemicals  are 
produced and used in ways that minimise any significant 
adverse effects on human health and the environment. 
An  EU  strategy  for  a  non-toxic  environment  that  is 
conducive  to  innovation  and  to  developing  sustainable 
is  being 
including  non-chemical  option 
substitutes 
prepared. 

legislation65  provides  baseline 
The  EU’s  chemicals 
protection  for  human  health  and  the  environment.  It 
also  ensures  stability  and  predictability  for  businesses 
operating within the internal market.  

In  2016,  the  European  Chemicals  Agency  (ECHA) 
published  a  report  on  REACH  and  the  CLP  Regulation66 
that  showed  that  enforcement  activities  are  still 
evolving.  Member  States  cooperate  closely  within  the 
Forum  for  Exchange  of  Information  on  Enforcement  67. 

65 Principally for chemicals: REACH (OJ L 396, 30.12.2006, p.1.); for 
Classification, Labelling and Packaging, the CLP Regulation (: OJ L 252, 
31.12.2006, p.1.), together with legislation on biocidal products and 
plant protection products. 
66 European Chemicals Agency, Report on the Operation of REACH and 
CLP 2016. 
67 ECHA, On the basis of the projects REF-1, REF-2 and REF-3. 

The trophic status of fresh surface water showed some 
improvement,  but  for  coastal  water  the  aggregated 
value 
reported  by  eutrophic  and  hypertrophic 
monitoring  stations  in  2012-2015  was  54 %,  compared 
with  39 %  in  2008-2011.  This  is  of  particular  concern 
considering  the  overall  issue  of  eutrophication  in  the 
Baltic Sea. 

Floods Directive 

The  Floods  Directive  established  a  framework  for  the 
assessment  and  management  of  flood  risks,  aiming  at 
the  reduction  of  the  adverse  consequences  associated 
with significant floods. 

Estonia  has  adopted  and  reported  its  first  Flood  Risk 
Management  Plans  under  the  Directive  and  the 
European Commission conducted an assessment. 

64 European Commission, Ninth Report on the Implementation Status 
and the Programmes for Implementation of the Urban Waste Water 
Treatment Directive (COM(2017)749) and Commission Staff Working 
Document accompanying the report (SWD(2017)445). 

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Environmental Implementation Review 2019 – Estonia 

This  cooperation  has  shown  that  there  is  scope  to 
increase  the  effectiveness  of  enforcement  activities, 
particularly  for  registration  obligations  and  safety  data 
sheets  where  the 
is  still 
relatively high. 

level  of  non-compliance 

including  controls  on 

While progress has been made, there is room to further 
improve  and  harmonise  enforcement  activities  across 
imported  goods. 
the  EU, 
Enforcement  remains  weak  in  some  Member  States, 
particularly  for  controls  on  imports  and  supply  chain 
obligations. The enforcement architecture is complex in 
most  EU  countries  and  enforcement  projects  reveal 
differences in compliance between Member States. 

A  2015  Commission  study  already  emphasised  the 
importance  of  harmonised  market  surveillance  and 
enforcement  when  implementing  REACH  at  Member 
State  level,  enforcement,  deeming  it  to  be  a  critical 
success  factor  in  the  operation  of  a  harmonised  single 
market68. 

In March 2018, the Commission published an evaluation 
of  REACH69.  The  evaluation  concludes  that  REACH 
delivers  on  its  objectives,  but  that  progress  made  is 
slower  than  anticipated.  In  addition,  the  registration 
incomplete.  The  evaluation 
dossiers  often  are 
underlines  the  need  to  enhance  enforcement  by  all 
actors,  including  registrants,  downstream  users  and  in 
particular  for importers, to  ensure a  level playing field, 
meet  the  objectives  of  REACH  and  ensure  consistency 
with  the  actions  envisaged  to  improve  environmental 
compliance  and  governance.  Consistent  reporting  of 
Member  State  enforcement  activities  was  considered 
important in that respect. 

Five  enforcing  authorities  are  responsible  for  REACH 
and CLP enforcement  in  Estonia: the Health Board, the 
Labour  Inspectorate,  the  Environmental  Inspectorate, 
the  Consumer  Protection  Board  and  the  Estonian  Tax 
and  Customs  Board.  Responsibilities  are  divided  as 
follows: 

- 

- 

- 

- 

their  own, 

in  mixtures  and 

the  Health  Board focuses  on  chemical  substances 
on 
in  articles 
(manufacture, import, wholesale); 
the  Labour  Inspectorate focuses  on  the  working 
environment and workers’ protection; 
the 
on 
environmental  hazards  during  manufacture  and 
professional use of substances; 
the Consumer Protection Board focuses on articles, 
substances and mixtures available at retailers; 

Inspectorate focuses 

Environmental 

- 

the  Estonian  Tax  and  Customs  Board focuses  on 
controlling  the  cross-border  flow  of  chemicals  and 
articles. 

Two  sectors  are  specific  to  the  Estonian  chemical 
industry:  oil  shale  chemistry  and  production  of  rare 
earth  metals  and  their  oxides.  Up  to  85 %  of  Estonia’s 
chemical industry production is exported. The chemical 
industry  accounts  for  about  5.2 %  of  the  processing 
industry  and  contributes  0.8 %  to  Estonian  GDP.  It  is 
characterised  by  strong  territorial  concentration,  as 
more than half of it is located in East- Virumaa70. 

Making cities more sustainable 

EU  policy  on  the  urban  environment  encourages  cities 
to  put  policies  in  place  for  sustainable  urban  planning 
and design. These should include innovative approaches 
to  urban  public  transport  and  mobility,  sustainable 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation. 

The  population  living  in  urban  areas  in  Europe  is 
projected  to  rise  to  just  over  80%  by  205071.  Urban 
areas  pose  particular  challenges  for  the  environment 
and human health, but  they also provide opportunities 
for using resources more efficiently. The EU encourages 
municipalities  to  become  greener  through  initiatives 
such  as  the  Green  Capital  Award  72,  the  Green  Leaf 
Award 73 and the Green City Tool 74. 

Financing greener cities 

Estonia  has  allocated  EUR 101  million  or  5.4 %  of  its 
allocation  under  the  European  Regional  Development 
Fund (ERDF) to sustainable urban development. 

68 European Commission, Monitoring the Impacts of REACH on 
Innovation, Competitiveness and SMEs, Final Report, 2015. 
69 COM(2018) 116. 

70 The Federation of Estonian Chemical Industries, Chemical industry 
in Estonia. 
71 European Commission, Eurostat, Urban Europe, 2016, p.9. 
72 European Commission, European Green Capital. 
73 European Commission, European Green Leaf Award. 
74 European Commission, Green City Tool. 

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Environmental Implementation Review 2019 – Estonia 

in  the  European  Urban 
The  country  participates 
Development  Network  (UDN)75,  which  includes  more 
than  500  cities  across  the  EU  responsible  for  carrying 
out  integrated  measures  based  on  sustainable  urban 
development strategies financed by ERDF in 2014-2020. 

Participation in EU urban initiatives and networks 

Estonian  municipalities  are  generally  involved  in  EU 
initiatives  on  environmental  protection  and  climate 
change. 

So far no Estonian city has won the EU Green Capital or 
Green  leaf  awards,  although  Talinn  and  Pärnu  have 
been candidates. 

As  mentioned  in  the  2017  EIR,  a  number  of  initiatives 
are  organised  under  the  Union  of  the  Baltic  Cities 
Sustainable  Cities  Commission,  a voluntary  network  of 
cities in the Baltic Sea region. This network addresses a 
number of issues, including environmentally sustainable 
in  areas  such  as 
development. 
spatial 
integrated  management 
management,  urban  water  management,  maritime 
activities  and  sustainable  urban  mobility.  In  addition, 
Tallinn’s urban planning department  is a  partner in the 
Baltic  Urban  Lab  project,  which  aims  to  identify  and 
promote best practices in brown field regeneration. 

It  runs  projects 

systems 

and 

Estonian  cities  participate 
initiatives  such  as 
Eurocities  and  the  EU  Covenant  of  Mayors.  As  of  June 
2018,  five  Estonian  cities  were  signed  up  to  the  EU 
Convenant of Mayors. 

in 

Tallinn  and  Tartu  are  involved  in  the  URBACT  initiative 
to  support  sustainable  urban  development,  through 
different thematic networks 76. 

These  welcome  urban 
initiatives  and  networks 
contribute  to  a  better  urban  environment.  In  2017, 
8.5 % of the Estonian population living in cities said that 
their neighbourhood was affected by pollution, grime or 
other  environmental  problems,  down  from  12.5 %  in 
2016 and 14 % in 2015. These figures are lower than the 
EU-28 average (20 % in 2017, 18.9 % in 2016 and 19.2 % 
in 2015)77. 

Nature and cities 

Around  16 %  of  Estonia’s  Natura  2000  network  is  in 
functional  urban  areas78,  just  above  the  EU  average  of 
15 % (see Figure 18). 

75 European Commission, The Urban Development Network. 
76 URBACT, Associated Networks by country. 
77 European Commission, Eurostat, Pollution, grime or other 
environmental problems by degree of urbanisation. 
78 Eurostat, Definition of Functional Urban Areas. 

21 

Figure  19:  Proportion  of  Natura  2000  network  in 
Functional Urban Areas (FUAs)79 

When it comes to biodiversity, Tallinn has a particularly 
strong  planning  process,  starting  with  good  mapping 
based  on  survey  work  for  species  and  habitats  and 
research80. 
backed  by  bio-data 
Furthermore,  the  city  has  a  good  organisational 
structure,  overseen  by  overall  strategic  plans  (the 
Tallinn  Environmental  Strategy  to  2030  and  the  Tallinn 
Environmental  Protection  Plan  2013-2018)  and  local 
action plans, with shared objectives throughout. 

inventories  and 

Policies are linked through the different planning levels 
and involve a good variety of implementation measures 
and  projects.  A  biodiversity  action  plan  has  been 
developed,  as  have  the  management  plans  for  all  of 
Estonia’s  protected  areas,  including  the  Pääsküla  Bog 
Conservation Area. 

Urban sprawl 

Estonia  had  a  Weighted  Urban  Proliferation  of  0.71 
UPU/m2 81 in 2009 compared to the EU average of 1.64 
UPU/m2, with an increase of 1.7 % from 2006 to 200982. 

Traffic congestion and urban mobility 

The number of hours spent annually in road congestion 
fell from 20.32 in 2014 to 18.66 in 2016 and is now one 
of the lowest in the EU 83. 

Tallinn  City  Council  decided  to  introduce  free  public 
transport in order to increase social inclusion, boost the 
local  economy  and  contribute  to  protecting  the 
environment. This increased  the number of passengers 
by  6 %  in  2013  compared  with  2012.  In  October  2013, 
Tallinn  made  people’s  train  fares  for  trips  within  city 
borders  free.  The  number  of  train  journeys  within  the 
city  increased  2.3  times  in  2014  compared  with  2012. 
There has also been significant investment in the public 

79 European Commission, the 7th Report on Economic, Social and 
Territorial Cohesion, 2017, p. 121. 
80 European Commission, Good Practice Report, European Green 
Capital 2018, p.30. 
81 Urban Permeation Units measure the size of the built-up area as 
well as its degree of dispersion throughout the region. 
82 EEA, Urban Sprawl in Europe, Annex I, 2014, pp.4-5. 
83 European Commission, Hours spent in road congestion annually. 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

transport  system  in  Tallinn’s  city  centre:  28.6  km  of 
former car lanes have been turned into public transport 
lanes 84. 

The urban area action plans for Tallinn, Tartu and Pärnu 
focus  on  increasing  the  proportion  of  people  using 
sustainable  means  of  mobility  and  providing  residents 
with  nursery  school  and  childcare  options  near  their 
homes.  The  urban  area  action  plans  for  Narva  and 
Kohtla-Järve/Jõhvi focus on increasing the proportion of 
people using sustainable means of mobility and reviving 
major underused districts. 

An environmental information screen has been set up in 
Tallinn’s city centre to inform people about the status of 
ambient  air,  the  most  recent  noise  map  and  the 
changing PM10 levels. 

84 European Commission, Good Practice Report, European Green 
Capital 2018, p.23. 

22 

 
                                                                 
Environmental Implementation Review 2019 – Estonia 

Part II: Enabling framework: implementation tools 

4. Green taxation, green public procurement, environmental 

funding and investments 

Green  taxation  and  environmentally  harmful 
subsidies 

European  Structural  and  Investment  Fund  (ESIF)  rules 
oblige  Member  States  to  promote  environment  and 
climate  in  their  funding  strategies  and  programmes  for 
economic, 
rural 
development and maritime policy. 

social  and 

territorial 

cohesion, 

revenue 

from  environment-related 

Estonia’s 
taxes 
remains  among  the  highest  in  the  EU.  Environmental 
taxes  accounted  for  2.88 %  of  GDP  in  2017  (EU-28 
average  2.4 %)  (see  Figure  19)  and  energy  taxes  for 
2.54 % of GDP  (EU average 1.84 %)  85. In the same year, 
environmental  tax  revenues  were  8.73 %  of  total 
revenues  from  taxes  and  social  security  contributions 
(higher than the EU-28 average of 5.97 %). 

Estonia’s  tax  structure  shows  that  the  proportion  of 
revenues  from  labour  tax  in  total  tax  revenues  is  in  line 
with the EU average, at 49.9 % in 2016, while the implicit 
tax  burden  on  labour  was  34.1 % 86.  Consumption  taxes 
remained  relatively  high  (42.5 %,  4th  in  EU-28),  showing 
that  there  is  limited  potential  to  shift  taxes  from  labour 
to consumption, particularly to environmental taxes. 

The  Commission  has  repeatedly  stated  in  the  European 
Semester that there is potential for new vehicle taxation 
in  Estonia,  in  addition  to  the  circulation  tax  for  heavy 
vehicles  and  the  new  heavy  goods  vehicle  road  usage-
charging 
taxes 
(excluding fuel taxes) amounted to only 0.06 % of GDP in 
Estonia  in  2016,  the  second  lowest  in  the  EU87.  As  of 
2018,  heavy  goods  vehicles  in  Estonia  will  be  subject  to 
road  usage  fees  that  will  partly  depend  on  their 
emissions. 

scheme.  Receipts 

transport 

from 

At the EIR dialogue held on 28 March 2017, the Estonian 
government’s  decision  of  17 March  2017  to  introduce  a 
vehicle registration tax dependent on the vehicle’s power 
/ CO2 emissions was mentioned. 

One  of  the  positive  environmental  fiscal  measures 
introduced  in  Estonia  is  the  mineral  resource  extraction 

85 Eurostat, Environmental tax revenues, 2018. 
86 European Commission, Taxation Trends Report, 2017. 
87 European Commission, European Semester Country Report 2018, p. 
24. 

23 

charge  imposed  on  various  state-owned  construction 
rocks,  energy  minerals  and  minerals  used  in  agriculture, 
based  on  the  quantity  of  the  extracted  resource88. 
Another  good  example  is  the  hunting  and  fishing  fee 
system, from which 77 % of revenues are earmarked for 
conservation purposes89. 

Figure  20:  Environmental  tax  revenues  as  %  of  GDP, 
2017 90 

Meanwhile, fossil fuel subsidies decreased over the past 
decade,  mainly  because  subsidies  for  coal  used  by 
households  ended.  However,  a  new  limited  subsidy  for 
peat  has  been  put  in  place  and  EUR  33  million  are  still 
spent to support petrol and diesel91.  

88 Institute for European Environmental Policy, Case Studies on 
Environmental Fiscal Reform, Mineral resource extraction charge. 
89 Institute for European Environmental Policy, Case Studies on 
Environmental Fiscal Reform, Hunting and fishing fees in Estonia. 
90 Eurostat, Environmental tax revenues, 2018. 
91 OECD, Inventory of Support Measures for Fossil Fuels, 2018. 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

Reasonable  progress  has  been  made  on  reducing  the 
‘diesel  differential’  (difference  in  the  price  of  diesel 
versus petrol) since 2005. In 2016, there was still an 8 % 
gap between petrol and diesel tax rates, making Estonia 
the  4th  best  performing  country  in  the  EU92.  Excise  tax 
rates levied on petrol and diesel in 2016 remained similar 
to those in 2015 in national  currency (EUR 0.46 per litre 
for petrol and EUR 0.44 for diesel)  93. A planned increase 
in the diesel tax rate for 2018 was not implemented due 
to concerns about rising fuel tourism, as rates in Estonia 
are  appreciably  higher  than  those  in  its  neighbouring 
countries other than Sweden and Finland94. 

in  Estonia95.  New 

Tax  treatment  for  company  cars  is  not  a  cause  for 
concern 
fiscal  measures  were 
introduced  for  company  cars  in  2018.  They  will  subject 
heavy  goods  vehicles  to  road  tolls  and  link  remaining 
subsidies  for  company  cars  to  the  vehicles’  power 
capacity  96.  Any  new  developments  that  reduce  the 
favourable taxation of company cars in Estonia would be 
welcome. 

average  CO2  emissions  of  134  grams  per  kilometre, 
above the EU average of 118 grams in 201699. 

The use of alternative fuels in new passenger cars sold in 
Estonia has been decreasing in recent years. In 2016, the 
number of new passenger cars using alternative fuels was 
only  11 %  of  the  2011  figure.  The  abolition  of  a  support 
scheme  showed  that,  without  direct  support  for  buying 
specialised vehicles, take-up of electric- or bio-methane-
run vehicles is unlikely to be high100. 

Green public procurement 

The  EU  green  public  procurement  policies  encourage 
Member  States  to  take  further  steps  to  apply  green 
procurement  criteria  to  at  least  50 %  of  public  tenders. 
The European Commission is helping to increase the use 
of  public  procurement  as  a  strategic  tool  to  support 
environmental protection. 

The purchasing power of public procurement amounts to 
around  EUR 1.8  trillion  in  the  EU  (approximately  14%  of 
GDP).  A  substantial  proportion  of  this  money  goes  to 
sectors  with  a  high  environmental 
impact  such  as 
construction  or  transport.  Therefore,  green  public 
procurement  (GPP)  can  help  to  significantly  lower  the 
negative  impact  of  public  spending  on  the  environment 
and  can  help  support  sustainable  innovative  businesses. 
The Commission has proposed EU GPP criteria101. 

There  are  no  CO2-based  motor  vehicle  taxes  in  place  in 
Estonia  97.  Incentives  to  encourage  the  purchase  of  cars 
with lower CO2 emissions were rare in 2016 and mostly 
linked  to  annual  circulation  taxes,  road  tolls,  and 
congestion or low emission zone charges. There were no 
incentives  to  acquire  cleaner  vehicles  or  use  public 
infrastructure  98.  New  vehicles  purchased  in  Estonia  are 
the  most  environmentally  unfriendly  in  the  EU,  with 

There  is  no  national  action  plan  or  national  strategy  on 
green  public  procurement  currently  in  force  in  Estonia. 
for 
sessions  are  being  organised 
Training 
local 
government 
authority 
state 
specialists,  to  explain  the  concept  of  environmentally 
sound procurement and discuss possibilities for putting it 
into practice. 

representatives 

and 

Environmentally-friendly requirements are currently only 
mandatory for vehicles. Mandatory GPP criteria will also 
be 
introduced  for  the  central  government  sector, 
furniture,  cleaning  products  and  services,  copying  and 
graphic  paper  and  computers  and  monitors.  GPP  is 
periodically  monitored  through  the  official  electronic 
public  procurement  website  (EProcurement  Estonia).  In 
2015, there were 10 850 public procurements in Estonia, 
of  which  605  (5.6 %)  included  green  criteria.  In  2016, 

92 European Environment Agency 2016, Environmental taxation and EU 
environmental policies, p.27. 
93 European Commission, Taxes in Europe Database, 2018. 
94 OECD 28th Joint Meeting on Taxation and Environment, 18th May 
2018. 
95 European Commission, Taxation of commercial cars in Belgium, 2017, 
p.3. 
96 FleetEurope, Major changes to company car taxation in Europe. 
97 ACEA, CO2 based motor vehicle taxes in Europe. 
98 European Environmental Agency, Appropriate taxes and incentives do 
affect purchases of new cars, 18 May 2018. 

99 European Environment Agency, Average CO2 emissions from new 
passenger cars sold in EU-28 Member States plus Norway, Iceland and 
Switzerland in 2016. 
100 European Commission, Transport in the European Union Current 
Trends and Issues, 2018, pp.27-28. 
101 In the Communication ‘Public procurement for a better 
environment’ (COM (2008) 400) the Commission recommended the 
creation of a process for setting common GPP criteria. The basic 
concept of GPP relies on having clear, verifiable, justifiable and 
ambitious environmental criteria for products and services, based on a 
life-cycle approach and scientific evidence base. 

24 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

there  were  10 343  public  procurements  in  Estonia,  of 
which 597 included green criteria (5.8 %). 
In October 2017, Estonia co-organised and hosted the 2nd 
Circular Procurement Congress in Tallinn. 

including  EUR 1.07  billion  from  the  Cohesion  Fund, 
EUR 443 million from the European Social Fund and EUR 
2.46  billion  from  the  European  Regional  Development 
Fund (ERDF)108. 

allocated 

Directly 
environmental 
investments 
infrastructure added up to EUR 800 million in 2007-2013. 
Estonia has allocated the highest EU amount of Cohesion 
Policy  funds  to  direct  environmental  investments,  with 
EUR 956 total per capita since 2000109. 

in 

Figure  21:  ESIF  2014-202  –  EU  allocation  by  theme, 
Estonia (EUR billion) 110 

Environmental funding and investments 

European  Structural  and  Investment  Fund  (ESIF)  rules 
include  environment  and 
oblige  Member  States  to 
funding  strategies  and 
climate  objectives 
programmes 
territorial 
cohesion, rural development and maritime policy. 

in  their 
for  economic, 

social  and 

Achieving  sustainability  requires  the  mobilisation  of 
public  and  private  financing  sources102.  Using  the 
European  Structural  and  Investment  Funds  (ESIF)103  is 
to  achieving  environmental  goals  and 
essential 
integrating 
into  other  policy  areas.  Other 
instruments such as Horizon 2020, the LIFE programme104 
and  the  EFSI105  may  also  support  implementation  and 
spread good practices. 

them 

According  to  the  2017  Special  Eurobarometer  on 
attitudes of EU citizens towards the environment, 84 % of 
in 
greater 
Estonians 
environmental protection (EU-28 average 85 %). 

investment 

support 

EU 

European Structural and Investment Funds 2014-2020 

Through  three  national  and  regional  programmes, 
Estonia  has  been  allocated  EUR 4.46  billion  from  ESIF 
funds  for  2014-2020.  This  means  that  with  its  national 
contribution  of  EUR 1.54  billion,  Estonia  has  a  total 
budget of EUR 6 billion to invest in areas such as the low-
carbon  economy,  sustainable  transport,  environmental 
protection and adaptation to climate change106. Figure 19 
shows ESIF financing for Estonia. 

Estonia’s  annual  total  public  environmental  expenditure 
as a percentage of GDP is estimated at around 1.67 %107. 

Cohesion policy 

EU funds are a key asset for protecting the environment 
in  Estonia111.  One  of  the  Commission’s 
investment 
priorities  for  Estonia  in  2014-2020  is  to  use  natural 
resources  more  efficiently and create a  less  energy- and 
carbon-intensive  economy112.  Boosting 
in 
these  areas  will  help  the  country  transition  to  a  circular 
economy. 

investment 

Estonia  has  been  allocated  over  EUR 4.4  billion  from  EU 
sources  in  total  cohesion  policy  funding  for  2014-2020, 

Innovation and the low-carbon economy are key areas to 
consider  when  estimating  environmental  spending.  The 

102 European Commission, Action Plan on Financing Sustainable Growth. 
103 ESIF comprises five funds – the European Regional Development 
Funds (ERDF), the Cohesion Fund (CF), the European Social Fund (ESF), 
the European Agricultural Fund for Rural Development (EAFRD), and the 
European Maritime and Fisheries Fund (EMFF). The ERDF, the CF and 
the ESF together form the Cohesion Policy funds. 
104 European Commission, LIFE Estonia Sheet, 2017. 
105 European Investment Bank, European Fund for Strategic 
Investments, 2016. 
106 European Commission, European Structural and Investment Funds 
(Country factsheet Estonia), 2017. 
107 Commission annualized estimate based on ESIF, Horizon 2020, EIB 
and EFSI loans, LIFE and national public environmental expenditures 
2014-2020. 

108 European Commission, Cohesion Policy and Estonia, 2014. 
109 COWI-MILIEU 2017 Study on the integration of environmental 
concerns in the Cohesion Policy funds (ERDF, ESF, CF), p. 35. 
110 European Commission, European Structural and Investment Funds 
Data By Country. 
111 ‘The objectives of the ESI Funds shall be pursued in line with the 
principle of sustainable development and with the Union’s promotion 
of the aim of preserving, protecting and improving the quality of the 
environment, as set out in Article 11 and Article 191(1) TFEU, taking 
into account the polluter pays principle’ Article 8, Reg. (EU) No 
1303/2013. 
112 European Commission, Summary pf the Partnership agreement for 
Estonia, 2014, pp. 1-2. 

25 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

ERDF  has  allocated  EUR 57  million  to  Estonia’s  low-
carbon economy 113. 

funding  for  environmental  projects 
representing more than EUR 32 million 119. 

is  around  20 %, 

The ERDF supports projects such as the Narva Water and 
Sewage  Treatment  System  Construction,  including  with 
investment in the treatment  and distribution of drinking 
water  and  collection  of  wastewater  for  all  residents  of 
Narva. Significant  environmental benefits stem from the 
elimination  of  groundwater  and  subsoil  contamination, 
made  possible  by  the  reconstruction  of  waste-water 
collectors and elimination of leakages 114. 

Rural development 

The  Estonian  Rural  development  programme  (RDP) 
outlines the country’s priorities for using EUR 993 million 
of funding available for 2014-2020. This funding includes 
EUR 823 million from the European Agricultural Fund for 
Rural  Development  (EAFRD)  and  EUR 169  million  of 
national co-funding 115. 

The  programme  takes  a  solid  environmental  approach, 
with its main priorities being water, soil, and biodiversity. 
Around  70 %  of 
farmland  will  be  under  agri-
environmental commitments. 37 % of the budget is being 
allocated  to  activities  that  make  it  possible  to  avoid 
deforestation  of  the  agri-environment.  The  plan  also 
includes  a  water  protection  measure  for  the  nitrate 
vulnerable  area and  support  measures  for  semi-natural 
habitats and organic farming 116. 

several  EAFRD-RDP  projects 
There  are  currently 
supporting  a  variety  of  environment-related  matters. 
They 
include  a  knowledge-transfer  programme  on 
organic  farming,  resource-efficient  greenhouses,  dairy 
in 
cowshed  renovation  and  solar  power  generation 
strawberry farms117. 

European Maritime and Fisheries Fund 

Estonia  has  allocated  around  EUR 129  million  in  co-
financing for the fisheries and maritime sector, with a EU 
contribution  of  EUR 101  million  118.  This  has  helped 
finance  projects  that  benefit  the  environment  in  the 
sustainable fisheries and sustainable aquaculture areas of 
Estonia’s  operational  programme.  The  proportion  of 

113 European Commission, 
https://cohesiondata.ec.europa.eu/countries/EE#, 2019. 
114 European Commission, EU invest in Estonia, 2017. 
115 European Commission, 
https://cohesiondata.ec.europa.eu/countries/EE#, 2019. 
116 European Commission, Factsheet on 2014-2020 Rural Development 
Programme for Estonia, 2017, pp. 1-2. 
117 European Commission, European Network for Rural Development, 
Projects and Practice, Estonia. 
118 European Commission, European Maritime and Fisheries Fund in 
Estonia, 2015. 

The energy efficiency of the fishing fleet will be improved 
with the replacement and modernisation of 140 engines. 
Other  actions  will  also  help  reduce  greenhouse  gas 
emissions and conserve or rehabilitate 9 000 hectares of 
terrain 120. 

The Connecting Europe Facility (CEF) 

The  CEF  is  a  key  EU  funding  instrument  developed 
specifically to direct investment into European transport, 
energy  and  digital  infrastructures.  It  aims  to  address 
identified  missing  links  and  bottlenecks  and  promote 
sustainability. 

By  the  end  of  2017,  Estonia  had  signed  project 
agreements amounting to EUR 208 million under the CEF 
121. 

EUR 15  million  will  go  to  the  deployment  of  hydrogen 
refueling  stations,  tackling  the  demand  for  hydrogen 
vehicles 122. 

Horizon 2020 

Estonia  has  benefited  from  Horizon  2020  funding  since 
the programme started in 2014. As of January 2019, 140 
participants  have  been  granted  a  maximum  amount  of 
EUR 41.6 million for projects from the Societal Challenges 
work 
environmental 
issues123 124.  

dealing  with 

programmes 

In  addition  to  the  abovementioned  work  programmes, 
climate and biodiversity expenditure is present across the 
entire  Horizon  2020.  In  Estonia,  projects  accepted  for 
funding  in  all  Horizon  2020  working  programmes  until 
December  2018  included  EUR  45  million  destined  to 
climate  action  (33.8 %  of  the  total  Horizon  2020 
contribution  to  the  country)  and  EUR  11  million  for 
biodiversity-related  actions  (8.5 %  of  the  Horizon  2020 
contribution to the country)125. 

119 European Commission, European Maritime and Fisheries Fund in 
Estonia, 2015, p. 2. 
120 European Commission, ESIF Data for Estonia. 
121 European Commission, European Semester Country Report for the 
Netherlands, 2018, p. 10. 
122 European Commission, H2Nodes Estonia. 
123 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). A maximum grant amount is the maximum 
grant amount decided by the Commission. It normally corresponds to 
the requested grant, but it may be lower. 
124 i.e. (ii) Food security, sustainable agriculture and forestry, marine 
and maritime and inland water research and the bioeconomy; (iii) 
Secure, clean and efficient energy; (iv) Smart, green and integrated 
transport; and (v) Climate action, environment, resource efficiency and 
raw materials. 
125 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). 

26 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

Several  successful  projects  are  taking  place  in  Estonia. 
The  LAkHsMI  project  is  developing  new  monitoring  and 
imaging technology for water that could be used for the 
production  of  renewable  energy  and  to  improve  the 
conservation of autochthonous species 126. The LeanShips 
project is trying to create greener ships, which would cut 
fuel use and CO2 emissions by 25 % 127. 

The European Fund for Strategic Investments (EFSI) aims 
to help overcome the current investment gap in the EU. 
As of January 2019, it has mobilised more than EUR 130 
million in Estonia. The secondary investment triggered by 
this is expected to be more than EUR 1.3 billion 137. 
Figure 22: EIB loans to Estonia in 2018 138 

LIFE programme 

Since  its  launch  in  1992,  the  LIFE  programme  has  co-
financed  a  total  of  34  projects  in  Estonia 128.  Altogether, 
they  represent  a  total  investment  of  EUR 38  million,  of 
which  EUR 20  million  have  been  provided  by  the  EU  129. 
Of  these  projects,  10  have  focused  on  environmental 
innovation  (under  the  LIFE  project’s  ‘environment  and 
resource  efficiency’  priority)  and  18  on  nature 
‘nature  and 
conservation  (under  the  LIFE  project’s 
biodiversity’ priority). 

For  2014-2017,  the  EU  has  allocated  EUR 5  million  to 
Estonian  projects130.  The  EstBatLIFE  project  is  among 
these  and  is  taking  action  to  improve  Pond  Bat  (Myotis 
dasycneme) habitats with a requested EU contribution of 
more  than  EUR 500 000131.Currently,  there  are  two 
ongoing  projects 
the  alvar 
grasslands and mire habitats 132. 

focusing  on  restoring 

A project in which Estonia took part was included in the 
Best LIFE Projects of 2016-2017 133. This was the SAMBAH 
project  134,  which  was 
included  under  ‘nature  and 
biodiversity’ and aimed to apply best practice to provide 
data  for  the  reliable  assessment  of  the  distribution  and 
habitat  use  of  the  Baltic  Sea  subpopulation  of  harbour 
porpoise. 

European Investment Bank 

In  2018  alone,  the  EIB  group  (the  European  Investment 
Bank  and  the  European  Investment  Fund) 135  loaned 
Estonian  businesses  and  public  institutions  more  than 
EUR 76  million  (see  Figure  21).  Of  this,  around  EUR 4.6 
million  (6 %)  went  to  environmental  projects.  In  2017, 
loans  of  more  than  EUR 50  million  went  to  various 
companies working on the circular economy in the Baltic 
countries 136. 

European Fund for Strategic Investments 

126 European Commission, The LAKHSMI Project.  
127 European Commission, Leanships project.  
128 European Commission, LIFE programme – Country profile: Estonia, 
2017. 
129 European Commission, LIFE by country: Estonia. 
130 Commission services based on data provided by EASME. 
131 European Commission, EstBatLIFE. 
132 European Commission, LIFE in Estonia, 2017, p. 2-4. 
133 European Commission, Best LIFE-Environment Projects 2016-2017.  
134 European Commission, SAMBAH Project. 
135 The EIB Group includes EIB and EFSI investments and loans. 
136 European Investment Bank, Estonia and the EIB. 

National environmental financing 

Estonia  spent  EUR 123.1  million  on  environmental 
protection  in  2016,  a  12 %  decrease  from  2015139.  32 % 
of  these  payments  went  to  the  waste  management 
sector,  while  12.5 %  were  allocated  to  wastewater 
management.  5.5 %  was  used  for  pollution  abatement 
and  16 %  for  protecting  biodiversity  and  the  landscape. 
Between 2012 and 2016, general government funding for 
environmental protection was EUR 652.5 million 140. 

As  it  has  been  mentioned  in  the  report,  one  of  the 
challenges  for  Estonia  is  to  ensure  that  environmental 
financing remains at an adequate level. Existent financial 
gaps  in  areas  such  as  waste  management,  water  quality 
or  biodiversity  are  delaying  the  correct  implementation 
law  and  policies.  Therefore, 
of  EU  environmental 
ensuring 
the 
resources 
implementation  gap  should  be  considered  as  a  priority 
for the country. 

financial 

reduce 

to 

2019 priority action 

 

Prepare  for  the  next  financing  period  2021-2027  to 
ensure that there is sufficient funding to implement 
the waste, water and management plans for Natura 
2000 sites. 

137 European Investment Bank, The EIB in Estonia, what we do. 
138 European Investment Bank, The European Investment Bank in 
Estonia, 2017. 
139 Eurostat, General government expenditure by function., 2018. 
140 Eurostat, General Government Expenditure by function, 2018. 

27 

                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

5. Strengthening environmental governance 

is  not  integrated  or  linked  to  the  main  environmental 
portals. 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  
(i) access to information;  
(ii) public participation in decision making; and  
(iii) access to justice in environmental matters.  
It is of crucial importance to public authorities, the public 
and  business  that  environmental  information  is  shared 
efficiently  and  effectively141.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows  citizens  and  NGOs  to  use  national  courts  to 
protect the environment142. It includes the right to bring 
legal challenges (‘legal standing’)143. 

Environmental information 

Estonia has a mixed governance structure. There are two 
important  environmental  portals,  one  run  by  the 
Environmental  Agency144  and  one  by  the  Ministry  of 
Environment145.  They  have  a  similar  structure  and 
overlap in the areas of water, air and emissions. They are 
generally  well 
include  some 
linked.  The  portals 
monitoring  data  in  tables  and  graphs  of  indicators.  For 
air,  the  Estonian  Environmental  Research  Centre  runs  a 
separate  portal146.  Information  on  chemicals  was  not 
available  on  any  of  the  environmental  portals,  only 
monitoring  data  related  to  water. 
Information  on 
chemicals  was,  however,  found  on  the  Health  Board’s 
chemical safety portal147. The main environmental portals 
focus  on  providing 
information  on  national  plans, 
national legislation and high level indicators in a number 
of  domains.  The  environmental  data  provided  does  not 
meet  INSPIRE  specifications.  Estonia  has  a  separate 
INSPIRE portal at inspire.maaamet.ee. The INSPIRE portal 

141 The Aarhus Convention, the Access to Environmental Information 
Directive, 2003/4/EC and the INSPIRE Directive, 2007/2 together create 
a legal foundation for the sharing of environmental information 
between public authorities and with the public. This EIR focuses on 
INSPIRE. 
142 The guarantees are explained in Commission Notice on access to 
justice in environmental matters, OJL 275, 18.8.2017 and a related 
Citizen's Guide. 
143 This EIR looks at how well Member States explain access to justice 
rights to the public, and at legal standing and other major barriers to 
bringing cases on nature and air pollution. 
144 Keskkonnaagentuur. 
145 Ministry of the Environment.  
146 Ambient air quality. 
147 REACH 2018: Registreerimisdokumentide esitamine. 

Estonia’s  performance  on  implementing  the  INSPIRE 
Directive  leaves  room  for  improvement.  The  country’s 
performance  has  been  reviewed  by  the  Commission 
based  on  their  2016  implementation  report148  and  their 
most  recent  monitoring  data  from  2017149.  There  has 
been good progress on coordination and documentation 
of  data  and  services.  Additional  efforts  are  needed  to 
make  the  data  accessible  through  services,  improve  the 
conditions for data reuse and prioritise high-value spatial 
datasets, 
implement 
environmental legislation150. 

in  particular 

those  used 

to 

Figure  23:  Access  to  spatial  data  through  view  and 
download services in Estonia (2017)  

Public participation 
The  general  part  of  Estonia’s  Environmental  Code  Act151 
and  its  Administrative  Procedure  Act152  include  general 
for  open 
obligations 
for  public  participation  and 
proceedings 
are 
sector-specific 
complemented 
environmental laws in the areas of air, nature, water and 
waste. In practice, the Estonian Ministry of Environment 
website  includes  a  clearly  visible  section153  on  public 
there  are  a  number  of 
consultation.  Moreover, 
government  web  portals154 
that  promote  public 

decision  making. 
variety  of 

These 

by 

in 

a 

148 INSPIRE EE country sheet 2017. 
149 INSPIRE, monitoring dashboard. 
150 List of high value spatial data sets. 
151General Part of the Environmental Code Act. 
152Administrative Procedure Act. 
153Ministry of Environment, Kaasamine ja osalemine. 
154 Osale (makes available policy documents) and Eelnõude infosüsteem 
(includes all legislative drafts, including letters from other government 
authorities). 

28 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Estonia 

participation  in  government  work.  A  good  example  of 
proactively  engaging  with  the  public 
is  the  annual 
‘partnering  event’,  where  the  Ministry  of  Environment 
introduces its annual workplan and priorities and leads a 
discussion  of  current  hot  topics.  Participation  in  this 
event increases each year (120 participants in 2018). 

Estonia’s  citizen  engagement  activities  have  been 
in  the  context  of  the 
identified  as  good  practices 
Commission’s Better Regulation Toolbox155. 

figures 

The  Eurobarometer 
from  2017  show  that 
Estonians agree relatively strongly (77 % of respondents) 
that  an  individual  can  play  a  role  in  protecting  the 
environment. This has remained largely unchanged since 
2014. 

public  authorities  and  the  public  through  the  digital 
services set out in the INSPIRE Directive. 

  Better inform the public about their rights to access 

justice. 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
that 
undertaken  by  public  authorities 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste157.  It 
includes  support  measures  provided  by  the  authorities, 
such as:  
(i) compliance promotion158;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring159; and  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement160.  
Citizen  science  and  complaints  enable  authorities  to 
liability161 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring 

is  an 

information 

Online information is given to farmers on how to comply 
with  obligations  on  nitrates  and  nature.  The  quality  of 
this 
indicator  of  how  actively 
authorities  promote  compliance  in  subject-areas  with 
serious implementation gaps. 
The  Fund  for  Advancement  of  Rural  Life  162  (Maaelu 
Edendamise  Sihtasutus)  provides  some  free  web-based 
guidance  material163,  including  on  obligations  that  apply 
in  Estonia’s  two  nitrate-vulnerable  zones.  Estonia  also 
provides  extensive 
information  about 
site-specific 
obligations relating to its Natura 2000 sites164. 

Major  industrial  installations  can  be  a  serious  pollution 
risk.  Public  authorities  must  have  plans  to  inspect  these 
installations  and  to  make  individual  inspection  reports 
available  to  the  public165.  The  Estonian  Environmental 
Inspectorate publishes an inspection plan166. Information 

157 The concept is explained in detail in the Communication on ‘EU 
actions to improve environmental compliance and governance’ 
COM(2018)10 and the related Commission Staff Working Document, 
SWD(2018)10. 
158 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
159 This EIR focuses on inspections of major industrial installations. 
160This EIR focuses on the availability of enforcement data and co-
ordination between authorities to tackle environmental crime. 
161 Directive 2004/35/CE, creates the framework. 
162 Rural Development Foundation. 
163 MES nõuandeteenistus. 
164 Protected Areas of Estonia. 
165 Article 23, Directive, 2010/75/EU. 
166Käitiste korrapärase kontrollimise ajakava aastateks 2016-2018. 

Access to justice 

Although Estonia has an official website with information 
on  access  to  justice  in  general,  this  fails  to  provide  the 
public  with 
user-friendly 
information  about  access  to  justice  rights  in  relation  to 
the environment. 

comprehensive, 

clear, 

In  Estonia,  legal  standing  is  generally  rights-based  and 
restrictive  so  far  as  individuals  are  concerned.  There  is 
broader  provision  for  legal  standing  in  the  case  of 
environmental NGOs. On this basis, it is likely that NGOs 
would be able to bring legal challenges in relation to both 
nature and air pollution cases, but individuals would not 
be  able  to  bring  a  nature-related  case  in  the  general 
interest. 

2019 priority actions 

 

Improve  access  to  spatial  data  and  services  by 
making  stronger  links  between  the  central  INSPIRE 
website and regional portals. Identify and document 
all  spatial  datasets  required  for  the  implementation 
of  environmental  law156  and  make  the  data  and 
documentation  at  least  accessible  ‘as  is’  to  other 

155 European Commission, Good Engagement Practices.  
156 European Commission, INSPIRE. 

29 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

about  inspection  reports  is  available  on  the  Ministry  of 
Environment website167. 

Citizen science and complaint handling 

the 

between 

cooperation 

Engaging  the  general  public  through  citizen  science  can 
increase knowledge about the environment and help the 
authorities  in  their  work.  There  are  two  public  portals: 
Estonian  Nature  Observations  Database168  (LVA)  and 
eBiodiversity  (eElurikkus).  The  former  is  the  result  of 
long-term 
Estonian 
Environment  Agency  and  the  Estonian  Naturalists’ 
Society.  Since  2010,  the  Agency  has  organized  annual 
public  campaigns  to  provide  observations  on  species169. 
The availability of clear online information about how to 
make  a  complaint  is  an  indicator  of  how  responsive 
authorities  are  to  complaints  from  the  public.  The 
Inspectorate  clearly 
website  of  the  Environmental 
shows170  the  contact  e-mail  address  and  24-hour 
telephone  number  for  complaints  about  environmental 
problems. 

2019 priority actions 

  Better 

inform 

the  public  about 

compliance 

 

 

promotion, monitoring and enforcement.  
information  on  the  outcomes  of 
Publish  more 
enforcement  action  and  on  the 
follow-up  to 
detected cross-compliance breaches on nitrates and 
nature. 
Improve  financial  security  for  liabilities  and  ELD-
guidance  and  publish  information  on  environmental 
damage. 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

Those 
environmental 
legislation at EU, national, regional and local levels need 
to have the knowledge, tools and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Enforcement 

When  monitoring 
identifies  problems,  a  range  of 
responses  may  be  appropriate.  While  Estonia  publishes 
the 
information 
inspection  reports, 
administrative  follow-up  to  detected  non-compliance. 
Furthermore,  there 
information  on 
responses  to  cross-compliance  breaches  on  nitrates  and 
crimes  are 
nature. 
published171. 

Statistics  on  environmental 

is  no  published 

lacking  on 

is 

Tackling  waste,  wildlife  crimes  and  other  environmental 
offences 
It  requires  close 
cooperation  between  inspectors,  customs  authorities, 
police and prosecutors. 

is  especially  challenging. 

The website of the Environmental Inspectorate refers to 
inter-agency  cooperation  as  does  the  website  of  the 
Prosecutor’s Office172 . 

Environmental liability 

The  Environmental  Liability  Directive  (ELD)  establishes  a 
framework  based  on  the  ‘polluter  pays’  principle  to 
prevent  and  remedy  environmental  damage.  The  2017 
EIR 
information  on 
financial  security  and 
environmental  damage,  on 
guidance.  The  Commission  is  still  collecting  evidence  on 
progress made. 

focused  on  gathering  better 

167 Ministry of environment, Tööstusheide. 
168 Nature observations database.  
169 Since 2015, there is a special smartphone application to support 
collecting observation data for the Nature Observations Database. 
170 Environmental Inspectorate, Keskkonnainfo 1313. 
171Environmental Inspectorate, Järelevalve statistika, Statistical reports 
are presented as downloadable xlsx files. 
172 Prosecutor’s office.  

30 

Administrative capacity and quality 

Central, regional and local administrations must have the 
ability  to  carry  out  their  own  tasks  and  work  effectively 
with  each  other,  within  a  system  of  multi-level 
governance. 

Most  environmental  issues  fall  within  the  responsibility 
of the Ministry of Environment. Local municipalities play 
a  key  role  in  construction-  and  territorial  planning.  The 
most  important  agencies  under  the  governance  of  the 
Ministry of Environment are the:  

 

 

 

Keskkonnaamet  (Environmental  Board),  which  has 
various  functions  in  the  field  of  nature  protection, 
environmental  protection, 
resource  use  and 
radiation; 
Keskkonnainspektsioon 
(Environmental 
Inspectorate),  which  is  the  primary  enforcement 
agency; and  
Keskkonnaagentuur  (Estonian  Environment  Agency), 
the  national  environmental 
which 
reports  and 
monitoring  programme,  prepares 
assesses the state of the environment. 

implements 

Local  governments  are  autonomous  entities  and  have 
loose  ties  with  the  central  government. 
relatively 
According  to  the  EUPACK  study173,  local  authorities’ 
engagement  in  policymaking  is  rather  superficial  and 
central  government  lacks  the  capacity  to  put  in  place 
better  coordination  mechanisms.  Local  governments 
have  formed  associations  that  attempt  to  coordinate 
their  activities  with  regard  to  relations  with  the  central 
government. 

173 Pesti, C., Randma-Liiv, T., Public administration characteristics in 
Estonia. EU PACK project, 2017, p 9. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

An  extensive  state-led  reform  decreased  the  number  of 
municipalities  in  2017.  There  are  now  79  municipalities 
as compared to 213 before the reform. 

Estonia’s  score  in  the  2018  Environmental  Performance 
Index is 64.31. It ranks 48th out of 180174. 

In  order  to  ensure  effective  environmental  governance, 
environmental authority staff must have the appropriate 
administrative and technical knowledge and skills. In the 
2017  EIR,  the  Commission  introduced  TAIEX-EIR  PEER-2-
PEER  as  a  new  instrument  facilitating  peer  learning 
between  experts  from  Member  States’  environmental 
authorities. Estonia has not  made use of this instrument 
yet,  but  Estonian  experts  participated  in  a  workshop  on 
air pollution caused by household heating175 

Coordination and integration 

Environmental 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised 
(EIA) 
Directive176 into national law provides an opportunity for 
countries  to  streamline  their  regulatory  framework  on 
environmental assessments.  

Impact  Assessment 

Despite a delay, Estonia has now transposed the revised 
Directive.  

the 

The  Commission  encourages 
streamlining  of 
environmental  assessments  to  reduce  duplication  and 
avoid  overlaps 
for 
projects.  Streamlining  helps  to  reduce  unnecessary 
administrative  burden. 
It  also  accelerates  decision 
making,  without  compromising  the  quality  of  the 
environmental assessment procedure177. 

in  environmental  assessments 

Estonia has introduced a joint procedure for assessments 
under  the  EIA  and  Habitats  Directives.  It  also  has  a 
coordinated  procedure  for  assessments  under  the  EIA, 
Water Framework and Industrial Emissions Directives. 

Adaptability, 
(eGovernment) 

reform 

dynamics 

and 

innovation 

When  it  comes  to  eGovernment,  Estonia  is  among  the 
EU’s leading countries. It is among the five EU countries 
that  are  very  close  to  having  a  fully  developed  digital 
channel  for  public  services,  with  a  score  above  95 %178. 
Estonia  uses  digital  identification,  digital  signing,  paper-
free  e-Government  and  more.  In  the  DESI  Report  2018, 

174 Yale Center for Environmental Law & Policy, 2018 Environmental 
Performance Index Yale University, p. 4. 
175 European Commission, TAIEX EIR Peer-to-Peer . 
176 Directive 2014/52/EU. 
177 The Commission issued a guidance document in 2016 regarding the 
setting up of coordinated and/or joint procedures that are 
simultaneously subject to assessments under the EIA Directive, Habitats 
Directive, Water Framework Directive, and the Industrial Emissions 
Directive, OJ C 273, 27.7.2016, p. 1. 
178 European Commission, Europe's Digital Progress Report, 2017. 

Estonia  had  a  score  of  77  out  of  100  on  digital  public 
services, higher than the EU average of 58179. 

Environmental  authorities  use  electronic  services  that 
make  it  possible  for  the  public  to  interact  with  them 
online. Since the introduction of digital signing and digital 
identification,  digital  means  of  communication  are  the 
public’s preferred choice. 

Environmental  authorities  aim  to  provide  all  their 
services  electronically.  The  Environmental  Board  has 
recently  introduced  a  new  portal  for  environmental 
decisions  (Keskkonnalubade  Infosüsteem  KOTKAS180).  It 
the  older,  more  cumbersome  e-service. 
replacies 
Installations  needing  environmental  permits  submit  all 
their data and applications electronically. 

As  part  of  Estonia’s  continuous  efforts  to  improve  its  e-
governance, an environmental monitoring database that 
would 
is  being 
improve  access  to  monitoring  data 
developed181.  For  water  quality  data,  a  comprehensive 
modeling  system  with  integration  of  relevant  data  is 
being developed182. Water quality data is currently rather 
difficult  to  find  and/or  to  understand  without  expert 
knowledge. The new modelling system could significantly 
improve the quality of environmental information and its 
accessibility. 

Enabling financing and effective use of funds 
Estonia  created  the  Environmental  Investment  Centre183 
investment 
to  finance  environmental  activities  and 
projects.  The  fund’s  website  provides  clear  information 
about funding opportunities. Funding is available for the 
following  areas:  energy  and  reduction  of  air  emissions; 
the  circular  economy;  waste;  fisheries;  environmental 
education; 
systems; 
environmental  management 
environmental  monitoring  and  surveillance;  nature 
conservation;  mineral  resources;  marine  environment; 
forestry; water. 

Centre 

Investment 

Environmental 

The 
the 
implementing  agency  for  funding  financed  by  the  state 
and  funding  available  from  the  EU  funds.  Calls  for 
applications are usually published in national newsletters 
and on the websites of the Ministry of Environment and 
the centre itself. 

is 

2019 priority action 

  Estonia can further improve its overall environmental 
governance 
citizens 
as 
engagement, compliance and enforcement, as well as 

transparency, 

(such 

179 European Commission, Digital Economy and Society Index Report 
2018, Digital Public Services. 
180 Keskkonnaministeerium. 
181 Ministry of Environment, Environmental Monitoring.  
182 Ministry of Environment, Veeinfosüsteem – Veeveeb. 
183 Environmental Investment Centre. 

31 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

administrative capacity and coordination). 

International agreements 

Genetic  resources:  Nagoya  Protocol  on  Access  to 
Genetic Resources and the Fair and Equitable Sharing of 
Benefits Arising (ABS)189 

The  EU  Treaties  require  the  EU  environmental  policy  to 
promote  measures  at  international  level  to  deal  with 
regional or worldwide environmental problems. 

Estonia  has  appointed  its  competent  authorities  for 
genetic 
for 
infringements of the Regulation. 

resources  and  has  applied  sanctions 

The EU is committed to strengthening environmental law 
and its implementation globally. It therefore continues to 
support  the  Global  Pact  for  the  Environment  process, 
which  was  launched  by  the  United  Nations  General 
Assembly  in  May  2018184.  The  EIR  is  one  of  the  tools  to 
ensure  that  the  Member  States  set  a  good  example  by 
respecting  European  Union  environmental  policies  and 
laws and international agreements.  

Estonia  has  signed  and  ratified  almost  all  Multilateral 
Environmental Agreements (MEAs), including the Nagoya 
Protocol 185 to which it is a party since 19 March 2019. 
Forests:  EU  Timber  Regulation  (EUTR)186/  Forest  Law 
(FLEGT)187 
Enforcement,  Governance  and  Trade 
Regulation 

It  is  estimated  that  10 000  Estonian  operators  place 
domestic  timber  on  the  EU  market  and  450  import 
timber  and  related  products.  Between  March  2015  and 
February 2017, Estonia reported having carried out 70 % 
of  the  1135  checks  that  it  had  planned  for  domestic 
timber  and  75 %  of  the  20  checks  it  had  planned  for 
imported  timber.  In  addition,  the  Estonian  authorities 
carried  out  214  checks  on  traders.  This  is  significant 
compared with other countries188. 

In  Estonia,  infringements  of  the  EUTR  found  during 
checks  of  domestic  timber  mainly  relate  to  breaches  of 
due diligence and prohibition. So far, these infringements 
have  led  to  125  penalties  being  imposed  on  operators 
(fines and compensation for environmental damage) and 
17 court  cases. With regard to imported timber, Estonia 
issued six notices of  remedial action for breaches of the 
due diligence requirement. 

On cooperation (Article 12 EUTR), Estonia reports to have 
collaborated with various Estonian competent authorities 
and other institutions in EU countries. It also highlighted 
the Nordic-Baltic action plan. 

184 UN General Assembly Resolution 72/277 and Organizational session 
of the ad hoc open-ended working group.  
185 Protocol on Access to Genetic Resources and the Fair and Equitable 
Sharing of Benefits Arising from their Utilization to the Convention on 
Biological Diversity. 
186 Regulation (EU) No 995/2010. 
187 Regulation (EC) No 2173/2005. 
188 Traders were checked by 19 countries, with numbers of checks 
ranging from 1 (Denmark, France, Luxembourg) to 747 (Cyprus). 12 out 
of 19 countries conducted between 1 and 65 checks. 

Estonia is one of the four countries that have put in place 
a  risk-based  plan  for  checks  and  conducted  checks  (on-
site  visits  and  inspections).  However,  no  due  diligence 
declaration  was  submitted  so  far  and  no  penalties  have 
been  applied.  Estonia  has  submitted  its  first  report  on 
implementing the EU ABS Regulation to the Commission 
(end of 2017). 

International  wildlife  trade:  trade:  the  Convention  on 
International  Trade  in  Endangered  Species  of  Wild 
Fauna and Flora CITES190 

Estonia  has  set  up  the  relevant  national  authorities  and 
processes (requests for) import, (re-) export and intra-EU 
trade documents on a regular basis. Reports on seizures 
of illegal shipments, in particular those reported every six 
months  to  TRAFFIC  under 
its  contract  with  the 
Commission, and those exchanged through the EU-TWIX 
platform, show that customs authorities are active. 

To  ensure  full  implementation  of  the  EU  Wildlife  Action 
Plan  (2016)  and  improve  the  rate  of  detection  of  illegal 
activities,  Estonia  is  working  on  defining  and  assessing 
priority risks as part of its enforcement strategies. 

Sustainable 
implementation of the UN SDGs 

development 

and 

the 

Sustainable development links environmental, social and 
economic policies in a coherent framework and therefore 
helps  to 
legislation  and 
policies. 

implement  environmental 

the  national 

for 
The  Ministry  of  Environment  was  responsible 
developing 
sustainable 
development,  which  was  approved  by  the  Estonian 
Parliament  in  2005.  Implementation  of  this  strategy  is 
now coordinated by the Government Office. 

strategy 

for 

The Estonian government  established the Committee on 
Sustainable  Development  (Säästva  Arengu  Komisjon) 
already  back  in  1996191.  Initially,  the  committee  was 
given  the  task  of  overseeing  sustainable  development 
goals  that  were  established  within  the  government.  In 
November  2017,  the  government  re-formulated  the 
committee’s  purpose  to  overseeing  the  implementation 

189 Regulation (EU) No 511/2014. 
190 European Commission, The Convention on International Trade in 
Endangered Species of Wild Fauna and Flora (CITES). 
191 Riigi Teataja, Riigi pikaajalise säästva arengu üksikküsimuste 
läbitöötamise asjatundjate komisjon. 

32 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Estonia 

of the SDGs in Estonia192. One of the committee’s tasks is 
to ensure that the SDGs are integrated in sector-specific 
policies. 

institution 

responsible 

is  officially 

for  policy 
No 
coordination,  but  the  local  self-government  unions  take 
part  in  monitoring  the  strategy  through  the  Estonian 
Commission 
This 
stakeholder 
commission  provides 
involvement. 

Sustainable  Development. 

forum 

for 

on 

a 

Estonia submitted a  voluntary national review report  on 
implementing the SDGs in 2016193. It was one of the first 
four EU countries to do so. 

192 Riigikantselei, Saastva arengu komisjon. 
193 Republic of Estonia, Government Office, Review on the 
implementation of the 2030 Agenda in Estonia, 2016. 

33