COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 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 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Estonia, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 255 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022     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 2022: Turning the tide through environmental compliance     {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Estonia  1 

This report has been written by the staff of the Directorate-General for Environment, European Commission. Any 
comments are welcome to the following email address: ENV-EIR@ec.europa.eu  

More information on the European Union is available on the internet (http://europa.eu). 

Photographs:  

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

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Estonia  2 

Table of Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................................. 8 
Nature protection and restoration ....................................................................................................................... 8 
Marine ecosystems............................................................................................................................................. 14 
Ecosystem assessment and accounting ............................................................................................................. 15 
3. ZERO POLLUTION ..................................................................................................................................................... 17 
Clean air ............................................................................................................................................................. 17 
Industrial emissions ............................................................................................................................................ 18 
Major industrial accidents prevention – SEVESO ............................................................................................... 20 
Noise .................................................................................................................................................................. 21 
Water quality and management ........................................................................................................................ 22 
Chemicals ........................................................................................................................................................... 25 
4. CLIMATE ACTION ..................................................................................................................................................... 28 
Key national climate policies and strategies ...................................................................................................... 28 
Effort sharing ..................................................................................................................................................... 29 
Key sectoral developments ................................................................................................................................. 29 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 30 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 32 

5. FINANCING ............................................................................................................................................................. 32 
Environmental investment needs in the European Union .................................................................................. 32 
EU environmental funding  2014-2020 .............................................................................................................. 34 
EU environmental funding 2021-2027 ............................................................................................................... 35 
National environmental protection expenditure ................................................................................................ 37 
Green budget tools ............................................................................................................................................. 38 
Overall financing compared to the needs .......................................................................................................... 40 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 42 
Information, public participation and access to justice...................................................................................... 42 
Compliance assurance ........................................................................................................................................ 43 
Effectiveness of environmental administrations ................................................................................................ 45 
Reforms through the Commission’s Technical Support Instrument (TSI) ........................................................... 46 
TAIEX EIR peer-to-peer projects ......................................................................................................................... 46 

 Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
Estonia  3 

Executive summary 

The main challenges identified in past EIRs with regard to 
implementation  of  EU  environmental  policy  and  law  by 
Estonia were: 

 

 

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

Estonia  is  now  on  track  to  decouple  municipal  waste 
generation from economic growth and  has made steady 
progress over the past decade on stepping up its recycling 
rate.  However,  with  only  28.9%  of  municipal  waste 
recycled  in  2020,  Estonia  remains  well  below  the  EU 
average and needs to progress faster to achieve the 2025 
targets.  An  increase  in  the  circular  material  usage  to 
17.3%  in  2020  -  above  the  EU  average  -  is  a  good 
achievement. However, with EUR 0.63 generated per kg of 
material  consumed  in  2020,  resource  productivity  in 
Estonia is dragged down by resource intensive industries. 
After  completion  of  the  Technical  Support  Instrument 
project on Estonian waste system analysis, including good 
circular economy measures in the Recovery and Resilience 
Plan  (RRP)  and  adoption  of  the  circular  economy  action 
plan planned in 2022, Estonia has excellent conditions for 
accelerating its transition towards a circular economy. 

Moving away from oil shale extraction and use is expected 
to  bring  along  multiple  benefits  for  the  environment  in 
terms  of  reduced  amounts  of  waste  and  pollution, 
improved  resource  productivity  and  less  pressure  on 
water resources. This transition will be crucial to achieve 
the climate neutrality goal. Improvements are needed in 
the  Land  Use  Land  Use  Change  and  Forestry  (LULUCF) 
sector, as removals by sinks have decreased between 2013 
and 2019 and  a six-fold decrease of the  LULUCF carbon 
sink by 2030 has been projected in the Estonian National 
Energy and Climate Plan (NECP).  

In general terms of biodiversity, Estonia presents a mixed 
picture. It is the second-best Member State in the EU as to 
the  share  of  EU-protected  species  and  habitats  in  good 
conservation status and its uptake of organic farming of 
22% is not far from the EU 2030 target of 25%. At the same 
time, most of its mire, forest and semi-natural grassland 
habitats remain at unfavourable status. Despite efforts to 
halt the deterioration, the numbers of key farmland and 
forest birds are declining under pressures from agriculture 
and  forestry.  For  the  Natura  2000  network,  Estonia  has 
designated all  Sites of Community Importance as Special 
Areas  of  Conservation,  but  still  needs  to  establish  site-
specific conservation objectives and measures to meet its 
obligations  under  the  Habitats  Directive.  Estonia  also 

needs  to  improve  the  management  of  semi-natural 
grasslands  and  forests  and  enhance  the  protection  and 
assessment requirements under Article 6 of the Habitats 
Directive  by  amending  the  Nature  Conservation  Act. 
Estonia  is  one  the  pioneers  of  wetland  restoration. 
Estonia’s  expertise  in  promoting  restoration  will  be  very 
valuable  under  the  future  Nature  Restoration  Law, 
demonstrating that restored wetlands can bring multiple 
benefits  and  co-exist  with  successful  farming  practices. 
The  new  Estonian  Nature  Conservation  Development 
Plan, which will be finalised by the end of 2022, would be 
an  excellent  tool  to  include  the  targets  from  the  Nature 
Restoration  Law  –  particularly 
in  relation  to  the 
restoration of peatlands, grasslands and forests. 

On  air  pollution,  although  the  emissions  of  key  air 
pollutants have decreased significantly over the last years, 
Estonia should continue to address emissions to air from 
usage of fossil fuels and other emitting sources replacing 
them with cleaner solutions.  

sustainable  water  management, 

On 
Estonia 
demonstrates  very  high  compliance  with  the  Drinking 
Water  Directive  and  the  Urban  Waste  Water  Treatment 
Directive  except  for  the  issues  related  to  the  use  of 
individual  or  other  appropriate  systems  in  the  sparsely 
populated  areas.  As  for  the  Nitrates  Directive,  Estonia 
needs to reduce and prevent eutrophication of inland and 
marine surface waters where the agricultural pressure is 
significant.  An  acute  eutrophication  problem  affecting 
is  a  shared  problem  with 
97%  of  the  Baltic  Sea 
neighbouring states. A significantly large portion of waters 
in 
to  be  below  good 
eutrophication status. 

region  are  assessed 

the 

EU  financing  continues  to  provide  support  for  the 
environmental implementation gap, and Estonia is due to 
receive over EUR 969.3 million from its RRP (2021-2026) in 
grants and EUR 2.2 billion from the cohesion policy (2021-
2027). Estonia’s environmental financing for investments 
was at an annual  1.25% of GDP  in 2014-2020, with over 
two  thirds  of  it  coming  from  national  sources.  The 
environmental  investment  needs  in  the  coming  period 
(where country-level breakdown is available) are found to 
be in a similar range (1.13% of Estonia’s GDP), suggesting 
that  the  majority  of  environmental  investment  needs 
would be met. Nevertheless, investment needs for water 
protection,  wider  environmental  sustainability,  higher 
circularity, R&D focused on environment-related issues as 
well as nature restoration can trigger additional needs for 
financing over baselines (i.e. an investment gap).  

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
 
 
Estonia  4 

Part I: Thematic areas 

1. Circular Economy and waste management 

Measures towards a circular economy 

Figure 1 – Circular material use rate (%), 2010-20201 

The new Circular Economy Action Plan adopted in March 
2020 is one of the main building blocks of the European 
Green Deal. The EU’s transition to a circular economy will 
reduce  pressure  on  natural  resources  and  will  create 
sustainable  growth  and  jobs.  It  is  also  a  prerequisite  to 
achieve the EU’s 2050 climate neutrality target and to halt 
biodiversity  loss.  The  Action  Plan  announces  initiatives 
along the entire life cycle of products, aiming to reduce the 
EU's consumption footprint and to double the EU's circular 
material  use  rate  by  2030.  It  targets  how  products  are 
designed,  promotes 
circular  economy  processes, 
encourages sustainable consumption, and aims to ensure 
that waste is prevented and the resources used are kept 
in the EU economy for as long as possible. 

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s circularity, as it includes all the materials that 
are  fed  back  into  our  economy.  Large  differences  in  the 
circularity rate exist across countries. To help achieve the 
EU circular economy action plan’s goal of doubling the EU 
circular  material  use  rate  by  2030,  ambitious  measures 
targeting  the  whole  product  life  cycle  are  needed  at  a 
level.  Such  measures  range  from 
Member  State’s 
sustainable  product  design  which  can 
increase  the 
durability,  reparability,  upgradability  and  recyclability  of 
products,  to  other  measures  such  as  remanufacturing, 
increasing  the  circularity  in  production  processes  and 
recycling,  as  well  as  boosting  eco-innovation  and 
increasing the uptake of green public procurement.  

Estonia’s circular (secondary) material use rate was 11.8% 
in 2016 and 17.3% in 2020, well above the EU average of 
12.8%, demonstrating a strong increase in the secondary 
material usage in the past few years. 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  minimise  the 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw material markets. As shown in 
Figure  2,  with  EUR  0.63  generated  per  kg  of  material 
consumed in 2020, resource productivity in Estonia is well 
below the EU average of EUR 2.09 per kg. 

Figure 2: Resource productivity 2010-20202 

Circular Economy Strategy 

The Commission encourages Member States to adopt and 
implement  national/regional  circular  economy strategies 
covering the whole life cycle of products. This is because 
such  strategies  are  one  of  the  most  effective  ways  to 
progress  towards  a  more  circular  economy  at  Member 
State  level.  Since  the  launch  of  the  European  Circular 

1 Eurostat, Circular Economy Monitoring Framework.  
2 Eurostat, Resource productivity, EUR/kg, chain linked volumes. 

Environmental Implementation Review 2022 – Estonia 

 
                                                                 
 
 
Economy Stakeholder Platform in 20173, national, regional 
or local authorities have used the platform to share their 
strategies and roadmaps. 

Currently,  Estonia’s  circular  economy  action  plan  is  in 
consultation.  The  strategy  is  entitled  ‘Estonian  Circular 
Economy  White  Paper  and  Action  Plan’,  and  it  is  to  be 
adopted  in  2022.  No  implementation  timetable  is  yet 
available. The strategy is also a part of the Environmental 
Development  Plan  scheduled  for  2023.  The  Minister  of 
Environment  has  established  an  advisory  group  at  the 
level  of  deputy  secretary-generals  that  consists  of  all 
ministries as well as the Government Office and will advise 
the  Minister  of  the  Environment  in  the  process  of 
developing  policy  measures  under  the  Circular  Economy 
White  Paper.  Transition  to  a  circular  economy  is  also 
stated  as  one  of  the  priority  reforms  the  new  holistic 
national  strategy  document  ‘Estonia  2035’  which  was 
adopted by the Parliament in 2021. 

Estonia  does  not  have  a  specific  sectoral  strategy  for 
plastics;  the  sector  is  currently  being  addressed  only 
through the Single Used Plastics Directive. Nor does it have 
a  specific  sectoral  strategy  for  textiles.  A  strategy  on 
construction, however, is in place. In 2021, the long-term 
view on ‘Construction 2035’ was adopted. Through seven 
steps,  the  focus  is  on  identifying  the  best  developments 
for  the  construction  sector,  shaping  a  high-quality  built 
environment. 

The adoption of the circular economy action plan by 2022 
is  also  a  reform  included  in  the  Estonian  Recovery  and 
Resilience Plan. 

Eco-Innovation 

A  successful  transition  to  a  circular  economy  requires 
social and technological innovation. This is because the full 
potential  of  the  circular  economy  can  only  be  reached 
when  it  is  implemented  across  all  value  chains.  Eco-
innovation is an important enabling factor for the circular 
economy.  New  approaches  to  product  design  and  new 
to  produce  circularity 
business  models  can  help 
innovations, creating new business opportunities. 

In 2021, Estonia ranked 18th on the 2021 Eco-Innovation 
Index, with a total score of 97, resulting in an average eco 
In  three  out  of  five 
innovation  performer  status. 
components of the Eco-Innovation Index of 2021, Estonia 
performs  below  the  EU  average,  namely  on  eco-
innovation inputs, eco innovation activities and resource 
efficiency outcomes, while for ecoinnovation outputs and 
socioeconomic outputs, it performs above the EU average. 

Estonia  5 

Figure 3 – Eco-innovation performance, 2010-20194 

Green Public Procurement (GPP) 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  14%  of  EU  GDP.  Public 
procurement  can  help  drive  the  demand  for  sustainable 
recyclability 
products 
standards. 

repairability  and 

that  meet 

8  323 public procurements were carried out in Estonia in 
2020. The value of public procurement was EUR 3.7 billion 
which makes up 14% of GDP and 32% of the state budget. 
Official statistics shows that only 4.5% of the total number 
of procurements and 17% of the total procurement cost 
are GPP.  

As from 1 January 2022, mandatory GPP criteria have been 
introduced  for  the  central  government  sector  for 
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).  EU 
Ecolabel  and  the  Eco-Management  and  Audit  Scheme 
(EMAS) 

EU Ecolabel and the Eco Management and Auditing 
Scheme (EMAS)  

The number of EU Ecolabel products and EMAS-licensed5 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and  national 
stakeholders  in  that  country  are  actively  engaged  in  the 
transition  to  a  circular  economy.  It  also  shows  how 

3 European Commission, Circular Economy Stakeholder Platform. 
4 European Commission - Directorate-General for Environment (DG ENV), 
Eco-innovation  Observatory’,  Eco-innovation  scoreboard  and  the  eco-
innovation index. 

5  EMAS  is  the  European  Commission’s  Eco-Management  and  Audit 
Scheme, a programme to encourage organisations to behave in a more 
environmentally sustainable way. 

 Environmental Implementation Review 2022 – Estonia 

 
                                                                 
 
 
supporting 
committed  public  authorities  are 
instruments designed to promote the circular economy.  

to 

explain the positive total waste generation trend observed 
from 2014 onwards. 

Estonia  6 

However, concerns have been raised about the lack of a 
unified  data  management  system  at  the  local  level,  and 
the quality of the data provided9. 

Figure 4: Municipal waste by treatment in Estonia, 2010-
202010 

Figure 4 also shows municipal waste by treatment and by 
kg per capita. Estonia has moved away from heavy reliance 
on  landfill  to  treating  municipal  waste  by  incineration, 
which  accounted  for  45%  of  waste  treatment  in  2019. 
Since  2014,  landfill  has  increased  again,  although  the 
latest  figures  for  2019  suggest  that  this  trend  is  slowing 
down. 

Estonia has made slow but steady progress over the past 
decade in stepping up its recycling rate but with only 29% 
of municipal waste recycled in 2020, it remains well below 
the EU average of 48%.  

Figure 5 shows that Estonia needs to step up investment 
in recycling to meet the EU 2025 recycling targets. 

As of September 2021, Estonia had 974 products, out of 
83 590 and 22 licences, out of 2 057 registered in the EU 
Ecolabel scheme , showing a low take-up of the products 
and licences6. Moreover, 20 organisations, amounting to 
42 sites from Estonia are currently registered in EMAS, the 
European  Commission's  Eco-Management  and  Audit 
Scheme7. Since the last  report  in 2019, there  have been 
663 new product registrations of the EU Ecolabel, as well 
as ni,e new licences.  Under EMAS, 12 new organisations 
were registered. 

As  Estonia  has  committed  to  the  adoption  of  a  circular 
economy action plan in its Recovery and Resiliance Plan, 
the corresponding priority action from 2019 is fulfilled.  

Waste management 

Turning waste into a resource is supported by:   
(i) fully implementing EU waste legislation, which 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;   
(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 
waste8 for which EU law sets mandatory recycling targets. 

Preventing products and materials from becoming waste 
for as long as possible is the most efficient way to improve 
resource  efficiency  and  to  reduce  the  environmental 
impact of waste. Waste prevention and reuse are the most 
preferred  options  and  are  therefore  at  the  top  of  the 
waste  hierarchy.  The  amount  of  municipal  waste 
generated is a good indicator of the effectiveness of waste 
prevention measures. 

Estonia  is  one  of  the  Member  States  with  the  lowest 
municipal waste generation per capita, with 383 kg/capita 
in  2020, well below the EU average of 505 kg/capita. Its 
total waste generation has increased only slightly between 
2010 and 2018 and even decreased in 2019. The fact that 
Estonia’s  GDP  has  grown  steadily  during  the  same  time 
indicates that Estonia is on track to decouple total waste 
generation  from  economic  growth.  Estonia’s  Waste 
Prevention Plan, implemented since 2014, might partially 

6 European Commission, Ecolabel Facts and Figures. 
7  As  of  May  2018.  European  Commission,  Eco-Management  and  Audit 
Scheme. 
8 Municipal waste consists of (a) mixed waste and separately collected 
waste  from  households,  including  paper  and  cardboard,  glass,  metals, 
plastics,  bio-waste,  wood,  textiles,  packaging,  waste  electrical  and 
electronic  equipment,  waste  batteries  and  accumulators,  and  bulky 

waste, 
including  mattresses  and  furniture;  (b)  mixed  waste  and 
separately  collected  waste  from  other  sources,  where  such  waste  is 
similar in nature and composition to waste from households. (Directive 
2008/98/EC, Art. 3 2b) 
9  World  bank,  Review  and  Recommendations  for  Estonian  Municipal 
Waste Information Management 
10  Eurostat, Municipal waste by waste operation, October 2021 

 Environmental Implementation Review 2022 – Estonia 

 
                                                                 
 
Figure 5: Recycling rate of municipal waste, 2010-202011 

The  Commission's  2018  Early  Warning  report'12  listed 
Estonia as one of the countries at risk  of missing the EU 
2020  target  of  recycling  50 %  of  municipal  waste.  The 
report  listed key priority measures  which  Estonia should 
take to close the implementation gap. The Commission is 
currently  finalising  its  analysis  of  the  progress  on  the 
recommendations  from  the  Early  Warning  Reports  as  a 
well as an analysis of progress towards achieving the 2025 
waste  recycling  targets.  This  report  will  be  presented  at 
the  end  of  2022  and  will  make  recommendations  as 
appropriate. 

Implementation of the 2018 waste legislative package 

Estonia has notified the transposition of the 2018 waste 
package13 to the Commission. A conformity assessment is 
now ongoing.  

Waste  Management  Plans  and  Waste  Prevention 
Programmes are instrumental for a sound implementation 
of  the  EU  waste  legislation.  They  set  out  key  provisions 
and investments to ensure compliance with existing and 
new legal requirements (e.g. waste preventiion, separate 
collection  for  a  number  of  specific  waste  streams, 
recycling  and 
targets).  Revised  plans  and 
programmes were due on 5 July 2020. 

landfill 

Estonia has extended the current waste management plan 
(2014-2020) until the end of 2022 and intends to adopt the 
new updated waste management plan (2022-2028) by the 
end of 2022. When the plan is notified to the Commission 

Estonia  7 

it  meets  the 
the  Commission  will  assess  whether 
requirements  of  Article  28  of  the  revised  Framework 
Directive on Waste.  

Estonia benefited from the Technical Support Instrument 
project 20EE03 funded by the Structural Reform Support 
Programme  2020  for  Estonian  waste  system  analysis. 
Under this project, the World Bank assessed the Estonian 
municipal  waste  management  system,  analysed  options 
and proposed an action plan and policy recommendations 
on  how  to  improve  its  effectiveness  and  make  it  more 
circular. The project was completed in October 2021 and 
it will feed into the new waste management plan. 

There  has  been  some  progress  since  the  2019  EIR  as 
regards measures for improving waste management and 
increasing recycling rate, but a fair amount of work is still 
needed to fully address the recommendations. In light of 
the upcoming Early Warning Report 2022, all 2019 priority 
actions are proposed again. 

2022 priority actions 

 

 

 

 

 

for 

targets 

instruments, 

Introduce  new  policy 
including 
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 
recycling  and 
generation  of  residual  waste  at  the  municipal 
for  non-
financial  penalties 
level,  with 
compliance.  Develop  and  run  implementation 
support  programmes  for  municipalities  to  help 
support  their  efforts  to  organise  separate 
collection and improve recycling performance.  
Improve and extend separate collection of waste, 
including 
for  biowaste.  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 
responsibility  systems,  in  line  with  the  general 
minimum requirements on EPR22 .

11 Eurostat, Recycling rate of municipal rate, April 2022. 
12  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)422 accompanying COM(2018)656. 

13  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. 

 Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
Estonia  8 

2. Biodiversity and natural capital

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and sets out new targets and governance mechanisms to 
achieve healthy and resilient ecosystems.   
In particular, the strategy sets out ambitious targets to:  
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;   
(ii) strictly protect at least a third of the EU’s protected 
areas, including all remaining EU primary and old-growth 
forests;   
(iii) effectively manage all protected areas, defining clear 
conservation  objectives  and  measures,  and  monitoring 
them appropriately.   
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore degraded ecosystems across the EU by 2030, and 
manage them sustainably, addressing the key drivers of 
biodiversity loss.  

The EU’s Habitats and Birds Directives are key legislative 
tools  to  deliver  on  the  targets  in  the  EU’s  biodiversity 
strategy  for  2030,  and  are  the  cornerstones  of  the 
European  legislation  aimed  at  conserving  the  EU’s 
wildlife14. 

Additional  goals  as  set 
in  the  Estonian  Nature 
Conservation Development Plan are to strictly protect at 
least 10% of forests, to restore 10 000 ha of mire habitats 
and to have 45 000 ha of semi-natural grasslands under 
active  management  by  2020.  According  to  preliminary 
estimates,  the  level  of  management  of  grasslands  will 
have reached 40 000 ha in 2020. 

The  Prioritised  Action  Framework  (PAF)  2021-2027 
foresees funding to improve management of 60 000 ha 
of semi-natural grasslands by 2028. 

The  new  Strategy  identifies  2030  goals  reflected  into 
more  than  100  measures,  each  with  corresponding 
indicators, priorities, deadlines, verification means, tools 
and responsible entities. 

Estonia 
intends  to  compile  management  plans  for 
protected  habitats  (wet  forests,  dry  forests,  rocky 
habitats,  rivers,  lakes,  dunes,  coastal  habitats,  marine 
habitats). 

A  national  action  plan  for  all  forest  habitats  will  be 
prepared  under  the  LIFE  integrated  project  (to  be 
finalised by 2029). 

In  1994,  Estonia  ratified  the  Convention  on  Biological 
Diversity.  

Nature protection and restoration  

Natura  200015,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  objectives 
in  the  Birds  and  Habitats 
Directives.  These  objectives  are:  (i)  to  ensure  the  long-
term  protection,  conservation  and  survival  of  Europe's 
most valuable and threatened species and habitats; and 
(ii)  to  maintain  or  restore  the  favourable  conservation 
status  of  these  species  and  habitats.  Key  milestones 
towards meeting the objectives of the Birds and Habitats 
Directives  are:  (i)  the  setting  up  of  a  coherent  Natura 
2000 network; (ii) the designation of sites of community 
importance (SCIs) as SACs16; and (iii) the setting of site-
specific  conservation  objectives  and  measures  for  all 
Natura 2000 sites.  

Setting up a coherent network of Natura 2000 sites 

Estonia hosts 60 habitat types17 and 95 species18 covered 
by  the  Habitats  Directive.  The  country  also  hosts 
populations of  75 bird taxa  listed in the Birds Directive 
Annex I.19 

By 2021, 17.9% of the national land area of Estonia was 
covered  by  Natura  2000  (EU  coverage  18.5%),  with 
Special Protection Areas (SPAs) classified under the Birds 
Directive covering 13.7% (EU coverage 12.8%) SCIs under 
the  Habitats  Directive  covering  17.2%  (EU  coverage 
14.2%) of Estonia’s territory. 

14 These should be reinforced by the Nature Restoration Law, according 
to the new EU Biodiversity Strategy.   
15  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 
designated  pursuant  to  the  Habitats  Directive  as  well  as  Special 
Protection  Areas  (SPAs)  classified  pursuant  to  the  Birds  Directive; 
figures of coverage do not add up due to the fact that some SCIs and 
SPAs  overlap.  Special  Areas  of  Conservation  (SACs)  means  a  SCI 
designated by the Member States. 
16 Sites of Community Importance (SCIs) are designated pursuant to the 
Habitats  Directive  whereas  Special  Protection  Areas  (SPAs)  are 
designated pursuant to the Birds Directive; figures of coverage do not 

add up due to the fact that some SCIs and SPAs overlap. Special Areas 
of Conservation (SACs) are SCIs designated by the Member States. 
17 EEA, Article 17 dashboard, Annex I total, 2019. 
18  EEA,  Article  17  dashboard,  Annex  II  +  Annex  IV  excluding  those  in 
Annex II + Annex V excluding those in Annex II, 2019. This counting only 
takes  into  account  species  and  habitats  for  which  assessment  of 
conservation status was requested. 
19  EEA, Article  12  dashboard,  Annex  I,  2020. This counting  only  takes 
into account birds taxa for which information was requested. 

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
The latest assessment of the SCI part of the Natura 2000 
network shows that the designation is complete. 

Figure  6:  EU-27  marine  &  terrestrial  protected  area 
coverage, 202120  

Figure  7:  Natura  2000  terrestrial  protected  area 
coverage, 202121  

Designating  SACs  and  setting  conservation  objectives 
and measures  

Estonia  9 

The  six  year  deadline  set  by  the  Habitats  Directive  to 
designate  SCIs  as    SACs  and  establish  appropriate 
conservation  objectives  and  measures  been  met,  as 
Estonia has designated all SCIs as SACs.  

The  Commission  is  concerned  that  the  quality  of  the 
objectives and measures set is only partially in line with 
legal  requirements  and  it  will  further  investigate  the 
matter. 

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
towards  maintaining  or  restoring 
favourable 
the 
conservation status of species and habitats. 

The  results  of  Habitats  Directive  Article  17  and  Birds 
Directive  Article  12  reports  on  progress  towards 
maintaining or restoring favourable conservation status 
of  species  and  habitats  are  key  to  measure  the 
performance of Member States. 

According  to  the  report  submitted  by  Estonia  on  the 
conservation  status  of  habitats  and  species  covered  by 
just  Article  17  of  the  Habitats  Directive  for  the  period 
2013-2018, the share of assessments for habitats in good 
conservation status in 2018 is 5% more than the 51.67% 
reported  under  the  previous  reporting  period  (2007-
2012)22. 

As  for  protected  species,  the  share  of  assessments  in 
good  conservation  status  in  2018  is  56.67%,  which  is 
2.71%  more  than  the  53.54%  reported  under  the 
previous reporting period (2007-2012))23. Of the 27% of 
EU forest area protected under the EU nature directives, 
only  20%  of  Estonian  habitats  show  a  favourable 
conservation status24. As far as birds are concerned, 60% 
of the breeding species showed short-term increasing or 
stable population trends (for wintering species this figure 
was  85.72%).  

At the same time, the share  of habitats in bad  or poor 
conservation status has decreased to 44% (from 48% in 
the  previous  reporting  period)  and  the  share  of 
assessments  for  species  in  bad  or  poor  conservation 
status  has  slightly  increased  to  36%  (from  35%  in  the 
previous  reporting  period).  The  main  pressures  for 
habitats  (in  descending  order)  are  agriculture,  natural 
processes  and  forestry.  The  main  pressures  for  species 
(in  descending  order)  are  forestry,  agriculture  and 
human-induced changes in water regimes. 

20  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
21 European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 

22 However, 26.7% of these changes were due to changes of methods 
or due to better data and only 6.7% reflect genuine changes. 
23 16.67% genuine changes 
24 State of Nature Report. EEA 2021. 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
 
                                                                 
Figure  8:    Assessments  on  conservation  status  for 
habitats  for  2007-2012  and  2013-2018  reporting 
periods25  

Figure  9:  Assessments  on  conservation  status  for 
species 
for  2007-2012  and  2013-2018  reporting 
periods26 

Estonia  10 

As  an  example  of  a  good  practice,  Estonia  included 
restoration of 10 000 ha of mire habitats by 2020 in tuts 
nature  conservation  development  plan.  This  was 
implemented by the action plan for protected mires. The 
restoration  programme  has  been  carried  out  with 
different funding sources,the most prominent being the 
EU  Cohesion  Fund  and  LIFE  project  “Conservation  and 
Restoration of Mire Habitats” 27. The programme helped 
to halt the degradation of wetlands affected by drainage 
and restored some former peat extraction sites. 

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The Biodiversity Strategy works in tandem with the new 
Farm to Fork Strategy and the new Common Agricultural 
Policy (CAP) to support and achieve the transition to fully 
sustainable agriculture.  
The Biodiversity and Farm to Fork strategies have set four 
important targets for 2030:  
- 50% reduction of the overall use of  – and risk  from  – 
chemical pesticides,  
- 50% reduction of the use of more hazardous pesticides, 
-  50%  reduction  of  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  20%  the  reduction  of  the  use  of 
fertilisers), 
- bring back at least 10% of agricultural area under high-
diversity landscape features  and increasing areas under 
organic farming to at least 25%. 

As  shown  in  the  Figure  10,  Estonia,  with  an  estimated 
22.41% of it surface area under organic farming is among 
the EU leaders - second only to Austria  - and far above 
the EU average of 9.07% (2020 data, Eurostat). This is not 
far from the EU 2030 target of 25%. 

While the overall share of habitats and species in good 
conservation status has slightly increased in Estonia, the 
majority  of  mire,  forest  and  semi-natural  grassland 
habitats remain in an unfavourable status. 

In June 2021, the Commission initiated an infringement 
procedure  which  raises  concerns  about  the  incorrect 
transposition  and  bad  application  of  the  Habitats 
Directive and the SEA Directive, in particular with regard 
to appropriate assessment procedure concerning logging 
activities in Natura 2000 areas 

25  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats and species, December 2021. Please note when comparing the 
figures  shown  for  2007-2012  and  2013-2018  that  these  may  also  be 
affected by changes of methods or due to better data availability. 

26 Idem. 
27 LIFE Mires Estonia; project no: LIFE14 NAT/EE/000126) 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
                                                                 
Estonia  11 

Soil ecosystem 

soil 

new 

strategy, 

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
on 
adopted 
EU 
The 
17 November 2021,  stresses  the 
importance  of  soil 
protection,  of  sustainable  soil  management  and  of 
restoring  degraded  soils  to  achieve  the  Green  Deal 
objectives as well as land-degradation neutrality by 2030.  
This entails:  
(i) preventing further soil degradation;  
(ii) making sustainable soil management the new normal;  
(iii) taking action for ecosystem restoration. 

One factor in the degradation of soil ecosystems is the 
area  of  soil  that  is  sealed  or  artificialised  32.  Despite  a 
reduction  in  the  last  decade  (land  take  was  over  1 000 
km2/year  in  the  EU-28  between  2000  and  2006),  land 
take in the EU-28 still amounted to 539km2/year in 2012-
201833. The concept of ‘net land take’ combines land take 
with the return of land to non-artificial land categories 
(re-cultivation). While some land was re-cultivated in the 
EU-28 in 2000-2018, 11 times more land was taken than 
returned.  

In  Estonia  (Figure  11)  the  land  taken  per  year  in  the 
period  2012-2018  can  be  seen  as  a  measure  of  an 
important pressure on nature and biodiversity, land use 
change,  which  as  the  same  time  constitutes  an 
environmental  pressure  on  people  living  in  urbanised 
areas. 

Estonia  ranks  slightly  above  the  EU  average  as  regards 
net  land  take  with  93.7  m2/km2  (EU-27  average:  83.8 
m2/km2) 34. 

its  reporting  on 

In  2018,  Estonia  updated 
land 
degradation according to the new 'Performance Review 
and 
reporting 
platform35  with  actions 
intended  to  achieve  the 
degradation identified. 

Implementation  System 

(PRAIS30 

Figure 10: Share of total utilised agricultural area 
occupied by organic farming per Member State, 
202028  

Estonia’s  utilised  agricultural  area  amounts  to  1  Mha, 
representing 23% of the total land area29. As described in 
the Commission analysis of Estonia’s CAP strategic plan30, 
an  above-average  proportion  of  Estonia’s  farmland  is 
considered to be intensive and steps to improve nutrient 
management are important.  

The  Farmland  Bird  Index  was  at  59  in  2019 31,  having 
fallen sharply from a value of 102 in 2007. This is below 
the EU-27 average of 75. The trend has been confirmed 
by  a  marked  decline  in  the  breeding  population  of  the 
skylark – a key indicator species in Estonia as in many EU 
countries.  

As  mentioned  above,  the  conservation  status  of 
grassland habitats of EU interest affected by agriculture 
is  deteriorating  with  only  8%  of  them  in  favourable 
status. There is  concern that the presence of permanent 
grassland is being eroded and where grassland is still in 
place, noted threats include cultivation and fertilisation. 

to  overall  CAP 

from 
Biodiversity  and  ecosystems  could  benefit 
improvements 
the 
management  of  semi-natural  grasslands,  and  from 
efforts to re-introduce landscape features in areas where 
they have been lost. 

support 

for 

28https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/defaul
t/table?lang=en  (Eurostat,    Area  under  organic  farming,  February 
2022). 
29 SWD(2021) 1001 
30 SWD/2020/375 
31 EUROSTAT [env_bio2] 
32 Artificial  land cover  is defined as the total of roofed built-up areas 
(including  buildings  and  greenhouses),  artificial  non  built-up  areas 
(including sealed area features, such as yards, farmyards, cemeteries, 

car  parking  areas  etc.  and  linear  features,  such  as  streets,  roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and  viaducts,  mobile  homes,  solar  panels,  power  plants,  electrical 
substations, pipelines, water sewage plants, and open dump sites). 
33 European Environment Agency Land take in Europe, fig. 6 
34 Idem. 
35 United Nations Convention to Combat Desertifcation, Prais3  

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
Figure  11:  Land  take  and  re-cultivation 
(m2/km2), 2012-201836 

in  EU27 

conservation status increased from 27% to 31% in the EU 
compared to 2015. 

Estonia  12 

In  Estonia,  forests  cover  58.44%  of  the  territory39  and 
52 000 ha are covered by primary forests 40. More than 
75% of the assessments of EU-protected forest habitats 
reveal a bad to poor status41. 

The  National  Forest  Programme  post-2020  is  under 
development and will be finalised by the end of 2022. 

Figure  12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)42 

However,  Estonia  has  not  yet  committed  to  set  Land 
Degradation Neutrality targets under the United Nations 
Convention to combat Desertification (UNCCD).37  

As  already  stated  in  the  EIR  2019,  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. 

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
part  of  the  ‘Fit  for  55’  package.  The  strategy  promotes 
the many services that forests provide. Its key objective 
is to ensure healthy, diverse and resilient EU forests that 
contribute significantly to the strengthened biodiversity 
and  climate  ambitions.  Forests  are  important  carbon 
sinks, and conserving them is vital if the EU is to achieve 
climate neutrality by 2050. 

Out of the 27% of the EU forest area protected under the 
Habitats Directive, less than 15% of assessments show a 
In  2018,  bad 
favorable 

conservation 

status38. 

36 European  Environment  Agency,https://www.eea.europa.eu/data-
and-maps/indicators/land-take-3/assessment 
37  United  Nations  Convention  to  Combat  Desertification,  The  LDN 
Target Setting Programme 
38 European Environment Agency, State of Nature in the EU 
39  European  Environment  Agency,  Forest  information  system  for 
Europe. 
40 European Commission, JRC, Mapping and assessment of primary and 
old-growth forests in Europe, p. 13. 

The  European  Union  Timber  Regulation  (EUTR)43, 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested  timber.  In  accordance  with  the  EUTR,  EU 
Member  States’  competent  authorities  must  conduct 
regular  checks  on  operators  and  traders,  and  apply 
penalties  for  non-compliance.  With  the  amendment  of 
Article 20 of the EUTR, reporting every 2 years has been 
changed  to  annual  reporting,  and  covers  the  calendar 
year as of 2019. 

In  the  period  March  2017  -  February  201944,  Estonia 
carried out 825 checks on domestic timber operators. It 
also  carried  out  five  checks  on  operators  importing 
timber. It is estimated that Estonia had 10 000 operators 
placing  domestic  and  450  operators  placing  imported 
timber  types  on  the  single  market  over  the  reporting 
period. 

41 SWD (2021) 652 
42  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
43 Regulation (EU) No 995/2010  . 
44 COM(2020) 629  

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
Estonia  13 

The  new  Deforestation  Regulation45  will  repeal  and 
replace  the  EUTR,  as  it  will  essentially  integrate  and 
improve  the  existing  system  to  check  the  legality  of 
timber. 

Invasive alien species (IAS) 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside changes in land and sea use, overexploitation, 
climate  change  and  pollution).  Besides  inflicting  major 
damage  on  nature  and  the  economy,  many  IAS  also 
facilitate the outbreak and spread of infectious diseases, 
to  humans  and  wildlife.  The 
threat 
posing  a 
Invasive  Alien  Species 
implementation  of  the  EU 
Regulation  and  other  relevant 
legislation  must  be 
stepped  up.  The  biodiversity  strategy  for  2030  aims  to 
manage recognised IAS and decrease the number of ‘red 
list’ species they threaten by 50%. 

The core of the Regulation on IAS46 (the IAS Regulation) 
is the list of IAS of Union concern.  

2022 priority actions 

The total number of IAS of Union concern is currently 66, 
of which: 30 are animal species and 36 are plant species; 
41  are  primarily  terrestrial  species,  23  are  primarily 
freshwater species, 1 is a brackish-water species and 1 is 
a marine species. 

According  to  a  2021  report47  on  the  review  of  the 
application of the IAS Regulation, the implementation of 
the  IAS  Regulation  is  already  starting  to  deliver  on  its 
objectives such as a coherent framework for addressing 
IAS at EU level and increased awareness of the problem 
of  IAS.  At  the  same  time,  the  above  report  identified 
some challenges and areas for improvement. Given that 
the deadlines for implementing the various obligations of 
the IAS Regulation applied gradually between July 2016 
and  July  2019,  it  is  premature  to  draw  conclusions  on 
implementation  of  the  IAS 
several  aspects  of  the 
Regulation.  

A 2021 report48 on the baseline distribution shows that 
of  the  66  species  on  the  Union  list,  11  have  been 
observed in the environment in Estonia. The spread can 
be checked in Figure 13. 

Figure  13:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Estonia, 2021 

 

 

 

 

 

 

 

legally 

site-specific, 

Ensure  sustainable  management  of  forests,  i.a.  by 
adopting the National Forest Programme post-2020.  
Establish 
compliant 
conservation objectives and measures for all SACs. 
To  consider  the  conservation  objectives  of  forest 
habitats  when  developing  the  National  Forestry 
Strategy post-2020.  
To  take  the  necessary  measures  to  ensure  that 
favourable  conservation  status  of  the  relevant 
species  and  habitats  is  also  achieved  in  privately 
owned forests. 
To  take  into  consideration  the  possible  impacts  of 
drainage 
conservation 
objectives  of  protected  habitats  and  species  and 
take any necessary measures to rectify them and not 
to incentivise them through the CAP. 
To 
improve 
in  order 
management  of  60  000  ha  of  semi-natural 
grasslands by 2028. 
To improve the system of implementation of Article 
6, paragraphs 2, 3 and 4 of the Habitats Directive by 
amending the Nature Conservation Act in order to 
ensure  a  stand  alone  appropriate  assessment 
that  an  appropriate 
procedure.  To  ensure 
assessment 
is  carried  out  according  to  the 
requirements  of  Article  6(3)  of  the  Habitats 

infrastructure  on 

intensify  efforts 

the 

to 

45  COM  (2021)  706  A  proposal  for  the  Regulation  on  the  making 
available  on  the  EU  market  and  export  of  products  associated  with 
deforestation and forest degradation. 
46 Regulation (EU) No 1143/2014 of the European Parliament and of the 
Council of 22 October 2014 on the prevention and management of the 
introduction and spread of invasive alien species 
47  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 

October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 
48  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D'  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines,  EUR 
30689  EN,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, ISBN 978-92-76-37420-6, doi:10.2760/11150, JRC123170. 

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
 
Estonia  14 

Figure  14:  Level  of  adequacy  of  GES  determination  by 
Estonia  (BAL  region)  with  criteria  set  under  the 
Commission  GES  Decision  -    Article  9  (2018  reporting 
exercise)52 

Estonia has one marine sub-region, BAL-Baltic Sea.   

In this marine sub-region, seven out of 11 determinations 
of GES were assessed as good or very good. The national 
determination of GES by Estonia is consistent for seven 
out of 11 descriptors. 

The  MSFD  also  requires  that  Member  States  make  an 
assessment of the current environmental status of their 
marine waters in relation to the determination of GES. A 
good or very good score indicates the Member State has 
good capabilities for assessing its marine environment in 
accordance  with  the  requirements  set  out 
in  the 
Commission GES Decision. 

Directive  before  granting/renewing  permits  for 
forest logging (forest notifications). 

Marine ecosystems 

The EU Biodiversity Strategy  2030 aims to substantially 
reduce  the  negative  impacts  on  sensitive  species  and 
habitats  in  marine  ecosystems  and  to  achieve  good 
environmental status as well as eliminate or reduce the  
incidental catches of protected, endangered, threatened 
and  sensitive  species  to  a  level  that  allows  species 
recovery and conservation49. 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 
status (GES) of their marine waters. To that end, Member 
States have to develop marine strategies for their marine 
waters, and cooperate with Member States sharing the 
same  marine  region  or  subregion.  These  marine 
strategies comprise different steps to be developed and 
implemented over six-year cycles. 

Among  other  obligations,  the  MSFD  requires  Member 
States  by  15  October  2018  to  define  a  set  of  GES 
characteristics  for  each  descriptor  (article  9),  and  to 
provide  an  initial  assessment  of  their  marine  waters 
(article  8).  The  Commission  then  assesses  whether  this 
constitutes  an  appropriate  framework  to  meet  the 
requirements of the Directive. 

The Commission assessed Estonia’s 2018 determinations 
of GES for each MSFD’s 11 descriptors50 and determined 
their  level  of  adequacy  in  relation  to  the  Commission 
Decision  on  criteria  and  methodological  standards  on 
GESof  marine  waters51.  A  good  or  very  good  score 
indicates  that  the  national  determinations  of  GES  are 
well  aligned  with  the  requirements  of  the  Commission 
GES  Decision,  providing  qualitative  and  quantitative 
national  environmental  objectives  to  be  achieved  for 
their marine waters. 

49  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
50  Annex  I  of  Directive  2008/56/EC  establishing  a  framework  for 
community action in the field of marine environmental policy (Marine 
Strategy Framework Directive), OJ L 164, 25.6.2008, p. 19–40. 
51  This  assessment  was  made  in  relation  to  the  ”Commission  GES 
Decision“, Commission Decision No 2017/848, pp. 43-74. 

52    Assessment  carried  out  by  the  European  Commission  of  the  data 
reported  by  the  MS,  January  2022.  Please  note  that  only  two  sub-
sections  of  descriptor  D1  are  displayed  (D1-M  Mammals  and  D1-B 
Birds). For  the analysis, these two sub-sections were considered as  a 
whole after averaging them. 

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
 
Figure  15:  Level  of  adequacy  of  initial  assessment  of 
Estonia’s marine environment (BAL region) with criteria 
set under the Commission GES Decision - Article8 (2018 
reporting exercise) 53 

recommendations per Member States and region on 
the 2018 updated reports for Articles 8, 9 and 10 of 
the MSFD.  

Estonia  15 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States to better integrate biodiversity considerations into 
public and business decision making at all levels and to 
develop  natural  capital  accounting.  The  EU  needs  a 
better performing biodiversity observation network and 
the  condition  of 
reporting  on 
more  consistent 
ecosystems.   

An ecosystem assessment is an analysis of the pressures 
on  –  and  the  condition  of  –  terrestrial,  freshwater  and 
marine  ecosystems  and  their  services.  It  uses  spatially 
explicit  data  and  a  comparable  methodology  based  on 
European data about the functions of  ecosystem assets 
and the ecosystem services they produce.   

Ecosystem  accounting  is  built  on  five  core  accounts 
(ecosystem  extent,  ecosystem  condition,  physical 
ecosystem  services,  monetary  ecosystem  services  and 
monetary  ecosystem  assets).  These  accounts  are 
compiled  using  indicators  of  ecosystem  assets  and  the 
ecosystem services they produce.   

In  2020,  countrywide  biophysical  mapping  and 
assessment  of  ecosystem  services  (MAES)  of  the  main 
terrestrial ecosystems (>99% of the area of the mainland 
natural ecosystems) was completed in the course of the 
national MAES project ELME (Establishment of tools for 
integrating socioeconomic and climate change data into 
assessing  and  forecasting  biodiversity  status,  and 
ensuring  data  availability)  co-funded  by  the  European 
Union  Cohesion  Fund  and  the  national  foundation 
Environmental Investment Centre. As an outcome, maps 
of  the  extent,  condition  of  ecosystems  and  ecosystem 
services  were  made  publicly  available  and  are  being 
implemented  in  practice  (e.g.  in  spatial  planning).  In 
2021–2023,  countrywide  socioeconomic  mapping  and 
assessment  of 
is 
conducted  under  the  ELME  project.  Maps  of  selected 
marine ecosystem services created in the ELME project 
in 2019 are integrated into the maritime spatial planning 
process.    

terrestrial  ecosystem 

services 

LIFE IP CleanEst project58 (2019–2028) is developing and 
implementing  methodology  for  MAES  of  freshwater 

9  descriptors  out  of  11  scored  as  good  or  very  good. 
Estonia’s  assessment  of 
is 
consistent  with  the  requirements  set  under  the 
Commission GES Decision for nine out of 11 descriptors. 

its  marine  environment 

the  MSFD54,  while 

As  highlighted  in  the  Commission’s  report  on  the 
regional 
implementation  of 
cooperation  has  improved  since  the  adoption  of  the 
MSFD, more cooperation is needed to attain full regional 
coherence  of  the  marine  strategies,  as  required  by  the 
Directive.  
Furthermore, in March 2022, the European Commission 
published a Communication55 with recommendations for 
Member States. The Commission assessment  highlights 
that  Member  States  need  to  step  up  their  efforts  to 
determine the good environmental status and the use of 
the  criteria  and  methodological  standards  according  to 
the Commission GES Decision. The above considerations 
form the basis for the 2022 priority actions. 

2022 priority actions  

 

 

Ensure  regional  cooperation  with  Member  States 
sharing  the  same  marine  (sub)  region  to  address 
predominant pressures.  
Implement  the  recommendations  made  by  the 
in  the  Staff  Working  Document56 
Commission 
on 
accompanying 

Communication57 

the 

53  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported  by  the  MS,  January  2022.  Please  note  that  only  two  sub-
sections  of  descriptor  D1  are  displayed  (D1-M  Mammals  and  D1-B 
Birds). For  the analysis, these two sub-sections were considered as  a 
whole after averaging them. 
54 COM(2020) 259  

55 COM(2022)550. 

56  SWD(2022)1392. 
57 COM(2022)550. 
58 LIFE project number LIFE17 IPE/EE/000007 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
                                                                 
 
 
ecosystems,  initially  at  regional  level  (in  northeastern 
Estonia),  with  potential  perspective  to  upscale  to  a 
countrywide 
initial  assessments  were 
completed in 2021. 

level.  The 

Eurostat  has  provided 
for  piloting 
ecosystem  accounts  in  Estonia.  The  first  results  were 
published  in  2019,  the  latest  project  lasts  from  2021–
2023.  

three  grants 

As  Figure  15  shows  significant  progress  has  been 
recorded regarding national MAES actions since January 
2016  (this  assessment  is  based  on  27  implementation 
questions and updated every six months).  

Although  there  are  a  multitude  of  open-source  large-
scale data sets covering Estonia,  compiling those in the 
countrywide mapping exercise has been challenging.  

Creating  one  whole  national  natural  capital  accounting 
system  will  be  the  joint  effort  of  different  MAES  and 
accounting projects, governmental institutions, scientists 
and NGOs in the coming years. Uptake of the results by 
decision makers and other users will be crucial. 

Figure 16: ESMERALDA MAES Barometer (January 2016 
- March 2021)59 

Estonia  16 

Progress  on  ecosystem  accounting  implementation  is 
assessed on a national scale based on 13 questions (see 
Figure 17). 

Figure 17: Ecosystem accounting Barometer60 

2022 priority action 

 

Continue supporting the mapping and assessment of 
ecosystems  and  their  services,  and  ecosystem 
accounting  development, 
through  appropriate 
indicators 
integrating  ecosystem  extent, 
for 
condition  and  services  (including  some  monetary 
values) into national accounts; continue supporting 
the  development  of  national  business  and 
biodiversity  platforms, 
including  natural  capital 
accounting systems to monitor and value the impact 
of business on biodiversity. 

59 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem assessment: summary for policymakers, p. 80, May 2021. 
60  MAIA  Portal,  Mapping  and  assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Experimental  Ecosystem 

Accounting (SEEA-EEA) as the methodological basis for the ecosystem 
accounting. The SEEA EA is an integrated an comprehensive statistical 
framework  that  is  based  on  five  core  accounts:  ecosystem  extent, 
condition, services and monetary ecosystem asset. 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
 
 
 
                                                                 
Clean air 

Figure  18:  Emission  trends  of  main  pollutants/  GDP  in 
Estonia, 2005-201968 

3. Zero Pollution

Estonia  17 

 EU clean air policies and legislation need to significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of  key  air  pollutants. Air  pollution  and  its  impacts  on 
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  clean-air  legislation  and  defining 
strategic  targets  and  actions  for  2030  and  beyond. The 
2030 zero-pollution action-plan targets are to reduce the 
health impacts of air pollution by 55% and to reduce the 
EU  ecosystems  threatened  by  air  pollution  by  25%, 
compared to 2005. 

The EU has developed a comprehensive suite of air quality 
legislation,  which  establishes  health-based  air  quality 
standards61and  emission  reduction  commitments62  per 
Member State for several air pollutants. 

Air  quality  in  Estonia  is  generally  good  with  exceptions. 
The  latest  available  annual  estimates  (for  2019)  by  the 
European  Environment  Agency63  point  to  about  500 
premature  deaths  (or  5  600  years  of  life  lost  (YLL)) 
attributable  to  fine  particulate  matter  concentrations64, 
(400  YLL)  to  ozone 
and 
concentration6566. 

  30  premature  deaths 

Figure 19: PM2.5 and NOx emissions by sector in Estonia, 
201969 

The  emissions  of  key  air  pollutants  have  decreased 
significantly  in  Estonia  over  the  last  years,  while  GDP 
growth  continued  (see  graph).    According  to  the  latest 
projections  required  under  Article  10(2)  of  the  National 
Emission  reduction  Commitments  Directive  (NECD)67. 
Estonia 
reduction 
commitments  for  all  air  pollutants  covered  by  the 
Directive  for  the  period  2020  to  2029  and  for  2030 
onwards. The llatest inventory data submitted by Estonia, 
prior to review by the Commission, indicate that Estonia is 
in compliance with the emission reduction commitments 
for all pollutants in 2020. 

reach  emission 

forecast 

to 

is 

Estonia  submitted 
Programme on 29 March 2019. 

its  National  Air  Pollution  Control 

61European Commission, 2016. Air Quality Standards. 
62 European Commission, Reduction of National Emissions  
63 European Environment Agency, Air Quality in Europe –2021 Rapport. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106 
64  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 

(PM2.5) refers to  particles with a  diameter  of  10  (2.5) micrometres or 
less. PM is emitted from many human sources, including combustion. 
65 Low-level ozone is produced by photochemical action on pollution. 
66  Please  note  that  these  figures  refer  to  the  impacts  of  individual 
pollutants; to avoid double-counting they cannot be summed up.  
67  Directive 2016/2284/EU. 
68 European Environment Agency. 
69 European Environment Agency. 

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
 
Estonia  18 

impact 
Green  Deal,  the  Commission  undertook  an 
assessment for the revision of the IED in 2021 with a view 
to  tabling  a  proposal  in  202272.  The  revision  seeks  to 
enhance the directive’s contribution to the zero pollution 
objective, as well as its consistency with climate, energy 
and circular economy policies. 

The  below  overview  of  industrial  activities  regulated  by 
IED is based on data reported to the EU Registry (2018)73. 

In Estonia, around 150 industrial installations are required 
to  have  a  permit  based  on  the  IED.  The  distribution  of 
installations is shown in the figure below. 

The  industrial  sectors  in  Estonia  with  the  most  IED 
installations  in  2018  are  the  intensive  rearing  of  poultry 
and pigs (35%), followed by the energy sector (16%), the 
waste  management  sector  including  landfills  (15%),  and 
the production of chemicals (7%). 

Figure  20:  Number  of  IED  industrial  installations  per 
sector in Estonia, 201874 

The industrial sectors identified as  contributing  with  the 
largest emissions to air were the energy sector (for sulphur 
oxides (SOx), nitrogen oxides (NOx), as well as for arsenic 
(As), cadmium (Cd), chromium (Cr), copper (Cu), mercury 

For the year 2020, no exceedances above the limit values 
established by the  Ambient  Air Quality Directive (AAQD) 
were registered70. 

In 2019 Estonia received a  priority action with regard to 
the National Air Pollution Control Programme (NAPCP). It 
is maintained given the need to ensure continued and full 
implementation. 

2022 Priority actions 

 

 

Take,  in  the  context  of  the  NAPCP,  actions 
towards  reducing  emissions  from  the  main 
sources mentioned above. 
Ensure  full  compliance  with  the  EU  air  quality 
standards  and  maintain  downward  emissions 
trends  of  air  pollutants,  to  reduce  adverse  air 
pollution impacts on health and economy, with a 
view to reach WHO guideline values in the future. 

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;   
(iv) clean up contaminated sites. 
To  achieve  this,  the  EU  takes  an  integrated  approach  to 
prevention and control of routine and accidental industrial 
emissions. The cornerstone of the policy is the Industrial 
Emissions Directive71 (IED).  As announced in the European 

70 European Environment Agency, Eionet Central Data Repository 
71  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). 

72  The  revision  of  the  IED  is  performed  in  parallel  to  the  revision  of 
Regulation  (EC)  No  166/2006  on  the  European  Pollutant  Release  and 
Transfer Register (E-PRTR). 
73 European Environment Agency, European Industrial Emissions Portal. 
74  European  Environment  Agency,  EU  Registry,    European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

Environmental Implementation Review 2022 – Estonia 

 
 
 
                                                                 
 
 
Estonia  19 

Figure 22: Relative releases to water from industry in 
Estonia, 201877 

(Hg),  nickel  (Ni),  lead  (Pb),  zinc  (Zn),  particulate  matter 
(PM2.5) and dioxins). Other contributing activities were the 
intensive  rearing  of  poultry  or  pigs,  ammonia  (NH3)  and 
surface  treatment  and  pulp,  paper  and  wood  products 
sector. The breakdown is shown in the following graph. 

Figure  21: Emissions to air from IED sectors and rest of 
national total air emissions in Estonia, 201875 

for  potentially  polluting 

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  forenables  the  public  to  have  access  to 
relevant information and to participate in the permitting 
process 
installations.  This 
empowers the public and NGOs to ensure that permits are 
appropriately  granted  and  that  the  conditions  of  these 
permits  are  complied  with.  As  part  of  environmental 
inspection, competent authorities undertake site visits at 
IED installations to take samples and to gather necessary 
information.  According  to  Article  23(4)  of  the  IED,  site 
visits must be carried out between once a year and once 
every  3  years,  depending  on  the  environmental  risks 
posed by the installations. In 2018, Estonia undertook 59 
site  visits,  the  majority  of  which  were  to  the  intensive 
rearing of poultry and pigs (25%), followed by the energy 
sector  (24%)  and  waste  management  sector,  including 
landfills (19%). 

In 2017, Estonia was the Member State with the highest 
damage  costs  aggregated  over  all  pollutant  groups 
normalised  against  GDP76,  principally  due  to  emissions 
from the energy sector, notably oil shale burning. 

The  environmental  burdens  for  industrial  emissions  to 
water mainly result from the pulp, paper and wood sector 
as  well  as  from  the  energy  sector  for  heavy  metals  and 
total  organic  carbon.  The  breakdown,  based  on  E-PRTR 
data, is presented in the figure below. 

75  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 
76  ETC/ATNI  Report  04/2020:  Costs  of  air  pollution  from  European 
industrial facilities 2008–2017 
77  European  Commission,  European  Environment  Agency,  E-PRTR, 
European  Industrial  Emissions  Portal.  The  heavy  metals  are  presented 

both  as  a  weighted  sum  of  eco  toxicity  and  human  toxicity  factors  to 
illustrate both the ecological and human impact (based on USEtox) (data 
retrieved on 3 November 2021). 

Environmental Implementation Review 2022 – Estonia 

 
 
 
                                                                 
 
Figure 23: Number of inspections in IED installations in 
Estonia in 201878 

Major industrial accidents prevention – 
SEVESO 

Estonia  20 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to:  
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals;   
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment;   
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents.   
The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso-III Directive) 
80. 

The  below  overview  of  industrial  plants  regulated  by 
Seveso-III Directive, (‘Seveso establishments’), is based on 
data  reported  to  the  eSPIRS  database  (2018)81  and  the 
Estonia  report  on  the  implementation  of  the  Seveso-III 
Directive for the period 2015-201882. 

In  Estonia,  among  the  62  Seveso  establishments,  31  are 
categorised as  lower-tier establishments (LTE) and 31 as 
upper-tier establishments (UTE)  – based on the quantity 
of hazardous substances likely to be present. The UTE are 
subject to more stringent requirements. The development 
of  the  number  of  Seveso  establishments  is  presented  in 
Figure 24.  

Figure 24: Number of Seveso establishments in Estonia, 
2011, 2014 and 201883 

The  development  of  best-available-technique 
(BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED79. Since the last 
EIR report, the Commission adopted BAT conclusions for 
Estonia for: (i) waste incineration; (ii) the food, drink and 
dairy industries; and (iii) surface treatment using organic 
solvents  including  the  preservation  of  wood  and  wood-
products with chemicals.  

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reductions in pollution.  In 2019, Estonia 
received priority actions to review permits to comply with 
newly adopted BAT conclusions and to strengthen control 
and  enforcement  to  ensure  compliance  with  BAT 
conclusions. These actions have been followed up by the 
Commission  through  the  reporting  by  Estonia  to  the  EU 
Registry.  No  non-compliant  permits  were  reported  in 
2018.  Estonia  also  received  a  priority  action  to  address 
water  and  air  pollution  from  the  power  sector  and 
intensive  rearing  of  poultry  or  pigs.  The  Commission 
follows up the latter aspect via the implementaton of the 
BAT  conclusions  for  intensive  rearing  of  poultry  or  pigs, 
which were to be reflected in permits by February 2021. 
As  mentioned  above,  emissions  from  the  energy  sector 
needs to be addressed by the implementation of the BAT 
conclusions on large combustion plants by August 2021.  

2022 priority action 

 

Continue addressing the emissions to air from the 
energy sector and the intensive rearing of poultry 
and pigs. 

Many  Seveso  establishments  are  required  to  draw  up 
external emergency plans (EEPs). These EEPs are essential 
to allow proper preparation and effective implementation 
of the necessary actions to protect the environment and 

78 EU Registry (data retrieved on 3 November 2021). 
79 European Commission BAT reference documents. 
80  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances. 
81 European Commission, Seveso Plants Information Retrieval System. 

82 As provided for by Article 21(2) of the Seveso-III Directive. 
83 European Commission, Assessment and summary of Member States’ 
Implementing  Decision  2014/896/EU 
implementation  reports  for 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
                                                                 
 
 
 
the population should a major industrial accident occur at 
them. 

According  to  Estonia,  the  EEP  is  required  for  26  UTE.  In 
2018, 27 UTE had an EEP and 13 of these EEP had been 
tested over the last three years. The summary is shown in 
Figure 25. The establishment of EEPs is essential to allow 
proper  preparation  and  effective  implementation  of  the 
necessary  actions  to  protect  the  environment  and  the 
population 
accident 
a  major 
should 
nevertheless happen. 

industrial 

Figure 25: Situation regarding EEP in Estonia, 201884 

The information to the public referred to in Annex V of the 
Seveso-III  Directive  –  especially  about  how  the  public 
concerned will be warned in the event of a major accident; 
the  appropriate  behaviour  in  the  event  of  a  major 
accident;  and  the  date  of  the  last  site  visit  –  are 
the  Seveso 
permanently  available 
establishments in Estonia.  

for  84%  of 

The  share  of  UTE  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available to the public over the last years are presented in 
Figure 26. This is an important provision of the Seveso-III 
Directive  as  public  awarness  of  this  information  may 
reduce the consequences of a major industrial accident. 

84 Idem. 
85 Idem. 
86 Directive 2002/49/EC 
87 WHO 2018, Environmental Noise Guidelines for the European Region 
88  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
89 These figures are an estimation by the European Environmental Agency 
based on  : (i) the  data  reported  by  Member  States  on noise exposure 
covered  by  Directive  2002/49/EC; (ii) ETC/ATNI,  2021, Noise indicators 
for 
under 

the  Environmental Noise Directive  2021: Methodology 

Estonia  21 

Figure 26: Share of UTE for which information on safety 
measures and requisite behaviours were actively made 
available to the public in Estonia, 2011, 2014 and 201885 

Estonia  has  some  issues  related  to  transposition  of  the 
Seveso 
III  Directive  which  are  the  subject  og  the 
infringement  case.  Estonia  has  incorrectly  transposed 
everal provisions of the Directive, ranging from time limits 
for supplying information to key definitions. 

2022 priority action 

 

Strengthen  control  and  enforcement  to  ensure 
compliance  with  Seveso-III  provisions,  especially  on 
information to the public and EEP. 

Noise 

The  Environmental  Noise  Directive86  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping  and  planning.   A  relevant  2030  zero  pollution 
action  plan  target  is  a  reduction  by  30%  of  the  share  of 
people chronically disturbed by transport noise compared 
to 2017.    

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress87. 

In Estonia, based on a limited set of data88, environmental 
noise is estimated to cause at least around 60 premature 
deaths  and  200  cases  of 
ischaemic  heart  disease 
annually89.  Moreover,  some  11  000  people  suffer  from 

on 

Air 

Pollution, 

estimating missing data, ETC/ATNI Report No 2021/06, European Topic 
Industrial 
Centre 
impact 
Pollution; (iii) the methodology 
calculations, ETC/ACM,  2018,  Implications  of  environmental noise on 
health  and  wellbeing  in  Europe,  Eionet  Report  ETC/ACM  No  2018/10, 
European Topic Centre on Air Pollution and Climate Change Mitigation. 

Transport, Noise and 

health 

for 

Environmental Implementation Review 2022 – Estonia 

 
 
 
                                                                 
 
disturbed  sleep.  In  Estonia,  the  overall  noise  exposure 
decreased  by  3%  between  2012  and  2017  based  on 
reported  data.  On  the  basis  of  the  latest  full  set  of 
information  that  has  been  analysed,  noise  mapping  of 
agglomerations, roads and railways is complete. 

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 . 

Water Framework Directive 

is 

(WFD)90 

The  Water  Framework  Directive 
the 
cornerstone of EU water policy in the 21st century91. The 
WFD  and  other  water-related  directives,92  set  the 
integrated  water 
sustainable  and 
framework 
management, which aims at a high level of protection of 
water resources, prevention of further deterioration and 
restoration to good status.  

for 

Estonia  22 

ofthe  existing  total  of  39  groundwater  bodies,  activities 
were  conducted  in  19  groundwater  bodies,  with  71%  of 
the  planned  measures  implemented  and  further  3%  in 
process of being implemented. Out of the existing total of 
750 surface water bodies, activities were conducted in 395 
surface water bodies, with 56% of measures implemented 
and  a further 10% of measures partially completed. For 
the remaining 34% of the surface water measures and 26% 
of groundwater measures, no information was available. 
In conclusion, the available data shows that the planned 
and  implemented  measures  contribute  significantly  to 
reaching the objectives of the WFD in 2021 and 2027. 

Based on the second  RBMPs reporting and data published 
in  202096,  in  Estonia  60.1%  of  all  surface  water  bodies97 
reach good ecological status (with unknown status 0.1%) 
and  only  9.7%  have  good  chemical  status 
(with 
unknown 88.3%).  For  groundwaters,  20.5  %  failed  to 
achieve  good  chemical  status  and  2.6%  are  in  poor 
quantitative status. 

The  figure  below  illustrates  the  proportion  of  surface 
water bodies in Estonia and other European countries that 
failed to achieve good ecological status. 

Figure  27:  Proportion  of  surface  water  bodies  (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District98 

By  March  2022,  all  Member  States  were  requested  to 
submit  the  third  generation  of  River  Basin  Management 
Plans  (RBMPs)  under  the  WFD.    Estonia  has  not  yet 
adopted and reported the thirdrd RBMPs. When received, 
the  Commission  will  assess  the  reported  status  and 
progress,  checking  how  the  findings  identified  in  the 
assessment of the second RBMPs93 have been addressed. 

The  Commission  published  in  December  2021  the  6th 
Implementation  Report,  which  assesses  implementation 
of the WFD and the Floods Directive94. This report includes 
an  assessment  of:  (i)  the 
implementation  of  the 
programmes  of  measures;  and  (ii)  the  new  priority 
substances. The assessment  report  for Estonia95 showed 
that  implementation  of  the  measures  set  out  in  the 
programme of  measures (PoM) have been implemented 
to  a  satisfactory  level,  especially  for  groundwater.  Out 

90 The Water Framework Directive (2000/60/EC). 
91 The EU Water Policy. 
92  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban Waste Water Treatment Directive (91/271/EEC), the new Drinking 
Water  Directive  (2020/2184/EC),  the  Nitrates  Directive  (91/676/EEC), 
the  Marine  Strategy  Framework  Directive  (2008/56/EC),  the  Industrial 
Emissions Directive (2010/75/EU) and the new Regulation on minimum 
requirements for water reuse (2020/741). 

93  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
94  See the 6th Implementation Report of the WFD and FD. 
95  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Estonia, 2022. 
96  WISE Freshwater (europa.eu) 
97 River, lake, transitional, coastal, territorial 
98 European Environment Agency, 2O21.   

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
The  following  figure  presents  the  percentage  of  surface 
water  bodies  in  Estonia  and  other  European  countries 
failing  to  achieve  good  chemical  status.  For  Estonia  the 
percentage is 2%, if water bodies failing due to substances 
(Persistent,  Bio-
behaving 
accumulative,  Toxic)  are  included.  Without  ubiquitous 
PBTs, 1% of surface water bodies are failing good chemical 
status (with unknown 88%). 

ubiquitous 

PBTs 

as 

Figure  28:  Percentage  of  surface  water  bodies  not 
achieving good chemical status99  

Under  the  IED  framework,  it  should  be  stressed  that 
Estonia showed a significant decrease over the last decade 
(15.4%) in industrial releases of heavy metals like Cd, Hg, 
Ni,  Pb  and  55.3%  in  TOC  (Total  Organic  Carbon)  to 
water100. 

2.77% 

for  manufacturing, 

The total water abstracted annually (corresponding to the 
2019 baseline) in Estonia from surface and groundwater 
sources  is  2.479.89 hm3  (EEA,  2022).  The  percentage  for 
water  abstraction  per  sector  is  0.20%  for  agriculture, 
2.28%  for  public  water  supply,  27.58%  for  electricity 
60.30% 
cooling, 
for 
manufacturing  cooling  and  6.87% 
for  mining  and 
quarrying,  as 
in  the  following  figure.  In 
Estonia,  water abstractions are not recorded in a separate 
register. 
in 
Keskkonnaregister (Environmental Registry).  The registry 
is  updated  on  the  basis  of  annual  self-reporting  by  the 
permit  holders  to  the  permitting  authority.  Small 
abstractions do not require permits in Estonia. 

the  relevant  data  are  kept 

illustrated 

Instead, 

Estonia  23 

Figure 29: Water abstraction per sector in Estonia101 

Recent data are not available for water exploitation index 
plus102 in Estonia103.  

It is worth to mention that in Estonia, the Cohesion Fund 
project  ‘Restoration  of  habitats  in  Pärnu  river  basin’, 
removed  seven  dams  from  the  river  and  its  tributaries 
between 2015 and 2021, establishing a 3 000 km network 
of  free‑flowing  water.  In  particular,  removing  the  Sindi 
dam, located close to the river mouth, made an important 
contribution  to  increasing  spawning  habitats  (EEA,  Dec 
2019).  According to 2021 information collected by  Dam 
Removal Europe, the positive results of the removal of the 
Sindi  dam  seem 
included  a  significant 
improvement of the fish population and caused change in 
the  perceptions  of  dam  removal  by  being  a  source  of 
inspiration for future projects in Estonia. 

to  have 

Floods Directive 

As  mentioned,  the  Commission  published  the  sixthth 
implementation  report  in  December  2021.  It  includes, 
amongst others, the review and update of the preliminary 
flood  risk  assessments  during  the  second  cycle  (2016-
2021). 

The  assessment  report104  showed  that  Estonia  has 
developed  a  national  spatial  data  portal  that  presents 
clear  information  on  flood  risk  areas  and  receptors  and 
allows  the  general  public  and  other  users  to  select  and 
download information on a variety of scales. However, it 
is  not  clear  how  future  floods  have  been  assessed;  a 

99 European Environment Agency, December 2019. 
100 European Environment Agency, June 2021. 
101  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
102 The Water Exploitation Index plus (WEI+) is a measure of total fresh 
water  use  as  a  percentage  of  the  renewable  fresh  water  resources 
(groundwater and surface water) at a given time and place. It quantifies 

how much water is abstracted and how much water is returned after use 
to the environment. 
103  European Environment Agency (EEA), Water Exploitation index  
104  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 
Identification of Areas of Potential Significant Flood Risk under the Floods 
Directive : Member State : Estonia, 2022 

Environmental Implementation Review 2022 – Estonia 

 
 
 
                                                                 
 
 
Estonia  24 

Figure  30:  Bathing  water  quality  in  Europe  in  the  2020 
season110 

Figure 31: Bathing water quality 2017-2020111 

general statement is made that these are the same as past 
floods, regarding locations, area, significance and impacts. 
A more detailed description of the methodology applied 
would benefit the reliability of the assessment results. The 
descriptive evaluation could be more quantitative, as well. 

Estonia has not yet reported on the second generation of 
Flood Risk Management Plans (FRMPs) under the Floods 
Directive.  The  European  Commission  will  assess  the 
progress since the adoption of the first FRMPs  and publish 
a new report, asin 2019. 

Drinking Water Directive 

On the Drinking Water Directive105, no new assessment of 
the quality of Drinking Water is available since  the  2019 
EIR. The quality of drinking water in Estonia has not been 
indicated as an area of concern. 

The recast Drinking Water Directive106 entered into force 
on  12  January  2021,  and  Member  States  have  until  12 
January  2023  to  transpose  it  into  their  national  legal 
system.  Estonia  will  have  to  comply  with  the  reviewed 
quality standards. 

Bathing Water Directive 

Regarding  the  Bathing  Water  Directive,  Figure  31  shows 
that in 2020, out of the 64 Estonian bathing waters sites, 
62.5%  were of excellent  quality,107. Detailed information 
on  Estonian  bathing  waters  is  available  from  a  national 
portal  108  and  via  an  interactive  map  viewer  of  the 
European Environment Agency 109. 

Nitrates Directive 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive112,  referring  to  the  period  2016-
2019113,  warns  that  nitrates  are  still  causing  harmful 
pollution  to  water  in  the  EU.  Excessive  nitrates  in  water 
are  harmful  to  both  human  health  and  ecosystems, 
causing  oxygen  depletion  and  eutrophication.  Where 
national authorities and farmers have cleaned up waters, 
it has had a positive impact on drinking water supply and 

110 European Environment Agency, Bathing Water Quality in 2020, 2022. 
111  European  Environment  Agency,  European  Bathing  Water  Quality  in 
2017, 2018, 2019, 2020. 
112 Council Directive 91/676/EEC 
113 COM(2021) 1000 final 

105 OJ L 330, 5.12.1998, pp. 32–54. 
106 OJ L 435, 23.12.2020, pp. 1–62. 
107  European  Environment  Agency,  2021.  State  of  bathing  water  — 
European Environment Agency (europa.eu)  , p. 17. 
108 http://vtiav.sm.ee/index.php/?active_tab_id=SV 
109 EEA, State of bathing waters in 2020 — European Environment Agency 
(europa.eu) 

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
 
biodiversity,  and  on  the  sectors  such  as  fisheries  and 
tourism  that  depend  on  them.  Nevertheless,  excessive 
fertilisation remains a  problem in  many parts of the EU. 
Compliance with the Nitrates Directive is a prerequisite for 
reaching  the  objective  of  reducing  nutrient  losses  by  at 
least  50%  by  2030  enshrined  in  the  EU  Biodiversity  and 
Farm  to  Fork  Strategies.  It  calls  for  rapid  action,  which 
should  start  with  the  full  enforcement  of  the  related 
legislation. 

In  Estonia,  the  surplus  of  nitrogen  is  low  and  there  is  a 
deficit of phosphorus. There is a well-developed network 
of  monitoring  stations  and  the  groundwater  quality  is 
generally good. However, a high number of surface waters 
are eutrophic, in and outside nitrate vulnerable zones and 
for both inland and marine waters. Estonia is one of seven 
Member  States  that  have  hotspots  where  nitrates 
pollution should be urgently diminished114. 

Urban Waste Water Treatment Directive 

In  Estonia  the  compliance  rate  with  the  Urban  Waste 
Water  Treatment  Directive  (UWWTD)  is  99%  which  is 
higher than the EU average in 2018. Estonia has met the 
targets for collection of urban waste water and biological 
treatment  of  urban  waste  water.  Further  efforts  are 
needed to provide biological treatment with nitrogen and 
phosphorus removal to additional 0.01 million population 
equivalent (p.e.) of urban waste water (0.8%). 

According  to  a  Commission’s  report115,  in  line  with  the 
UWWTD, Estonia is required to provide in urban areas: 

 
Collection of 1.5 million p.e. of waste water; 
  Biological treatment to 1.4 million p.e. of waste 

water; 

  Biological treatment with nitrogen removal to 1.3 

million p.e. of waste water. 

Estonia reuses 91.9 % of waste water sludge in agriculture 
and landfills the remaining 8.1 %. 

The  main  pollution  sources  to  coastal  waters  is  diffuse 
pollution (agriculture, forestry, also cross-border influence 
from  the  open  sea)  and  point  sources.  Discharges  from 
storm  water  overflows  are  not  reported  as  significant 
pressures. 

Estonia  25 

Figure 32: Proportion of urban waste water that  meets 
all  requirements  of  the  UWWTD  (collection,  biological 
treatment,  biological  treatment  with  nitrogen  and/or 
phosphorus  removal)  in  compliant  urban  areas  of  the 
UWWTD (‘compliance rate’), 2018116 

fully 
the  2019  priority  actions  were  not 
Since 
implemented,  they  are  reproposed.  An  action  stemming 
from the Estonia-specific annex to the above-mentioned 
Commission report on the implementation of the Nitrates 
Directive has been added. 

2022 priority actions 

 

  Assess  new  physical  modifications  of  water 
bodies  in  line  with  Article  4(7)  of  the  WFD.  In 
these  assessments,  alternative  options  and 
adequate  mitigation  measures  have  to  be 
considered. 
Continue current efforts to tackle agricultural and 
non-agricultural  pollution  in  water  bodies  and 
continue efforts to establish ecological flows for 
all relevant water bodies. 
the 
Improve 
between water, marine and nature policies. 
Complete  implementation  of  the  Urban  Waste 
Water 
all 
agglomerations,  by  building  up  the  necessary 
infrastructure. 

implementation 

coordinated 

Treatment 

Directive 

for 

 

 

  Revise  the  designation  of  nitrate  vulnerable 
zones  under  the  Nitrates  Directive  to  include 
areas  that  drain  into  waters  that  are  eutrophic 
and revise the action programme in particular to 
reduce and prevent eutrophication of inland and 
marine  surface  waters  where  the  agricultural 
pressure is significant. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 

114 https://ec.europa.eu/commission/presscorner/detail/en/ip_21_5109 
115 Country profiles on urban waste water treatment (europa.eu) 
116 European Commission, WISE Freshwater, 2021. 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
                                                                 
 
Estonia  26 

Estonia has devised and partly implemented both REACH 
and CLP enforcement strategies121. They include: 

 

 

risk-based  prioritisation: 
companies and reactive inspections and 
campaigns  focused  on  new  requirements  and 
issues most frequently raised with the helpdesk. 

focus  on  high-risk 

As a rule, all infringements of REACH are classed as serious 
or very serious environmental administrative offences. If 
the  infringement  is  sufficiently  serious,  the  competent 
authority  may  decide  to  impose  further  penalties  in 
addition  to  a  fine.  That  authority  may  also, where 
necessary, order  the  provisional  seizure  of  assets  and 
documents.  

There were 2 040 REACH checks in Estonia in the reporting 
period. Most  of  them  were    proactive  (inspections),  rather 
than reactive/non-routine (i.e. investigations in response to 
complaints, accidents and referrals). It is worth emphasising 
that non-compliance cases formed a small percentage of 
the total number of checks122. 

Figure 33: Percentage (%) of non-compliance cases out of 
the total number of REACH and CLP controls during 2019 
per Member State and compared to the EU average123 

effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  –  ‘Towards  a  Toxic-Free  Environment’117, 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU’s zero pollution 
ambition  –  a  key  commitment  of  the  European  Green 
Deal. 

legislation118 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.  

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of Chemicals 
(‘the  REACH  Regulation’)  and 
the  Regulation  on 
Classification, Labelling and Packaging (‘CLP Regulation’). 
In December 2020, the Commission assessed the Member 
States’  reports  on  the  implementation  and  enforcement 
of these Regulations119, in line  with Article 117(1) of the 
REACH Regulation and Article 46(2) of the CLP Regulation. 
According 
latest  available  data,  national 
enforcement structures have not changed much in recent 
years. However, it is apparent from this report that there 
are many disparities in the implementation of the REACH 
and  CLP  Regulations,  notably 
law 
enforcement.  Recorded  compliance  levels  in  Member 
States seem to be quite stable over time, but with a slight 
worsening  trend,  which  is  likely  due  to:  (i)  enforcement 
authorities  being  more  effective 
in  detecting  non-
compliant  products/companies;  and  (ii)  more  non-
compliant products being put on the EU market. 

in  the  area  of 

the 

to 

In August 2021, the Commission published a measurable 
assessment  of  the  enforcement120  of  the  two  main  EU 
Regulations on chemicals (the REACH Regulation and the 
CLP  Regulation)  using  a  set  of  indicators  on  different 
aspects of enforcement. 

Responsibility  for  checking  compliance  with  REACH  in 
Estonia lies with the following authorities:  

  Health Board 
 
 
 

Environmental Board 
Estonian Rescue Board 
Consumer  Protection  and  Technical  Regulatory 
Authority 
Labour Inspectorate 
Tax and Customs Board   

 
 

117 COM(2020) 667 final. 
118 REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 
119 European Commission, Final Report on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu). 
120  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators. 

121 Technical assistance to review the existing Member States reporting 
questionnaire  under  articles  117(1)  of  REACH  and  46(2)  of  CLP,  Final 
report, p. 76. 
122 Idem, p.87-88 
123 European Commission, Final Report, on the operation of REACH and 
CLP, pp.87-88, 2022. 

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
 
Estonia  27 

2022 priority actions 

  Upgrade  the  implementation  and  enforcement 
of  administrative  capacities  towards  a  zero 
tolerance to non-compliances. 
Fully implement the REACH and CLP enforcement 
strategies. 

 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
Estonia  28 

4. Climate Action 

of greenhouse gases by 2050 by 80 % in comparison 
with the emission levels of 1990. As the country moves 
towards  this  target,  emissions  will  be  reduced  by 
about  70  %  by  2030  and  by  72  %  by  2040  in 
comparison with the 1990 emission levels. 

In  May  2022,  the  government  adopted  the  ’Estonia 
2035’  strategy  setting  out  five  long-term  strategic 
goals,  including  climate  neutrality  by  2050.  Estonia 
remains a GHG-intensive economy due to its reliance 
on oil shale. It is on the right track towards a significant 
reduction 
in  greenhouse  gas  emissions,  whereas 
additional efforts are needed in specific sectors.  

In its RRP, Estonia allocates over 42% of the budget to 
climate  measures,  including  investments  in  clean 
energy production, energy efficiency and, sustainable 
transport.  

The National Adaptation Strategy was adopted in April 
2017  to  increase  the  readiness  and  capacity  of  the 
state,  the  regional  and  local  level  to  adapt  to  the 
effects of climate change. 

Between 1990 and 2020,  economy wide greenhouse 
gas emissions in Estonia decreased by 65%. However, 
it  is  important  to  contribute  to  renewable  energy 
solutions to cut greenhouse gas emissions.  

Figure  34:  Total  greenhouse  gas  emissions  (incl. 
international aviation) in Estonia, 1990-2020  

climate 

incentivises 
generation, 

legislation 
from  power 

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets 
the  EU  target  of  reaching  climate  neutrality  by  2050 
and reducing greenhouse gas (GHG) emissions by 55% 
by  2030  compared  to  1990.  The  law  also  limits  the 
contribution that carbon removals can make towards 
emission  reductions  in  2030  to  ensure  a  sufficient 
mitigation effort.   
The  EU  and  its  Member  States  submitted  updated 
nationally  determined  contribution  (NDC)  to  the 
UNFCCC in December 2020.   
The EU is working across all sectors and policies to cut 
GHG emissions and make the transition to a climate-
neutral  and  sustainable  economy,  as  well  as 
addressing the unavoidable  consequences of climate 
change.   
EU 
emissions 
industry, 
reductions 
transport, the maritime sector and fluorinated gases 
(F-gases) used in products.   
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010142  and  sets  binding  GHG  emission 
standards for different vehicle categories143.   
Under the F-gas Regulation, the EU’s F-gas emissions 
will be cut by two thirds by 2030 compared with 2014 
levels.  
From  2021,  emissions  and  removals  of  GHGs  from 
LULUCF  have  been  included  in  the  EU  emission-
reduction efforts.   
The  EU  adaptation  policy  is  an  integral  part  of  the 
European Green Deal. From 2021, Member States are 
required  to  report  on  their  national  adaptation 
the  EU  Climate  Law  recognises 
policies144,  as 
adaptation  as  a  key  component  of  the  long-term 
global response to climate change. Member States will 
be required to adopt  national strategies, and the EU 
will  regularly  assess  progress  as  part  of  its  overall 
governance  on  climate  action.  The  updated  EU 
adaptation strategy, published in February 2021, sets 
out how the EU can adapt to the unavoidable impacts 
of  climate  change  and  become  climate  resilient  by 
2050.  

Key national climate policies and strategies  

Estonia has an integrated National Energy and Climate 
Plan (NECP) for the years 2021-2030. The work builds 
on  long-term  energy  and  climate  plans,  and  is  also 
consistent  with  the  Low-Carbon  Strategy  until  2050. 
Estonia’she long-term target  is to reduce the emission 

While  declining,  emissions 
in  the  energy  sector 
account  for  the  largest  share  of  the  greenhouse  gas 
emissions in Estonia and are mostly covered by the EU 
ETS. Although the share of renewable energy sources 
has increased in recent years, energy and heat are still 
predominantly produced from fossil fuels; i.e. oil shale 
and  gas.  Consequently,  Estonia  remains  one  of  the 
most carbon intensive economy in the EU.  

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
 
Effort sharing  

For  emissions  not  covered  by  the  EU’s  emissions 
trading  scheme  (ETS),  Member  States  have  binding 
national targets under the Effort Sharing legislation124. 
Under  EU  legislation,  Estonia  has  a  target  not  to 
increase  greenhouse  gas  emissions  in  the  non-ETS 
sectors  (buildings,  road  and  domestic  maritime 
transport, agriculture, waste and small industries) by 
more than 11% by 2020 and reduce them by 13% by 
2030,  compared  to  2005  (Figure  36).  The  country’s 
non-ETS emissions in 2020  were lower than its 2020 
target.  Over  the  last  few  years,  emissions  have 
decreased  in  industry,  and  the  domestic  transport 
sectors.  

In  its  National  Energy  and  Climate  Plan,  Estonia 
intends to achieve higher reductions than its current 
non-ETS target for 2030 of -13%. Estonia will need to 
put  in  place  more  climate  mitigation  measures  to 
reach the  2030 NECP target. 

Estonia  29 

Figure  35:  Emissions  and  targets  under  the  Effort 
Sharing  Decision/  Effort  Sharing  Regulation 
in 
Estonia,  2020  and  2030  as  percentage  change  from 
2005 

Figure  36:  Emissions,  annual  emission  allocations 
(AEAs)  and  accumulated  surplus/  deficit  of  AEAs 
under  the  Effort  Sharing  Decision  in  Estonia,  2013-
2020 

Key sectoral developments 

In road transport, the GHG intensity of vehicle fuels in 
Estonia  decreased  by  1,8%  from  2010  to  2019.  The 
country  needs  to  act  swiftly  to  meet  the  current 
reduction  target  by  6%.  There  are  several  types  of 
action that Member States can take in this regard, for 
example,  further  expanding  the  use  of  electricity  in 
road  transport,  supporting  the  use  of  biofuels,  in 
particular  advanced  biofuels, 
the 
development  and  deployment  of  renewable  fuels  of 
non-biological origin and reducing upstream emissions 
before  refining  processes. Road  transport  in  Estonia 
represented  17%  of  the  total  greenhouse  gas 
emissions  in  2020.  Emissions  have  increased  by  9% 
compared to 2005.  

incentivizing 

124 Regulation (EU) 2018/842 

Environmental Implementation Review 2022 – Estonia 

 
                                                                 
 
 
 
Estonia  30 

To reach the climate targets, the building stock needs 
to be renovated.  

Figure  38:  Reported  and  accounted  emissions  and 
removals from LULUCF in Estonia 127 

Emissions from agriculture, have increased. 

Figure  37:  Greenhouse  gas  emissions  by  sector  in 
Estonia125  –  historical  emissions  1990-2020, 
projections 2021-2030126 

The Land Use, Land Use Change and Forestry (LULUCF) 
sector, reported decreasing net removals over recent 
years and has switched from net removals in 2019 to 
net emissions in 2020. Furthermore, Estonia projects a 
further decrease of net removals by 2030 due to the  
existing  age  structure  of  its  forests  and  extensive 
forest cover.  

A six-fold decrease of the LULUCF carbon sink has been 
forecasted  by  2030,  as  announced  in  the  Estonian 
National Energy and Climate Plan. Improvements are 
needed  in  this  regard  as  removals  by  sinks  in  the 
LULUCF sector have decreased from 2013 to 2019 (Fig. 
38). Special attention should be brought to this sector 
to allow a sustainable use of biomass and ensure the 
functioning of the forest sink. 

Use of revenues from the auctioning of EU 
ETS allowances 

The  total  revenues  from  the  auctioning  of  emission 
allowances under the EU ETS over the years 2012-2021 
were  nearly  EUR  784  million.  In  2020,  100  %  of  the 
auctioning revenues were spent on climate and energy 
purposes. In Estonia, 50% of auctioning revenues are 
earmarked  and  directed  through  the  four-year  State 
Budget  Strategy  and  spent  on  climate  and  energy 
projects and measures, which may take multiple years. 
Unspent revenues are carried over to later years and 
always used for climate and energy projects.  Around 
48%128  of  the  auctioning  revenues  earmarked  for 
these measures have been covered with sub-decisions 
for  more  concrete  climate  and  energy  actions.  The 
remaining  50%  go  to  the  general  budget,  which, 
among  others,  goes 
to  climate  and  energy 
investments. 

2022 priority actions 

 

 

reduce 

Further 
particularly in buildings and transport. 
transitioning  on 
Prepare 

energy 

climate-neutral 

consumption, 

125 The sectors in the figure correspond to the following IPCC sectors: 
Energy  supply:  1A1,  1B  and  1C.  Energy  use  in  manufacturing 
industries: 1A2. Industrial processes and product use: 2. Transport: 
1A3.  Other  energy  use:  1A4,  1A5  and  6.  Agriculture:  3.  Waste:  5. 
International aviation: 1.D.1.a. 
126  European  Environmental  Agency,  Total  GHG  trends  and 
projections. 

127 The differences between reported and accounted emissions from 
LULUCF under the Kyoto Protocol are described in the ‘explanatory 
note  on  LULUCF  –  accounted  and  reported  quantities  under  the 
Kyoto Protocol’.   
128 The final data will be presented in the report on the use of ETS 
Auctioning  Revenues  under  Regulation  (EU)  2018/1999  on  the 
Governance of the Energy Union and Climate Action. 

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
 
energy  system  (energy  efficiency,  continued 
phasing out of oil shale activities, generation of 
climate-neutral 
and 
electricity, 
cooling). 
Increase  uptake  of  renewable  energy.  Estonia 

heating 

 

has great potential for offshore wind farms in 
the  Nordic-Baltic  region,  and  is  exploring  the 
development of green hydrogen production. 
Ensure sustainable use of biomass. This would 
improve the functioning of the LULUCF sink. 

 

Estonia  31 

Environmental Implementation Review 2022 – Estonia 

 
 
Estonia  32 

Part II: Enabling Framework: Implementation Tools 

5. Financing

Environmental investment needs in the 
European Union 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps.   

Post-2020,  environmental  implementation  will  also  be 
supported by the EU’s  COVID-19 Recovery  Fund (via  the 
RRF) and the ‘do no significant harm’ principle which runs 
across the EU budget. The renewed commitments made 
at  COP26  (Glasgow,  October-November  2021)  and  the 
Biodiversity  Convention  (April-May  2022)152  will  also  be 
reflected in the EU budget.  

Overall environmental investment gaps (EU-27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed and what is forecast to be invested if no additional 
action  is  taken)  for  climate,  energy  and  transport  were 
estimated in 2021 at EUR 390 billion a year (EU-27129 with 
a  further  EUR  130  billion  a  year  to  deliver  the  EU's  core 
environmental objectives130. The costs of climate-change 
adaptation  can  also  be  significant,  and  are  estimated  to 
reach a total of EUR 35-62 billion (narrower scope) or EUR 
(wider  scope)  per  year131.  Those 
158-518  billion 
investment  needs  reflect  the  implementation  objectives 
to  2020  and  to  2030  (except  for  climate-change 
adaptation, the costs of which are expected to last over a 
longer time horizon).  

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1132.  Almost  40%  of 
the  environmental-investment  needs  relate  to  dealing 
with pollution, which accounts for nearly two thirds of the 
total  gap  if  combined  with  water  management.  The 

in  circular  economy  and  waste 

investment  gap 
is 
estimated  to  be  between  EUR  13-28  billion    a  year, 
depending  on  levels  of  circularity  implemented.  The 
annual  biodiversity  financing  gap  is  estimated  at  around 
EUR 20 billion. 

Table 1: Estimated breakdown of the EU’s environmental 
investment gaps, by environmental objective, 2021-2030 
per year133 

Estimated investment gap (EU-27, 
p.a.)  

Environmental 
objective 

Pollution  prevention 
& control 

Water management & 
industries 

Circular  economy  & 
waste 

 EUR 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems 

& 

 21.5 

R & D & I and other 

Total 

 6.2 

 110.1 

Environmental investment needs in Estonia  

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Investments  in  the  circular  economy  is  a  priority  in 
Estonia, followed by sustainable water services and nature 
and 
following 
investments. 
environmental investment needs have been identified by 
sector.  

biodiversity 

The 

Pollution prevention & control 

The  EU’s  First  Clean  Air  Outlook134  under  the  Clean  Air 
Programme estimated that the total air pollution control 
costs  for  Estonia  to  reach  the  NECD  emission  reduction 
requirements (ERRs)135 by 2030 amount to EUR 220 million 

129 SWD(2021)621, accompanying proposal COM(2021)557 to amend the 
REDII Directive (EU) 2018/2001. 
130 SWD(2020) 98 final/2. 
131  SWD(2018)292.  Impact  assessment  accompanying  the  Proposal  for 
the LIFE Regulation (COM(2018)385). 
132  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  
133 European Commission, DG Environment, ”Study supporting EU green 
investment needs analysis” (ongoing, 2021-2023) and DG Environment 
internal analysis ”Environmental Investment needs and financing in the 
EU’s green transition“,  July 2020.  

134 International Institute for Applied Systems Analysis (IIASA), 
Progress towards the achievement of the EU's air quality and 
emissions objectives, 2018.  
135 Covering the reductions of and the emission ceilings for 5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and VOC  by 
2030,  compared 
to  2005.  Requirements  are  based 
on  Directive (EU) 2016/2284.  

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
Estonia  33 

requirements  of  the  UWWD  and  DWD,  around  EUR  893 
million will be required, out of which  EUR 434 million in 
the next four years and EUR 459 million in the next 5-12 
years.   Moreover,  the  recent  6th  Water  Framework 
Directive  and  Floods  Directive  Implementation  Report141 
and the financial - economic study142 accompanying it, are 
also a relevant source of information in this domain. 

Waste & circular economy 

According to a Commission study,143 to meet the recycling 
targets for municipal waste and packaging waste, Estonia 
still needs to  invest an additional EUR 64 million (around 
9  million  per  year)  over  the  baselines  between  2021-
2027 in  collection,  recycling  reprocessors,  biowaste 
treatment,  waste  sorting  facilities  and  digitalising  waste 
registries.  

In  addition,  the  cost  of  replacing    biowaste  treatment 
facilities is estimated at EUR 2.3 million between 2021 and 
2027  (EUR  0.3  million  per  year).  This  does  not  include 
investment  necessary  for  other  key  waste  streams 
(plastics, textiles, furniture) or to unlock a higher uptake 
of circularity and waste prevention across the economy.  

Biodiversity & ecosystems 

Prioritised  action  frameworks  (PAFs)  adopted  by  the 
Member  States  according  to  Article  8  of  the  Habitats 
Directive  present:  (i)  the  conservation  priorities  for  the 
Natura  2000  network  and 
supporting  green 
infrastructure;  (ii)  the  costs  of  these  conservation 
priorities; and (iii) planned funding sources for biodiversity 
and ecosystems in the period corresponding to the current 
multiannual financial framework (MFF) for 2021-2027. 

its 

The recently submitted PAF for Estonia shows that nature 
protection costs (including Natura 2000) in 2021-2027 are 
EUR 304.5 million. This represents an annual cost of about 
EUR  43.5  million,  of  which  EUR  26.2  million  are  one  off 
costs144.  More  efforts  may  be  necessary  to  cover  the 
increased ambitions of the EU Biodiversity Strategy 2030 
and  any  relevant  financing  gaps  on  protection  and 
restoration. 

per year, including, EUR 117 million for capital investment 
(assuming  the  2030  climate  and  energy  targets  are 
achieved). 

The second EU’s Clean Air Outlook136  that the EU would 
largely  achieve  the  reductions  of  air  pollutant  emissions 
that correspond to the obligations under the NEC Directive 
for 2030 if: (i) all relevant legislation adopted up to 2018 is 
implemented (including all air-pollution legislation and the 
2030  climate  and  energy  targets  set  in  2018);  and  (ii) 
Member  States  also 
the  measures 
announced 
their  national  air-pollution-control 
programmes.  The  only  exception  is  for  ammonia  for  15 
Member States, including Estonia.  

implemented 

in 

Water management  

According to the OECD study on Financing a Water Secure Future 
(2022)137,  the  remain  gaps  in  public  water  supply  and 
sewerage  treatment,  despite  large  investments  over  the 
past  decade.  Wastewater  is  still  not  collected  in  the 
required  quantities  and  its  treatment  does  not  always 
meet requirements, especially in rural areas. According to 
Estonia’s  current  plan,  after  2023,  water  companies 
serving larger communities will need to be financially self-
sustainable  and  cover  the  investment  needs  with  water 
tariffs  and  loans.  The  government  is  supporting  this 
process  with  improved  financing  support  for  regional 
companies. EU funding has provided a significant share of 
past public funding over the past decade.  

industrial  wastewater  discharges 

Up to 2030, the additional cumulative investment need for 
Estonia over the baseline levels was estimated at EUR 361 
million (around 36 million per year), with around 90% of 
that  relating  to  wastewater138.  Further,  pre-treatment 
into 
standards  for 
municipal  sewerage  systems  are  outdated  and  do  not 
cover  many  important  hazardous  substances.  Whilst 
Estonia reported some measures as part of the River Basin 
Management Plan under the Water Framework Directive 
completed  for  all  river  basin  districts  139,  the  firstt 
programme of measures has not been fully implemented. 
A lack of adequate finance is likely to continue  to hinder 
the implementation of the second (2015-2021140) and the 
thirds  (2021-2027)  programme  of  measures.  In  Estonia, 
the  "Water  Infrastructure  Investment  Plan"  in  2019 
estimated that 1.1 billion Euro should be invested in the 
water management infrastructure in the next 12 years. In 
order  to  maintain  or  achieve  compliance  with  the 

136 COM(2021) 3 Final and Report Annex.   
137 OECD, Financing a Water Secure Future, 2022 
138 OECD, Estonia - Country fact sheet- Financing Water Supply, Sanitation 
and Flood Protection.  
139  WFD  and  FD  Implementation  Reports  -  Environment  -  European 
Commission (europa.eu) 
140 Not yet evaluated 
141 WFD and FD Implementation Reports – DG Environment – European 
Commission. 

142  European  Commission,  Directorate-General 
for  Environment, 
Economic data related to the implementation of the WFD and the FD and 
the financing of measures, Final report. Publications Office, 2021. 
143 European Commision, Study on investment needs in the waste sector 
and on the financing of municipal waste management in Member States, 
2019. 
144  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving synergies with EU funding instruments report to the European 
Commission, 2021.  

 Environmental Implementation Review 2022 – Estonia 

 
                                                                 
EU environmental funding  2014-2020 

Figure  39:  ESI  Funds  allocated  to  Estonia,  including 
environmental investments, 2014-2020148 

Estonia  34 

The MFF for 2014-2020 allocated almost EUR 960 billion 
(in commitments, 2011 prices)145 for the EU to spend over 
this  period.  The  commitment  in  this  2014-2020  MMF  to 
the  green  transition  included  a  20%  climate  spending 
target.  It  also  included  funding  opportunities  for  the 
environment, in particular under the European Structural 
and Investment (ESI) Funds146. The 2014-2020 MFF budget 
was subsequently topped up with over EUR 50 billion (in 
current  prices)  from  the  REACT-EU  programme  for 
cohesion-policy action against COVID-19147.  

Estonia received EUR 4.9 billion from the ESI Funds over 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 
EUR  349.8  million  with  a  further  EUR  243.6  million 
identified  as  indirect  environmental  investment  value, 
totalling EUR 593.5 million. Figure 40 shows an overview 
of  (planned)  individual  ESI  Funds  earmarked  for  Estonia 
(EU amounts, without national amounts). 

Table 2:  Direct  and indirect environmental investments 
under the ESI Funds in Estonia, 2014-2020149 

Instrument 

Under Cohesion policy (ERDF + CF) 
Direct environmental investments 
water 
biodiversity and nature 
land rehabilitation 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 
other energy150 
sustainable transport 
sustainable tourism 
business development, R&I 

Under EAFRD/rural development 

Allocations  
for the environment  
(EUR million) 

558.5 
321.4 
129.8 
53.2 
50.2 
88.1 
237.1 
4.1 
76.9 
24.2 
95.4 
3.0 
33.6 

11.7 

145 Council Regulation (EU, Euratom) No 1311/2013. 
146  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI), the European Agricultural Fund for Rural Development (EAFRD) and 
the European Maritime and Fisheries Fund (EMFF).   
147 Regulation (EU) 2020/2221. 
148 European Commission, DG Environment - Data analysis based on ESI 
Funds  Open  Data  Portal  (cohesiondata.ec.europa.eu),  Integration  of 
in  Cohesion  Policy  Funds  (COWI,  2017), 
environmental  concerns 
Regulation 
(EU)  2021/1060  and 
Implementing Regulation (EU) No 215/2014. Environmental investments 
here  are  captured  via  the  combined  use  of  intervention  fields  and 
coefficients under the Regulation (EU) No 1303/2013 and Regulation (EU) 
2021/1060  allowing for a more precise identification and valuation of 
Indirect  environmental 
investments.  N.B. 
relevant  environmental 

(EU)  No  1303/2013,Regulation 

investments are valued using the Annex I environmental coefficients of 
the Regulation (EU) 2021/1060 (as opposed to full value).    
149 European Commission, DG Environment - Data analysis. The values of 
environmental investments identified here in the specific environmental 
areas may differ from the tracking values at cohesiondata.ec.europa.eu, 
e.g.  for  clean  air  or  biodiversity  due  to  two  factors:  the  set  of 
environmental  coefficients  used  and  the  range  of  funds  assessed.  DG 
Environment’s analysis here covered the full range of ESI Funds. See also 
previous footnote. 
150  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention field 
53  and  54  respectively  (with  40%  environmental  coefficients)  of 
Regulation (EU) 2021/1060, Annex I. 

 Environmental Implementation Review 2022 – Estonia 

 
                                                                 
 
  
Direct environmental investments 
water 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 
Environment  protection  &  resource 
efficiency 
Direct environmental investments 
business development, R&I 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

5.2 
0.6 
4.6 
6.4 
3.7 
2.8 

23.3 
23.2 
23.2 

0.1 
0.1 

593.5 
349.8 
243.6 

Funding for the environment from the ESI Funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States  such  as  the  LIFE 
programme,  Horizon  2020,  or  loans  from  the  European 
Investment Bank (EIB). The LIFE programme151 is entirely 
dedicated  to  environmental  and  climate  objectives.  It 
finances  best-practice  actions  for  green  solutions  to  be 
deployed. They add up to an estimated total of EUR 636 
million of EU environmental financing for Estonia in 2014-
2020.  

In the period 2014-2020, Estonia received EU support for 
seven  LIFE  projects  (for  nature  and  environment),  with 
EUR 32.0 million from the LIFE programme (out of 1 028 
EU27 LIFE projects with a total EU contribution of EUR 1.74 
billion).152 

In  2014-2020,  about  EUR  10.5  million  were  allocated  to 
Estonia  under  Horizon  2020  for  the  environment  (in 
particular for earth observation, reseach and innovation), 
with  3.8%  for  the  environment  out  of  Estonia’s  total 
allocation.153  From  the  European  Fund  for  Strategic 
Investments  (EFSI)  Estonia  received  a  total  of  EUR  58.0 
million  in  financing,  without  projects  dedicated  to  the 

151 European Commission, LIFE Programme. 
152 LIFE Country overview Estonia 2021 (europa.eu) 
153 Source: https://sc5.easme-web.eu/. 
154  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
155 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm 
156  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing 
environmental 
implementation: InvestEU, the successor of EFSI, Pillar II and III of the Just 
Transition  Mechanism.  The  EIB  Group  stands  as  a  key  implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budgetary capacity of the mandate. 
157 EIB Activity Report 2021. 
158  European  Commission,  2021-2027 
NextGenerationEU. 

long-term  EU  budget  & 

several  programs 

finance 

that 

Estonia  35 

environment.154 Estonia did not receive any EIB loans for 
the  environment,  despite  the  overall  EUR  1.4  billion  EIB 
lending to Estonia in the period.155 The country ranks24th 
by size of total EIB lending. 

In 2020, the EIB provided EUR 24.2 billion in funding across 
Europe to fight climate change, 37% of its total financing. 
It  also  provided  EUR 1.8 billion  (3%  of  its  financing)  for 
broader environmental lending156 157.  

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investments (public and private) to 
be made across the EU by 2030. The 2021-2027 MFF and 
the NextGenerationEU spending programme will mobilise 
EUR  2.018  trillion  (in  current  prices)  to  support  the 
recovery from COVID-19 and the EU’s long-term priorities, 
including  environmental  protection158.  Following  the  EU 
Green  Deal’s159  pledge  to 
‘do  no  harm’  and  the 
Interinstitutional  Agreement  on  the  2021-2027  MFF160, 
30% of the EU budget  in 2021-2027 will support  climate 
efforts,  while  biodiversity  will  receive  7.5%  of  the  EU 
budget as of 2024 and 10% as of 2026.  

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)161. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds  (by  developing  the  EU  Green  Bond 
Standard)162.  Reinforced  by  the  renewed  sustainable-
finance  will 
finance  strategy 
increase 
the 
flows 
environment. The new strategy on adaptation to climate 
change164 can help to address many risks from uninsured 
climate-related  events165.  The  EIB  will  align  50%  of  its 
lending for climate and environment projects by 2025166, 
with  an  EUR  250  billion  contribution  to  the  Green  Deal 
investment plan by 2027.  

(2020)163,  sustainable 

climate  and 

investment 

to 

https://ec.europa.eu/info/business-economy-euro/banking-and-

159 COM/2019/640 final. 
160 Interinstitutional Agreement, OJ L 433I. 
161 
finance/sustainable-finance/eu-taxonomy-sustainable-activities_en   
162 EU Green Bond Standard - 2021/0191 (COD). 
163 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
164 COM(2021) 82 final. 
165  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 
EIOPA (the Association for European Insurance and Occupational Pension 
Authorities)  dashboard  on 
insurance  protection  gap  for  natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
166 EIB Climate Bank Roadmap 2021-2025, November 2020. 

 Environmental Implementation Review 2022 – Estonia 

 
 
 
                                                                 
Estonia  36 

Table  3  makes  an  overview  of  the  EU  funds  earmarked 
specifically to Estonia for the 2021-2027 period. The funds 
allocated  for  individual  countries  are  also  supplemented 
by other EU funding available to all Member States. 

Table  3:  Key  EU  funds  allocated  to  Estonia  (current 
prices), 2021-2027 

Instrument 

Cohesion policy 

ERDF 
CF 
ESF+ 
ETC (ERDF) 

Just Transition Fund 

EAFRD/rural 
development  

under  CAP  Strategic 
Plans 2023-2027171 

European  Maritime, 
and 
Fisheries 
Fund 
Aquaculture 
(EMFAF) 

 RRF  
2021 – 2026174  

Country funding allocation 
(million EUR) 

Total: 167 
1 692.6 
820.2 168 
502.6  
58.1169 

353.9170 

440.1172 

97.4173 

969.3175 (grants) 

In Estonia, the programming for the majority of EU funds 
(cohesion  policy 
is 
ongoing.  However, the negotiations have been concluded 
under the RRF.  

funds,  EAFRD  and  EMFAF) 

Estonia’s  recovery  and  resilience  plan  consists  of  25 
investments  and  16  reforms.  They  will  be  supported 
by EUR  969.3  million in  grants.    41.5 % of  the  plan  will 
support climate  objectives.  The  plan  has  a  focus  on 
circular  economy,  especially  on  its  business  angle,  but 
lacks  other 
investments,  notably 
biodiversity  measures.  The  plan  is  well  aligned  with  the 
overarching  national  strategy  “Estonia  2035”.  The  main 

environmental 

investments in the recovery plan are linked to the green 
and digital transitions. The plan will support a total of EUR 
220 million in the green transition of businesses through a 
dedicated Green Fund, the deployment of innovative and 
resource-efficient green technologies, the valorisation of 
bio-resources, 
integrated  hydrogen 
technologies,  the  development  of  green  skills  and 
significant 
in  transport  decarbonisation, 
notably  supporting  the  shift  to  rail  transport.  It  includes 
circular  economy  reform;  one  of  the  milestones  is  the 
adoption of the circular economy action plan 176. 

the  uptake  of 

investments 

Figure 40: Climate expenditure in RRP, 2021-2026177 

Under NextGenerationEU, the Commission will issue up to 
EUR 250 billion of EU green bonds (one third of all bonds 
issued  under  NextGenerationEU)  until  2026  that  will 
comply  with  the  general  spirit  of  the  ‘do  no  significant 
harm’  principle.  However,  this  EUR  250  billion  in  green 
bonds  will  not  be  subject  to  the  currently  developed 
delegated  acts  related  to  the  EU  Taxonomy  and  will  not 
fully align with the proposed EU standard for green bonds. 

In addition to EU funds earmarked specifically for Estonia 
in  the  2021-2027  period,  there  are  also 
funding 
programmes that can been accessed at the EU level which 
are  open  to  all  Member  States.  These  include  the  LIFE 
programme  (EUR  5.4  billion),  Horizon  Europe  (EUR 95.5 
billion)178,  the  Connecting  Europe  Facility179  (EUR  33.7 
billion)180 or the funds to be mobilised via the InvestEU181 

167  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
168  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is  not 
included. 
169 Interreg initial allocations per MS including ETC transnational and ETC 
cross-border cooperation.  
170  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
171 European Commission, CAP strategic plans. 
172 Regulation (EU) 2021/2115, Annex XI.  
173 Regulation (EU) 2021/1139, Annex V. 
174  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented until 31 December 2026.   
175 Council Implementing Decision, FIN 523. 

176 European Commission, Estonia recovery and resilience plan.  
177 European Commission 
178  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
179 The CEF (Transport) includes also EUR 11.3 billion transferred from the 
Cohesion Fund. 30 % of the transferred amount will be made available, 
on a competitive  basis,  to  all  Member  States eligible  for  the  Cohesion 
Fund.  The  remaining  70%  will  respect  the  national  envelopes  until  31 
December  2023.  Any  unspent  amount,  by  that  date,  under  national 
envelopes will support all Cohesion Fund’s Member States. 
180 Regulation (EU) 2021/1153. 
181  The  InvestEU  Fund  is  foreseen  to  mobilise  over  EUR  372  billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to back 

 Environmental Implementation Review 2022 – Estonia 

 
 
 
 
                                                                 
 
 
Estonia  37 

Figure 41: Environmental protection investments in the 
EU-27 (EUR million and % of GDP), 2018186 

programme.  These  other  sources  of  funding  will  also 
support  the  green  transition,  including  research  and 
innovation  activities 
for  environmental  protection 
(Horizon  Europe)182,  clean  transport  and  energy  (the 
sustainable 
Connecting 
infrastructure (InvestEU)184. 

Facility)183 

Europe 

or 

National environmental protection 
expenditure 

Total  national  environmental  protection  expenditure 
(including all relevant current and capital expenditure)185 
in the EU-27 was EUR 272.6 billion  in 2020, representing 
2% of the EU27 GDP . 

This  percentage  has  remained  quite  stable  over  time. 
Although the largest absolute amounts of expenditure are 
concentrated in a few countries, most countries spend 1-
2%  of  their  GDP  on  environmental  protection,  with 
Belgium  and  Austria  spending  the  greatest  share  (both 
direct  more  than  3%  of  their  GDP  on  environmental 
expenditure).  

Of  this  spending,  the  EU-27’s  capital  expenditure  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR 54.5 billion in 2020, representing around 0.4% of EU-
27 GDP. Most  Member States invested 0.2-0.5% of their 
in  environmental  protection,  whereas  Estonia 
GDP 
dedicated  0.7%.  In  2014-2020,  this  amounted  to  around 
EUR 376 billion of environmental investment in the EU27, 
and to EUR 1.23 billion in Estonia. 

protection 

investments 

from  specialist  producers 

By  institutional  sector,  around  a  quarter  of  Estonia’s 
environmental 
(capital 
expenditure)  came  fromgeneral  government,  while  a 
(of 
further  41%  came 
environmental protection  services, e.g. waste and  water 
companies)  and  35%  from  traditional 
industry  (or 
business)  sector  that  normally  pursue  environmental 
activities as ancillary to their main activities.  At EU level, 
37%  comes  from  governments,  33%  from  specialist 
producers and 30% from industry (business). 

the  investment  of  financial  partners  such  as  the  European  Investment 
Bank (EIB) Group and others. 
182 European Commission, Horizon Europe. 
183 European Commission, Connecting Europe Facility. 
184 European Union, InvestEU. 
185      At  economy  level,  including  final  consumption,  intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 

excludes  EU  funds,  while  may  include  some  international  expenditure 
beyond  domestic.  Data  source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy. 

186 Eurostat, Environmental Protection Expenditure Account, 2021. 

 Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
 
 
Figure  42:  EU-27  Member  States'  environmental 
protection  investments  (Capex)  by  institutional  sectors 
(Total economy = 100%), 2018187 

These  data  are  based  on  the  climate-bonds  taxonomy, 
which is broadly similar to the EU Taxonomy190. 

Figure 43: Annual EU green bond issuance in 2020 (EUR 
billion)191 

Estonia  38 

The  breakdown  of  investment  by  environmental  topic  is 
only partially available, at the level of institutional sectors 
(rather  than  at  the  level  of  economy),  due  to  different 
reporting  standards.  At  Estonia’s  general  government 
level,  78%  of  the  environmental  protection  investments 
went to the protection of water and soil, with 17% to R&D 
and  9%  to  biodiversity.  With  regard  to  the  country’s 
specialist  producers,  39%  of  the  relevant  investments 
were in wastewater, 23% in waste mangement and 23% in 
biodiversity, 10% in water and soil protection and 4% in air 
protection. As regards the business sector, three quarters 
of the relevant investments went to the protection of air, 
followed by wastewater and waste management with 10% 
each. 

In  2020,  the  total  annual  issuance  of  European  green 
bonds (including some non-EU countries)188 was  EUR 137 
billion189, up from EUR 105 billion in 2019. Looking only at 
EU-27 Member States, green-bond issuance in 2020 was 
EUR  124  billion.  In  2014-2020,  83%  of  the  green  bonds 
issued by European countries served objectives in energy, 
buildings  or  transport,  while  8%  supported  water  and 
waste, with a further 6% supporting sustainable land use, 
with  links  to  ecosystem  conservation  and  restoration. 

187 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
188  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  The  majority  of  green  bonds 
issued are green “use of proceeds” or asset-linked bonds. The very first 
green  bond  was  issued  in  2007  with  the  AAA-rated  issuance  from 
multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 

Green budget tools 

Green taxation and tax reform 

Estonia’s  revenue  from  environmentally-related  taxes  in 
2020 was EUR 657.4 million, as shown in Figure 44, slightly 
above  the  EU-average.  Within  this,  energy  taxation 
in  2020. 
represents  the  highest  share  with  91.5% 
Pollution/resources  tax  is  high,  6.8%,  almost  double  the 
EU average. On the other hand, transport tax is extremely 
low, only 1.7%, compared to 19% at EU level, which may 
not provide real incentivisation for greener vehicules. 

Interactive  Data  Platform  at  www.climatebonds.net.  Further 
Taxonomy: 

189 At Eurostat’s annual average EUR/USD exchange rates. 
190 
information 
Bonds 
https://www.climatebonds.net/standard/taxonomy  
191 Climate Bonds Initiative, 2022. 

Climate 

on 

 Environmental Implementation Review 2022 – Estonia 

 
 
 
                                                                 
 
 
Figure 44: Environmental taxes in the EU27, 2020192 

charge  for  the  capital  city  and  more  environmentally 
motivated parking fees at municipal level. 

Estonia  39 

Environmentally-harmful subsidies 

Addressing  and 
removing  environmentally  harmful 
subsidies is a further step towards wider fiscal reforms196 
197. 

Fossil-fuel  subsidies  are  costly  for  public  budgets,  and 
make it difficult to achieve the Green Deal objectives. In 
many cases, these subsidies also counteract incentives for 
green investments. Annual fossil-fuel subsidies have been 
around EUR 55 billion in the EU since 2015. They rose by 
4%  between  2015  and  2019,  although  some  countries 
(such  as  Latvia,  Lithuania,  Sweden,  Greece  and  Ireland) 
managed  to  decrease  them  in  this  period.  In  the  EU, 
subsidies  for  petroleum  products  in  sectors  such  as 
transport  and agriculture continued to increase in 2015-
2019. However, subsidies  for coal and lignite decreased, 
due  to  the  diminishing  role  of  solid  fuels  in  electricity 
generation. As a share of GDP, fossil-fuel subsidies ranged 
from 1.2% in Hungary to less than 0.1% in Malta in 2019 
(with an EU average of 0.4%).  

 In Estonia, the total fossil fuel subsidies corresponded to 
0.16 % of GDP, less than half of the EU average. In 2020, 
the EU27’s total amount of fossil fuel subsidies decreased 
to EUR 52 billion (due to falling consumption trends amid 
the  COVID-19-related  restrictions).  Without  Member 
State  actions,  these  subsidies  are  likely  to  rebound  as 
economic activity picks up from 2020. 

Further details on fossil fuel subsidies in Estonia are shown 
below.  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 on supporting petrol and diesel. 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society,  and  promote  a  just 
transition. Tax reforms can contribute to this by sending 
the right price signals and incentives to economic actors. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil-fuel subsidies, and a shift in 
the 
to  pollution,  while 
simultaneously taking account of social considerations193. 
The Green Deal promotes the ‘polluter pays principle’,194 
which  stipulates  that  polluters  should  bear  the  cost  of 
measures to prevent, control and remedy pollution. The 
polluter-pays  principle  is  facilitated  by  the  European 
Commission’s Technical Support Instrument  (TSI) project 
on greening taxes.  

tax  burden 

labour 

from 

instruments 

According to a Commission’s study on green taxation and 
other  economic 
(2021),  Estonia  could 
introduce a fertiliser levy and a ‘pay-as-you-throw' scheme 
to  further  address  particular  areas  of  environmental 
concern195.  New  vehicles  purchased  in  Estonia  are  the 
most environmentally unfriendly in the EU, with average 
CO2  emissions  of  132  grams  per  kilometre  compared  to 
the  EU  average  of  118.5  grams  in  2017.  There  are  no 
registration or annual vehichle taxes on motor vehicles in 
Estonia,  besides  the  heavy  goods  vehicle  tax  which  is 
imposed on lorries with a registered or full weight of 12 
tonnes and more. The 2030 Estonian National Energy and 
Climate Action Plan recommends introducing a congestion 

192 Eurostat, Environmental taxes accounts (env_eta). 
193 COM (2019/640 final), p.17. 
194 Article 191(2) of the Treaty on the Functioning of the European Union: 
“Union  policy  on  the  environment  (…)  shall  be  based  on  the 
precautionary  principle  and  on  the  principles  that  preventive  action 
should  be  taken,  that  environmental  damage  should  as  a  priority  be 
rectified at source and that the polluter should pay”. 

195  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021.  

197  European  Commission,  Study  on  assessing  the  environmental  fiscal 
reform potential for the EU28, January 2016 –Study  

 Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
 
Figure 45: Trends in natural gas, petroleum products and 
coal subsidies in Estonia198 

Estonia participates in the Commission’s green-budgeting 
TSI, which started in 2021.  

Overall financing compared to the needs 

Estonia  40 

The  overall  environmental  financing  for  investments  in 
2014-2020 in the EU is estimated to have been equivalent 
to  0.6-0.7% of GDP, taking into account major EU funds 
and national financing.  It ranged from   0.3% (Ireland) to  
1.91%  (Bulgaria),  linked  to  the  level  of  environmental 
challenges 
the  EU 
environmental 
in  2021-2017  are 
estimated to  range between 0.9-1.5% of  projected GDP 
(in  2021-2027),  suggesting  a  potential  environmental 
financing gap of  0.6-0.8% of GDP, with baseline financing 
levels assumed 203. 

investment  needs 

States.  Overall 

in  Member 

% GDP 

2013 

2014 

2015 

2016  2017  2018  2019 

2020 

Natural gas  0,02 

0,01 

0,01 

0,01 

0,01 

0,01 

0,02 

0,01 

Petroleum 
products 

0,26 

0,23 

0,22 

0,15 

0,17 

0,15 

0,14 

0,12 

Coal 

0,07 

0,06 

0,02 

0,01 

0,01 

0,00 

0,00 

0,00 

Green budgeting practices    

‘Green  budgeting’  encompasses  various  climate  and 
environmental tagging and tracking practices in budgets. 
Some  EU  Member  States  already  use  certain  green-
budgeting practices199. Green budgeting helps identify and 
track green expenditure and green revenues to increase 
implications  of 
transparency  on  the  environmental 
budgetary  policies.  This  is  aimed  at  improving  policy 
coherence  and  supporting  green  policies  (including 
climate and environmental objectives)200. 

The Commission has also drawn up climate-proofing and 
sustainability-proofing guidance as tools to assess project 
eligibility and a project’s compliance with environmental 
legislation  and  criteria201.  The  Commission  developed  a 
green-budgeting  reference  framework202  and  launched  a 
TSI project on green budgeting in 2021 to help Member 
States  develop  national  green-budgeting  frameworks  to 
improve  policy  coherence  and  the  green  transition. 

198 OECD, Fossil Fuel Subsidy Tracker. 
199 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. 
200  European  Commission,  European  Commission  Green  Budgeting 
Reference  Framework.  European  Commission,  Green  Budgeting  in  the 
EU Key insights from the 2021 Commission survey. 
201 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
202 European Commission, Green Budgeting Reference Framework, based 
on the review of the OECD Paris Collaborative on the Green Budgeting 
initiative, 2017. 

Figure 46: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU27 (% of 
GDP)204 

is 
Estonia’s  environmental  financing  for  investments 
estimated  to  have  been    1.25%  of  GDP  in  2014-2020,  in 
with over two thirds relying on national sources. With that 
level maintained for 2021-2027, the bulk of environmental 
investment  needs  (1.13%  of  GDP,  including  needs  with 
country-level  breakdown)  would  be  met,    suggesting  no 

203  DG  Environment  data  analysis.  EU  financing  sources  covered:  ESI 
Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon 2020,  LIFE,  EFSI  (EU 
amount),  EIB  loans.  National  financing:  total  national  environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 
dataset. Cut-off date for data: end 2021. N.B. The total financing may be 
higher,  in  particular  through  further  indirect  investments,  requiring 
further analysis in the future.   
204 Eurostat, ESI Funds Open Data, 2021. 

 Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
                                                                 
 
 
investment  gap 

respect. 
major  overall 
Nevertheless,  when  also  accounting  for  needs  currently 
assessed  only  at  EU-level  (water  protection,  circularity, 
biodiversity  strategy  etc.),  additional  environmental 

that 

in 

Estonia  41 

investment  needs  may  be  triggered  that  will  require 
adequate financing.  

 Environmental Implementation Review 2022 – Estonia 

 
 
 
Estonia  42 

6. Environmental Governance 

Information, public participation and access to 
justice 

Table  4:  Country  dashboard  on  the  implementation  of 
the INSPIRE Directive, 2016-2020210 

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;  
(iii) access to justice in environmental matters.   
It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively205.  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  environment206.  It  includes  the  right  to  bring  legal 
challenges (‘legal standing’)207.  

Environmental information 

Estonia’s implementation of the INSPIRE Directive is good. 
Its  performance  has  been  reviewed  based  on  the    2021 
country  fiche208.  Good  progress  has  been  made  on  data 
identification  and  documentation;implementation  levels 
are good. However, more efforts are needed to: 

 
 

environmental  datasets 

(i) make the data more widely accessible, and 
(ii)  prioritise 
in 
implementation,  especially  those  identified  as 
high-value  spatial  datasets  for  implementing 
environmental legislation209. 

together  create  a 

205  The  Aarhus  Convention,  the  Access  to  Environmental 
Information  Directive  (Directive  2003/4/EC)  and  the  INSPIRE 
Directive(Directive  2007/2/EC) 
legal 
foundation  for  the  sharing  of  environmental 
information 
between public authorities and with the public. This EIR focuses 
on the INSPIRE Directive's implementation.  
206 These guarantees are explained in the Commission Notice on 
access to justice in environmental matters, OJL 275, 18.8.2017 
and a related Citizen's Guide. 
207  This  EIR  focuses  on  the  means  implemented  by  Member 
States to guarantee rights of access to justice, legal standing and 
to  overcome  other  major  barriers  to  bringing  cases  on  nature 
and air pollution. 

2016 

2020 

Legend 

Effective coordination and data 
sharing 

Ensure  effective 
coordination  

■  ■  

Data 

sharing 

without obstacles   ■  ■ 

INSPIRE 
indicators 

i.  Conformity  of 
metadata  

ii.  Conformity  of 
spatial 
data 
sets211 

iii. Accessibility of 
spatial  data  sets 
through view and 
download 
services 

performance 

■  ■ 

■  ■ 

■  ■ 

iv.  Conformity  of 

network services  ■  ■ 

■ Implementation of this 
provision  is  well  advanced 
completed. 
or 
(nearly) 
issues  are 
Outstanding 
be 
minor 
easily. 
addressed 
Percentage: >89% 

and 

can 

■ Implementation of this 
provision  has  started  and 
made  some  or  substantial 
progress  but 
is  still  not 
close  to  being  complete. 
Percentage: 31–89%  

■  Implementation of this 
falling 
provision 
is 
behind. 
significantly 
are 
efforts 
Serious 
close 
to 
necessary 
implementation 
gap. 
Percentage: <31% 

Public Participation 

The  Environmental  Board  has  a  special  section  on  its 
website  explaining  opportunities  to  participate  in  EIA 
processes, with links to relevant databases and sources of 
information212.  Notifications  on  public  participation 
opportunities  are  published  in  the  official  publication 
Ametlikud Teadaanded, available online213. This database 
is unlikely to be used by members of the public as a regular 

208 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/EE. 
209 European Commission, List of high value spatial data sets. 
210 INSPIRE knowledge base, 2021. 
211  In  2016,  the  deadlines  for  implementation  of  the  spatial  data 
interoperability were still in the future: 23.11.2017 for Annex I data and 
2110.2020 for Annex II and III data. It must be also considered that this 
conformity indicator will in many cases never reach 100% conformity as 
the majority of the countries provide as-is-data sets in addition to  the 
INSPIRE harmonised data sets. 
212 
avalikustamised/raagi-kaasa 
213 https://www.ametlikudteadaanded.ee/eng/index 

https://keskkonnaamet.ee/keskkonnateadlikkus-

Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
  
  
  
 
source of information; however, it does provide an option 
to  subscribe  to  notifications,  which  can  be  narrowed  in 
range  to 
impact 
assessments, or further narrowed by  geographical area.  

include  only  e.g.  environmental 

EIA and SEA procedures are carried out by many different 
authorities (municipalities, the Environmental Board, the 
Transport  Board,  Consumer  Protection  and  Technical 
Regulatory  Authority  etc.),  and  there  are  no  publicly 
available data on overall levels of participation and access 
to information in these procedures. However, a biannual 
study  on  environmental  awareness  in  Estonia  organized 
by  the  Ministry  of  Environment  has  in  recent  years  also 
studied  people’s  awareness  and  attitudes  towards 
environmental decision-making214. According to the latest 
considered 
report 
participation 
decision-making 
environmental 
important.  However,  only  6%  of  respondents  had 
participated in public hearings within the last two years (as 
a  comparison,  11%  had  participated  in  environmental 
discussions  in  social  media).  Respondents  rated  their 
ability to participate in environmental decision-making at 
municipal  level  higher  than  at  national  level.  On  both 
levels the general outlook was pessimistic, with only 13% 
and 5% respectively assessing the ability to participate are 
good, and 66% and 71% respectively believing that access 
was restricted or lacking. 

(2020),  40%  of 
in 

respondents 

Access to justice 

No  interest  needs  to  be  proven  for  an  NGO  to  have  a 
standing in an environmental court case, but cases which 
have  significant  effects  on 
the  environment  are 
interpreted narrowly. For plans and programmes that are 
considered  administrative  acts, 
i.e.  which  create, 
terminate  or  change  the  individual  rights  of  any  person, 
standing  is  awarded  to  those  persons  whose  individual 
subjective rights have been breached (breach of rights is 
presumed 
for  environmental  NGOs).  Plans  and 
programmes may also be considered to be administrative 
acts  only  in  part.  Plans  and  programmes  that  are  not 
administrative acts do not have a direct effect on anyone’s 
rights. Such plans and programmes cannot be challenged. 
Challenging omissions to adopt a plan or programme that 
is  an  administrative  act  follows  a  different  logic.  In  such 
cases,  the  standing  is  firstly  dependent  on  whether  the 
omission could have breached a subjective right – this may 
also be theoretically relevant as regards those plans and 
programmes which are not administrative acts. Secondly, 

to 

are 

back 

2008 

going 

Studies 

214 
https://envir.ee/kaasamine-
keskkonnateadlikkus/keskkonnateadlikkus/uuringud 
215  The  concept  is  explained  in  detail  in  the  Communication  on  "EU 
improve  environmental  compliance  and  governance" 
actions  to 
COM(2018)10  and  the  related  Commission  Staff  Working  Document, 
SWD(2018)10.  

available 

at: 

Estonia  43 

standing  would  be  dependent  on  whether  the  authority 
had a clear obligation to act (or act in a certain manner). 
There  is  a  system  of  regular  supervision  of  regulatory 
legally  binding  acts  but  it  is  hardly  accessible  for  the 
members of the public and NGOs, they can only alert the 
attention of those bodies or officials who are entitled to 
initiate an extraordinary supervision procedure. 

Easy-to-read information on how to access judicial review 
procedures 
(including 
environmental  matters)  is  available  on  the  web  page  of 
Estonian Courts. 

administrative  matters 

in 

In  2019,  a  priority  action  was  addressed  to  Estonia  to 
better  inform  the  public;  it  can  be  concluded  that there 
has been substantial progress made in this regard. 

2022 priority actions 

 

in 

datasets 

environmental 

  Make  spatial  data  more  widely  accessible  and 
prioritise 
the 
implementation  of  the  INSPIRE  Directive,  especially 
those  identified  as  high-value  spatial  datasets  for 
implementing environmental legislation.  
Continue  the  good  practice  of  measuring  attitudes 
towards environmental decision-making, and address 
barriers to participation identified.  
Consider further steps to bring together information 
on  EIA  and  SEA  processes  in  a  single  place,  and  to 
report on overall levels of public participation. 
Improve  access  to  courts  by  the  public  concerned 
when  it  comes  to  challenging  administrative  or 
regulatory decisions, in particular, under the areas of 
planning related to water, nature and air quality.  

 

 

Compliance assurance  

Environmental compliance assurance covers all the work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, and manage waste215.   
It includes support measures provided by the authorities 
such as:  
(i) compliance promotion216;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring217 
(iii)the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement218. 

216 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation.  
217 This EIR focuses on inspections of major industrial installations.  
218  This  EIR  focuses  on  the  availability  of  enforcement  data  and  co-
ordination between authorities to tackle environmental crime. 

 Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
Citizen science and complaints enable authorities to focus 
their efforts better. Environmental  liability219 ensures  tat 
the polluter pays to remedy any damage.    

Compliance promotion and monitoring  

tend 

in  Estonia,  rather  than 

the  nature  directives  and 

to  provide  general 
Government  websites 
their 
information  on 
implementation 
information 
focused on how farmers and other land managers or duty 
holders  can  support  implementation.  In  recent  years 
NGOs  have  done  extensive  work  on  introducing  the 
Natura 2000 network and its requirements to landowners 
under  a  LIFE  project,  NaturallyEst-LIFE220  involving  the 
Environmental  Law  Centre  and  the  Estonian  Fund  for 
Nature.  For  nitrates,  the  picture  is  similar,  with  limited 
practical guidance; although the Fund for Advancement of 
Rural  Life  continues  to  offer  an  explanatory  overview  of 
the requirements in nitrate vulnerable zones, and links to 
other useful sites221. 

to 

Board’s 

register 

electronic 

in  addition 

scientific  data 

An inspection plan for the years 2021-2023 was adopted 
in 2021, but does not appear to be easily accessible to the 
public222.  All  inspection  reports  are  available  in  the 
of 
Environmental 
environmental permits223. The reports are comprehensive 
and, 
(results  of 
measurements etc.), they usually contain a short overview 
of  the  findings  (and  instructions)  of  the  inspector;  but 
information on the follow-up to inspections is not readily 
available.  The  Environmental  Board  also  publishes 
aggregate data on environmental monitoring, but it only 
includes data  on infringements that have been detected 
(and  not,  for  example,  data  on  how  many  on-site 
inspections were carried out)224. The data are aggregated 
by  both  subject  areas  (defined  according  to  the  specific 
acts)  and  counties.  A  more  in-depth  overview  of  the 
environmental  monitoring  results  of  the  year  2019  can 
also  be  found  in  the  yearbook  of  the  Environmental 
Inspectorate225. 

Estonia  44 

Complaint handling and citizen science 

The  Environmental  Inspectorate  has  been  merged  with 
the Environmental Board; the new authority is named the 
Environmental  Board.  Comprehensive  information  on 
when to report infringements or incidents is available on 
its  website226.  However,  the  hotline  previously  available 
for  reporting 
incidents  has  been  changed  –  such 
information should now be reported to the general state 
authority  hotline  number  (1247).    The  environmental 
Board encourages reporting of  environmental breaches, 
but  NGOs  have  also  shown  their  commitment227; 
examples  include  a  campaign  to  encourage  reporting  of 
illegal felling in forests228. For example, the infringement 
procedure initiated in June 2021 against Estonia  related 
to  incorrect  transposition  and  bad  application  of  certain 
provisions of the Habitats Directive and the SEA Directive  
in connection with forest logging and forest management 
in Natura 2000 is based on an NGO’s complaint229. 

The most recent statistics on the number and content of 
complaints are from 2019230. In 2019, the hotline received 
5019  complaints;  however,  the  information  provided  is 
limited to the subject and number of complaints, with no 
information on the follow-up – how the information was 
used, whether it led to the identification of infringements, 
etc. 

More  generally,  citizen  science  continues 
to  be 
encouraged to some extent. The public portals for citizens 
science – LVA and eElurikkus – referred to in the 2019 EIR 
governance  report  are  still  actively  used,  although  their 
main objective is to gather information on the state of the 
natural  environment  rather  than  to  contribute  to 
compliance monitoring and enforcement.  

Enforcement 

infringements  are 
Statistics  about  environmental 
published on the website of the Environmental Board231; 
they  include  information  about  detected  infringements, 
cases resolved (number and amounts of fines, etc.), and 
the environmental damage caused. They also provide data 
on the number of criminal proceedings commenced, but 

219  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
220 https://k6k.ee/looduskaitse 
221 https://www.pikk.ee/ 
222  See  https://adr.envir.ee/et/document.html?id=2af237a5-82c4-4f05-
8571-58b1f172a8e0 for the entry in the Environment Board document 
registry. 
223 https://kotkas.envir.ee/annual_reports_registry 
224 
https://keskkonnaamet.ee/jarelevalve-teavitamine-
1247/jarelevalve/uuringud-statistika; statistical reports are presented as 
downloadable xlsx files. 
225 
https://old.keskkonnaamet.ee/sites/default/files/kki_aastaraamat_201
9_final.pdf 

https://keskkonnaamet.ee/jarelevalve-teavitamine-

https://www.err.ee/1608309641/kaarel-relve-rikkumismenetlus-

226 
1247/teatamine/teata-rikkumisest-1247 
227 Inform us of breaches 1247 | Keskkonnaamet 
228 See https://www.eestimetsaabiks.ee/metsakaitsja-abc 
229 
mida-riik-niisama-ara-siluda-ei-saa 
230 
https://old.keskkonnaamet.ee/sites/default/files/kki_aastaraamat_201
9_final.pdf 
231 
https://keskkonnaamet.ee/jarelevalve-teavitamine-
1247/jarelevalve/uuringud-statistika; statistical reports are presented as 
downloadable xlsx files. 

 Environmental Implementation Review 2022 – Estonia 

 
 
 
                                                                 
show  no  information  about  the  outcome  of  cases.  The 
annual overview of crime statistics in Estonia compiled by 
the Ministry of Justice does not contain any information 
about environmental crimes232. 

The  Environmental  Board233  and  the  Prosecutor’s  Office 
share  responsibility  for  tackling  environmental  crimes. 
The  Environmental  Board  conducts  pre-trial  criminal 
proceedings  under  the  direction  of  the  Prosecutor’s 
Office;  the  Prosecutors’  Office  represents  the  State  in 
courts.  The  Environmental  Board  also  cooperates  with 
other enforcement agencies such as the Police and Border 
Guard  Board  (based  on  a  cooperation  plan  and  joint 
inspections) and the Tax and Customs Board (on an ad hoc 
basis)234;  information  on  these  arrangements  is  not, 
however, available online.  

In the 2020 annual report of the Prosecutor’s Office stated 
that environmental crime  must  become a  priority235. On 
14 April 2020 the ministers for environment, justice, and 
the  interior  signed  a  joint  declaration  on  prioritising  the 
however, 
fight 
information on the implementation of this declaration is 
not available online.  

environmental 

crime236; 

against 

Environmental Liability Directive  

While there is no publicly-accessible registry of ELD cases, 
yearly  overviews  of  environmental  liability  cases  are 
available  as  separate  documents  on  the  Environmental 
Board website237. These documents include a description 
of  the  liability  cases,  the  nature  of  the  environmental 
damage,  and  a  description  of  the  prevention  and/or 
remedial  measures  required.  In  2020  there  were  four 
cases  under  the  Environmental  Liability  Directive,  and  a 
total of 136 cases resulting in environmental damage.  

type  of 

securities 

Estonia’s  legislation  transposing  the  ELD  (Environmental 
Liability  Act)  does  not  require  operators  to  have  any 
specific 
cover  potential 
environmental  damage.  Most  of  the  larger  Estonian 
insurance  companies  exclude  damage 
to 
obligations arising under the Environmental Liability Act or 
the Directive (ELD) in the standard terms and conditions 
of  the  liability  insurance  they  offer.  A  few  insurance 

related 

to 

https://keskkonnaamet.ee/jarelevalve-teavitamine-

https://www.just.ee/kuritegevus-ja-selle-ennetus/kuritegevuse-

232 
statistika 
233 
1247/jarelevalve/keskkonnarikkumised 
234  Evaluation  report  on  the  eighth  round  of  mutual  evaluations  'The 
implementation  and  operation  of  European  policies  on 
practical 
preventing and combating Environmental Crime'. Report on Estonia. 
235 
2020/keskkonnakuritegevus-uus-prioriteet-eesti-oiguspoliitikas 
236 
keskkonnakuritegevuse-luubi-alla  
https://aastaraamat.prokuratuur.ee/prokuratuuri-aastaraamat-
2020/keskkonnakuritegevus-uus-prioriteet-eesti-oiguspoliitikas 

https://aastaraamat.prokuratuur.ee/prokuratuuri-aastaraamat-

https://envir.ee/uudised/kolm-ministrit-votsid-

Estonia  45 

companies cover some damage related to environmental 
damages  claims,  such  as  the  cost  of  removing  pollution, 
and unforeseen environmental damage238. 

2022 priority actions 

 

Provide regular updates on progress on implementing 
the  2020  Joint  Ministerial  Declaration  on  tackling 
environmental crime.  

 

  Actively encourage public reporting of environmental 
damage and infringements, and provide information 
on  how  those  reports  are  used  to 
improve 
compliance. 
incidents  of 
Provide  up-to-date 
environmental  damage,  including  ELD  through  the 
registry or databases that are made accessible to the 
public.  
Improve  the  information  available  to  farmers  and 
other land managers on compliance with the Nature 
and Nitrates Directives. 

information  on 

 

Effectiveness of environmental 
administrations  

Those involved in implementing 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.  about  the 
intended benefits. 

Administrative capacity and quality 

Estonia’s  score  in  the  2020  Environmental  Performance 
Index  is  65.3.    It  ranks  30th    out  of  180239worldwide.  At 
present, 
the  number  of  complaints  and  pending 
infringements handled by the Commision against Estonia  
in the environmental field can be considered below the EU 
average. 

According to the Digital Economy and Society Index (DESI) 
2021 Estonia is  a top performer in digital public services 
and  scores   4th  in  e-government 240in  the  EU.  As  to 
enterprises having green action through information and 

237  https://keskkonnaamet.ee/media/1230/download  (xlsx  table;  2019-
…); https://keskkonnaamet.ee/media/1228/download (xlsx table 2009-
2018). 
238 
https://www.salva24.ee/doc/vastutuskindlustuse_yldtingimused.pdf, 
https://www.iizi.ee/public/IIZI%20kinnisvara%20vastutuskindlustuse%2
0lisatingimuste%2017.09.2018%20v%C3%A4listused.pdf   
239  Yale  Center  for  Environmental  Law  &  Policy,  2020  Environmental 
Performance Index. 
240 DESI 2021 

 Environmental Implementation Review 2022 – Estonia 

 
 
                                                                 
communication  technologies  (ICT)  (%  of  enterprises), 
Estonia performs below average and needs to encourage 
enterprises  to  engage  in  more  environmentally-friendly 
actions. 

Coordination and integration  

Impact  Directive 

revised  Environmental 

As already mentioned in the 2017 EIR, the transposition of 
(EIA 
the 
Directive)241  provides  an  opportunity  to  streamline  the 
regulatory  framework  on  environmental  assessments. 
Despite  a  delay  in  full  transposition  in  relation  to  the 
deadline (May 2017), Estonia has transposed the revised 
Directive. On 25 July 2019, the Commission issued a letter 
of  formal  notice  regarding  the  non-conformity  of  the 
Estonian national legislation with certain provisions of the 
EIA Directive, urging Estonia to bring its legislation fully in 
line with the requirements of the Directive. 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments  to  reduce  duplication  and 
avoid  overlaps  in  environmental  assessments  applicable 
to  projects.  Moreover,  streamlining  helps  to  reduce 
unnecessary  administrative  burden  and  accelerates 
decision-making, 
done  without 
is 
the  environmental 
compromising 
assessment  procedure242.  Estonia  had  introduced  the 
streamlining of environmental assessments under the EIA 
and  Habitats  Directives    prior  to  the  revision  of  the  EIA 
Directive. Coordinated procedures have been established 
for  the  EIA,  Water  Framework  Directive  and  Industrial 
Emissions Directive. 

provided 
it 
the  quality  of 

A  noteworthy  example  of    good  practice  is  the  Single 
that  has  been 
Environmental  Permitting  Platform 
developed  to  operationalise  the  Single  Environmental 
Permitting  Regime,  which  simplifies,  harmonises  and 
clarifies many environmental permits. 

Estonia  46 

Reforms through the Commission’s Technical 
Support Instrument (TSI) 

The Commission supports environmental implementation 
and  the  green  transition,  not  only  through  the  EU 
financing  programmes,  but  also  by  granting  technical 
assistance such as the Technical Support Instrument (TSI). 
The Commission’s 2020 TSI supported two environment-
in  Estonia:  ‘Estonian  waste  system 
related  projects 
analysis’  (described  in  the  section  on  waste,  p.9)  and 
‘Analyses  and  action  plan  towards  sustainable  water 
services 
in  Estonia’.  An  additional  project  can  be 
mentioned  under  the  TSI  2019,  namely  ’Support  for  the 
Estonian Transport and Mobility Master Plan’. In 2021, the 
Commission supported one project, namely ’Development 
of a sustainable finance roadmap for Estonia’. In 2022, a 
request  was  approved  to  define  the  structural  reforms 
needed  for  smart  assessment  of  the  effectiveness  of 
protection of Estonian biodiversity. 

TAIEX EIR peer-to-peer projects 

facilitate  peer-to-peer 

The TAIEX EIR Peer-to-Peer tool243 has been launched by 
the  Commission  to 
learning 
between environmental authorities. During the reporting 
period, Estonia has been very involved in TAIEX EIR events. 
In  2019,  Estonia  participated  in  three  TAIEXEIR  Peer-2-
Peer multi-country workshops: one  on air pollution from 
household heating; one on the EU Timber Regulation for 
Nordic-Baltic competent authorities and one on life-cycle 
approach  and  circularity  in  policy  and  procurement 
planning. The first two were hosted by Estonia. The same 
year, it also benefited from an expert mission and a study 
visit  in  Sweden  relating  to  waste  management.  In  2021, 
Estonia took part in two multicountry workshops: the first 
on ammonia-reducing technology and measures, and the 
second on zero pollution. 

241 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment. 
242 The Commission issued a guidance document in 2016 regarding the 
that  are 
setting  up  of  coordinated  and/or 

joint  procedures 

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.  
243 https://ec.europa.eu/environment/eir/p2p/index_en.html 

 Environmental Implementation Review 2022 – Estonia