COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review 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 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
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, 7.7.2025  SWD(2025) 307 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review       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 2025 Environmental Implementation Review for prosperity and security     {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Estonia  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Transitioning to a circular economy ..................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 14 
Global and EU biodiversity frameworks ............................................................................................................. 14 
Nature protection and restoration – Natura 2000 ............................................................................................. 14 
Recovery of species ............................................................................................................................................ 16 
Recovery of ecosystems ..................................................................................................................................... 18 
Prevention and management of invasive alien species ...................................................................................... 25 
Ecosystem assessment and accounting ............................................................................................................. 25 
3. ZERO POLLUTION ..................................................................................................................................................... 27 
Clean air ............................................................................................................................................................. 27 
Industrial emissions ............................................................................................................................................ 28 
Major industrial accidents prevention – Seveso ................................................................................................. 30 
Mercury Regulation ............................................................................................................................................ 31 
Noise .................................................................................................................................................................. 32 
Water quality and management ........................................................................................................................ 32 
Chemicals ........................................................................................................................................................... 38 
4. CLIMATE ACTION ..................................................................................................................................................... 41 
The EU emissions trading system ....................................................................................................................... 41 
Effort sharing ..................................................................................................................................................... 42 
Land use, land-use change and forestry ............................................................................................................. 43 
Adaptation to climate change ............................................................................................................................ 43 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 45 

5. FINANCING ............................................................................................................................................................. 45 
Climate finance landmarks ................................................................................................................................. 45 
Environmental financing and investments ......................................................................................................... 46 
Public financial management ............................................................................................................................. 50 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 53 
Information, public participation and access to justice...................................................................................... 53 
EU-supported environmental capacity building ................................................................................................. 57 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
Estonia  3 

Executive summary 

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
the  main  outstanding  challenges  and 
describing 
opportunities 
legal 
implementation in Estonia. The purpose of this report is to 
provide information on the implementation performance 
and  highlight  the  most  effective  ways  to  address  the 
implementation gaps  that impact human health and the 
environment and hamper the economic development and 
competitiveness  of  the  country.  The  report  relies  on 
detailed  sectoral  implementation  reports  collected  or 
issued  by  the  Commission  under  specific  environmental 
legislation. 

environmental 

regarding 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of the citizens, the distance to target 
and financial implications. 

Estonia  is  now  on  track  to  decouple  municipal  waste 
generation from economic growth. It has made slow but 
steady  progress  over  the  past  decade  in  stepping  up  its 
recycling  rate.  Although  Estonia  is  one  of  the  Member 
States  with  the  lowest  municipal  waste  generation  per 
capita,  concerns  have  been  raised  about  the  lack  of  a 
unified  data  management  system  at  the  local  level,  and 
the  quality  of  the  data  provided.  Estonia  diverted 
municipal  waste  from 
incineration  rate 
reached 42 % and the landfill rate reduced to 13 % in 2022, 
which is close to the 2035 target. Resource productivity in 
Estonia is dragged down by resource-intensive industries. 
In  2023,  Estonia  generated  EUR 0.63  per  kg  of  material 
against the EU average of EUR 2.22. 

landfill;  the 

On  air  pollution,  although  the  emissions  of  key  air 
pollutants have decreased significantly over the last few 

(1) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 

to 

years, Estonia should continue to address emissions to air 
from usage of fossil fuels and other emission sources by 
replacing them with cleaner solutions. 

The  Urban  Wastewater  Treatment  Directive  aims  to 
protect  human  health  and  the  environment  from  the 
effects of untreated urban waste water. An infringement 
proceeding has been open against Estonia since February 
2024  for  non-compliance  with  the  requirements  of  the 
directive in respect of discharges of industrial waste water 
treatment  plants.  Finally, 
into  urban  wastewater 
measures  are  needed  to  address  deteriorating  chemical 
water quality and enhance resilience. 

investment  gap 

is 
Estonia’s  overall  environmental 
EUR 0.8 billion  per  year,  representing  around  2.18 %  of 
the national GDP, more than the EU average (0.77 %). The 
highest share is for biodiversity and ecosystems. Thus, it is 
necessary  to  ensure  an  increased  level  of  financing  and 
further exploit opportunities in private financing to close 
the investment gap. 

On climate change, there is some progress in promoting 
zero-emission road transport solutions and in renovating 
building  stock.  Estonia  has  one  out  of  the  three  regions 
identified  as  hotspots  of  climate  risks  that  are  most 
affected  by  climate  change:  low-lying  coastal  regions. 
Estonia  is  vulnerable  to  the  impacts  of  climate  change, 
such  as  rises  in  temperature,  rainfall  and  sea  level,  and 
extreme  weather  phenomena  accompanied  by  coastal 
and inland floods, wildfires and new pathogens. 

On  environmental  governance,  Estonia  provides  an 
example  of  good  joint  application  of  the  Environmental 
Liability Directive and the Industrial Emissions Directive in 
cases  where  environmental  damage  is  caused  by  an 
operator  acting  under  an  Industrial  Emissions  Directive 
permit.  Nevertheless,  Estonia  needs  to  ensurе  legal 
standing  and  better  access  to  courts  for  the  public 
concerned. 

implementation  review,  COM(2016) 316 
environmental 
final  of  27 May  2016,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
Estonia  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial  systems  by  reducing  input  materials,  keeping 
products and materials in the loop for longer and reducing 
waste generation, thus decoupling economic growth from 
circular  economy  has 
resource 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
action  plan  (CEAP) (2)  measures  either 
in  place  or 
legislatively  advanced,  Member  States  will  now  have  to 
focus on a swift and effective implementation. 

consumption.  A 

The 2020 CEAP launched the legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
were all introduced following a holistic life-cycle approach, 
with  measures  addressing  the  different  stages  of  a 
product’s life cycle, from design through use to end of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a  measure of one aspect of circularity: the 
share of the total amount of material used in the economy 
that is accounted for by recycled waste. A higher CMUR 
value means that more secondary materials were used as 
a  substitute  for  raw  materials,  thus  reducing  the 
environmental impacts of extracting primary material. 

Estonia’s  CMUR  has  been  increasing  since  2014  and 
reached 21.4 % in 2022, with a decrease in 2023 to 18.1 % 
but  still  remaining  above  the  EU  average  of  11.8 % 
(Figure 1). 

25

20

15

10

5

0

2013

2015

2017

2019

2021

2023

Estonia

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur,  last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cur. 

10 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
can help to minimise negative impacts on the environment 
and reduce dependency on volatile raw material markets. 
In  2023,  Estonia  generated  EUR 0.63  per  kg  of  material 
against the EU average of EUR 2.23 (Figure 2). 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Estonia

EU-27

NB: The unit of measurement used is EUR/kg chain-linked volume (2015). 
Chain-linked  volumes  focus  on  changes  on  quantities  and  prices  of 
commodities  in  previous  years,  taking  into  account  inflation,  and  are 
indexed to the nearest appropriate year, in this case, 2015. 

Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
2024, 
7 August 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

10 December 

accessed 

2024, 

Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 

(2) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  A  new  circular 
economy action plan for a cleaner and more competitive Europe, 

to 

COM(2020) 98 
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Estonia 

 
 
Estonia  5 

circular strategies at the national, regional and city levels. 
These should be tailored to each national and local reality, 
to  harness  the  proximity  economy’s (3)  potential,  while 
following  the  principles  of  a  holistic  whole-value-chain 
approach. 

Since the launch of the online European Circular Economy 
Stakeholder  Platform  in  2017 (4)  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies,  roadmaps  and  good  practices,  for  example 
alternative business models and innovative technologies. 

In  2023,  Estonia  adopted  a  white  paper  on  circular 
economy (5) outlining the broad objectives and framework 
for  the  transition  to  a  circular  economy.  It  identifies 
strategic  actions  centred  around  six  development 
priorities: 

(i)  resources are used responsibly and based on demand, 
with  resource  use  being  considered  properly  and 
waste production minimised; 

(ii)  the  business  models  of  Estonian  companies  are 

forward-looking and circular; 

(iii)  the  necessary  know-how  and  expertise 

for 
implementing  circular  economy 
is  ensured  and 
cooperation  between  stakeholders  and  sectors 
functions well; 

(iv)  functional digital solutions are created to support the 
circular economy and high-quality data for monitoring 
the situation are ensured; 

(v)  the circular economy is well coordinated and there is 
a supportive legal and economic environment; 

(vi)  environmentally 
environmentally 
mainstreamed in society. 

conscious 
friendly 

thinking 
behaviour 

and 
are 

In 2023, Estonia also published an action plan for circular 
economy (6)  under  the  recovery  and  resilience  plan 
(RRP) (7). The action plan groups together 10 key actions 
for the transition from across the policy landscape. Other 
circular-economy-related  activities  in  the  plan  include 
support  for  the  digitalisation  of  the  economy  and  for 
provision of the right skills to workers, and the adoption of 
resource-efficient green technologies. 

Between 2021 and 2023, a project (8) aiming to contribute 
to  the  promotion  of  circular  economy  through  the 
development  of  circular  economy  roadmaps  for  all 

municipalities  in  Estonia  was  carried  out.  As  a  result,  79 
roadmaps  were  prepared.  The  roadmaps  are  mostly 
informative and their implementation is not monitored. 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  14 %  of  EU  GDP.  Public 
procurement  using  green  or  circular  criteria  (life-cycle 
analysis,  PaaS  (platform  as  a  service),  second  hand)  can 
help drive the demand for sustainable products that meet 
reparability and recyclability standards.  

In  2020,  8 323  public  procurements  were  carried  out  in 
Estonia.  The  total  value  of  public  procurement  was 
EUR 3.7 billion, which makes up 14 % of Estonia’s GDP and 
32 % of the state budget. Official statistics show that only 
4.5 %  of  the  total  procurements  and  17 %  of  the  total 
procurement costs are green public procurement (GPP). 

On  1 January  2022,  mandatory  GPP  criteria  were 
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. 

On  24 February  2023,  Minister  of  the  Environment 
Regulation No 6, Environmental criteria and conditions for 
the procurement of road vehicles comprising the subject 
matter  of  the  procurement  contract  in  procurement 
documents, entered into force. It sets out the conditions 
for  procuring  environmentally  friendly  light  vehicles, 
trucks and buses. 

The EU Ecolabel and the eco-management and audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number  of  eco-management  and  audit  scheme  (EMAS)-
licensed  organisations  in  each  country  provide  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. The EU Ecolabel is 
awarded  to  products  with  best-in-class  environmental 
is  a  voluntary  environment 
performance.  EMAS 

(3) 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
European 
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
(5)  Ministry of Climate, Ringmajanduse valge raamat, Tallinn, 2022, 

Stakeholder 

Economy 

Platform 

website, 

(4) 

https://ringmajandus.envir.ee/sites/default/files/2022-
09/20220803_Valge%20raamat.pdf. 
For  more  information,  see  Ministry  of  Climate,  ‘Eesti  taaste  ja 
ringmajanduse 
vastupidavuskava 

sätestatud 

raames 

(6) 

(7) 

(8) 

2025, 

2023, 

22 January 

tegevuskava’, 
accessed 
https://ringmajandus.envir.ee/sites/default/files/2024-
10/Eesti%20ringmajanduse%20tegevused%202024.pdf. 
State  Support  Services Center,  Estonian  Recovery  and  Resilience 
Plan 
Tallinn, 
last 
https://pilv.rtk.ee/s/kwzABsf9cJY4mmb. 
For  more  information,  see  the  Estonian  Environmental  Agency 
project 
on 
web 
(https://keskkonnaportaal.ee/et/ringmajanduse-voimekuse-
tostmine#KOVideteekaardid). 

updated 

16 June 

2023, 

page 

the 

Environmental Implementation Review 2022 – Estonia 

 
 
Estonia  6 

The EU’s approach to waste management is based on the 
waste  treatment  hierarchy:  prevention,  preparing  for 
reuse,  recycling,  recovery  and,  as  the  least  preferred 
option,  disposal 
landfilling  and 
includes 
incineration without energy recovery). 

(which 

All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 
to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy. 

in  Estonia 
The  total  amount  of  waste  generated 
significantly 
increased  over  the  period  considered 
(Figure 3). However, the upward trend is primarily driven 
by  mineral  waste  and  a  moderate  decrease  can  be 
observed  when  this  waste  is  excluded.  Estonia’s  GDP 
shows steady growth, except for a drop in 2020, which is 
most  likely  to  be  due  to  the  COVID-19  outbreak.  This 
indicates that a decoupling from economic growth can be 
observed for total waste excluding major mineral waste. 
However, this is only partly the case for total waste. 

Figure 3: Generation of waste (total and excluding major 
mineral waste), population and GDP, 2010–2022 

at 
scheme 
management 
environmental impacts of organisations. 

aimed 

reducing 

the 

As of September 2024, Estonia had 1 789 products out of 
98 977, and 21 licences out of 2 983 registered in the EU 
Ecolabel  scheme,  indicating  low  take-up  of  licences  in 
particular (9). Moreover, 19 organisations from Estonia are 
currently registered in EMAS, one fewer than in 2021 (10). 

No priority actions were suggested for Estonia in the 2022 
Environmental  Implementation  Review  (EIR),  and  the 
country has fulfilled previous priority actions by adopting 
a  circular  economy  policy  framework  through  its  white 
paper and its action plan. These need to be strengthened 
and their implementation needs to be prioritised. 

2025 priority actions 

• 

Speed  up  the  transition  to  a  circular  economy  by 
implementing  an  updated  national  strategy  and  the 
EU framework and recommendations, in particular to 
complement it with upstream circularity measures. 

•  Adopt measures to increase the CMUR. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 
sustainable; 

(ii)  fully 

implementing  EU  waste 

legislation,  which 
includes the waste hierarchy, the obligation to ensure 
separate collection of waste, landfill diversion targets, 
etc.; 

(iii)  reducing waste generation per capita and in absolute 

terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical  raw  materials,  with  a  view  to  reducing 
dependencies and building resilient value chains, and 
stimulating  demand  for  recycled  content 
in  all 
products; 

(v)  limiting energy recovery to non-recyclable materials; 

and 

accessed 

15 October 

nama_10_gdp, 

Sources: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table;  Eurostat,  ‘Generation  of  waste  by  waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen,  last 
updated 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/default/
table?lang=en; Eurostat, ‘Population change – Demographic balance and 
crude  rates  at  national  level’,  demo_grind,  accessed  15 October  2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default/t
able?lang=en&category=demo.demo_ind. 

30 September 

22 October 

accessed 

2024, 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

Construction and demolition waste 

One  of  the  main  objectives  of  the  EU  Waste  Law  is  to 
decouple  economic  growth  from 
its  environmental 
impacts. 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (11) 
by  the  Joint  Research  Centre  shows  that  recycling  and 

(9) 

(10) 

website, 

European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
2025, 
http://ec.europa.eu/environment/ecolabel/facts-and-
figures.html. 
As  of  October  2021.  European  Commission,  ‘EMAS  Register – 
Published  organisations’,  EMAS  Register  website,  accessed 

22 January 

accessed 

(11) 

22 January 
https://webgate.ec.europa.eu/emas2/public/registration/list. 
European Commission: Joint Research Centre, Cristobal Garcia, J., 
Caro, D. et al., Techno-economic and environmental assessment of 
construction and demolition waste management in the European 
Union,  Publications  Office  of  the  European  Union,  Luxembourg, 

2025, 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
Estonia  7 

Figure 4:  Member  States’  prospects  of  meeting  the 
preparing  for  reuse  and  recycling  targets  for  municipal 
waste and packaging waste 

preparation for reuse are preferred over incineration and 
landfilling from an environmental perspective for most of 
the  different  streams  of  construction  and  demolition 
waste.  However,  the  economics  are  often  unfavourable 
for  recycling  and  preparation  for  reuse  compared  with 
incineration and landfilling. If available technology were to 
be  applied,  it  is  estimated  that  the  increase  in  recycling 
and  preparation  for  reuse  would  lead  to  an  additional 
33 Mt of greenhouse gas (GHG) emission savings annually 
(more  than,  for  example,  the  combined  annual  GHG 
emissions from Estonia, Latvia and Luxembourg). 

The rate of recycling and preparation for reuse of mineral 
construction and demolition waste in Estonia in 2022 was 
66.6 %,  compared  with  the  EU  average  of  79.8 %. 
Measures  to  further  increase  the  rate  of  recycling  and 
preparation  for  reuse  of  construction  and  demolition 
waste  include  separate  collection  at  the  source –  for 
instance,  through  digitalised  pre-demolition  audits (12) 
(‘resource 
producer 
responsibility (EPR) and other economic instruments; and 
upstream  measures  such  as  increasing  the  recycled 
content 
in  construction  products  and  the  circular 
design (13) of construction works. 

assessments’); 

extended 

Boosting implementation – the 2023 Waste Early 
Warning Report 

This section focuses on the management of municipal and 
packaging  waste (14),  for  which  EU  law  sets  mandatory 
recycling targets. In June 2023, the Commission published 
the  Waste  Early  Warning  Report (15) 
identifying  the 
general  trends  in  waste  management  and  the  Member 
States at risk of missing 2025 waste targets (see Figure 4). 
Estonia is at risk of missing the municipal waste target but 
not the packaging waste target. 

Member  States  not  at  risk  of  missing  the  55 % 
for 
preparing 
municipal  waste  and  the  65 %  recycling  target  for 
packaging waste 

for  reuse  and  recycling  target 

Member States at risk  of missing the preparing for 
reuse  and  recycling  target  for  municipal  waste  but 
not  at  risk  of  missing  the  recycling  target  for 
packaging waste 

Member States at risk of missing both targets 

  Outside coverage 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not on track to meet recycling targets for municipal waste and packaging 
waste’, briefing No 28/2022, Copenhagen, 2023. Reference data © ESRI. 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
reaching certain waste management targets for municipal 
and packaging waste. Member States that want to use this 
possibility  have  to  notify  the  Commission  24 months  in 
advance  of  the  deadline  and  submit  an  implementation 
plan  laying  down  the  steps  they  envisage  to  reach  the 
postponed targets within a new time frame. Regarding the 

2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 
European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works – 
Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for buildings 
design, 
2020, 
Brussels, 
https://ec.europa.eu/docsroom/documents/39984. 

(12) 

(13) 

(14)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected waste from households, including paper and cardboard, 
glass, metals, plastics, biowaste, wood, textiles, packaging, waste 
electrical  and  electronic  equipment,  waste  batteries  and 
accumulators,  and  bulky  waste, 
including  mattresses  and 
furniture;  and  (ii)  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, 
Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(15) 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
 
2025  targets,  11  Member  States,  not  including  Estonia, 
have used this prerogative. 

Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Estonia  8 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission  is,  on  one  hand,  working  together  with  the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of  the  Waste  Framework  Directive,  the  Packaging  and 
Packaging  Waste  Directive  and  the  Directive  on  Waste 
Electrical and Electronic Equipment (16). 

Estonia  is  currently  taking  important  steps  through  a 
planned  waste  reform  that  will 
include  targets  for 
municipalities,  an  increase  of  the  landfill  tax  and  the 
introduction of incineration taxes. 

Management of municipal and packaging waste 

Estonia  is  one  of  the  Member  States  with  the  lowest 
municipal  waste  generation  per  capita,  with  373 kg  per 
capita in 2022, well below the EU-27 average of 513 kg per 
capita (Figure 5). 

However, Estonia had a 33 % rate of preparing for reuse 
and  recycling  in  2022,  which  is  significantly  below  the 
estimated  EU-27  average  of  49 %  in  the  same  year (17). 
Until 2014, Estonia had made great progress in diverting 
municipal waste from landfill, mainly to incineration but 
also  to  recycling.  However,  since  then,  waste  volumes 
have increased, the recycling rate has stayed largely stable 
and the share of landfilled waste has increased again. The 
most  recent  data  show  a  positive  development  towards 
higher  recycling  rates  and  less  landfilling  of  municipal 
waste (Figure 6). 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
2024, 
env_wasmun, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

from 

Estonia  diverted  municipal  waste 
landfill  by 
introducing a mechanical biological treatment plant. The 
incineration  rate  reached  42 %  and  the  landfill  rate 
reduced to 13 % in 2022, which is close to the 2035 target. 
However,  this  led  to  the  overcapacity  of  mechanical 
incineration 
biological  treatment  plants  and  waste 
facilities  for  energy  recovery,  hindering  the  recycling  of 
municipal  waste (18).  The  share  of  composting  and 
digestion  is  rather  low,  at  5 %  in  2022,  due  to  an 
insufficient  separate  collection  system  and  uneven 
capacity for treating biowaste across regions. 

Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–2022 

Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

22 October 

accessed 

(16) 

(17) 

https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32012L0019. 
The  EU  average  might  have  been  influenced by  not  all  Member 
States  fully  applying  the  reporting  rules  for  municipal  waste  set 
out in the Waste Framework Directive as amended in 2018. 

(18) 

EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal  and  packaging  waste –  Estonia,  Copenhagen,  2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/estonia/view. 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
Packaging waste 

Estonia’s  packaging  waste  generation 
significantly 
increased between 2010 and 2017 but started to decrease 
in 2017. In 2022, the country generated 143 kg per capita, 
which  is  significantly  below  the  estimated  European 
average  of  186 kg  per  capita 
in  the  same  year 
(Figure 7) (19).  This  low  figure  may  be  an  indication  that 
some  quantities  of  generated  municipal  waste  are  not 
reported (20). 

In 2022, the overall recycling rate for packaging waste was 
73 %, which is slightly above the estimated EU-27 average 
of 65 % and is above the 2025 target (Figure 8). This high 
recycling rate is partly due to a deposit refund scheme for 
beverage packaging that has been in place since 2005 (EC, 
2023).  The  overall  recycling  rate  is  mainly  driven  by 
paper/cardboard  and  plastic  packaging  recycling.  The 
plastic packaging recycling rate has slightly increased since 
2017  due  to  increased  opportunities  for  recycling,  the 
entry of new operators into  the market and the start  of 
full-time  operation  of  Estonia’s  largest  plastic-recycling 
plant in 2018. However, in 2022, the plastic packaging rate 
was 44 %,  which  is still below the  2025 material-specific 
target  of  50 %.  The  peaks  in  glass  recycling  in  2019  and 
2022  were  influenced  by  the  recycling  of  stocks  of  glass 
waste  from  previous  years.  The  recycling  of  wooden 
packaging 
is  affected  by  competition  with  biomass 
demand  for  energy  purposes(21).  The  recycling  rates  of 
both  steel  and  aluminium  waste  exceeded  the  2025 
target. 

Figure 7: Packaging waste generation, 2010–2022 

Estonia  9 

Source:  Eurostat,  ‘Packaging waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

Figure 8: Packaging waste recycling rates (%), 2010–2022 

Source:  Eurostat,  ‘Packaging waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

Policies to encourage waste prevention 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of  EU  waste  legislation.  They  set  out  key  provisions  and 
investments to ensure compliance with existing and new 
legal requirements (e.g. on waste prevention, on separate 
collection for certain waste streams, on recycling and on 
landfill targets). 

Estonia’s  current  national  waste  prevention  programme 
(NWPP)  is  integrated  into  the  NWMP  for  2023–2028. 
While  there  is  no  explicit  differentiation  between  waste 
management and waste prevention, Estonia’s dedication 
to  tackling  food  waste 
is  clearly  articulated.  This 
commitment is outlined in a food waste prevention plan 
in the appendix to the NWMP. This includes six key areas 
to prevent and reduce food waste. Beyond food waste, the 
priority  waste  streams  for  prevention  mentioned  in  the 
NWMP are household waste, construction and demolition 
waste, hazardous waste, packaging waste, biodegradable 
waste, waste textiles and waste from the shale oil industry 
(22). Preventing and reducing littering was introduced as a 
new priority in the NWPP for 2023–2028. 

(19) 

(20) 

The  EU  average  might  have  been influenced by  not  all  Member 
States fully  applying  the  reporting  rules for  packaging  waste  set 
out in Commission Implementing Decision (EU) 2019/665. 
Commission Staff Working Document – The early warning report 
for  Estonia,  SWD(2023) 180  final  of  8 June  2023,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2023%3A180%3AFIN. 

(21)

(22) 

https://ec.europa.eu/eurostat/databrowser/view/ENV_WAS

PAC__custom_842634/default/table?lang=en 
EEA,  Waste  Prevention  Country  Profile –  Estonia,  Copenhagen, 
2023, 
https://www.eea.europa.eu/themes/waste/waste-
prevention/countries/2023-waste-prevention-country-fact-
sheets/estonia_waste_prevention_2023. 

Environmental Implementation Review 2022 – Estonia 

 
 
 
 
 
 
 
its 
The  programme  does  not  specify  a  budget  for 
implementation. Estonia intends to finance the activities 
through EU and local funds, as well as through funds from 
the Environmental Investment Centre (23). 

The evaluation of the NWPP for 2014–2020 did not specify 
any indicators or targets for waste prevention; hence, its 
impact  has  not  been  assessed.  However,  a  variety  of 
supporting,  regulatory  and  awareness-raising  measures 
are highlighted. 

Other  examples  of  reuse  initiatives  in  Estonia,  although 
not incorporated into the NWMP for 2023–2028, include 
the yearly financial support provided by the Environment 
Investment  Centre  for  waste  prevention  and  reuse 
activities.  In  addition,  it  is  notable  that,  from  2024,  only 
reusable  containers  and  utensils  are  permitted  for  food 
and beverage services at public events in Estonia(24). 

Policies to encourage separate collection and recycling 

Estonia intends to further develop the separate collection 
of  waste  and  introduce  related  changes  through  a 
comprehensive  municipal  waste  reform  backed  up  by 
support  measures  aiming  to  cover  waste  prevention, 
recycling and infrastructure for the separate collection of 
municipal waste. 

(separate  or 

Estonia has a door-to-door separate collection system at 
household  properties  in  cities  for  paper  and  cardboard 
and  for  biowaste.  There  is  a  bring  point  system  for  the 
separate  collection  of  glass,  plastic,  metal,  paper  and 
cardboard  packaging 
commingled), 
complemented  by  door-to-door  packaging  collection  in 
some areas. Most municipalities allow for the collection of 
food  and  garden  waste  in  the  same  biowaste  bin; 
otherwise,  garden  waste  and  wooden  packaging  are 
collected  at  civic  amenity  sites.  The  separate  collection 
system  mainly  targets  packaging,  and  the  collection  of 
non-packaging recyclable waste is mainly arranged at civic 
amenity sites. 

In Estonia, EPR applies to all packaging and there is some 
advanced fee modulation in place. Estonia has packaging 
taxes in place that only apply when recycling rates are not 
fulfilled. 

In  order  to  incentivise  sorting  at  the  source,  nearly  all 
regions  and  municipalities  have  implemented  various 
types  of  volume-based  pay-as-you-throw  schemes. 
Moreover, Estonia has a mandatory deposit return system 
for  most  aluminium  drink  cans, some  glass  drink  bottles 
and most plastic drink bottles. 

Estonia  10 

Policies to discourage landfilling or incineration 

Estonia has had a landfill tax in place since 1991, and the 
rate has been EUR 29.84/t since 2015. This is considerably 
lower than the average landfill tax in those Member States 
applying  such  taxes.  Estonia  has  had  a  ban  in  place  for 
landfilling  unsorted  municipal  waste  since  2004,  but 
led  to  considerable  amounts  still  being 
exemptions 
been 
However, 
landfilled. 
strengthened and, since 2020, the share of biodegradable 
waste in municipal waste being landfilled cannot exceed 
20 % by weight, all municipal waste has to be pretreated 
before  landfilling  and  landfilling  of  separately  collected 
waste is banned. Estonia has no tax on waste incineration, 
but  incineration  of  separately  collected  waste  is  also 
banned. 

requirements 

have 

Estonia’s  efforts  translated  into  positive  outcomes,  with 
the  rate  for  total  packaging  waste  and  all  packaging 
materials except plastic packaging already above the 2025 
targets,  and  the  reported  landfill  rate  close  to  the  2035 
target. On the other hand, Estonia has made  only minor 
progress  recently  on  the  recycling  and  preparation  for 
reuse  of  municipal  waste,  while  the  combined  share  of 
landfilling and incineration has remained rather stable. 

In the 2022 EIR, the European Commission recommended 
introducing  new  policy  instruments,  setting  mandatory 
targets at the municipality level for recycling and residual 
waste  generation,  improving  and  extending  separate 
collection systems, shifting reusable and recyclable waste 
away  from  incineration  and  improving  the  EPR  systems. 
While 
these 
it  may  be  expected  that  some  of 
recommendations  will  be  taken  up  as  part  of  an 
announced  reform  of  the  national  Waste  Act  and  other 
relevant laws, these developments have yet to be finalised 
and thus the priority actions from the previous reporting 
period remain valid. 

2025 priority actions 
• 

through 

including 

Further shift reusable and recyclable waste away from 
incineration, 
economic 
instruments. 
Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps  of  the  waste  hierarchy.  In  particular,  improve 
collection  and  increase  treatment  capacity  for  bio-
waste. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 

• 

• 

• 

•  Develop  EPR  schemes  for  problematic  waste  and 

(23) 

EEA,  Waste  Prevention  Country  Profile –  Estonia,  Copenhagen, 
2023, 
https://www.eea.europa.eu/themes/waste/waste-
prevention/countries/2023-waste-prevention-country-fact-
sheets/estonia_waste_prevention_2023. 

(24) 

EEA,  Waste  Prevention  Country  Profile –  Estonia,  Copenhagen, 
2023, 
https://www.eea.europa.eu/themes/waste/waste-
prevention/countries/2023-waste-prevention-country-fact-
sheets/estonia_waste_prevention_2023. 

Environmental Implementation Review 2022 – Estonia 

 
 
• 

introduce fee modulation. 
Ensure  the  achievement  of  the  2025  waste  targets, 
following 
the 
Commission  in  the  Early  Warning  Reports  where 
applicable. 

the  recommendations  made  by 

Estonia  11 

Environmental Implementation Review 2022 – Estonia 

 
Estonia  12 

2. Biodiversity and natural capital

Global and EU biodiversity frameworks 

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and action plans (NBSAPs), or to communicate national 
targets  aligned  with  the  global  targets,  by  the  end  of 
2024. The EU biodiversity strategy for 2030 (BDS) aims to 
put EU biodiversity on a path to recovery by 2030. It sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
and 
as  measures 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (25)  and  a  dashboard  of  indicators (26) 
provide  information  on  implementation  progress.  The 
recently adopted EU Nature Restoration Regulation (27) is 
the first EU-wide, comprehensive law of its kind and a key 
instrument  for  the  EU  to  deliver  on  the  global 
biodiversity targets for 2030. It lays down an overarching 
objective  at  the  EU  level  to  put  in  place  effective 
restoration measures on 20 % of EU land and sea by 2030 
and for all ecosystems in need of restoration by 2050. To 
achieve this, it sets binding targets for Member States to 
restore and maintain ecosystems, as well as an effective 
national 
implementation 
restoration plans. The BDS is the main instrument used 
by the EU to deliver on its obligation under the GBF. 

implementation 

framework 

enable 

based 

on 

to 

The  Commission  has  submitted  to  the  Convention  on 
Biological Diversity its report on GBF-aligned EU targets 
that  stem  from  the  BDS  and  from  other  policy 
instruments under the European Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 

In 

financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

The EU aims to allocate to biodiversity objectives at least 
7.5 % of annual spending under the EU budget in 2024, 
rising  to  10 % 
in  2026  and  2027.  For  details  on 
biodiversity  financing  and  investments  in  Estonia,  see 
‘Biodiversity and ecosystems’ in Chapter 5. 

Estonia’s  new  environmental  development  plan  for 
2030,  entitled  Keskkonnavaldkonna  arengudokument 
(KEVAD; the acronym forms the Estonian word meaning 
‘spring’ (28)),  combines  all  environmental  development 
plans  and  sets  general 
for  biodiversity 
conservation. 

targets 

In addition to ensuring a network of protected areas that 
is ecologically well-functioning and effectively protected, 
Estonia  will  enhance  biodiversity  mainstreaming  in  the 
planning  process  to  preserve  biodiversity  beyond 
protected  landscapes  and  implement  new  ways  of 
landowners  to  recognise  and  protect 
incentivising 
natural  values.  Estonia  will  also  promote 
the 
performance of its green network, which will support the 
ecological  coherence  of  habitats  and  the  adequacy  of 
species corridors. 

Estonia  has  not  yet  submitted  an  updated  NBSAP  or 
national  targets  to  the  Convention  on  Biological 
Diversity. 

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

2025 priority action 

• 

Submit  to  the  CBD  an  updated  NBSAP  or  national 
targets  following  the  adoption  of  the  Kunming-
Montreal Global Biodiversity Framework. 

(25) 

(26) 

(27) 

Actions 

Strategy 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 

Dashboard 

Strategy 

Tracker 

(28) 

Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
the 
see  also 
http://data.europa.eu/eli/reg/2024/1991/oj; 
Commission 
law 
the 
on 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 
https://kliimaministeerium.ee/kevad. 

page 

web 

2025 Environmental Implementation Review – Estonia 

 
 
Estonia  13 

coverage:  18.6 %),  with  special  protection  areas  (SPAs) 
classified under the Birds  Directive covering  13.7 % (EU 
coverage: 12.8 %) and SCIs under the Habitats Directive 
covering  17.2 %  (EU  coverage:  14.3 %)  of  Estonia’s 
territory. 

With 18.7 % of its marine waters covered by protected 
areas,  Estonia  surpasses  the  EU  average  of  12.1 % (34). 
The latest assessment of the SCI part of the Natura 2000 
network shows that the designation is complete. 

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

Considering  both  areas  covered  by  Natura  2000  and 
other  nationally  designated  protected  areas,  Estonia 
legally  protects  21 %  of  its  terrestrial  area  (EU-27 
coverage: 26.1 %) and 18.7 % of its marine area (EU-27 
coverage: 12.3 %) (35). 

Figure 9:  Natura  2000  terrestrial  protected  area 
coverage per Member State (%), 2023 

Nature protection and restoration – Natura 
2000 

Natura  2000 (29),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (30); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
Natura  2000  sites 
is  a  cornerstone  of  the  EU’s 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area by 2030. 

the 

these 

requires 

commitments 

Meeting 
full 
implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
Natura 2000 will enable the natural habitat types and the 
species’ habitats concerned to be maintained or, where 
appropriate,  restored  to  a  favourable  conservation 
status in their natural range. 

Estonia  hosts  60  habitat  types (31)  and  95  species (32) 
covered by the Habitats Directive. The country also hosts 
populations of  75 bird taxa listed in the Birds Directive 
Annex I (33). 

As shown in Figure 9, in 2023, 17.9 % of the national land 
area  of  Estonia  was  covered  by  Natura  2000  (EU 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

(30) 

(29)  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. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
See indicators A1.1.1 and A1.2.1 of the EU Biodiversity Strategy 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
Dashboard 
dashboard/?version=1). 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
2025, 
accessed 
Article 17 

dashboard, 

February 

(31) 

(32) 

in 

https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
This  counting  only  takes  into  account  birds  taxa  for  which 
information was requested. 
https://biodiversity.europa.eu/countries/estonia. 
Eurostat dataset env_bio4, 2022 data, accessed 12 March 2025 

(33) 

(34) 
(35) 

2025 Environmental Implementation Review – Estonia 

 
 
 
Designating Special Areas of Conservation and 
setting site-specific conservation objectives and 
measures 

The  six-year  deadline  set  by  the  Habitats  Directive  to 
designate  SCIs  as  SACs  and  establish  appropriate 
conservation objectives and measures has been met, as 
Estonia  has  designated  all  SCIs  as  SACs.  However,  an 
infringement  procedure  is  open  against  Estonia  on 
account of the failure to establish adequate conservation 
objectives and measures for all its SACs.  In response to 
the  Commission’s  enforcement  efforts,  Estonia  has 
accelerated  establishment  of  those  objectives  and 
measures. The Commission is now assessing the quality 
of the objectives and measures recently established. 

2025 priority actions 

• 

• 

of 

the 

establishment 

Finalise 
site-specific 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 
Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
implementation  of 
the  Nature  Restoration 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (36). 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 

(36) 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 

Luxembourg, 

Union, 

Estonia  14 

protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

Under  Article 17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of  habitats  and  species  every  six  years.  The  current 
reporting cycle, covering the years 2019 to 2024, is due 
for submission in July 2025. Figures 10 and 11 show the 
latest available conservation status data. 

For  protected  species,  the  share  of  assessments 
indicating good conservation status in 2018 was 56.25 %, 
which  is 2.71 % more than the  53.54 % reported under 
the  previous  reporting  period  (2007–2012) (37).  The  EU 
average was 27.5 %. As far as birds are concerned, 60 % 
of the breeding species showed short-term increases or 
stable  population  trends  (for  wintering  species,  this 
figure was 85.72 %). 

The share of assessments  indicating species having bad 
or  poor  conservation  status  increased  slightly,  to  36 % 
(35 % in the previous reporting period). 

Figure 10:  Assessments  of  conservation  status  of 
species  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
2021, 
19 December 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

The main pressures for species (in descending order) are 
forestry,  agriculture  and  human-induced  changes  in 
water regimes. 

https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
16.67 % of which reflect genuine changes. 

(37) 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
Estonia  15 

Conservation  Act  to  require  the  permission  of  the 
Environmental  Board  not  only  for  the  construction  of 
new  drainage  systems  but  also  for  the  renovation  and 
maintenance of existing ones in all protected areas. 

recent 

inter  alia, 

impact  assessments  (EIAs), 

Pressures  stemming  from  infrastructure  development 
need  to  be  addressed  by, 
improved 
implementation  of  Articles 6(3)  and  (4)  of  the  Habitats 
issues  with 
Directive.  There  have  been 
environmental 
including 
appropriate  assessments  under  the  Habitats  Directives 
regarding  large  infrastructure  projects,  such  as  Rail 
Baltica  or  Via  Baltica.  Problems  included  the  lack  of 
assessment  of  a  protected  species  subject  to  a  site’s 
conservation  objectives, 
justifications  of  overriding 
public interest or logging in compensation areas. 

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

regard 

in  particular  with 

An  infringement  procedure  is  open  against  Estonia, 
based  on  concerns  about  the  bad  application  of  the 
Habitats  Directive, 
to 
appropriate  assessment  procedure  concerning  logging 
activities  in  Natura  2000  areas.  In  response  to  the 
infringement procedure, Estonia has restricted logging in 
Natura 2000 areas; however, further steps are needed to 
achieve 
through 
amendments to the Nature Conservation Act in respect 
of  appropriate  assessment  and  through  establishing  a 
forest management plan. 

in  particular 

compliance, 

full 

In Estonia, 56.7 % of habitats assessments indicate good 
conservation status, which is considerably above the EU 
average of 14.7 %. 

According  to  the  report  submitted  by  Estonia  on  the 
conservation status of habitats covered by  Article 17 of 
the  Habitats  Directive  for  2013–2018,  the  share  of 
assessments  of  habitats  indicating  good  conservation 
status in 2018 was 5 % more than the 51.67 % reported 
under the previous reporting period (2007–2012) (38). 

At the same time, the share  of habitats in bad  or poor 
conservation status decreased to 44 % (from 48 % in the 
previous reporting period). 

Figure 11:  Assessments  of  conservation  status  of 
habitats  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in conservation status 
in a Member State may result from changes to methods or use of better 
data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

Of  the  27 %  of  forest  area  protected  under  the  Nature 
Directives,  only  20 %  of  Estonian  habitats  show  a 
favourable conservation status (39). 

The main pressures for habitats (in descending order) are 
agriculture, natural processes and forestry. 

In relation to pressures caused by drainage systems for 
forestry  and  agriculture  (human-induced  changes  in 
water  regimes),  Estonia  intends  to  change  its  Nature 

(38)  However,  26.7 %  of  these  changes  were  due  to  changes  in 
methods or due to better data, and only 6.7 % reflect genuine 
changes. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 

(39) 

European 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – Estonia 

 
 
 
Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will result in a  20 % reduction in the use of 
is  no 
fertilisers)  while  ensuring 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

high-diversity landscape features; and 
increase the area under organic farming to at least 
25 %. 

The “Vision for agriculture and food” (40), adopted by the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective. 

The  CAP  and  national  CAP  strategic  plans  (SPs)  that 
establish the framework for the transition to sustainable 
agriculture  are  key 
instruments  to  facilitate  and 
strengthen  the  efforts  of  European  farmers  to  protect 
biodiversity  and 
large.  The 
Commission approved Member States’ CAP SPs in 2022. 
CAP 
the 
implementation  of  EU  environment  policy  and  SPs 
should lead to better protection of soil, water, air quality 
and biodiversity. 

the  environment  at 

largest  source  of 

funding 

the 

for 

is 

Estonia  16 

measures  is  difficult  to  be  assessed.  The  uptake  of  the 
eco-schemes is voluntary for farmers.  

The  utilised  agricultural  area  in  Estonia  increased  from 
955 900 ha  in  2012  to  1 003 510 ha  in  2016  and  then 
decreased to 986 210 ha in 2022 (41). 

Landscape  features  are  small  fragments  of  non-
productive  and  typically –  but  not  exclusively –  semi-
natural vegetation present in or adjacent to agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
land.  Based  on  the  Land 
covered  by  agricultural 
Use/Cover  Area  Frame  Survey 
landscape  features 
estimates, the share of agricultural land covered by non-
productive landscape features in Estonia is 5.6 %, which 
is exactly the EU average. 

In  2024,  the  CAP  basic  regulations  were  amended (42) 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land.  These  changes 
removed the obligation for farmers benefiting from CAP 
area-related support to have a minimum share of 3–4 % 
of  non-productive  area  or  landscape  features  in  their 
farms.  The  amended  regulations  set  out,  however,  an 
obligation  for  Member  States  to  establish  and  provide 
support  for  eco-schemes  covering  practices  for  the 
maintenance of non-productive areas, such as land lying 
fallow,  and  for  the  establishment  of  new  landscape 
features on arable land. 

The recently adopted Nature Restoration Regulation (43) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (44). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

Estonia’s  environmental  development  plan  for  2030 
contains several actions aiming to improve biodiversity in 
agricultural ecosystems: 

While certain CAP result indicators focus on the national 
measures  favouring  sustainable  agriculture  practices 
that  regenerate  the  ecosystems,  the  impact  of  these 

(40)  https://agriculture.ec.europa.eu/overview-vision-agriculture-

(41) 

(42) 

5 December 

food/vision-agriculture-and-food_en   
Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 

• 

(43) 

(44) 

the 

enhancing 
agricultural 
biodiversity 
landscapes,  with  a  particular  focus  on  pollinators 
and farmland birds; 

of 

environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 

in  cropland  mineral  soils’  and 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
Estonia  17 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
resilience,  adaptation  and 
security  and  climate 
mitigation. 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 
resilience (46) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 
the  proposed  directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Estonia (47). 

soil  organic 

loss  of 

carbon, 

• 

restoring  and  maintaining  heritage  meadows  and 
valuable permanent grasslands; 
using sustainable tillage practices; 

• 
•  mitigating the negative effects of drainage, ensuring 
that  both  agricultural  drainage  systems  and  forest 
drainage  ditches  are  as  close  to  nature  as  possible 
and do not harm biodiversity; 
preserving 
biodiversity-friendly 
creating 
and 
landscape  features  and  habitats,  including  small 
wetlands, tree rays and grassland habitats. 

• 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
23.42 % of Estonia’s land area is used for organic farming. 
This is the second-best result in the EU and  well above 
the  EU  average  of  10.50 % (45).  Estonia  is  contributing 
substantially to achieving the target of 25 % of the EU’s 
agricultural land being used for organic farming by 2030. 

Figure 12: Share of total utilised agricultural area 
occupied  by  organic  farming  per  Member  State 
(%), 2022 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

2025 priority action 

Implement  eco-schemes  and  agri-environmental 
the 
measures 
environmental needs of Estonia. 

practices 

address 

and 

to 

• 

(45) 

(46) 

This is based on the latest available information from Eurostat, 
which 
is  currently  under  review;  European  Commission, 
Agriculture biologique au sein de l’union européenne, factsheet, 
Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 
Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 

(47) 

of 

final 

5 July 

2023, 

https://eur-
COM(2023) 416 
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a directive of 
the European Parliament and of the Council on soil monitoring 
and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
5 July 
2023, 
https://environment.ec.europa.eu/system/files/2023-

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
Estonia  18 

land  has  a  high  or  very  high 
45 %  of  Estonia’s 
susceptibility to topsoil compaction. 18 % of the national 
territory  consists  of  peatland  areas  experiencing 
degradation and losing organic soils,  of which  72 % are 
on agricultural land. 

Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
for 
large  herbivores.  Grasslands  are  essential 
to 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

The  majority  of  Estonian  grassland  habitats  protected 
under 
the  Habitats  Directive  have  unfavourable 
conservation status (five out of eight grassland habitats 
reported  under  Article 17  in  2013–2018 = 62.5 %) (48). 
in 
Equally,  Fennoscandian  wooded  pastures  are 
unfavourable condition. 

Estonia is taking measures to address the main pressures 
and 
lack  of 
threats,  which  are 
low-density  grazing), 
management  (e.g.  mowing  or 
afforestation,  ploughing,  fertilisation,  construction  and 
development, and drainage for wet meadows. 

fragmentation, 

Estonia  has  a  grassland  action  plan (49),  which  aims  to 
maintain or restore the favourable status of 50 000 ha of 
grassland habitats (‘heritage meadows’) by 2027. This is 
particularly 
important  because  about  half  of  the 
protected  species  in  the  country  are  found  in  semi-
natural meadow communities. 

The  country’s  current  CAP  SP 
includes  two  rural 
development  programme  actions  for  maintaining  high-
nature-value grasslands and heritage meadows. 

Estonia received the LIFE Natura 2000 Award in 2022 for 
its project ‘ (￼50. 

Alvars are a habitat based on a limestone plain with thin 
or no soil and, as a result, sparse grassland vegetation. 
Estonia  has  a  special  responsibility  for  this  grassland 

type,  as  one  third  of  all  alvar  grasslands  in  Europe  are 
found in Estonia. 

The project has restored 2 500 ha of alvar grasslands in 
Estonia – roughly 25 % of the global total – by removing 
woodlands and forests that developed spontaneously on 
these sites. 

During the project, the status of the Habitats Directive’s 
priority  habitat  type  Nordic  alvar  and  Precambrian 
calcareous  flatrocks  (6280*)  was  directly  improved  by 
more than doubling the habitat area of alvar grasslands 
in favourable condition in Estonia. 

All  restored  sites  became  eligible 
for  CAP  agri-
environmental payments, ensuring the viability of both 
farming activities and the habitats in the longer term. 

As a spin-off from the project, a farmers’ cooperative set 
up on Muhu island. The cooperative markets meat from 
the restored alvar grasslands. 

2025 priority action 

• 

Promote active management of grasslands through 
extensive grazing to maintain the condition of these 
semi-natural habitats. 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I to the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

The majority of Estonian bogs, mires and fens protected 
under 
the  Habitats  Directive  have  unfavourable 
conservation status (five out of  eight habitats reported 
under Article 17 in 2013–2018 = 62.5 %) (51). 

The main pressures and threats are draining of forest and 
agricultural  land,  and  mining  activities  that  affect  the 

(48) 

(49) 

ASSESSMENT 

07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 
https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Grasslands&country=EE&region=. 
Environmental  Board,  Heritage  Meadows  Action  Plan,  Pärnu, 
2021, 
https://keskkonnaamet.ee/sites/default/files/documents/2021-
09/parandniitude_tegevuskava_2021-2027_1.pdf. 

(50)

(51) 

https://webgate.ec.europa.eu/life/publicWebsite/project/

LIFE13-NAT-EE-000082/restoration-of-estonian-alvar-
grasslands; 
https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Bogs,+mires+&+fens&country=EE&region=. 
nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Bogs%2C+mires+%26+fens&country=EE&region=. 

2025 Environmental Implementation Review – Estonia 

 
 
 
water regime of mire habitats and other developments. 

and 

Peatland 

Peatlands are unique and rare ecosystems that, despite 
only covering around 3-4% of the planet’s land surface, 
contain up to one-third of the world’s soil carbon, which 
is  twice  the  amount  of  carbon  as  found  in  the world’s 
forests. 
sustainable 
restoration 
management is highly important to both combat climate 
change  and  preserve  biodiversity.  Living  peatlands  not 
only  sequester  carbon  dioxide  (CO2)  but  also  provide  a 
healthy habitat for valuable species and remove nitrates 
from polluted agricultural run-off through denitriﬁcation. 
Peatland loss also means biodiversity loss, more floods 
and  droughts,  degraded  drinking  water  for 
local 
communities  and  eutrophication  of  open  waters.  This 
last  impact  should  be  avoided,  especially  around  the 
Baltic Sea, which is affected by eutrophication at a level 
of 97 %. Damage is caused when peatlands are drained 
for agriculture and tree planting, with peat extracted for 
fuel or horticulture. 

As  a  direct  consequence  of  peat  extraction,  about 
30 000 ha of raised bogs have been destroyed in Estonia, 
of which around 20 000 ha are still used. 

In  Estonia,  drained  peatlands  are  one  of  the  most 
important emitters of GHG after the oil shale industry. As 
a  result  of  the  drainage  of  bogs,  total  GHG  emissions 
(carbon dioxide (CO2), methane (CH4) and nitrous oxide 
(N2O))  in  Estonia,  converted  into  CO2  equivalent,  are 
estimated to be 2.3–2.7 times higher than the emissions 
if  those  wetlands  were  still  in  their  natural  state. 
Therefore, restoring the natural state of degraded areas 
from  drainage  is  important  not  only  for  biodiversity 
conservation but also for climate change mitigation. 

According  to  its  nature  conservation  and  development 
plan for 2012–2020, Estonia intends to restore the water 
regime of 10 000 ha of mire habitats and of 1 000 ha of 
former  peat-mining  areas.  The  country  established  an 
action  plan  for  the  restoration  of  mires  (2015–2023), 
which  set  out  a  priority  list  of  mires  in  need  of 
restoration. 

land’ 

‘Conservation  on 

Estonia  won  the  Natura  2000  Award  in  2024  in  the 
category 
large-scale 
restoration  of  mire  habitats.  Funded  by  the  EU  LIFE 
programme,  the  intervention  focused  on  restoring  the 
most important mire areas in six Natura 2000 sites and 
achieved the restoration of natural water  conditions  in 
nearly 8 000 ha of mires. 

for 

Estonia  19 

The  project  targeted  10  Natura  2000  wetland  habitat 
types  recognised  as  EU-level  conservation  priorities, 
including 
raised  bogs,  bog  woodlands, 
Fennoscandian  deciduous  swamp  woods  and  western 
Taiga forests. 

active 

2025 priority action 

• 

Implement  peatland  conservation  and  restoration 
measures and include such measures and objectives 
in the national restoration plans. 

Forest ecosystems 

Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
diverse  and  resilient  EU 
forests  that  contribute 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I to the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
is  a 
Directives, 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several  guidelines  on  forestry  management  were 
published  in  2023.  They  covered  biodiversity-friendly 
afforestation, reforestation and tree planting; closer-to-
nature  forest  management;  and  defining,  mapping, 
monitoring  and  strictly  protecting  primary  and  old-
growth  forests.  Further  guidance  on  payment  schemes 
for ecosystems services has also been published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (52) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (53).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

In  Estonia,  forests  covered  56.1 %  of  the  territory in 
2020 (54)  and  52 000 ha  are  covered  by  primary 

(52) 

(53) 

COM(2023)728, 

Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 
forests, 
2023, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en  
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 

November 

22 

(54) 

Union, 

Luxembourg, 

European 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
EEA,  forest  information  system  for  Europe,  ‘Countries –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. 

2020, 

2025 Environmental Implementation Review – Estonia 

 
 
forests (55).  More  than  75 %  of  the  assessments  of  EU-
protected forest habitats in Estonia reveal a bad or poor 
status (56). 

that  are  made  using  any  of  seven  listed  commodities 
have  no  links  to  deforestation.  The  EUDR  repeals  the 
EUTR.  

Estonia  20 

Estonia  will  encourage  the  use  of  sustainable  forestry 
practices to increase the species and structural diversity 
of  economic  forests,  to  preserve  native  trees  and  to 
ensure  the  protection  and  conservation  of  remaining 
natural and old-growth forests. 

Figure 13:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  per  Member  State  (%  of 
assessments), 2013–2018 

• 

2025 priority actions 
• 

Ensure  sustainable  management  of  forests,  i.a.  by 
adopting the National Forest Programme post-2020 
and consider the conservation objectives of Natura 
2000  forest  sites  when  developing  the  National 
Forest Management Plan. 
Improve conservation status of forests by promoting 
sustainable 
forest  management  and  ensuring 
compliance  with  the  Habitats  Directive  before 
granting/renewing permits for forest logging. 

Marine ecosystems 

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

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
in  the  MSFD  have  become  available. 
Nevertheless, Member States had to report updates by 
15 October  2024,  and  these  will  be  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
reporting, 
in  accordance  with  the  MSFD  and  the 
Commission  GES  decision (60),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold  values  for  the  descriptors  in  the  MSFD  that 
may  have  been  established  in  cooperation  with  other 
Member  States  at  the  EU  or  regional  level (61).  Estonia 

(58) 

Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461 

(60) 

(59)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 
Commission  Decision  (EU) 2017/848  of  17 May  2017  laying 
down  criteria  and  methodological  standards  on  good 
environmental  status  of  marine  waters  and  specifications  and 
standardised  methods  for  monitoring  and  assessment,  and 
repealing  Decision 2010/477/EU  (OJ  L 125,  18.5.2017,  p. 43), 
http://data.europa.eu/eli/dec/2017/848/oj. 
Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 

(61) 

Source: Commission staff working document – New EU forest strategy 
final  of  16 July  2021,  p. 24,  eur-
for  2030,  SWD(2021) 652 
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

. 

The  EU  Timber  Regulation  (EUTR) (57)  prohibits  the 
placing on the EU market of illegally harvested timber.  

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(59).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 

(EUDR) (58)  entered 

force 

into 

(55) 

(56) 

(57) 

base: 

European  Commission:  Joint  Research  Centre,  Mapping  and 
assessment  of  primary  and  old-growth  forests  in  Europe, 
Publications  Office  of  the  European  Union,  Luxembourg  2021, 
p. 13, 
"https://publications.jrc.ec.europa.eu/repository/handle/JRC12
4671"https://publications.jrc.ec.europa.eu/repository/handle/J
RC124671￼. 
Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652 
Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 

Accompanying 

the 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
reported  the  Article 8,  9  and  10  data  required  by 
Article 17 of the MSFD, which are now being assessed by 
the Commission. 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (62). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
work 
levels  of 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated programmes 
of measures, which are required under Article 13 of the 
MSFD and  which must  be updated every  six years. The 
Commission has assessed Member States’ programmes 
of measures. 

Figure 14:  Level  of  adequacy  of  Estonia’s  updated 
programme of measures under  Article 13 of the MSFD 
(2022 reporting exercise) 

Source: Technical assessment carried out by the European Commission, 
pursuant  to  Article 16  of  the  MSFD,  based  on  the  data  reported  by 
Estonia in March 2023. 

The most important known localities of marine, seal and 
seabird  habitats  are  protected  under  the  Natura  2000 
network. 

The majority of marine habitats protected under Annex I 
to the Habitats Directive are of favourable status (63), but 
face numerous pressures and threats, such as pollution, 
eutrophication,  physical  modifications  of  habitats  and 
disturbances  (dumping,  mining,  construction),  by-catch 
and invasive alien species (IAS). 

Estonia  21 

Marine  species  protected  under  the  Birds and  Habitats 
Directive are seabirds and marine mammals. 

Around 50 % of marine species are categorised as being 
of favourable status (64). 

The  main  threat  for  both  mammals  and  seabirds  is  by-
catch caused by gill nets and fyke nets. 

While the grey seal is of favourable conservation status, 
the ringed seal is of unfavourable status. 

Of  the  main  seabird  species  affected  by  by-catch,  the 
long-tailed  duck,  tufted  duck  and  great-crested  grebe 
increasing  populations,  whereas 
show  stable  or 
populations of eider and Steller’s eider are decreasing. 

Estonia  has  improved  its  by-catch  monitoring,  with  an 
additional  survey  complementing  the  reporting  under 
the  common  fisheries  policy.  The  country  has  also 
reduced  the  incidental  by-catch  of  grey  seals  and  sea 
birds, most likely by increasing the selectivity of fishing 
nets. 

for  biodiversity 

Estonia’s updated programme of measures was assessed 
as  strongly  adequate 
(D1),  non-
indigenous  species  (D2),  hydrographical  changes  (D7) 
and  energy,  including  underwater  noise  (D10).  For 
instance,  Estonia  adequately  covered  pressures  for 
biodiversity  (D1),  establishing  new  measures  to  reduce 
by-catch of vulnerable species through new technologies 
and restrictions on fishing licences. 

In  addition,  Estonia  stood  out  for  measures  on 
hydrographical  changes  (D7)  by  conducting  a  thorough 
assessment  of  pressures  likely  to  permanently  alter 
hydrographical  conditions,  which  resulted 
the 
introduction of new measures to address the impact of 
infrastructure  development,  offshore  installations  and 
mineral extraction. 

in 

Measures  on  food  webs  (D4),  eutrophication  (D5)  and 
contaminants  (D8)  and  contaminants  in  seafood  (D9), 
however,  only  partially 
environmental 
pressures, indicating potential for improvement on these 
specific descriptors. 

address 

2025 priority action 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  capacity 
of inspection authorities. 

Strategy  Framework  Decision  (Directive  2008/56/EC)  and 
Commission  Decision  (EU)  2017/848  (OJ  C,  C/2024/2078, 
11.3.2024), http://data.europa.eu/eli/C/2024/2078/oj. 
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 

(62) 

(63) 

(64) 

https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Coastal+habitats&country=EE&region=. 
Article 17 
Summary 
https://circabc.europa.eu/faces/jsp/extension/wai/navigation/
container.jsp. 

Factsheet – 

National 

Estonia, 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
Prevention and management of invasive alien 
species 

added later under Commission Implementing Regulation 
(EU) 2022/1203. 

Estonia  22 

IAS  are  a  major  cause  of  biodiversity  loss  in  the  EU. 
Besides  inflicting  direct  and  indirect  damage  on  nature 
and  the  economy,  some  IAS  also  carry  and  spread 
infectious  diseases,  posing  a  threat  to  humans  and 
IAS 
wildlife.  Regulation 
Regulation) aims to prevent, minimise and mitigate the 
adverse impacts of IAS on biodiversity. It focuses action 
on a list of IAS of EU concern (the ‘Union list’), which is 
regularly updated (65). 

(EU)  No 1143/2014 

(the 

The third update of the Union list (66) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS Regulation (67) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already widespread on their territory. 

This  aligns  with  target 6  of  the  GBF  to  reduce  the 
introduction of IAS by at least 50 % by 2030 and minimise 
their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
including  through  eradication  and 
managing  them, 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (68).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (69),  and  at 
USD 423 billion annually at the global level (70). 

The total number of IAS of Union concern in the country 
is 17. This includes 11 species recorded in the previous 
EIR (2021) and 6 additions. Of these additions, four were 
already on the Union concern list in 2021, and two were 

(65) 

(66) 

(67) 

Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update  the  list  of  invasive  alien  species  of  Union  concern  (OJ 
L 186,  13.7.2022,  p. 10),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203. 
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 (OJ L 317, 4.11.2014, p. 35). 

Figure 15:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Estonia, 2024 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 
capital accounting. 

Similarly, target 14 of the GBF (71) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 

(68)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(70) 

(69)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
Biodiversity 
Summary 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

on 
Science-Policy 
for 
Services), 
Invasive  alien  species  assessment,  2023, 

(Intergovernmental 

Ecosystem 

and 

(71)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
biodiversity 
framework 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 

2025 Environmental Implementation Review – Estonia 

 
 
 
condition in the EU (72). 

The  (EU)  No 691/2011  on  European  environmental 
economic  accounts 73  introduces  new  requirements  for 
Member States to report on the condition of ecosystems 
including  urban  ecosystems,  croplands,  grasslands, 
forest  and  woodlands,  coastal  beaches,  dunes  and 
wetlands. Data reported by the Member States will feed 
into the second European ecosystem assessment, due in 
2027, and can also be used to support policy decisions. 

An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

(2019–2028) 

IP  Cleanest  project (74) 

The  LIFE 
is 
developing  and  implementing  methodology  for  the 
mapping and assessment of freshwater ecosystems and 
their  services,  initially  at  the  regional  level  (in  north-
eastern  Estonia),  with  the  potential  to  upscale  the 
project  to  the  country  level.  For  the  last  five  years  of 
implementation,  the  project  has  focused  on  the 
measures in the existing water management plan, as well 
as on potential new solutions, such as developing remote 
monitoring solutions and mapping ecosystem services. 

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 

Estonia  23 

biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (75). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Natural  capital  assessments  help  private  businesses  to 
better  understand  both  the  negative  and  positive 
impacts that they have on nature, and to appreciate how 
nature contributes to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

In 2022, Estonia received priority actions on supporting 
the  mapping  and  assessment  of  ecosystems  and  their 
services,  and  ecosystem  accounting  development,  as 
well  as  on  supporting  the  development  of  national 
business  and  biodiversity  platforms.  Although  there  is 
supporting 
some 
monitoring solutions and ecosystem services, more work 
needs to be done to continue the implementation of the 
related  2022  priority  action.  There  is  still  no  Estonian 
business  and  biodiversity  network  member  of  the  EU 
Business & Biodiversity Platform. 

tangible  progress  on  projects 

2025 priority action 

• 

Support  the  development  of  the  national  business 
and biodiversity network.

(72) 

(73) 

for 

Summary 

Assessment – 

European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem 
policymakers, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 
Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 

(74) 
(75) 

of 

final 

2022, 

11 July 

https://eur-

COM(2022) 329 
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 
LIFE project LIFE17 IPE/EE/000007. 
The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and 
a cross-media communication strategy. 

2025 Environmental Implementation Review – Estonia 

 
 
 
Estonia  24 

3. Zero pollution

dioxide (SO2), ammonia (NH3) and PM2.5. According to the 
latest  projections  submitted  under  Article 10(2)  of  the 
NECD  in  2023,  Estonia  is  projected  to  meet  its  emission 
reduction  commitments  for  2030  onwards  for  NOx, 
NMVOC, SO2, NH3 and PM2.5. 

Estonia  submitted  its  updated  national  air  pollution 
control  programme  (NAPCP)  to  the  Commission  on 
30 March 2023. 

Figure 16: Emission trends of main pollutants / GDP in 
Estonia (%), 2005–2022

250%

200%

150%

100%

50%

0%

NH₃

PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

Clean air 

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

The EU has developed a comprehensive suite of air quality 
policies (76).  These  set  health-based  EU  air  quality 
standards (77)  and  stipulate  Member  States’  national 
emission  reduction  commitments (78)  for  several  air 
pollutants. 

The  air  quality  in  Estonia  is  generally  good,  with  some 
exceptions. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (79)  for  Estonia  attribute  100  deaths  each  year  (or 
880 years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (80), 10 deaths each year (or 180 YLL) to nitrogen 
dioxide (NO2) (81) and 30 deaths each year (or  1 300 YLL) 
to ozone (82). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Estonia since 2005, while GDP growth has 
continued  (see  Figure 16).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (83)  in  2024, 
Estonia has met its emission reduction commitments for 
2020–2029 for air pollutants  nitrogen oxides (NOx), non-
methane  volatile  organic  compounds  (NMVOC),  sulphur 

(76) 

(77) 

(78) 

(79) 

(80) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
Commission 
website, 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en. 
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 
Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10  refers  to  particles  with  a  diameter  of  10 µm  or  less.  PM2.5 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(81)  Nitrogen  dioxide  (NO2)  here  pertains  to  a  group  of  gases  called 
NOx, which also comprises nitrogen monoxide (NO). NOx is emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(82) 

(83)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
42,83%

20,86%

(iv)  contribute to decarbonisation. 

Figure 17: PM2.5 and NOx emissions by sector in Estonia 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
2,44%

19,03%

NOₓ

0,08%

35,08%

17,68%

2,29%

14,03%

3,98%

30,69%

11,01%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

In 2023, no exceedances above the limit values set by the 
Ambient Air Quality Directive (AAQD) (84) were registered 
in Estonia (85). 

In the 2022 EIR, Estonia received two priority actions. The 
first priority action was to further reduce emissions in the 
context  of  the  NAPCP.  Estonia  has  made  substantial 
progress on this, as the latest reported data show that the 
2020–2029  emission  reduction  commitments  have  been 
met  and  that  the  emission  reduction  commitments  for 
2030  onwards  are  projected  to  be  reached.  The  second 
priority action was to ensure full compliance with EU air 
quality  standards  and  maintain  downward  emission 
trends.  Based  on  the  latest  data,  Estonia  has  made 

(84)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 
Eionet 
EEA, 
(https://cdr.eionet.europa.eu/). 

Repository 

11.6.2008, 

Central 

L 152, 

p. 1), 

Data 

(85) 

(OJ 

(86)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 

Estonia  25 

substantial  progress  in  this  regard.  Full  compliance  has 
been ensured for all limit values and target values. Since 
2019, downward emission trends have been reported for 
all  main  pollutants  except  for  NMVOC,  which  requires 
further action. 

2025 priority actions 

•  As part of the NAPCP, take action to reduce emissions 

• 

of air pollutants. 
Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

Industrial emissions 

The  main objectives of  EU policy on industrial emissions 
are to: 

(i)  protect  air,  water  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii)  improve  energy  and  resource  efficiency,  including 

water; 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (86). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (87). 

In Estonia, around 145 industrial installations are required 
to have a permit based on the IED, the majority being in 
the  intensive  rearing  of  poultry  and  pigs  sector  (39 %), 
followed  by  the  waste  management  sector  (including 
landfill) (15 %), the energy sector (13 %) and the chemical 
sector (7 %). 

Figure 18  shows  the  damage  to  health  and  the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 

emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 
EEA, 
Portal, 
Industrial 
European 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 

Emissions 

(87) 

2025 Environmental Implementation Review – Estonia 

 
 
 
Estonia  26 

shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions  ‘intensity’. Although 
Estonia has relatively low damage (4th lowest in the EU), 
it is above the EU average of EUR 27.5/EUR 1 000 GVA in 
emissions  intensity  (14th  highest  in  the  EU).  The  main 
industrial contributor to emissions to air (88) is the energy 
sector. 

emissions  intensity,  based  on  its  ratio  with  industrial 
activity  (expressed  in  GVA).  Estonia  has  the  fifth  lowest 
amount of emissions of heavy metals to water and is the 
eighth  lowest  for  emissions  intensity  (below  the  EU 
intensity  of  0.864 kg/EUR 1 billion  GVA).  As 
average 
shown  in  Figure 21,  the  main  industrial  contributors  to 
emissions  to  water  in  Estonia  are  the  energy  sector  and 
the pulp, paper and wood sector for heavy metals. 

Figure 18:  Industrial  air  pollution  damage  and  intensity 
per Member State, 2021 

Figure 20:  Industrial  releases  and  intensity  of  heavy 
metals to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
Portal, 
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 19. 

Figure 19: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

Figure 21:  Relative  releases  to  water  from  industry  in 
Estonia (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human Toxicity

Total organic carbon
(TOC)

Electricity and heat production

Pulp, paper and wood

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
Geospatial 
2024, 
Catalogue, 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

NB:  Cd,  cadmium;  Hg, mercury;  Ni,  nickel;  Pb,  lead;  TOC,  total  organic 
carbon; total N, total nitrogen; total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Concerning  Estonia  in  particular,  Figure 21  shows  the 
industrial emissions of heavy metals to water, taking into 
account  the  human  toxicity  of  each  metal,  as  well  as 

Estonia has been subject to an infringement procedure for 
not conforming with the transposition of and not correctly 
applying  the  IED  since  2023,  in  particular  on  indirect 
release of pollutants to water. 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 

(88) 

European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 

https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
Estonia  27 

potentially  polluting  installations.  Thus,  the  public  and 
non-governmental  organisations 
(NGOs),  alongside 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 
requiring a site visit to take place at least every 1–3 years, 
using  risk-based  criteria.  In  addition,  IED  enforcement 
provisions require Member States to determine effective, 
proportionate,  and  dissuasive  penalties  applicable  to 
infringements  of  IED-based  national  provisions.  In  the 
revised  directive, 
that  worst 
the  provisions 
infringements can be sanctioned by fines of at least 3% of 
the  annual  EU  turnover  of  the  legal  person.  The  revised 
IED  also  introduces  a  right  to  compensation  for  people 
whose health has been harmed by such infringements. 

set 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions  on  (i)  ferrous  metal  processing,  (ii)  textiles 
industry,  (iii)  common  waste  gas  management  and 
treatment  systems 
in  the  chemical  sector  and  (iv) 
smitheries and foundries. 

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  2022,  Estonia  received  priority  actions  to  address 
pollution from the energy sector and the intensive rearing 
of  poultry  and  pigs.  Data  are  not  yet  available  to  assess 
progress towards this priority action. However, the energy 
sector  remains  among  the  main  sources  of  industrial 
emissions. 

2025 priority actions 

• 
Complete the correct transposition of the IED 1.0. 
•  Reduce industrial air pollution damage and intensity. 
•  Address the current implementation issues related to 

• 

• 

indirect release of pollutants to water. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation with the IED. 

Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 

(i)  control  major-accident  hazards  involving  dangerous 

(ii) 

substances, especially chemicals; 
limit the consequences of such accidents for human 
health and the environment; 

(iii)  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive) (89). 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (90)  and  the  report  by 
Estonia on the implementation of the Seveso III Directive 
for 2019–2022 (91). 

In Estonia, in 2024, among the 63 Seveso establishments, 
28 were categorised as lower-tier establishments and 35 
as upper-tier establishments (UTEs), based on the quantity 
of  hazardous  substances  likely  to  be  present.  UTEs  are 
subject to more stringent requirements. The development 
of  the  number  of  Seveso  establishments  is  presented  in 
Figure 22. 

Figure 22: Number of Seveso establishments in Estonia, 
2018, 2022 and 2024 

80

60

40

20

0

31

31

23

33

28

35

2018

2022

2024

UTE

LTE

NB: LTE, lower-tier establishment. 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-

2022, 

(89)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 
repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 

(90) 

(91) 

https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 
in September 2024. 
As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Estonia 

 
 
 
Estonia  28 

en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Member  States  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  the 
population should a major industrial accident. 

In Estonia, in 2022, an EEP was required for all 33 UTEs. 
They all had an EEP and all of them had been tested within 
the last three years. The summary is shown in Figure 23. 

Figure 23: Situation regarding EEPs in Estonia, 2022 

33

33

33

33

35
30
25
20
15
10
5
0

UTE with EEP

Total of UTE

UTE for
which EEP
were
required

UTE for
which EEP
were tested
over the last
three years

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
2014/896/EU 
Implementing  Decision 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States' 
reports  on 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

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

The  shares  of  UTE  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 are presented 
in Figure 24. This provision on knowledge is an important 
provision of the Seveso III Directive, as awareness by the 

public  of 
consequences of a major industrial accident. 

information  may  ameliorate 

this 

the 

Figure 24: Share of UTE for which information on safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public per Member State (%), 2022 

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

AT BG CZ DK EL FI HR IE LT LV NL PT SE SK

NB: No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
involving 
2012/18/EU  on  the  control  of  major  accident  hazards 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
reports  on 
2024;  Analysis  and  summary  of  Member  States' 
implementation of Directive 2012/18/EU on the control of major accident 
hazards  involving  dangerous  substances  according  to  the  format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. No data available for Greece.  

In  2022,  Estonia  received  a  priority  action  to  strengthen 
control and enforcement  to  ensure compliance with  the 
Seveso III Directive rules, especially those on information 
for  the  public  and  on  EEPs.  Data  reported  on  the 
implementation  of  the  directive  for  2019–2022  show 
improvement  in  the  number  of  EEPs  established  and 
reviewed for UTEs in Estonia. 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 

2025 Environmental Implementation Review – Estonia 

 
 
 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

Measures  should  have  been  put  in  place  in  Estonia  to 
ensure  a  socially  and  economically  sound  phase-out, 
including an adequate reimbursement of the alternatives 
to dental amalgam through the health insurance scheme 
and the training of dental practitioners.  The Commission 
is  monitoring  whether  the  phase-out  has  taken  place 
under the terms and conditions of the regulation. Estonia 
will also need to ensure that the manufacture and export 
of  mercury-containing 
lamps  are  prohibited  by  the 
deadlines set out in the Mercury Regulation. 

Noise 

The Environmental Noise Directive (92) requires a common 
approach to avoid, prevent and reduce the harmful effects 
of  noise.  The  designated  authorities  are  responsible  for 
making  and  approving  noise  maps  and  action  plans  for 
agglomerations,  major  roads,  major  railways  and  major 
airports.  Member  States  decide  on  noise  limits  that  are 
not  set  at  the  EU  level.  Nevertheless,  the  zero  pollution 
action  plan  sets  as  a  2030  target  a  30 %  reduction 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

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 stress (93). 

(92)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 
relating  to  the  assessment  and  management  of  environmental 
noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

(94) 

(93)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 
These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Indicators  under  the 
Industrial  Pollution  (ETC/ATNI),  Noise 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 

Estonia  29 

In Estonia, environmental noise is estimated to cause at 
least  around  40  cases  of 
ischaemic  heart  disease 
annually (94)  and  some  2 300  people  to  suffer  from 
disturbed sleep(95). 

Based  on  the  latest  full  set  of  information  analysed, 
Estonia  has 
its  noise  mapping  of 
completed 
agglomerations, roads, railways and airports. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025;  these  plans 
have not been assessed yet. 

Estonia  received  no  priority  action  in  the  2022  EIR  as 
regards noise. 

2025 priority action 

• 

Complete  and  implement  action  plans  on  noise 
management. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures on transitional waters, coastal waters and fresh 
water  (including  surface  waters  and  groundwater)  be 
significantly reduced. Achieving, maintaining or enhancing 
a  good  status  of  waterbodies  as  defined  by  the  Water 
Framework  Directive  (WFD)  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) 
in  a  more 
sustainable and resource-efficient way. 

is  managed 

Water Framework Directive 

The WFD (96) is the cornerstone of EU water policy in the 
21st  century (97).  The  WFD  and  other  water-related 
directives (98) form the basis of sustainable and integrated 

European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise. 

Bilthoven, 

(95)  More information on the adverse health effects of noise pollution 

(96) 

(97) 
(98) 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 
https://environment.ec.europa.eu/topics/water_en. 
These 
(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
Directive 
lex.europa.eu/eli/dir/2008/105/oj), 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 

the  Groundwater  Directive 

include 

Floods 

the 

2025 Environmental Implementation Review – Estonia 

 
 
  
 
Estonia  30 

coastal  waters  reach  good  ecological  or  good  chemical 
status. 

Figure 25:  Ecological 
waterbodies in each RBMP cycle (%) 

status/potential  of 

surface 

Only 53 % of the surface waterbodies have good or better 
ecological status/potential. 

identified 
The  most  significant  pressure 
pollution;  more  precisely,  the  problem 
pollution, which affects 93 % of the waterbodies. 

is  diffuse 
is  nutrient 

Figure 26: Chemical status of surface waterbodies in each 
RBMP cycle (%) 

water management in the EU. They aim to achieve a high 
level  of  protection  of  water  resources,  prevention  of 
further  deterioration  and  restoration  to  good  status. 
These  objectives  are  very 
important  for  the  EU’s 
competitiveness,  strategic  autonomy  and  security,  yet 
have become even more challenging in the face of climate 
change affecting our precious water resources. 

The WFD establishes a procedural framework for reaching 
good  surface  water  ecological  and  chemical  status  and 
good groundwater quantitative and chemical status. This 
implies  monitoring  and  classification  of  all  waterbodies, 
assessment of pressures and impacts and identification of 
the  most  cost-effective  measures  to  achieve  the 
objectives of the directive. The directive dates from 2000 
and  set  an  initial  deadline  of  2015  for  achieving  its 
objectives, with the option to extend the deadline to the 
end of 2027. Every six years, Member States must report 
their  river  basin  management  plans  (RBMPs)  to  the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 2025. 

Estonia’s  three  river  basin  districts  contain  746  surface 
waterbodies, mainly river tributaries, and 31 groundwater 
bodies.  Most  surface  waterbodies  are  natural,  with  only 
around  7.1 %  being  heavily modified  and  5.7 %  artificial. 
Heavily  modified  water  and  artificial  waterbodies  must 
reach  good  ecological  potential  rather  than  good 
ecological status, which means that all measures must be 
taken  to  mitigate  the  adverse  impact  of  the  sustainable 
human development  activities causing the waterbody to 
be  heavily  modified /  artificial,  while  not  significantly 
affecting these activities. 

in 

the 

show 

change 

ecological 
Figures 25–28 
status/potential (99) and chemical status of surface waters, 
and the quantitative and chemical status of groundwater 
in 2010, 2015 and 2021. It follows from the assessment of 
the  third  RBMPs  that  the  ecological  status/potential  of 
surface  waterbodies  has  deteriorated  since  the  second 
RBMPs,  with  only  53 %  having  good  ecological 
status/potential. For chemical status, the situation has not 
improved  since  the  second  RBMPs,  with  only  9.7 %  of 
surface  waterbodies  classified  as  having  good  chemical 
status.  For  83 %  of  surface  waterbodies,  the  status 
remains  unknown,  despite  it  being  more  than  20 years 
since the entry into force of the directive. None of the 16 

specific  priority 

substances:  mercury 

Failure to achieve good chemical status is mainly due to 
two 
and 
polybrominated  diphenyl  ethers.  Both  pose  significant 
threats to humans and the aquatic environment, and they 
belong  to  ubiquitous,  persistent,  bioaccumulative  and 
toxic  substances.  In  the  second  RBMPs,  in  addition  to 
mercury,  other  metals  (cadmium,  lead,  nickel)  and  two 
pesticides  (cybutryne  and  dichlorvos)  were  causing  the 
failure.  However,  the  picture  is  far  from  being  complete 
since  a  very  large  proportion  (83 %)  of  the  waterbodies 

(https://eur-lex.europa.eu/legal-
Directive 
Urban 
content/EN/TXT/?uri=celex%3A32006L0007), 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
the 
(https://eur-
new 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184), 

Drinking  Water 

Treatment 

Directive 

Nitrates 

the 

the 

(99) 

(https://eur-lex.europa.eu/legal-
MSFD 

the 

Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

and 

the 

IED 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
were  not  assessed  for  chemical  status,  and  therefore 
marked as having unknown status. 

the  maximum  allowable  concentration  in  around  3 %  of 
monitoring stations. 

Estonia  31 

Figure 27: Quantitative status of groundwater bodies  in 
each RBMP cycle (%) 

Until the end of 2027, Member States can still apply time-
related  exemptions,  subject  to  providing  evidence  of 
compliance  with  the  strict  criteria  set  out  in  the  WFD. 
After 2027, the possibilities for applying exemptions will 
be much more limited. 

The 2022 EIR identified the following priority actions. 

•  Assess new physical modifications of waterbodies in 

• 

line with Article 4(7) of the WFD. 
Continue  efforts  to  tackle  agricultural  and  non-
agricultural  pollution  in  waterbodies  and  continue 
efforts  to  establish  ecological  flows  for  all  relevant 
waterbodies. 

Only  two  groundwater  bodies 
(6.5 %)  have  poor 
quantitative  status,  although two  more  are  identified  as 
being at risk of failing to remain in good quantitative status 
by  2027  because  of  ecological  decreases  in  associated 
surface  waters,  distortion  of  the  water  balance  and 
lowering of water tables. Furthermore, water abstraction 
is  seen  as  one  of  the  key  pressures  on  groundwater  in 
Estonia. 

Figure 28: Chemical status of groundwater bodies in each 
RBMP cycle (%) 

The  situation  has  not  changed  much  since  the  second 
RBMPs, with eight groundwater bodies failing to achieve 
good chemical status. Failure is mostly due to mining of oil 
shale, industry and agriculture. Other reasons are reduced 
ecology  of  associated  surface  waters,  deterioration  of 
water quality in protected drinking water areas, and saline 
or  other 
linked  to  the 
overabstraction  of  groundwater  bodies  adjacent  to  the 
coast. The main pollutants are chemical oxygen demand, 
ammonium  (from  chemical  fertilisers  in  agriculture), 
mono-basic  phenols,  aminomethylphosphonic  acid  (a 
metabolite  from  glyphosate)  and  sulphate.  As  regards 
nitrates, the trend is unclear, but data reported under the 
Nitrates Directive show that nitrate concentrations exceed 

intrusion  that  might  be 

Estonia  has  made  limited  progress.  Nevertheless,  in  the 
context of the third RBMPs, it is positive to note that most 
of the measures set out in the third RBMPs are allocated 
to  agricultural  producers,  with  a 
total  cost  of 
EUR 632 million.  Estonia  has  also  mapped  measures  to 
reduce  levels  of  mercury  and  several  other  priority 
substances 
sediment 
(polybrominated  diphenyl  ethers,  cadmium,  anthracene, 
thiophene  and  phenylene  monomers,  lead,  cybutryne, 
benzo(a)pyrene, 
dichlorvos, 
benzo(g,h,i)perylene, 
sulfonate, 
perfluorooctane 
polycyclic aromatic hydrocarbons, nickel). 

surface  waters, 

fluoranthene, 

fish  or 

in 

2025 priority actions 

Without prejudice to the list of recommended actions in 
the Commission report to the European Parliament and to 
the  Council  on  the  assessment  of  the  third  RBMPs,  the 
following priority actions can be highlighted. 

• 

• 

Improve  river  continuity  and  ecological 
flows, 
boosting efforts to introduce nature-based solutions 
to reduce hydromorphological pressures.  
Ensure  periodic  reviews  of  permits  for  discharges, 
abstractions  and  other  water  uses, 
including 
hydropower pressures.  

•  Reduce  pollution  from  nutrients,  chemicals,    metals 

and saline discharges.  

•  Better justify exemptions to the achievement of good 

• 

status.  
Improve  the  classification  of  water  bodies  and 
strengthen monitoring systems.  

•  Develop  more  robust  programmes  of  measures, 
tackle  obstacles  identified  in  the  implementation  of 
for 
measures  and  ensure  adequate 
implementation, including through better use of the 
cost recovery and polluter pays principle.  

financing 

2025 Environmental Implementation Review – Estonia 

 
 
 
Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  report  their  flood  risk 
management  plans  (FRMPs),  based  on  the  flood  hazard 
and  risk  maps  (FHRMs)  and  the  preliminary  flood  risk 
assessments  drawn  up  during  the  second  cycle  (2016–
2021). 

The  Commission  assessed  the  FRMPs  and  reported  its 
findings to the European Parliament and to the Council on 
4th  February  2025,  together  with  the  assessment  of  the 
RBMPs. 

The  analysis  of  Estonia’s  RBMPs  has  identified  nutrients 
from  agriculture  as  an 
important  pressure  on 
groundwater /  surface  waters  that  is  affecting  these 
waters’ good status and as one of the main factors in not 
meeting the WFD objectives. 

The  main  progress  identified  in  the  assessment  of  the 
three  Estonian  second-cycle  FRMPs  relate  to  a  more 
inclusion  of 
detailed  description  of  objectives  and 
indicators  to  evaluate  progress.  The  second  FRMPs  also 
contain  a  clear  description  of  a  qualitative  cost–benefit 
assessment  methodology used to prioritise measures. In 
terms of climate-change-related impacts, more data have 
been collected and updated forecasts have been made. 

2025 priority actions 

Estonia should further improve flood management and: 

• 

FRMPs  should  provide  details  on  how  the  FHRMs 
were  used  in  the  choice  of  measures  and  how  to 
consider pluvial flooding. 

•  Better explain the choice and implementation of flood 
prevention  and  protection  measures  (prioritisation, 
monitoring, costs of measures). 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 

(100)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(101)  Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 
2024/365, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 
OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 

(102)  OJ L, 

2024/369, 

Estonia  32 

list  of 
implementing  acts  establishing  (i)  a  watch 
substances  and  compounds  of  concern  for  drinking 
water (100), (ii) a methodology for measuring microplastics 
in drinking water (101) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (102). Member States will have to take 
these  various  Commission  acts 
into  account  when 
implementing the recast directive. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019. 

The  quality  of  drinking  water  (supplied  by  large  water 
suppliers)  in  Estonia  does  not  give  rise  to  concern (103). 
From  January  2026,  the  European  quality  standards  for 
per- and polyfluoroalkyl substances in drinking water will 
apply, ensuring harmonised Member States’ reporting of 
per- and polyfluoroalkyl substances monitoring data in the 
future. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

Figure 29  shows  that  in  2023,  out  of  the  63  Estonian 
bathing waters, 43 (66.2 %) were of excellent quality, 12 
bathing  waters  (18.5 %)  were  of  good  quality  and  6 
bathing waters (9.2 %) were of sufficient quality; 2 bathing 
waters (3.1 %) were found to be of poor quality. Detailed 
information on Estonian bathing waters is available from 
a  national  portal (104)  and  through  an  interactive  map 
viewer of the EEA (105). 

2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 
the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
In summary, the compliance  for all  parameter groups in Estonia 
was at least 99.77 % in 2017, 99.84 % in 2018 and 98.92 % in 2019. 

(103) 

(104)  http://vtiav.sm.ee/index.php/?active_tab_id=SV. 
(105)  EEA, 

‘State  of  bathing  water’,  EEA  website,  2024, 

https://www.eea.europa.eu/en/topics/in-depth/bathing-
water/state-of-bathing-water. 

2025 Environmental Implementation Review – Estonia 

 
 
Figure 29: Bathing water quality per Member State, and 
Switzerland and Albania (%), 2023 

Estonia  33 

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

2025 Environmental Implementation Review – Estonia 

 
 
 
Nitrates Directive 

The  Nitrates  Directive  (106) aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive (107),  referring  to  2016–2019 (108), 
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 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. 

The  report  on  the 
Directive covering 2020–2023 will be available in 2025. 

implementation  of  the  Nitrates 

2025 priority action 

• 

Tackle  nutrient  pollution,  especially  nitrates  from 
implementation  of  the 
agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the effects of untreated urban waste water. It therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
phosphorus  removal,  to  the  waste  water  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 
and/or phosphorus (i.e. eutrophic or tending to become 
eutrophic). 

Overall, in Estonia, the compliance rate was 99 % in 2020. 
Only  two  agglomerations,  generating  22 286  population 
equivalent  (p.e.)  of  urban  waste  water,  did  not  comply 
with the requirements of the directive. 

Estonia  34 

Figure 30:  Proportion  of  urban  waste  water  that  fully 
complies with the UWWTD (%), 2020109 

Source:  European  Commission:  Directorate-General  for  Environment, 
Fribourg-Blanc,  B.,  Dhuygelaere,  N.,  Berland,  J.  and  Imbert,  F.,  12th 
technical  assessment  of  UWWTD  implementation  –  Final  version, 
Publications  Office  of  the  European  Union,  2024,  12th  technical 
assessment of UWWTD implementation - Publications Office of the EU 

infringement  proceeding  has  been  open  against 
An 
Estonia since February 2024 for non-compliance with the 
requirements of the directive in respect of discharges of 
industrial waste water into urban wastewater treatment 
plants (110). It is essential that Estonia takes the necessary 
measures  to  fully  transpose  and  comply  with  the 
requirements of the directive. 

This  is  all  the  more  important  as  the  directive  has  been 
revised  in  order  to,  among  other  things,  strengthen 
existing  treatment  standards and  establish  an  additional 
treatment of micropollutants in urban waste water. Other 
new  requirements  relate  to  moving  towards  the  energy 
neutrality  of  the  sector,  establishing  an  EPR  system  to 
ensure sustainable financing of micropollutant treatment 
by  the  most  polluting  industries  and  ensuring  access  to 
sanitation,  especially  for  vulnerable  and  marginalised 
groups.  Estonia  has  until  31 July  2027  to  transpose  the 
new directive into its national legal system. 

Since  the  2019  and  2022  priority  actions  were  not  fully 
implemented,  they  are  reproposed.  An  action  stemming 
from  the  Estonia-specific  annex  to  the  abovementioned 
Commission report on the implementation of the Nitrates 
Directive has been added. 

(106)  https://environment.ec.europa.eu/topics/water/nitrates_en. 
(107)  https://eur-lex.europa.eu/legal-

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

(108)  https://environment.ec.europa.eu/topics/water/nitrates_en. 

(110) 

INFR(2023)2180. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
2025 priority actions 

• 

the  necessary  measures 

Take 
full 
implementation  of  the  current  urban  wastewater 
treatment  directive,  taking  into  account  the  new 
requirements of the recast directive. 

to  ensure 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  towards  a  toxic-free  environment (111), 
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. 

The  EU’s  chemicals  legislation (112)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

Since 2007, the Commission has gathered information on 
the  Registration,  Evaluation, 
the  enforcement  of 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (113)  on  the 
these 
implementation 

enforcement 

and 

of 

(111)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
p. 1), 
L 353, 
No 1907/2006 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(112)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
https://eur-lex.europa.eu/legal-
30/12/2006, 
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 

p. 1), 

Estonia  35 

in  the  area  of 

regulations (114).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies 
and (ii) more non-compliant products are being placed on 
the EU market. 

In August 2021, the Commission published a  measurable 
assessment  of the enforcement (115) of the two  main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (116). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (117).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (118).  The 
Commission  is  working  on  the  delegated  acts  to  include 

(113)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
2020, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

Union, 

(114) 

the 

European 

(115)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
of 
2021, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(116)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally, 
microplastics. 

Luxembourg, 

(117)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex) 

(118)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
lists  some  time-limited  specific 
UV-328,  the  COP  decision 
exemptions. 

2025 Environmental Implementation Review – Estonia 

 
 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

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. 

• 
• 

Estonia  36 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of finding non-
compliances.  Therefore, 
rates 
presented above cannot be considered the average non-
compliance  rates  of  products  in  the  EU.  However,  the 
proportion  of  non-compliance  cases  found  in  the  REF-8 
project are of concern. 

the  non-compliance 

Figure 32:  Number  of  REF-8  checks  performed  per 
100 000 inhabitants (EU average = 1.24) 

The  Member  States’  reporting  exercise  set  out 
in 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 
absence  of  new  country-specific  data  on  enforcement 
since 2022. 

In  2022,  Estonia  had  devised  and  partly  implemented 
REACH  and  CLP  Regulation  enforcement  strategies (119). 
No progress has been reported. 

In  2020,  Estonia  participated 
in  an  EU  coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE  (REF)-8  project (120).  The  report  was 
adopted in November 2021, so it could not be taken into 
account in the previous EIR. 

Figure 31: Compliance of imported products – results of 
the REF-8 project (%) 

(119)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
p. 76, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

Estonia’s  participation 
enforcement project was around the EU average. 

the  REF-8 

in 

coordinated 

In  2022,  Estonia  received  two  priority  actions  related  to 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of non-compliance, and fully implementing the 
enforcement strategy for the CLP and REACH Regulations. 
In  the  absence  of  reporting  since  2022,  no  progress  has 
been  shown  and  these  priority  actions  remain  valid  in 
2025. 

(120)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
and 
p. 20, 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
2025 priority actions 

Estonia  37 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement towards a policy of 
zero tolerance for non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 
European  Chemicals  Agency, 
the 
in 
coordinated enforcement projects, called REFs. 
Increase  customs  controls  and  controls  of  products 
sold online with regard to compliance with chemicals 
legislations. 

including 

• 

• 

2025 Environmental Implementation Review – Estonia 

 
 
Estonia  38 

4. Climate action 

Social  Climate  Fund  to  help  citizens  during  the 
transition;  (ii)  increasing  targets  under  the  effort 
sharing  regulation;  and  (iii)  a  revised  regulation  for 
Land  Use,  Land  Use  Change  and  Forestry (122).  The 
package  has  been  fully  adopted,  and  the  Member 
States have been implementing the legislation. 

The  key  strategic  document  at  country  level  is  the 
National Energy and Climate Plan (NECP) (123).Estonia 
had  not  submitted  the  NECP  by  the  end  of  March 
2025.  The  legal  deadline  for  the  submission  was  in 
June 2024. 

To  minimise  the  impacts  of  climate  policies  on 
vulnerable people and sectors, Estonia is using the Just 
Transition  Fund,  Modernisation  Fund  and  will  use 
Social Climate Fund from 2026 (for more information, 
see Chapter 5 ‘Financing’). 

Figure 33: 
international aviation), 1990–2022 

Total  GHG 

emissions 

(excluding 

in  recent  years, 

resilient  by  2050,  ensuring 

The  impacts  of  climate  change  have  continued  to 
increase 
inflicting  damage  and 
suffering  in  the  EU  and  around  the  world.  Globally, 
2023 was the hottest year on record, while Europe has 
been warming twice as quickly as the global average, 
and 
is  now  the  fastest-warming  continent.  The 
frequency and severity of extreme climate events are 
also  increasing.  Against  this  backdrop,  the  EU  has 
demonstrated  its  determination  to  implement  the 
European Green Deal and to become climate neutral 
and 
sustainable 
competitiveness  and  supporting  EU  industry  in  the 
net-zero transition. The European Climate Law is the 
EU’s  response  to  the  need  for  action.  It  sets  the 
objective of achieving climate neutrality by 2050 and a 
midterm target of a reduction in GHG emissions of at 
least 55 % by 2030, and outlines the adaptation efforts 
necessary  to  adjust  to  climate  change’s  present  and 
future impacts. Almost all the ‘Fit for 55’ proposals set 
out in the European Green Deal have been agreed in 
law,  and  the  European  Commission  recommended  a 
new intermediate climate target of a 90 % reduction in 
emissions  by  2040.  In  2024,  the  Member  States 
submitted updated national energy and climate plans 
for  2021–2030,  reflecting  the  increased  ambition  of 
the  revised  EU  legislation.  In  2024,  the  European 
Commission  also  released,  jointly  with  the  EEA,  the 
first-ever European climate risk assessment. 

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved steady decreases in its emissions, reaching a 
running  total  in  2022  of – 32.5 % (121).  However,  the 
EU  and  its  Member  States  need  to  step  up  their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 
55 %  reduction  in  net  GHG  emissions  by  2030  and 
climate neutrality by 2050. Between 1990 and 2022, 
net  GHG  emissions  of  Estonia  decreased  by  59 %, 
making it one of the countries with an above-average 
decrease. 

The ‘Fit for 55’ legislative package reflects the need to 
includes  (i) 
speed  up  the  green  transition. 
strengthening and expanding the EU emissions trading 
system (ETS), with the creation of a new, second, ETS 
for transport and buildings together with a dedicated 

It 

(121)  EU net domestic emissions, including the land use, land-use 
(LULUCF)  sector  and  excluding 

change  and 
forestry 
international aviation. 

(122)  A  full  overview  of  the  Fit  for  55  package  is  available  at 

https://commission.europa.eu/strategy-and-
policy/priorities-2019-2024/european-green-
deal/delivering-european-green-deal/fit-55-delivering-
proposals_en. 

The EU emissions trading system 

The EU ETS is the key tool for reducing GHG emissions 
cost-effectively  across  all  Member  States.  It  is  the 
world’s biggest carbon market, covering around 40 % 
of  the  EU’s  total  GHG  emissions  from  electricity  and 
heat generation, the manufacturing industry, aviation 
within Europe (124) and, from 2024, maritime transport 
also. 

(123)  More  information  about  NECP  is  on  the  dedicated  website 

https://energy.ec.europa.eu/topics/energy-
strategy/national-energy-and-climate-plans-necps_en. 
(124)  Flights  between  the  EU  Member  States  including  departing 
flights  to  Norway,  Iceland,  Switzerland  and  the  United 
Kingdom. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
The system sets a limit or cap on the total amount of 
GHGs that can be emitted at the EU level. Within this 
limit,  companies  buy  emissions  allowances  (one 
allowance gives the right to emit 1 t of CO2 eq (carbon 
dioxide  equivalent)),  in  auctions  or  through  trading 
allowances with others. The cap is reduced annually to 
ensure  that  overall  emissions  in  the  sectors  covered 
decrease over time. 

The emissions under the ETS decreased by 59 % from 
2005 to 2023. 

In  2023,  61 %  of  emissions  from  ETS  installations  in 
Estonia came from power generation. The remainder 
came  almost  entirely  from  refineries  (37 %).  Since 
2019,  the  power  sector  has  been  the  driver  of  ETS 
emissions reductions in the country, decreasing them 
by 48 %. Emissions from cement and lime production 
still accounted for about 7 % of industry emissions in 
2019,  down  from  26 %  in  the  previous  year,  but 
vanished in 2022. 

From  2027,  a  new  emissions  trading  system,  called 
ETS2,  for  buildings,  road  transport  and  additional 
sectors  (mainly  industry  not  covered  by  the  current 
ETS)  will  become  fully  operational (125).  Member 
States  should  have  notified  full  transposition  the 
provisions  of  the  revised  EU ETS  Directive  related  to 
the  new  ETS2  into  national  law  by  30 June  2024. 
Estonia  did  not  communicate  full  transposition  into 
law  by  this  deadline.  The  Commission 
national 
therefore opened an infringement procedure against 
Estonia on 25 July 2024, by sending a letter of formal 
notice for failing to fully transpose the provisions into 
national law. 

Estonia had two months to respond and address the 
shortcomings  raised  by  the  Commission.  In  the 
absence  of  a  satisfactory  response,  the  Commission 
may decide to issue a reasoned opinion. 

also 

opened 

Commission 

The 
infringement 
procedures  against  Estonia  on  25 January  2024,  by 
sending  a  letter  of  formal  notice  for  failing  to  fully 
transpose previous revisions of ETS Directive (126) into 
national 
law.  Estonia  has  since  notified  partial 
transposition  of  either  one  or  both  revisions  to  the 
the  absence  of  a  complete 
Commission. 
transposition, the Commission may decide to issue a 
reasoned opinion. 

In 

Estonia  39 

Effort sharing 

The  Effort  Sharing  Regulation  (ESR) (127)  covers  GHG 
emissions  from  domestic  transport  (excluding  CO₂ 
emissions from aviation), buildings, agriculture, small 
industry  and  waste.  Emissions  from  these  sectors 
account  for  around  60 %  of  the  EU’s  domestic 
emissions.  The  regulation  sets  the  EU-wide  target  to 
reduce  emissions  from  the  effort  sharing  sectors  by 
40 %  by  2030  compared  to  2005  levels.  This  overall 
target  for  the  EU  translates  to  binding  national 
emission  reduction  targets  for  each  Member  State. 
Estonia‘s target is – 24 %. 

In addition to the 2030 targets, Member States have 
annual  GHG  emissions 
(annual  emission 
allocations), reducing every year until 2030. 

limits 

There  is  some  flexibility  to  take  account  of  annual 
fluctuations  in  emissions,  by  trading  emissions  and 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
projections  Estonia  will  need  to  implement  new 
measures and/or use available flexibilities to achieve 
its 2030 ESR target. Projected gap is 10.2 percentage 
points to the 2030 target. 

The  largest  contributor  is  the  domestic  transport 
sector, which accounted for 48 % of all effort sharing 
emissions in 2022. 

Sustainable transport has yet to take off in Estonia. At 
0.4 % in 2022, the share of battery electric vehicles in 
Estonia’s passenger car fleet is still very low compared 
to  EU  average  of  1.3 %.  So  too  is  the  number  of 
publicly accessible charging points, at 290 in 2023, or 
one charging point for every 13 e-vehicles (against the 
EU average of 1:10). Passenger cars are used for 89 % 
of  distances  travelled  (EU  average:  85 %).  Buses  and 
coaches, the main form of public transport, are used 
for  9 %. The share of freight  land transport  by rail is 
high (at 40 %, against the EU average of 16 %), but only 
19 %  of  the  rail  network  is  electrified  (EU  average  is 
56 %).  In  maritime  transport,  it  is  important  to 
concentrate  action  on  reducing  the  environmental 
impact of ferry traffic, including by deploying low and 
zero emission vessels and developing necessary port 
and bunkering infrastructure. 

Agriculture  accounted  for  29 %  of  effort  sharing 
emissions. The emissions in the sector have decreased 
significantly since 2005 (32 % reduction from 2005 to 
2022),  but  they  have  increased  in  the  recent  years 
(10 % increase from 2015 to 2022). Emissions from the 

(125)  Directive  (EU)  2023/959  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.EN
G). 

(126)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 

- EN - EUR-Lex. 

(127)  Regulation 

(EU) 

2018/842 

(https://eur-

lex.europa.eu/eli/reg/2018/842). 

2025 Environmental Implementation Review – Estonia 

 
 
sector  are  expected  to  increase  by  4.5 %  in  2050 
compared  to  2020  due  to  livestock  and  the  use  of 
fertilisers. 

for  7 %  of  effort  sharing 
Buildings  accounted 
emissions.  Estonia  has  a  substantial  difference 
between  energy  performance  of  residential  and 
commercial buildings. While final energy consumption 
of commercial and public buildings is the lowest in the 
EU, consumption of residential buildings is the second 
highest.  Estonia’s  efforts 
reduce  energy 
consumption in the residential sector have not made 
a meaningful contribution to its 2030 reduction target 
for energy consumption by buildings. The residential 
final energy consumption was lower in 2022 than 2020 
but has increased by 3.6 % since 2015. Total emissions 
of buildings have decreased by 42 % since 2005, which 
is above EU average decrease of 29 %. 

to 

Figure 34: Effort sharing emissions by sector, 2022 

Estonia  40 

help Estonia continue the reverse in the decline in net 
carbon removals from the atmosphere. 

Estonia‘s target in 2030 is to enhance land removals by 
an additional –0.4 Mt of CO2 equivalent compared to 
the yearly average of the period 2016–2018. The latest 
projections show a surplus to target of −0.4 Mt of CO2 
equivalent  in  2030.  Therefore,  Estonia  is  on  track  to 
meet the 2030 target. 

Adaptation to climate change 

Halting  all  GHG  emissions  would  still  not  prevent 
climate impacts that are already occurring. Therefore, 
adaptation to climate change is also a key component 
of climate policy. 

Estonia  has  one  out  of  three  regions  identified  as  a 
hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions (128). 

Estonia is vulnerable to the impacts of climate change 
such as rises in temperature, rainfall and sea level, and 
extreme weather phenomena accompanied by coastal 
and  inland  floods,  wildfires  and  new  pathogens. 
Estonia’s overall insurance coverage is low  with only 
5–20 % of the economic losses from 1980–2020 being 
insured. 

Estonia’s  adaptation  framework  has  weaknesses. 
Estonia  adopted  its  national  adaptation  strategy  in 
2017  and  has  not  yet  been  updated  such  that  it 
integrates  climate  adaptation  into  key  vulnerable 
sectors  and  tackles  the  barriers  to  adaptation. 
Likewise,  measures  to  protect  densely  populated 
areas  and  areas  around  inland  waterbodies  and 
forests – issues of key importance – have not yet been 
taken. 

2025 priority actions 

Land use, land-use change and forestry 

European  Commission  identified  five  priority  actions 
in the 2022 edition (129) of the review. 

The LULUCF sector plays a significant role in achieving 
the EU’s climate neutrality goal. In the EU, this sector 
absorbs more GHGs than it emits, removing significant 
volumes of carbon from the atmosphere. Thus, it is the 
only sector with negative emissions. 

That  is  not  the  case  in  Estonia.  In  2014  net  carbon 
removals  turned 
into  net  emissions  and  have 
remained above zero since then. Since 2020 there has 
LULUCF  emissions.  As 
been  a 
in  the  context  of  the  European 
recommended 
Semester, 
forest 
management  and  action  to  restore  wetlands  could 

improvements 

continued 

reduction 

in 

in 

is  still 

little  progress 

in  reducing  energy 
There 
consumption of buildings, especially in the residential 
sector. 

Estonian  emissions  primarily  come  from  the  energy 
sector. Estonia is making progress in transitioning on 
climate-neutral  energy  systems  as  it  committed  to 
cease electricity production from oil shale by 2035 and 
to phase out oil shale in energy production by 2040 in 
their Just Transition territorial Plan. 

Estonia  made  significant  steps 
implementing 
reforms to accelerate the deployment of renewables. 

in 

(128)  European Climate Risk Assessment (EUCRA). 2024. Available 

(129)  2022 edition. 

at European Climate Risk Assessment (europa.eu). 

2025 Environmental Implementation Review – Estonia 

 
 
 
Overall  share  of  renewables  is  way  above  the  EU 
average. 

is  no  direct  mention  of  ensuring 

There 
the 
sustainability criteria or GHG saving criteria in any of 
the reported measures. 

As Estonia had not submitted its final national energy 
and  climate  plan  (NECP)  plan  by  the  end  of  March 
2025,  the  European  Commission  encourages  Estonia 
to  submit  it.  The  plan  will  be  assessed  and  the 
assessment  will  be  available  on  the  Commission 
website: National energy and climate plans. 

Estonia  41 

2025 priority actions 

• 

Implement  all  polices  and  measures  that  are 
needed to achieve targets laid down in the Effort 
Sharing  Regulation  (ESR)  and  the  Land  Use  and 
Land-Use  Change  and 
(LULUCF) 
Regulation. More detailed priority actions will be 
set  out  after  the  submission  and  assessment  of 
the  final  National  Energy  and  Climate  Plan 
(NECP).  

Forestry 

2025 Environmental Implementation Review – Estonia 

 
 
Estonia  42 

Part II: Enabling framework – implementation tools 

5. Financing

The  EU  budget  supports  climate  investment  in  Estonia 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022,  Estonia’s  revenues  from  auctioning  reached 
EUR 725 million in total, with 53 % of it spent on climate 
and energy, corresponding to EUR 381 million. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 1.4 billion per year in 
Estonia. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 0.6 billion per year; thus, there is a 
gap of EUR 0.8 billion per year. 

Of  the  environmental  investment  gap,  EUR 591 million 
concerns  biodiversity  and  ecosystems,  with  a  further 
for  each  of  pollution 
EUR 60–70 million  needed 
prevention and control, circular economy and water. 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
recovery and resilience facility (RRF) EUR 275.7 billion and 
CAP EUR 145.9 billion (130). 

In  Estonia,  the  EU  cohesion  policy  (considering  EU 
contribution amounts) provides EUR 1.4 billion for climate 
action  in  2021–2027  (with  around  40 %  of  this  via  the 
ERDF),  with  a  further  EUR 43 million  from  European 
Maritime, Fisheries and Aquaculture Fund (131). 

The  RRF  contributes  to  climate  finance  in  Estonia  with 
EUR 0.57 billion  up  to  2026,  representing  59.4 %  of  the 
RRP (132). 

(EIB)  provided 
Investment  Bank 
The  European 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 391 million was assigned 
to Estonia in the reference period (133). 

National financing, including EU emissions trading 
system revenues 

to  EUR 142 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
in  2020, 
budgets,  amounted 
EUR 249 million  in  2021  and  EUR 334 million  in  2022  in 
Estonia, totalling EUR 725 million in the three-year period. 
In Estonia, 50 % of the auctioning revenues are earmarked 
and directed through the four-year state budget strategy 
and used for climate and energy purposes, which may take 
multiple years. Unspent revenues are carried over to later 
years and always used for climate and energy projects. The 
remaining 50 % goes to the general budget, which covers, 
among other things, climate and energy investment (not 
included here) (134). 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  to  climate  action  at  the  EU 
level. 

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (135). 

therefore, 

and, 

(130)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
pp. 94–96, 
the 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024, 

(131)  See 

the 

Cohesion 

Open 

Data 

Platform 

(https://cohesiondata.ec.europa.eu/). 

(132)  EU  Commission  datasets  and  the  Recovery  and  Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

(133)  A  list  of  financed  projects  is  provided  by  the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

(134)  European  Commission:  Directorate-General 

for 
Climate Action, Progress Report 2023 – Climate action, 
the  European  Union, 
Publications  Office  of 
Luxembourg, 
2023, 
https://climate.ec.europa.eu/news-your-
voice/news/climate-action-progress-report-2023-
2023-10-24_en. 

(135)  NB:  Indirect  investments  (from  climate  and  other 
policies) in support of the environment are accounted 
for via the tracking. 

2025 Environmental Implementation Review – Estonia 

 
 
Environmental financing and investments 

Table 1: Key environmental allocations from EU funds to 
Estonia (million EUR), 2021–2027 

Estonia  43 

This section describes Estonia’s investment needs, current 
financing  and  gaps  as 
four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (136). 

relate 

they 

the 

to 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient  to  enable  Estonia  to meet  its objectives in the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is estimated to be EUR 1.4 billion per year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 0.7 billion per year, can be attributed to the need to 
support  biodiversity  and  ecosystems.  For  pollution 
prevention and control, the annual investment needs are 
estimated  to  be  EUR 204 million;  for  water  they  are 
EUR 138 million and for circular economy EUR 348 million 
(in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing 
is  estimated  to  currently  reach 
EUR 0.6 billion  per  year  in  Estonia  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 1.2 billion for Estonia in total, during 2021–2027 (or 
EUR 178 million per year). 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

European  Maritime,  Fisheries  and 
Aquaculture Fund 

Other MFF sources 

RRF (d) (2021–2026) 

Allocations 

632.7 (a) 
273.8 
330.5 
28.4  
431.5 (b) 
246.4 
185.1 

24.4 

157.6 (c) 

224.7 

(a) 

(b) 

(c) 

(d) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its  publication  date.  Source  and 
information: 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf ). Source: European Commission.    

Space  Fund,  Horizon  Europe,  LIFE  and  the  Connecting  Europe 
Facility. 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

Estonia,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
the LIFE programme (EUR 5.4 billion) (137), Horizon Europe 
(EUR 95.5 billion) (138),  the  Connecting  Europe  Facility 

(136)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gaps  estimates  are  based  on  the  Directorate-General  for 
Environment’s 
internal  analysis  (of  2024).  Throughout  this 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

(137)  https://cinea.ec.europa.eu/programmes/life_en. 
(138)  European  Commission,  Horizon  Europe,  https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en. 

2025 Environmental Implementation Review – Estonia 

 
 
 
Estonia  44 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels  (i.e.  the  gap)  reaches  an  estimated  EUR 0.8 billion 
per  year  in  Estonia,  representing  around  2.18 %  of  the 
national GDP, higher than the EU average (0.77 %). 

Figure 16: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

(EUR 33.7 billion) (139)  and  funds  that  can  be  mobilised 
through the InvestEU programme (140). 

Estonia’s RRP supports climate objectives through funding 
of  EUR 0.57 billion  (59.4 %  of  total),  with  no  additional 
amounts for the environment. 

EIB  provided 

EUR 158.1 million 

The 
in 
around 
environment-related  financial  contributions  to  Estonia 
from 2021 to mid 2024, most of which, EUR 134.6 million 
(85 %),  was  in  the  area  of  sustainable  energy,  transport 
and  industrial  projects,  which  provides  significant  co-
benefits  to  reducing  air  pollution,  environmental  noise 
and other pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Estonia, the 
total national environmental protection expenditure was 
EUR 636 million  in  2020  and  EUR 615 million  in  2021, 
representing 2.3 % and 2 % of GDP, respectively. 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Estonia,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
EUR 140 million in 2020, before falling to EUR 129 million 
in 2021, representing around 0.4–0.5 % of GDP. 

investment 

protection 

protection 

investment 

Splitting by institutional sector, 12 % of Estonia’s national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 64 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  28 %  from  the  general  business 
sector,  whose  environmental  activities  are  usually 
ancillary  to  its  main  activities.  At  the  EU  level,  38 %  of 
environmental  protection 
from 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (141). 

investment  comes 

from 

Estonia’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 612 million  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funds  (including  EIB  funds)  reaches  35.6 %,  with  around 
64 % national financing. The total public financing (EU plus 
national public) represents 43 % of the total. 

Source: Analysis of Directorate-General for Environment. 

The following table provides the distributions of Estonia’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

(139)  The  Connecting  Europe  Facility  Transport  part  also  includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % 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. 

(140)  The  InvestEU  Fund  is  set  to  mobilise  over  EUR 372 billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to 
back  the  investment  of  financial  partners such as  the  EIB  group 
and others. 

(141)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
 
 
 
 
 
 
 
Table 2: Summary of environmental investment gaps in 
Estonia per year, 2021–2027 

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Investment gap per year 

%  
of total 

%  
of GDP 

Million 
EUR  
(2022 
prices) 

66 

66 

8.4 

0.18 

The gap 

8.3 

0.18 

65 

8.3 

0.18 

591 

75.0 

1.63 

Total 

788 

100.0 

2.18 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Estonia’s investment 
needs  are  estimated  to  reach  EUR 0.2 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 188 million,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
needs to reduce environmental noise reach EUR 55 million 
per  year,  most  of  which  is  delivered  by  the  (same) 
sustainable  energy  and  transport  investments  that  also 
benefit clean air (142). Industrial site remediation requires 
an  estimated  EUR 7 million  per  year.  Microplastics 
pollution  and  the  chemicals  strategy  require  around 
EUR 4–5 million per year (each) (143). 

Current investments 
levels  supporting  pollution 
The  current 
prevention 
estimated 
an 
EUR 138 million per year in Estonia in 2021–2027. Most of 

investment 
and 

control 

reach 

(142)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
implementation 
report 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

2023 

(143)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

Estonia  45 

the  financing  concerns  clean  air  (EUR 130 million  per 
year).  Protection  from  environmental  noise  receives 
around  EUR 55 million  per  year,  with  a 
further 
EUR 10 million for site remediation. 

In Estonia, the EU MFF provides an estimated 44 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further 20 % from the RRF, adding up to 64 % of the total. 
EIB financing contributes 13 % and national sources reach 
23 % (144). 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  Estonia 
needs  to  provide  an  additional  EUR 66 million  per  year 
(0.18 % of GDP), mostly related to clean air and noise. The 
adequate 
the 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

implementation  of 

the  NECP  with 

According to the latest (2023) NAPCP review report (145), 
Estonia complied with ammonia  reduction requirements 
in 2020 and 2021, while it is at high risk of non-compliance 
with  ammonia  concerning  the  NECD’s  2030  emission 
reduction commitments (and at low risk for the other four 
pollutants),  based  on  the  policies  and  measures  in  its 
NAPCP  that  take  into  account  climate,  energy  and  CAP 
plans and financing baselines. 

Circular economy and waste 

Investment needs 

Estonia’s investment needs in circular economy and waste 
reach  EUR 348 million  per  year 
(including  baseline 
investments).  Most  of  this,  around  EUR 294 million  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 54 million  necessary 
for  waste  management 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 

(144)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 
Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
tracking: 
Annex  VI.  Further 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(145)  European Commission, ‘National air pollution control programmes 
website, 
European 

information  on  clean  air 

Commission 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en. 

2025 Environmental Implementation Review – Estonia 

 
 
needed for the uptake of circularity and waste prevention 
across the economy (146). 

Current investments 

Circular economy investments across the economy reach 
around EUR 240 million per year in Estonia in 2021-2027, 
with  a 
for  waste 
further  EUR 42 million  provided 
management that does not constitute circular economy. 

Around 4.7 % of this combined financing for circularity and 
waste comes from the EU MFF, with a further 0.2 % from 
the  RRF,  adding  up  to  4.9 %  of  the  total.  EIB  loans 
identified  in  support  of  circularity  and  waste  represent 
1.1 %  of  the  total.  The  share  of  national  sources  is 
absolutely  overwhelming,  reaching  94 %  of  the  total 
financing (147). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Estonia  needs  to  increase 
circular  economy 
investments  by  an  estimated 
EUR 54 million per year, with an additional EUR 12 million 
concerning  waste  management  action,  not  belonging  to 
circular 
to 
EUR 66 million per year, representing 0.18 % of Estonia’s 
GDP. 

economy.  Combined, 

amounts 

this 

Of  the  circular  economy  gap,  EUR 14 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital tools, critical raw material recycling, and measures 
proposed under the amendment of the Waste Framework 
Directive, 
further 
investment  need  to  unlock  Estonia’s  circular  economy 
potential. 

and  EUR 40 million 

constitutes 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 138 million (in 2022 prices) in Estonia. This comprises 
investment needs both for the water industry and for the 

(146)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
2019, 
https://op.europa.eu/en/publication-detail/-
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

(147)  Waste management and circular economy expenditure tracking in 
the  EU  funds,  EIB  projects  and  in  the  national  expenditure 
(Eurostat).  Datasets:  EPEA  accounts  (env_epi)  and  circular 
economy private investments (cei_cie012). 

(148)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
2020, 
28 May 
States’, 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 

Estonia  46 

protection and the management of water. The largest part 
of  the  total  annual  need,  EUR 80 million,  relates  to  the 
management  of  waste  water  (also  including  additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 23 million  is  necessary  for  drinking-water-related 
investments and around EUR 32 million for the protection 
and management of water (148). 

Current investments 

Water investments in Estonia are estimated to be around 
EUR 73 million per year (in 2022 prices) in 2021–2027. Of 
this,  EUR 21 million  supports  wastewater  management, 
EUR 17 million drinking water and around EUR 34 million 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Of the total financing,  10.1 % is provided by the EU MFF 
(mostly  through  cohesion  policy),  with  no  further 
contribution  from  the  RRF  or  from  the  EIB.  The  bulk  of 
financing comes from national sources (89.9 %) (149). 

The gap 

To meet the various environmental targets under the WFD 
and the Floods Directive, Estonia’s water investment gap 
reaches  EUR 65 million  per  year  (0.18 %  of  GDP),  with 
most of it related to waste water (EUR 59 million per year). 
Drinking  water  measures 
require  an  additional 
EUR 7 million per year. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 710 million per year (in 2022 prices) 
in  Estonia  in  2021–2027.  This  includes  the  following 
financing needs: 

• 

• 

action 

prioritised 

framework (150), 
Estonia’s 
concerning  the  Natura  2000  areas:  EUR 43.5 million 
per year, mostly running costs; 
additional BDS costs (151): EUR 480 million per year on 
top of the framework; 

Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

(149)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 
(150)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

European 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

Commission 

(151)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
Office 
2022, 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

2025 Environmental Implementation Review – Estonia 

 
 
costs (152): 

The gap 

Estonia  47 

• 

sustainable 
EUR 187 million per year. 

soil 

management 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 119 million per year (in 2022 prices) in 2021–2027. 
78.9 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

6.7 % of the total financing is estimated to come from EU 
cohesion  policy,  48 %  from  CAP,  9.5 %  may  come  from 
Horizon Europe and around 3.7 % from LIFE. The EU MFF 
altogether accounts for 72 % of the financing and the RRF 
for 2 %, adding up to a total of 74 % from the EU budget. 
The rest, 26 %, comes from national sources (153). 

At  1.9 %,  Estonia’s  share  of  RRF  funding  dedicated  to 
supporting measures for biodiversity is above the average. 
Estonia has also programmed 22.6 % of its CAP budget for 
2021–2027 in measures dedicated to support biodiversity, 
which is above the EU average. Lastly,  2.2 % of Estonia’s 
cohesion  policy  EU  contribution  amount  is  estimated  to 
contribute 
ESF+), 
biodiversity 
corresponding to less than half of the EU average. 

(disregarding 

to 

Figure 36: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

NB: ESF+, European Social Fund Plus. 

(152)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
COM(2023) 416 
2023, 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 
in 
biodiversity 

(153)  Based  on 

tracking 

budget 

5 July 

final 

the 

EU 

of 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Estonia’s 
investment gap is estimated to be around EUR 0.6 billion 
per year, corresponding to 1.63 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States  already  use  green  budgeting  tools  for  identifying 
and  tracking  green  expenditures  and/or  revenues  (154). 
Green budgeting practices provide increased transparency 
on the environmental implications of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (155). 

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 
2021 to 2204 (156). Estonia participated. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (157),  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 830 million in 
Estonia in 2022, representing 2.3 % of its GDP (EU average: 
2.0 %).  Energy  taxes  formed  the  largest  component  of 
environmental taxes, accounting for 2.1 % of GDP, which 
is higher than the EU average of 1.6 %. Transport taxes, at 
0.04 % of GDP, were under the EU average (0.4 %), while 
taxes on pollution and resources, at  0.16 %, were above 

eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

(155)  European  Commission, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

reference 
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

(154)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-

2023, 

(156)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 

(157)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
https://op.europa.eu/en/publication-detail/-
p. 1), 
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
the EU average (0.08 %). In 2022, environmental taxes in 
Estonia  accounted  for  7 %  of  total  revenues  from  taxes 
and social security contributions (above the EU average of 
5.0 %) (158). 

Figure 37: Environmental taxes per Member State, 2022 

Estonia  48 

served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems)  and  3.8 % 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  supranational 
issued  by 
financial  corporates,  29.1 %  by  sovereign  governments 
and  23.1 %  by  non-financial  corporates.  8.3 %  of  the 
issuances was linked to government-backed entities, 6.4 % 
to developments banks and 1.4 % to local governments. 

issuances)  was 

Figure 38: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

to  a  2024  study (159),  Estonia  applies 
According 
environmental taxes used to discourage environmentally 
harmful activities and behaviours in the fields of water, air, 
soil and waste management (levies on plastics). 

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia). 

Green bonds and sustainable bonds 

Environmentally harmful subsidies 

In 2023, the total value of green bonds issued by Member 
States  was  USD 245 billion  (EUR 227 billion),  up  from 
USD 234 billion (EUR 198 billion) in 2021. 

During 2021–2023 combined, Estonia issued green bonds 
worth  USD 97.6 million  (EUR 82.5 million),  with  all  of  it 
issued in 2023 (160). 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 
action  programme  objectives  and 
the  enabling 
conditions (161). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 

(158)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(159)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 2, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(160)  Climate  bonds  initiative  (https://www.climatebonds.net/).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

(161)  Article 3(h) and 3(v) of the eighth environment action programme. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
Estonia  49 

the 2021 energy crisis and subsequent increase in energy 
prices. 

NB: RES, renewable energy source. 
Source : analysis of Directorate-General Energy 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (162). 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (163). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

In  Estonia,  the  energy  subsidies  showed  some  volatility 
between  2015  and  2021,  with  FFS  totalling  around 
EUR 0.1 billion  per  year.  In  2022,  the  overall  energy 
subsidies increased to above EUR 0.4 billion per year, and 
then  decreased  in  2023,  with  similar  levels  of  FFS  as 
before. 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden. Estonia’s value 
reached 0.3 %, under the EU average (0.8 %) (164). 

Figure 39:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

Estonia did not receive a specific priority action in 2022. It 
was,  however,  noted  that  certain  additional  investment 
needs may require adequate financing. 

There  is  an  overall  environmental  investment  gap  of 
around 2 % of GDP in Estonia, with a significant part of it 
related to the needs arising from the BDS and sustainable 
soil management. 

2025 priority action 

With  regard  to  existing  investment  gaps,  the  following 
general priority action is specified. 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 
environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

(162)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

Union, 

(164)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

Union, 

(163)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
 
 
6. Environmental governance

Information, public participation and access to 
justice 

Table 3:  Estonia  dashboard  on  implementation  of  the 
Inspire Directive, 2016–2023169 

2016 

2023 

Legend 

Estonia  50 

to 

(iii) 

and 

access 

justice 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making 
in 
environmental  matters.  It  is  of  crucial  importance  to 
public  authorities,  the  public  and  businesses  that 
is  shared  efficiently  and 
environmental 
effectively (165).  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 
environment, safeguard the rights of citizens and ensure 
accountability  of  authorities (166).  It  includes  the  right  to 
bring legal challenges (‘legal standing’) (167). 

information 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to  set  up  a  European  spatial-data  infrastructure  for 
sharing environmental spatial information between public 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

Estonia’s  performance 
Inspire 
Directive is substantial and has been reviewed based on 
its 2023 country fiche (168) (see Table 3). 

implementing  the 

in 

(165)  The  Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32003L0004) 
Inspire 
Directive  (Directive  2007/2/EC)  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002) together create a legal 
foundation for the sharing of environmental information between 
public authorities and with the public. 

and 

the 

(166)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 
2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-

■ 

effective 

Effective coordination and data sharing  ■ Implementation of 
Ensure 
this  provision  is  well 
coordination 
advanced  or  (nearly) 
completed. 
Outstanding 
issues 
are minor and can  be 
addressed 
easily. 
Percentage > 89 % 

Data 
without obstacle 

Inspire performance indicators 

sharing 

■ 

■ 

■ 

(i)  Conformity  of 
metadata 

(ii)  Conformity  of 
spatial datasets  

(iii)  Accessibility  of 
datasets 
spatial 
through  view  and 
download services 

■ 

■ 

■ 

■ 

■ 

■ 

(iv)  Conformity  of 
network services 

■ 

■ 

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

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

Source:  European  Commission,  ‘Estonia’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/estonia_en. 

In 2022, Estonia received a priority action on the need to 
make  spatial  data  more  widely  accessible  and  prioritise 
the environmental datasets. Estonia has made progress on 
the accessibility of spatial data. However, the accessibility 
of  high-value 
implementing 
environmental  legislation (170)  still  needs  improvement, 
and a priority action is proposed in 2025. 

spatial  datasets 

for 

/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

(167)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

(168)  European  Commission, 

‘Estonia’, 

Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/estonia_en. 

(170)  The  European  Commission  provides  a  list  of  high-value  spatial 
(https://github.com/INSPIRE-MIF/need-driven-data-
datasets 
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx). 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
Public participation 

Public involvement  at both the planning and the project 
phase  maximises  transparency  and  social  acceptance  of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the  EIA  Directive (171)  and  the  Strategic  Environmental 
Assessment (SEA) Directive (172). 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 
the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and continues to support the 
Member  States  in  this  regard  (173).  Estonia  has  already 
taken 
to  accelerate  permit-issuing 
procedures  taking  advantage  of  the  broad  flexibilities 
offered  by  the  EU 
legal  framework,  such  as  the 
establishment  of  one-stop  shops  and  accelerated  short 
deadlines  for 
issuing  permits  for  renewable  energy 
projects. 

steps  aiming 

The average speed in the EU for issuing permits involving 
an  EIA  procedure 
is  20.6 months,  with  a  minimum 
duration  of  11.4 months  and  a  maximum  duration  of 
75.7 months (174).  In  Estonia,  the  full  EIA  process  takes 
22 months, with a minimum of 10 months and maximum 
of 42 months which is slightly slower than the EU average. 

(171)  Directive  2011/92/EU  of  the  European  Parliament  and  of  the 
Council of 13 December 2011 on the assessment of the effects of 
certain public and private projects on the environment (OJ L 26, 
28.1.2012, 
https://eur-lex.europa.eu/legal-
p. 1), 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(172)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the assessment of the effects of certain 
plans and programmes on the environment (OJ L 197, 21.7.2001, 
p. 30), 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042. 

(173)  Commission Staff Working Document  (SWD/2022/0149 final), 18 
May 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229
953). 

2022, 

( 

(174)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 

Estonia  51 

The  duration  of  each  step  in  an  EIA  process  (screening, 
scoping,  EIA  report,  public  consultation,  reasoned 
conclusion,  development  consent)  varies  considerably 
between Member States and projects. Effective use of EU 
procedures can positively influence the timely approval of 
activities  underpinning  the  decarbonisation  of  the 
economy on the way to net zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a support study has been published with information by 
Member State (175). 

in 

in  Estonia 

the  2022  EIR, 

the 
As  mentioned 
Environmental Board has a special section on its website 
explaining  opportunities  to  participate  in  EIA  processes, 
with 
related  databases  and  sources  of 
information (176).  Notifications  on  public  participation 
opportunities  are  published  in  the  official  publication 
Ametlikud Teadaanded, available online (177). 

links 

to 

EIA  and  SEA  procedures  are  carried  out  by  many 
authorities  and  there  are  no  publicly  available  data  on 
overall levels of participation and access to information in 
these procedures. 

Access to justice 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  EU  Charter  of 
Fundamental Rights, is a fundamental right and part of the 
democratic process. It is vital to ensure the full application 
of EU law in all Member States and the legal protection of 
the  rights  of  individuals,  including  in  environmental 
matters.  Access  to  justice  is  essential  to  enable  judicial 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 

Impact  Assessment 

revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(175)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

(176)  https://keskkonnaamet.ee/keskkonnateadlikkus-

avalikustamised/raagi-kaasa. 

(177)  https://www.ametlikudteadaanded.ee/eng/index. 

2025 Environmental Implementation Review – Estonia 

 
 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As  mentioned  in  the  2022  EIR,  Estonia  provides  both 
individuals and NGOs withstanding in environmental court 
cases. 

For  plans  and  programmes 
that  are  considered 
administrative  acts  (i.e.  those  that  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). 

In  2022,  a  priority  action  was  addressed  to  Estonia  to 
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. No updated information 
has been provided to the Commission. The framework is 
currently under assessment. 

2025 priority actions 

spatial  datasets 

•  Make  spatial  data  more  widely  accessible  and 
prioritise  environmental  datasets  in  implementing 
the  Inspire  Directive,  especially  those  identified  as 
implementing 
high-value 
environmental legislation. 
Ensure  that  relevant  information  on  EIA  and  SEA 
procedures 
(including  on  public  participation 
opportunities and on publication of final decisions) is 
electronically  accessible,  through  at  least  a  central 
portal  or  easily  accessible  points  of  access,  at  the 
appropriate administrative level. 

for 

• 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, to manage waste (178) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

(178)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 
compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
(https://eur-
Commission 

document 

working 

staff 

Estonia  52 

Compliance promotion, monitoring and enforcement 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders  to  comply  by  providing  information,  guidance 
another  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
including 
the  use  of  administrative  and  criminal 
enforcement tools. 

As mentioned in the 2022 EIR, inspection reports, as well 
as  statistics  about  environmental 
infringements,  are 
available on the Environmental Board’s website (179). They 
include information about detected infringements, cases 
resolved  (number  and  amounts  of  fines,  etc.)  and  the 
environmental damage caused. 

From the 2023 Environmental Board annual report (180), it 
emerges  that  the  number  of  decisions  adopted  in  2023 
was  812, 
in  2022. 
lower  than  the  887  adopted 
Nonetheless,  there  was  more  than  a  tenfold  increase  in 
fines imposed in 2023 (EUR 8 533 863 in 2023 compared 
with  EUR 559 757  in  2022),  taking  into  account  both 
administrative  fines  and  criminal  penalties  imposed  for 
infringements. 

No  updated  information  was  found  on  the  2020  joint 
ministerial declaration on tackling environmental crime. 

The  2022  EIR  recommended  that  Estonia  (i)  provide 
regular  updates  on  progress  on  implementing  the  2020 
joint  ministerial  declaration  on  tackling  environmental 
crime; 
(ii)  actively  encourage  public  reporting  of 
environmental  damage  and  infringements  and  provide 
information  on  how  those  reports  are  used  to  improve 
compliance; and (iii) improve the information available to 
farmers and other land managers on compliance with the 
Nature  and  Nitrates  Directives.  Concerning  compliance 
promotion,  monitoring,  and  criminal  and  administrative 
enforcement,  the  2022  priority  actions  are  not  assessed 
here due to a lack of systematic information. Similarly, the 
Commission is not aware of whether information is easily 
available online at the national level for farmers regarding 
compliance with the Nitrates and Nature Directives, and 
hence the related 2022 priority action is not assessed. 

lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

(179)  https://www.just.ee/kuritegevuse-statistika. 
(180)  https://keskkonnaamet.ee/sites/default/files/documents/2024-
03/Keskkonnaameti%20j%C3%A4relevalve%20valdkonna%20kok
kuv%C3%B5te%202023.pdf. 

2025 Environmental Implementation Review – Estonia 

 
 
The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203) (181) and new sectoral legislation with stronger 
provisions  on  compliance  monitoring,  enforcement  and 
penalties. Issues important for the transposition and the 
implementation  of  the  relevant  new  instruments  are 
highlighted below; a detailed assessment of these topics 
will be included in the next EIR once more implementation 
in  place  and  more  systematic 
measures  are  put 
information is available. 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU 
legislation  on  chemicals,  mercury, 
fluorinated GHG and IAS of EU concern. It also covered the 
establishment  of  qualified  offences,  subject  to  more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Concrete 
provisions on the types and levels of penalties for natural 
and  legal  persons  who  commit  an  offence  were  also 
introduced.  Other  provisions  will  help  considerably  to 
improve  the  effectiveness  in  combating  environmental 
crime  of  all  actors  along  the  enforcement  chain.  These 
include  obligations  to  ensure  adequate  resources  and 
investigative  tools,  specialised  regular  training  and  the 
establishment  of  cooperation  mechanisms  within  and 
between Member States as well as national strategies on 
combating environmental crime. 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
in  particular  through  training,  coordination, 
crime, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 

including  by 

(181)    Directive  2024/1203/EU  on  the  protection  of  the  environment 
https://eur-

criminal 

law 

through 
lex.europa.eu/eli/dir/2024/1203/oj/eng 

(182)  https://www.impel.eu/en. 
(183) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

project 

(184)  https://www.environmentalprosecutors.eu. 
(185)  https://www.eufje.org/index.php?lang=en. 
(186 ) Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage, https://eur-

Estonia  53 

the  recognised  EU-level  networks  of  environmental 
enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 
Law (182),  EnviCrimeNet (183),  the  European  Network  of 
Prosecutors for the Environment (184) and the EU Forum of 
Judges  for  the  Environment (185).  The  European  Union 
Agency for Law Enforcement  Cooperation and European 
Union  Agency 
Justice  Cooperation 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences. 

for  Criminal 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)  (186)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
for  better 
tool  and  a  key  enabler 
cross-cutting 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (187), which will be finalised in 2025, and which 
was  supported  by  an  external  study (188),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

indicators 

One  of  the  most  relevant 
in  assessing 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the  previous  reporting  period.  Fewer  ELD  cases  were 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 
tendency  in  the  number  of  ELD  occurrences  and  their 
overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  be  compared 

lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626. 

(187)  Commission  staff  working  document  -  Evaluation  of  the 

(188) 

Environmental Liability Directive, forthcoming 2025.  
 European Commission: Directorate-General for Environment and 
Fogleman,  V.,  Study 
in  support  of  the  evaluation  of  the 
Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Estonia 

 
 
the  development  of 

with the overall number of environmental damage cases, 
some of  which  may have been handled under the other 
liability instruments. 
The ELD has not always been effective in ensuring that the 
polluter  pays,  because  the  liable  operators  often  lack 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
financial  security 
encourage 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this directive. 
From 1 May 2013 to 23 February 2022, Estonia reported 6 
occurrences  of  an  imminent  threat  of  environmental 
damage  and  11  occurrences  of  environmental  damage 
under  the  ELD.  In  the  previous  reporting  period,  there 
were  two  confirmed  occurrences  of  an  imminent  threat 
and  two  occurrences  of  environmental  damage.  For 
comparison,  in  Estonia,  there  were  879  occurrences  of 
environmental damage between 2012 and 2017, but only 
13  occurrences  of  an  imminent  threat  of  or  actual 
environmental damage under the ELD between 2009 and 
2019. 
there  were  136  occurrences  of 
environmental  damage  but  only  4  occurrences  of 
environmental damage under the ELD. 

In  2020, 

Estonia  has  not  introduced  mandatory  financial  security 
for ELD liabilities. Environmental insurance policies are not 
generally  available. Environmental extensions to general 
liability policies are widely available but cover tends to be 
limited  to remediating off-site land/soil pollution from a 
sudden and accidental incident on an insured site. They do 
not  provide  cover  for  other  ELD  liabilities.  Demand  for 
them is also low. 

The 2022 EIR, in relation to  the ELD, recommended that 
Estonia  provide  up-to-date  information  on  incidents  of 
environmental damage, including under the ELD, through 
the registry or databases that are made accessible to the 
public. Its second report under the ELD states that Estonia 
had created a registry of ELD cases that is available online. 
Reports  on  ELD  cases  are  published  as  well.  In  can  be 
concluded that Estonia  has made substantial progress in 
the implementation of this priority action. 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level) covering the ELD and its interactions with the 
other national liability-related instruments, to ensure 
more  efficient  ELD  implementation,  improve  the 

(189)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

(190)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-

Estonia  54 

expertise  of  the  competent  authorities  and  raise 
awareness among all stakeholder groups. 

EU-supported environmental capacity building 

initiative 

The  Commission’s  2023  Compact (189) 
to 
enhance  the  administrative space  identifies  the  capacity 
to  lead  the  green  transition  as  one  of  three  key  pillars, 
along with the public administration skills agenda and the 
capacity  for  Europe’s  Digital  Decade.  Compact  also 
recognises the role of the EIR reporting tool in improving 
environmental  governance.  The  two  main  capacity-
building  opportunities  for  the  environment  provided  by 
the European Commission are the TSI (190) and the TAIEX-
EIR  PEER  2  PEER  tool (191).  The  technical  assistance 
available through the cohesion policy is subject to shared 
management and is not dealt with in this subsection. 

The Commission’s technical support instrument 

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation  of 
reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. 

The  Commission’s  TSI  had  annual  calls  in  2021,  2022, 
2023, 2024 and 2025. The following environment-related 
projects have been selected for Estonia: 

•  Defining 

the 

framework 

for  assessment  of 
effectiveness  of  biodiversity  conservation  measures 
in Estonia (2022); 
Implementation  of 
towards 
sustainable  water  services  from  the  Ministry  of  the 
Environment of Estonia (2023); 

the  action  plan 

• 

•  Developing  technological  solutions  and  production 
possibilities  of  sustainable  aviation 
(SAF) 
production  in  Baltic  states  from  the  Ministry  of 
Climate (2024); 
Improving  access  to  finance  for  the  implementation 
of  railway  sector  projects  in  order  to  facilitate 
integration  of  Baltic  states  in  the  European  rail 
network from the Ministry of Climate (2024); 

fuel 

• 

•  Development  of  unified  cross-border  public  service 
obligation (PSO) model for the Rail Baltica railway line 
from the Ministry of Climate (2024); 
Sustainable  and  effective  Blue  Economy  public 
governance  system  from  the  Ministry  of  Climate. 
(2025). 

• 

funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(191)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 

tool 

2025 Environmental Implementation Review – Estonia 

 
 
Estonia  55 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

•  Online  platforms:  EU  Batteries,  Packaging  and 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where a  delegation of  experts travels to the requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
multi-country  workshops  are  those  requested  by  the 
Commission to present new and upcoming environmental 
legislation and policy in all Member States (192). 

Workshops involving Estonia are as follows: 
• 

Future  challenges  for  air  protection  (24 November 
2022) with the Czech EU Presidency; 

•  Best  practices  in  applying  Article 6(3)  of  Habitats 
Directive:  Practical  solutions  to  carry  out  Natura 
impact  assessments  effectively 
(25–27 October 
2023); 

•  Reducing air pollution from transport and residential 

energy (11–13 June 2024); 

Packaging Waste Regulation (28–29 October 2024); 

•  New aspects in the cross-border cooperation against 
environmental crime (19–20 November 2024). 

Estonia was involved in two expert missions, one on best 
practice in applying Article 6(3) of  the Habitats Directive 
(26–27 April 2023), where it was the host, and one on the 
emission  inventory  and  assessment  of  the  impact  of 
policies  and  measures  on  emissions  in  Lithuania  (15–
17 May 2023). Furthermore, Estonia also benefited from a 
study  visit  to  Sweden  on  best  practice  in  applying 
Article 6(3)  of  the  Habitats  Directive  (18–21 September 
2023). 

2025 priority action 

• 

Improve overall national environmental governance, 
in  particular  administrative  capacity  to  support  the 
green transition and coordination at the regional and 
local levels. 

(192)  Flagship  multi-country  workshops  in  the  reporting  period  are: 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
quality: 
implementation  of  the  NEC  Directive  to  further 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25 September  2024);  Industrial  emissions  transposition 
and implementation of the revised directive (12 September 2024); 
Noise:  progress  towards  meeting  Member  States’  noise  limit 
values and EU reduction targets (5 June 2024); Best practice use 

of  environmental  footprint  methods  on  the  EU  market  (30 May 
2024);  Sustainable  finance  (9 November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13 June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 
in  planning  and  approval  of  renewable  energy  projects 
(17 November 2022); Environmental compliance and governance 
(14 November  2022);  Biowaste  management  (19–20 September 
2022); and  Renewable energy projects: permit granting processes 
(13 June 2022). NB: The first flagship workshop on zero pollution 
for air, water and soil took place 9 February 2022. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
Estonia  56 

Annex 
2025 priority actions 
Circular economy and waste management 
Transitioning to a circular economy 
•  Speed up the transition to a circular economy by implementing an  updated national strategy and the EU framework 

and recommendations, in particular to complement it with upstream circularity measures. 

•  Adopt measures to increase the CMUR. 

Waste management 

• 
• 

Further shift reusable and recyclable waste away from incineration, including through economic instruments. 
Increase reuse of products and scale up waste recycling infrastructure associated with the higher steps of the waste 
hierarchy. In particular, improve collection and increase treatment capacity for bio-waste. 
Increase the collection and recycling rate of waste electronic and electric equipment (WEEE). 
Invest in waste prevention measures to reduce the total amount of waste generated. 

• 
• 
•  Develop EPR schemes for problematic waste and introduce fee modulation. 
•  Ensure the achievement of the 2025 waste targets, following the recommendations made by the Commission in the 

Early Warning Reports where applicable. 

Biodiversity and natural capital 
Global and EU biodiversity frameworks 

•  Submit  to  the  CBD  an  updated  NBSAP  or  national  targets  following  the  adoption  of  the  Kunming-Montreal  Global 

Biodiversity Framework. 

Nature protection and restoration – Natura 2000  

• 

Finalise the establishment of site-specific conservation objectives and measures for all Natura 2000 sites (including by 
adopting their management plans) and ensure their effective implementation. 

•  Ensure  the  effective  implementation  of  Natura  2000  management  plans  and  sufficient  administrative  capacity  and 
financing both for Natura 2000 and the implementation of the Nature Restoration Regulation. Ensure implementation 
of Prioritised Actions Framework 2021-2027 (PAFs). 

Recovery of ecosystems 

Agricultural ecosystems 

• 

Implement  eco-schemes  and  agri-environmental  measures  and  practices  to  address  the  environmental  needs  of 
Estonia. 

Grasslands 

•  Promote active management of grasslands through extensive grazing to maintain the condition of these semi-natural 

habitats. 

Wetlands/peatlands 

• 

Implement peatland conservation and restoration measures and include such measures and objectives in the national 
restoration plans. 

Forest ecosystems 

•  Ensure sustainable management of forests, i.a. by adopting the National Forest Programme post-2020 and consider 
the conservation objectives of Natura 2000 forest sites when developing the National Forest Management Plan. 
Improve conservation status of forests by promoting sustainable forest management and ensuring compliance with the 
Habitats Directive before granting/renewing permits for forest logging. 

• 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
 
 
 
 
 
 
Estonia  57 

Marine ecosystems 

•  Step  up  implementation  of  the  IAS  Regulation,  including  with  regard  to  enforcement  and  capacity  of  inspection 

authorities. 

Zero pollution 
Clean air 

•  As part of the NAPCP, take action to reduce emissions of air pollutants. 
•  Ensure full compliance with the current AAQD standards, also in light of future stricter requirements under the revised 

AAQD. 

Industrial emissions  

•  Complete the correct transposition of the IED 1.0. 
•  Reduce industrial air pollution damage and intensity. 
•  Address the current implementation issues related to indirect release of pollutants to water. 
•  Engage with industry and environmental NGOs to ensure proper contribution to and implementation of BAT conclusions 

and ensure timely updates to permits following the publication of BAT conclusions. 

•  Ensure effective public participation and access to justice in relation with the IED. 

Noise 

•  Complete and implement action plans on noise management. 

Water quality and management 

Water framework directive 

• 

Improve  river  continuity  and  ecological  flows,  boosting  efforts  to  introduce  nature-based  solutions  to  reduce 
hydromorphological pressures.  

•  Ensure periodic reviews of permits for discharges, abstractions and other water uses, including hydropower pressures.  
•  Reduce pollution from nutrients, chemicals,  metals and saline discharges.  
•  Better justify exemptions to the achievement of good status.  
• 
•  Develop  more  robust  programmes  of  measures,  tackle  obstacles  identified in  the implementation  of measures  and 
ensure  adequate  financing  for  implementation,  including  through  better  use  of  the  cost  recovery  and  polluter  pays 
principle.  

Improve the classification of water bodies and strengthen monitoring systems.  

Floods directive 

• 

FRMPs should provide details on how the FHRMs were used in the choice of measures and how to consider pluvial 
flooding. 

•  Better explain the choice and implementation of flood prevention and protection measures (prioritisation, monitoring, 

costs of measures). 

Nitrates directive 

• 

Tackle nutrient pollution, especially nitrates from agriculture, through the implementation of the Nitrates Directive. 

Urban wastewater treatment directive 

• 

Take the necessary measures to ensure full implementation of the current urban wastewater treatment directive, taking 
into account the new requirements of the recast directive. 

2025 Environmental Implementation Review – Estonia 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Estonia  58 

Chemicals 

•  Upgrade the administrative capacities in implementation and enforcement towards a policy of zero tolerance for non-

• 

• 

• 

compliance. 
Increase  involvement  in  the  activities  of  the  Forum  for  Exchange  of  Information  on  Enforcement  of  the  European 
Chemicals Agency, including in the coordinated enforcement projects, called REFs. 
Increase customs controls and controls of products sold online with regard to compliance with chemicals legislations. 

Climate action 

Implement  all  polices  and  measures  that  are  needed  to  achieve  targets  laid  down  in  the  Effort  Sharing  Regulation 
(ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) Regulation. More detailed priority actions will 
be set out after the submission and assessment of the final National Energy and Climate Plan (NECP).   

Financing 
•  Use more national funding (for instance by increasing taxes in favour of the environment and reducing environmentally 

harmful subsidies), EU funding and private funding to help close the investment gap. 

Environmental governance 
Information, public participation and access to justice 
•  Make spatial data more widely accessible and prioritise environmental datasets in implementing the Inspire Directive, 

especially those identified as high-value spatial datasets for implementing environmental legislation. 

•  Ensure that relevant information on EIA and SEA procedures (including on public participation opportunities and on 
publication of final decisions) is electronically accessible, through at least a central portal or easily accessible points of 
access, at the appropriate administrative level. 

Compliance assurance 

• 

Encourage the use of training programmes provided by the Commission (or developed at the national level) covering 
the  ELD  and  its  interactions  with  the  other  national  liability-related  instruments,  to  ensure  more  efficient  ELD 
implementation, improve the expertise of the competent  authorities and raise awareness among all stakeholder 
groups. 

EU-supported environmental capacity building 

• 

Improve overall national environmental governance, in particular administrative capacity to support the green transition 
and coordination at the regional and local levels. 

2025 Environmental Implementation Review – Estonia