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Reminder of a holder of the permit

As a rule, the Environmental Board does not apply directly applicable requirements to permits from various acts (e.g. Atmospheric Air Protection Act, Water Act, Waste Act, Industrial Emissions Act), regulations or other legislation. They apply (are to be executed) regardless of whether they are listed on the permit or not. Considering the abundance of directly applicable requirements and to facilitate the day-to-day work of operators, the Environmental Board points out the main directly applicable requirements in the reminder.
  • Environmental protection measures must ensure high level environmental protection.
  • Environmental hazards must be avoided.
  • An environmental risk must be reduced to the maximum extent possible by taking appropriate precautionary measures.
  • Renewable and non-renewable natural resources must be used sustainably.
  • Costs related to the assessment, prevention, reduction or remedying of an environmental nuisance, threat, risk or damage must be borne by the person who caused them, unless otherwise provided by law.
  • A charge must be paid for the use of the environment in the events provided by law. Find out more on the environmental charges page.
  • Duty of care. This means that everyone must, to a reasonable extent, take measures to reduce the environmental nuisance caused by their act or omission.
  • Duty to acquire knowledge for prevention of environmental threat. This means that before commencing an activity that will cause an environmental threat, everyone must, to a reasonable extent, acquire knowledge that, given the type and scope of the activity, is necessary for preventing the environmental threat.
  • Environmental threat must be prevented and precautionary measures taken.
  • Raw materials, natural resources and energy must be used sustainably.
  • Upon choosing the location of installation, the purpose of reducing environmental nuisances to the maximum extent possible must be served.
  • The environmental protection training of the persons operating at the installation must be ensured.
  • The Environmental Board or, in another event provided by law, another authority must be immediately informed of a significant environmental nuisance (e.g. accident, incident, violation, etc.).
  • If the operator wishes to change the activity for which a permit has been granted to the operator and the change may result in a significant environmental nuisance, the operator must inform the issuer of the permit about the planned change well in advance.
  • Upon termination of the operations and thereafter it must be ensured that no significant environmental nuisances occur.
  • The holder of an environmental permit has the right to transfer the rights and duties arising from the permit to another person during the term of validity of the permit.
  • To change the data of the holder of an environmental permit, the permit holder and the applicant for the permit must submit a joint application to the issuer of the environmental permit. The application must specify the date on which the data of the permit holder will be changed. An application for changing the data of an environmental permit holder in the environmental permit must be submitted no later than ten days before the arrival of the date (§60 of the General Part of the Environmental Code Act (KeÜs)).
  • In case of mergers and divisions of companies, the transfer of assets of companies is regulated by contracts under the law of obligations. The general rule is that the issuer of the permit must be proved how, to who and when the possession has been transferred and whether the prerequisites necessary for obtaining the permit have been fulfilled. Therefore, the company must explain and prove whether, how, to who and when the lawful possession of the installation has been transferred.
  • The company must also prove that the new holder of the installation meets all the prerequisites/requirements for obtaining the permit and that there are no grounds for refusal/revocation of the permit. In several areas, special requirements are made to the holder of the permit, in other words, only a person who has, for example, a certain technical capacity, expertise or experience can obtain the permit. The transfer of rights and obligations arising from a permit is therefore a restrictive condition for the holder of the permit to continue to comply with the specific conditions provided for in legislation. Therefore, the rights and obligations arising from the permit can only be transferred to a person who could also be the so-called original holder of the permit.
  • It is important to notify the issuer of the permit of the merger or transfer of the company and to request immediately, or within the latest term provided for in the legislation, an amendment of the permit with regard to the data of the holder of the permit (providing also relevant and necessary additional documents). The issuer of the permit then carries out the necessary investigative activities, e.g. assesses the compliance of the applicant with the requirements established for the holder of the permit and makes the necessary changes to the permit holder only if the applicant meets the requirements set to the holder of the permit. Thus, the transfer of a permit depends on the circumstances characteristic of each individual case and the Environmental Board resolves situations in accordance with the provisions of special law. Notify the issuer of the permit of the changes in data immediately or within the term specified by law.

Principles of water protection

  • All persons are obliged to avoid pollution and depletion of water and littering of water bodies and wells and damage to aquatic life.
  • All persons are obliged to apply production technology, land improvement, agrotechnical, hydrotechnical and sanitary measures to protect water from pollution and depletion or littering of water bodies when using water.
  • The right for special use of water is based on an environmental permit (§41 of KeÜS), which grants the right to one or more activities specified in §187 of the Water Act (VeeS), and an integrated environmental permit (THS).
  • For the special use of water on a land of another person, the user shall have also the consent of the landowner. the consent of the landowner. The consent of the landowner is not required for the use of such land that is located under a water body in state ownership or that is deemed to be in state ownership in accordance with §31 (2) of the Land Reform Act.

Water user is required to:

  • Use water efficiently and economically and comply with the requirements established for water use.
  • Avoid violating the rights of other water users and landowners and avoid causing damage to public health, nature and industrial facilities as a result of water use.
  • In case of special use of water, maintain records of the water used and the amount and properties of the effluent, and in case of soil removed from the bottom of the sea by dredging (hereinafter the dredging spoils) and dumping, maintain records of the composition and volume of the dumped waste or other substances or objects.
  • Upon taking water with an environmental protection permit, when measuring the amount of water by using a water meter, DN < 300 mm and nominal consumption < 900 m3/h, 10-year period of validity of verification should be applied.
  • Organise monitoring of the effluent, monitoring of the use of water and water body under the conditions and pursuant to the procedure determined in the permit for the special use of water, and submit the monitoring report to the issuing authority by the due date set out in the permit
  • Use an evaluated person responsible for sampling, who meets the requirements established by §243 of the Water Act (VeeS), when carrying out self-monitoring, which is a water investigation, required by the environmental permit.
  • Follow meeting the requirements for the sanitary protection zone of water intake and feeding zone of drinking water intake, if necessary. 

Damming and/or use of hydro-electric energy

  • The requirements for lowering of water level and damming of a water body are established by §174 and §175 of VeeS. The specified requirements are set out in Regulation No. 54 of the Minister of the Environment.  The most important requirements are:
  • Damming must be organised in such a way as to ensure the damming levels specified in the permit for the special use of water and the preservation of environmental flow in the natural streambed downstream a hydraulic structure (§2 (1) of Regulation No. 54). 
  • When damming a body of water for use of hydro-electric energy, it is necessary to prevent fish from entering the turbines or the facilities through which water is diverted from the water body (§5 (1) of Regulation No. 54).
  • When lowering the water level of a water body, the streambed and aquatic biota below the dam shall not be damaged by changing the volumetric flow rate, and releasing sludges and litter into a streambed below the dam must be prevented (§8 (2) and (3) of Regulation No. 54).
  • In case of liquidation of damming or lowering the water level up to the level that does not require permit for the special use of water, the owner or possessor of the dam shall submit an application for registering activities involving risk to aquatic environment to the Environmental Board.
  • The person planning damming must avoid violating the rights of other water users and landowners and avoid causing damage to public health, nature and industrial facilities as a result of water use, and therefore, the owner or possessor of the dam is obliged to be prepared to ensure the safe passage of high water from the dam during the period of spring/autumn high water, extraordinary rains, etc. (§117 (2) of VeeS)
  • The owner or possessor of the dam is required to ensure a good technical condition of the dam and its maintenance when necessary (§174 (5) 1) of VeeS).

Protection of water bodies and groundwater against pollution, littering and depletion

  • Obligations to prevent harmful effect of water, pollution and depletion of water are provided for in §116-117 of VeeS.
  • The requirements for the prevention and reduction of load and pollution caused by hazardous substances and other pollutants are provided for in §125 of VeeS.
  • The requirements for the protection of catchment areas against pollution from agricultural production are provided for in §158-163 of VeeS.
  • The requirements for storage of manure and liquid manure are provided for in V§164 of VeeS. The specified requirements for the use and storage of fertilisers, in order to protect groundwater and surface water and prevent and limit contamination arising from agricultural production are established by Regulation No 45 of the Minister of the Environment.
  • The requirements for the protection of catchment areas against agricultural pollution in nitrate sensitive areas are established by §168 of VeeS. 

Water protection requirements for sewerage facilities

Water protection requirements for sewerage facilities are established by §133-137 of VeeS. The specified requirements for sewerage facilities are established in Regulation No. 31 of the Minister of the Environment. 

The most important requirements are:

  • If the cleaning process of a small (50-1999 ie) or a large treatment facility (starting from 2000 ie) ceases, the issuer of an environmental protection permit and an environmental supervision authority must be immediately notified, and within one day also in writing (Regulation No 31, §20).
  • A possessor of a small and large treatment facility is obliged to keep a maintenance record of the waste water treatment plant (Regulation No. 31, §22).
  • A large treatment facility must have volumetric flow rate meter and other measuring instruments necessary for monitoring and controlling the cleaning process and the possibility of automatic sampling (Regulation No. 31, §19 (2));
  • Sewerage systems must be periodically maintained in order to ensure the proper functioning of the systems, including the banks of bioponds should be mowed and free of brush (Regulation No 31, §18)
  • Inspection of the condition of the sewerage facility (incl. an overview of the condition of bioponds if the bioponds are part of the cleaning system) must be carried out at least once every five years, and an an act must be drawn up, which the possessor maintains for at least 10 years (Regulation No 31, § 23)
  • Small and large treatment facilities must be surrounded by a fence which must have information of the holder and operator of the waste water treatment plant with the name and contact details on it (Regulation No 31, §17). 
  • Water protection requirements for storage facilities for oil products, shale oil, shale oil products or biofuels are provided for in §138-142 of VeeS. 
  • The requirements for planning, construction and use of storage facility for oil products, shale oil, shale oil products or biofuel and the specified extents of the clearance are established in Regulation No. 42 of the Minister of the Environment. 

Restrictions in sanitary protection zone of water intake

Restrictions in sanitary protection zone of water intake are provided for in Chapter 6 of Section 6 of VeeS. The most important requirements are:

Economic activities are prohibited in the sanitary protection zone of water intake, except:

  1. Construction, servicing and use of the water intake
  2. Maintenance of the sanitary protection zone
  3. Forest maintenance
  4. Mowing grasses and cleaning up or removal of grass after mowing
  5. Use of lawfully constructed construction works and other activities related to the construction works in the planned manner unless the construction works cause deterioration of the quality of water
  6. Carrying out research.
  • The owner or possessor of the sanitary protection zone of a surface water intake may allow persons to enter the sanitary protection zone of the water intake for the purposes of recreation and environmental education on a temporary and restricted basis if the protection of the water intake and water is ensured. Said activities are not permitted without the consent of the water undertaking administering the sanitary protection zone of surface water.
  • The owner (possessor) of the well is responsible for the sanitary condition of the well and its surroundings.

Water protection requirements regulated by regulations

  • Requirements for wastewater treatment and discharge of wastewater, storm water, mining water, quarry and cooling water into recipient, compliance assessment measures and limit values for the concentrations of pollutants (Regulation No 61).
  • Specified requirements for damming a water body, liquidation of damming and lowering of water level as well as the methods for determining the environmental flow (Regulation No 54). 
  • List of groundwater bodies and procedures for their identification, status classes and their designation, values ​​of quality indicators for chemical status and conditions for quantitative status, list of pollutants endangering groundwater, threshold values ​​for their content by groundwater and quality limit values ​​for groundwater and background level (Regulation No 48).
  • The requirements for the use and storage of fertilisers, in order to protect groundwater and surface water and prevent and limit contamination arising from agricultural production (Regulation No 45).
  • The quality standards and requirements for the use of sewage sludge in the creation of green areas, recultivation and agriculture (Regulation No 29).
  • The requirements for construction and use of a storage facility for oil products, shale oil, shale oil products or biofuel and the specified extent of the clearance of the storage facility (Regulation No 42).
  • The list of priority substances and priority hazardous substances, the environmental quality standards of priority substances, priority hazardous substances and certain other pollutants, and methods for application of quality standards, the quality standards of river basin specific pollutants and the activities associated with the watch list of substances (Regulation No 28).
  • The requirements for the planning, construction and use of a sewerage facility and the specified extent of the clearance of the sewerage facility (Regulation No 31).
  • The list of the data to be set out in a spreading plan for liquid manure and the procedure for submission and processing of the spreading plan and the list of the data to be set out in a fertilisation plan and the procedure for keeping the fertilisation plan (Regulation No. 59).
  • The water protection requirements for aquaculture as well as the limit values for pollutant concentration of effluent water from aquaculture and the requirements for discharge of such water into a recipient and monitoring thereof (Regulation No 17).
  • Requirements for the construction of a dug well, the construction design and construction and demolition and reconstruction of a drilled well or a borehole, the procedure for the design, construction, commissioning, reconstruction, demolition and conservation of a drilled well or a borehole and formats for approval of the location of a drilled well or a borehole, applications for building permit and permit for use, notification of construction or use, drilling log, notification of construction or use of a dug well, submission of data of a drilled well or a borehole and dug well to the Environmental Register and notification of demolition of a drilled well or a borehole and a dug well (Regulation No 43)
  • An environmental permit must be applied for before a building permit, if it is a new stationary emission source (§79 (6) of AÕKS).
  • The best available techniques, energy efficient technology, environmentally friendly sources of energy and abatement equipment to reduce emissions of pollutants. If abatement of pollutants is prescribed by the air pollution permit, working without abatement equipment or with defective abatement equipment is prohibited. The start-up and shut-down periods must be kept as short as possible in operation of combustion plants (§29,§101 (1) 21) of AÕKS).
  • The efficiency of the equipment installed for abatement of pollutants must be regularly checked and documented records of the checks must be kept (§101 (1) 4) of AÕKS).
  • Assess at least once per year the compliance of air quality with the air quality limit values or target values established for pollutants on the basis of AÕKS outside the production area of the installation if the emissions of pollutants released from the emission source are likely to cause an exceedance of the upper assessment threshold of air quality established on the basis AÕKS in the air quality zone or agglomeration. This assessment may include measurements and/or calculations (§ 101 (1) 6) of AÕKS).
  • the Environmental Board must be informed of significant environmental disturbance relating to the activity of the operator regardless of whether the requirements provided for in the permit are complied with. The Environmental Board, the local government and the Health Board must be immediately informed of the accidents in case of which environmental impact is not excluded. The accident must be registered and its duration recorded (§101 (1) 7) of AÕKS).
  • To render all necessary assistance to the Environmental Board upon assessment of compliance with the requirements and enable carrying out of checks for sampling or collection of other relevant information and submit without undue delay the information required for environmental inspection (§101 (1) 8) of AÕKS, §102 (4) of AÕKS).
  • All the documentation and information concerning the application for an air pollution permit, issue and amendment thereof, monitoring prescribed thereby, inspection of compliance with the requirements, possible non-compliance and measures taken for restoration of compliance with the requirements must be preserved during the term of validity and at least six years after revocation of the air pollution permit. They shall be accessible at the request of the Environmental Board (§102 (1-2) of AÕKS).
  • The Environmental Board and the local government must be informed in advance of all intended modifications to the production technology or parameters of the emission sources which may cause the emissions of pollutants to exceed the provisions of the environmental permit or integrated environmental permit or the dispersion conditions of the pollutants in the ambient air to deteriorate significantly (§101 (1) 3) of AÕKS).
  • The limit value of emissions from an emission source outside the scope of application of the Industrial Emissions Act must not be exceeded. The limit values established for so-called medium-power combustion plants, the requirements for monitoring the emissions of pollutants and the criteria for adherence to the limit values of emissions have been established by Regulation No. 44 of the Minister of the Environment of 5.11.2017 (§105 (1) and (3) of AÕKS).

Ambient air protection requirements for the users of organic solvents

  • Paints and varnishes containing volatile organic compounds, which do not comply with the limit values for the content of volatile organic compounds, established by Regulation KEM No 36, shall not be used as coating materials for buildings.
  • Refinishing materials that do not meet the limit values for volatile organic compounds set by KEM No 36, shall not be used to cover vehicles or their parts outside production installations. (§113 (1) of AÕKS).

Requirements for installations using organic solvents in the areas of activity specified in § 113 of THS.

  • Measures must be taken to ensure that the limit values for volatile organic compounds of outgoing gas are met or compliance with the requirements arising from the volatile organic compounds emissions reduction scheme prepared on the basis of §139 of the Industrial Emissions Act (THS) (§136 of THS).
  • Substances or mixtures which are classified as carcinogens, mutagens or toxic to reproduction shall be substituted as soon as possible and to the maximum volume possible by less hazardous substances or mixtures as much as possible. (§140 of THS).
  • Controlled conditions are implemented to prevent the release into the environment of volatile organohalogen compounds carrying the risk phrase R40 or R68 or the hazard statement H341 or H351 and of the volatile organic compounds carrying the hazard statements or risk phrases referred to in §140 of THS as much as possible (§141 of THS).
  • Measures shall be taken in order to minimize the emissions of volatile organic compounds during an installation start-up and shut-down. (§143 of THS).
  • At each request of the Environmental Board, data must be submitted so that the compliance of the concentration of pollutants with the established limit values and/or the requirements of the volatile organic compounds emissions reduction scheme (exceptions of emissions limit values in §137 (2) of THS) (§145 (2) of THS) can be assessed.

Ambient air protection requirements for filling stations and terminals

When handling petrol at terminals and service stations (i.e. filling stations), the terms and conditions of KEM No. 85 must be met, which include the following requirements: 

  • Storage installations of terminals must comply with the requirements set out in Annex 1 of Regulation No 85 of KeM and loading and unloading equipment with requirements in Annex 2.
  • The concentration of petrol vapours at the exit of a regeneration unit of the terminal shall not exceed the limit established in Regulation No. 85 of KeM and it must be checked with control measurements in compliance with the Regulation.
  • Mobile containers supplying petrol to the service stations must be capable of receiving and storing evaporation residues generated in the containers of filling stations, which are stored until the last reloading at the terminal.
  • When loading petrol into storage installations at filling stations and in tanks used for the intermediate storage of vapours, vapour is returned through a vapour-tight connection line to the mobile container delivering the petrol (e.g. road tanker). If the equipment has not been installed or it is not functioning properly, loading must not be carried out. 
  • Petrol vapour recovery system means equipment aimed at recovering the petrol vapour displaced from the fuel tank of a motor vehicle during refuelling at a filling station and which transfers that petrol vapour to a storage tank at the filling station or back to the petrol dispenser selling the petrol, and it must comply with the requirements set out in Regulation No 85 of KeM and it must be periodically inspected.
  • Petrol vapour recovery system must be installed in:
  • New filling stations 
  • An existing filling station (which has been built or granted a design, construction or activity licence on or after 1 January 2012), which is undergoing significant renovations
  • Any existing filling station with a capacity of more than 3,000 m3 per year by 31 December 2018 at the latest. 

Requirements for air measurements and computational assessment of air quality

  • Measurements (including noise level measurements) must be proved and carried out by a competent measurer. This means that measuring can be carried out by an accredited laboratory, which must ensure the representability of the measurements (§61 (2-3) of AÕKS, §102 (5) of AÕKS, Metrology Act (MõõteS)).
  • If the air pollution permit establishes the obligation of continuous monitoring of a pollutant, the operator will forward the data of continuous monitoring to the database of air quality assessment in real time (§102 (5) of AÕKS).
  • When measuring emissions, the requirements of §106, §107 (2) of AÕKS and Chapter 4 of Regulation No. 84 of KEM must be observed.
  • In case of determination or specification of emissions by measuring, the regulation of the Minister of the Environment reflecting the determination of the corresponding emission must be followed:
  • Regulation No. 59 of the Minister of the Environment of 24.11.2016
  • Regulation No. 66 of the Minister of the Environment of 14.12.2016
  • Regulation No. 31 of the Minister of the Environment of 01.06.2020
  • In addition, relevant implementing provisions established pursuant to THS on emissions monitoring (in certain cases also the limit values) or Annex 3 of KEM No. 44 must be complied with in case of emissions monitoring of pollutants of respective installations.
  • Air quality measurements must comply with the requirements of §43 (3) and (4) of AÕKS and Chapters 2 and 4 of KEM 84.
  • If air quality is calculated, the requirements set out in §43 (4) of AÕKS and Chapter 5 of KEM No. 84 must be taken into account.
  • In case of doubts, it is recommended to ask for the opinion of the Environmental Board before ordering measuring, to specify the requirements and conditions. Read more: Meelespea välisõhu valdkonna mõõtmiste teostajatele (PDF) (Reminder for people carrying out measuring of ambient air area).
  • The list of accredited laboratories can be found on the website of the Estonian Accreditation Centre under the test laboratories section.

Requirements for operators in the EU greenhouse gas emission trading system

  • An operator of a stationary emission source shall submit to the Environmental Board an updated monitoring plan before any significant changes in the monitoring methods used. (§166 (4) of AÕKS).
  • An operator of a stationary emission source shall check on regular basis whether the monitoring methods used by the operator can be improved and submit a relevant report to the Environmental Board for approval pursuant to Article 69 of European Commission Regulation (EU) No. 601/2012 (§166 (3) of AÕKS).
  • By 25 March each year, the operator of a stationary emission source organises the certification of emissions of the previous calendar year in the trading register (§166 (7) of AÕKS).
  • An operator of a stationary emission source surrenders in the trading registry by 30 April each year the quantity of emission allowances pursuant to the report for the preceding calendar year (§168 (1) of AÕKS).
  • If the activity is terminated before the expiry of the permit, the issuer of the permit must be informed of this.
  • The activities and methods used in waste handling must not endanger health, property or the environment.
  • The waste handling must implement all the necessary measures to avoid or reduce as much as possible the environmental nuisances caused by waste and the harmful impact of the waste on the environment, including landscapes and sites of special interest, and the human health (§29 (1) of JäätS).
  • Avoid rise of excessive harmful influences such as noise and odour. The activity must comply with the Regulation SOM No. 42 on standard noise levels. 

Requirements and principles of waste management

The following waste hierarchy shall apply as a priority order in prevention of waste generation and in development and implementation of measures for waste handling:

  • Prevention of waste generation
  • Preparing for re-use
  • Recycling
  • Other recovery, e.g. energy recovery
  • Disposal.

The waste hierarchy may be departed from if this ensures the best overall environmental result taking account of the whole life-cycle of a substance, material or product (§ 22¹ of JäätS).

  • The best available techniques must be used (§ 29 (3) JäätS, which refers to §8 of THS).
  • All the waste stored at the facility is treated or recovered within three years or is disposed of within one year after being stored (§34 (3) 2)-3) of JäätS).
  • A waste handler is required to handle the waste in the possession thereof according to the established requirements or transfer the waste for handling to a person holding the right for receiving waste.
  • Waste holders must have adequate information concerning the types, quantities and origin of the waste in their possession, concerning its properties relevant in terms of waste management and concerning the hazards resulting from the waste to health, the environment or property (§28 (1-1¹) of JäätS).
  • Waste handler is required to have regular records of the type, quantity, properties and origin of the waste generated, collected, stored or temporarily stored, transported, treated, recovered or disposed of in the course of their activities. If waste is transferred to other waste handlers, records shall also be kept of the destination, frequency of collection, modes of transport of and recovery and disposal operations regarding the waste (§116 (2) of JäätS).

Handling of hazardous waste

  • A person who wishes to handle hazardous waste must comply not only with the general obligations related to waste management, but also with the specific requirements for the handling of hazardous waste.

Mixing of hazardous waste

  • Mixing of hazardous waste with other types of hazardous waste, non-hazardous waste or any other substances or materials is not permitted, except in the case provided for in §61 of JäätS.
  • Waste which has already been mixed shall be separated if this is technically feasible and does not entail excessive costs or if this is necessary for the prevention of potential health or environmental hazards.
  • Mixing of hazardous waste with other types of hazardous waste or with non-hazardous waste or any other substances or materials is permitted if the provisions of §29 (1) and (2) of JäätS are complied with in order to prevent or, if prevention is not possible, reduce the health or environmental hazards resulting from the waste and if mixing is technologically and economically justified.
  • Hazardous waste shall not be mixed for the purpose of reclassification of hazardous waste into non-hazardous waste by way of diluting and thereby reducing the original content of hazardous waste below the limit value for classification as hazardous waste. (§60-61 of JäätS).

Packaging of hazardous waste

  • In the course of collection, temporary storage and transport of hazardous waste, the waste shall be packaged in order to prevent the health and the environmental hazards resulting from the waste and facilitate their recovery or disposal.
  • A waste handler is required to label hazardous waste, except the hazardous waste produced by households, or their packaging before the waste is transferred to the waste handler (§62 (1-2) of JäätS).
  • The procedure for labelling hazardous waste and packaging of hazardous waste.

Transport of hazardous waste

Waste oil

Handling of metal waste

  • A person who wishes to handle metal waste must comply not only with the general obligations related to waste management, but also with the specific requirements for the handling of metal waste.
  • It is prohibited to buy up metal objects as waste if the objects are of obvious artistic or historical value.
  • Electrical wires and cable may be bought up as waste only from network operators holding legal market licences, telecommunications network operators holding activity licences or undertakings holding waste permits whose lawful activities produced the waste.
  • Traffic signs and road signs, metal covers of underground utilities and railroad rails may be bought up as waste only from undertakings holding activity licences for road management work, railway infrastructure managers or undertakings holding waste permits whose lawful activities result in the production of such waste.
  • Motor vehicles or essential parts thereof may be bought up from persons as waste only on the basis of a certificate concerning the deletion of the vehicle from the register issued by the Estonian Road Administration or a person authorised thereby or from undertakings holding waste permits whose lawful activities result in the production of such waste (§105 (1-4) of JäätS).
  •  A person who for the purpose of further commercial distribution and recovery collects and transports waste metal produced and transferred by other persons (hereinafter collector of waste metal) and the person transferring the waste metal shall prepare a document concerning the buying up of the waste metal which shall be signed by both parties and, in addition to other requisite information provided by legislation, shall set out: (§ 106 (1) of JäätS)

 1) The registry code or personal identification code and residence or seat of the person transferring the waste metal
 2) A brief description of the waste metal, the type and amount thereof and, in the case of a motor vehicle, also the type, mark, chassis number and colour thereof
 3) The registration number of the vehicle used for delivering the waste metal
 4) The value of the waste metal.

  • Cash settlement upon the buying-up and further distribution of waste metal is prohibited. Upon the buying-up of waste metal and commercial distribution of bought-up waste metal, the waste metal shall be paid for by way of a non-cash settlement in the form of a transfer from the bank account of the buyer to the bank account of the seller (§107 of JäätS).

Requirements for handling products of concern (incl. batteries, accumulators, motor vehicles, electrical and electronic equipment, tyres) regulated by regulations

Requirements for waste management regulated by regulations

  • Prior to the commencement of extraction, the holder of the permit must, upon obtaining an environmental permit, obtain the right to use state-owned property for the extraction of mineral resources on state-owned property (§90 of the Earth’s Crust Act (MaaPS)). Before that, no preparatory activities for mining in the mining claim and its service plot are not allowed.
  • If the type of the intended purpose of the land does not correspond to the activities planned by the extraction permit of mineral resources in the area of the mining claim applied for, an application must be submitted to the local government for changing the intended purpose of the land to mining or peat industrial land respectively.
  • If necessary, the issues related to the use of transport routes of the extracted material must be resolved.
  • An environmental permit does not grant the right to build on the mine service plot and outside the mining claim. Construction must be based on the Construction Code. The consent of the Ministry of the Environment is required for building on or in mineral reserve (§14 (2) of MaaPS).
  • The consent of the Environmental Board is required for the use and transfer of extracted mineral matter left over when erecting a building (incl. for compliance with the soil protection requirements and for construction of ditches, settlement tanks and roads) (§96 of MaaPS).
  • Safety in the extraction area (incl. marking the site) must be ensured.
  • Depending on the volume mined, instrumental surveying must be carried out and declarations submitted on the basis of surveying must be corrected. The frequency of instrumental surveying is: more than 200,000 tonnes/cubic metres (hereinafter unit) – quarterly; 50,000 to 200,000 units - once a year; 10,000 to 50,000 units - once every 2 years; less than 10,000 units - once every 3 years.
  • The amount of extracted, used or unusable peat supply must be surveyed and calculated once during the period of validity of the environmental permit. Instrumental surveying must be carried out three years before the expiry of the permit.
  • To submit a report on land disturbed by extraction and its reclamation on the basis of the mine survey measurement data during the quarter following the quarter of carrying out mine survey measurement together with the report on the volume of extraction.(§82 of MaaPS).
  • The mine survey measurement documentation for and the calculation of the residual amount of peat appended to an application for extension of validity of a peat extraction permit cannot be compiled earlier than three years before submission of the application for extension of validity of the permit.
  • Reclamation of the land where extraction has been carried out should be started as soon as possible. The first step is to ask the Environmental Board about the conditions for reclamation, then a reclamation project should be prepared and the necessary works on the basis thereof should be carried out (§81 of MaaPS).
  • The volumes of the transfer or the use of overburden outside the mining claim must be indicated by the mining company in the declarations to be submitted at the end of the quarter. A separate permit for this is not required from the Environmental Board as of 1 January 2020. 
  • In order to change the holder of the permit, a corresponding application must be submitted (§66 of MaaPS).
  • An application for extension of validity of an environmental permit shall be submitted at least one year prior to the expiry of the permit. If an environmental impact assessment needs to be made in connection with the planned operations, the application for extension of validity of a permit should be submitted at least two years prior to the expiry of the permit. (§67 (5) of MaaPS).
  • The latest mine survey measurement documentation together with a calculation of the residual amount of the mineral resources shall be appended to an application for extension of validity of an environmental permit. The mine survey measurement documentation for and the calculation of the residual amount of peat appended to an application for extension of validity of a peat extraction permit cannot be compiled earlier than three years before submission of the application for extension of validity of the permit (§67 of MaaPS).
  • Upon reregistration of an environmental permit, the agreement on assignment of the mining right, the calculation of the residual amount of mineral resources within the boundaries of the mining claim determined by the reregistered extraction permit and the mine survey measurement documentation. Residual amount is calculated on the basis of the results of mine survey measurement as at the end of the quarter preceding the day of submitting the application for reregistration. The residual amount of peat is calculated on the basis of the estimated amount of extracted peat supply, which is determined on the basis of the information concerning extraction, production or inventory or the results of measuring stacks. (§73 of MaaPS)

Termination of mining

  • Mining claim and the mine service plot must be reclaimed during the term of validity of the permit.
  • Reclamation conditions should be obtained from the Environmental Board. 
  • A reclamation project must be drawn up on the basis of the reclamation conditions.
  • In order to implement the reclamation project, consent of the Environmental Board must be received.
  • Report on land disturbed by extraction and its reclamation should be submitted to the issuer of an environmental permit on the basis of the mine survey measurement data (§ 80-81 of MaaPS).
  • Radiation safety principles must be followed.
  • Ensure radiation safety and physical protection of the radiation sources in the holder’s possession and verify at least annually that the radiation source or the equipment containing thereof is present at the place of use or storage and in apparently good condition.
  • Ensure the safety of the radiation source by correct installation and placement of the radiation source in the premises, mark the radiation source and the premises and use protective equipment.
  • Ensure monitoring of control and surveillance areas.
  • Keep records of every radiation source and radioactive waste for which the holder is responsible, the location and transfer thereof, take annual inventories of radiation sources and radioactive waste.
  • Ensure that exposed workers receive radiation safety training and instructions which take into account the nature of work and the conditions at workplace.
  • Prepare the rules necessary for carrying out radiation works and instructing exposed workers and ensure updating of these rules upon commissioning of new technology or equipment.
  • Organise medical examination of exposed workers and ensure medical examination of category A exposed workers at least once a year.
  • Organise monitoring of individual doses incurred by exposed workers and submission of monitoring data to a dose register.
  • Ensure regular control and calibration of measuring instruments used and be responsible for their fitness for use and professional use thereof.
  • At the request of competent authorities, prove the legality of possession of radioactive substances or radiation apparatuses containing radioactive substances.
  • Ascertain that the recipient has an appropriate radiation practice licence before transfer of radiation sources
  • Recover radiation sources after the use thereof is terminated pursuant to the recovery plan submitted in the application for the licence.
  • Ensure that radioactive waste is managed in such a manner that the estimated harmful effect on future generations will not exceed the effect permitted by the Radiation Act (KiS) or legislation established on the basis thereof.
  • Cover all expenses incurred in radioactive waste management.
  • Ensure that the activity and quantities of generated radioactive waste and emissions are as low as possible.
  • Alleviate the consequences of emergency exposure situations.
  • Immediately inform the Environmental Board and the Emergency Centre of loss, theft or unauthorised use of radiation sources and of any incidents or accidents which took place during radiation practices and resulted in unintentional exposure of workers or members of the public.
  • Control the integrity of radiation sources after each incident if it may have damaged the radiation source and, if necessary, inform the Environmental Board of this incident and the measures implemented.
  • During procurement procedures for radiation sources, prefer manufacturers who agree to include a clause in the contract of sale regarding return of the radiation source to the producer.
  • Ensure sufficient funds to cover the expenses of recovering radioactive substances, radiation sources containing radioactive substances and radioactive waste.
  • Upon high risk radiation practices, prepare a response plan to emergency exposure situations and ensure that a recognized radiation expert has approved the design documentation of the facilities of radiation practices and the commissioning of new radiation sources.

Additional obligations of holders of radiation practice licences in case of activities related to high-activity radiation sources (§38 of KiS)

  • Ensure that written information is included with the radiation source which proves that the radiation source is identified by a unique number and includes photos of the source, container, transport packaging of the source and, if necessary, devices and equipment.
  • Ensure that proper tests have been performed with the frequency determined by the issuer of the licence in order to check and maintain the integrity of the radiation source.
  • Return every disused source immediately after discontinuing the use thereof to the manufacturer, transfer it to another holder of a radiation practice licence or to a radioactive waste management facility.
  • Enter into a contract with manufacturer upon purchase of a radiation source according to which the manufacturer undertakes to take back the radiation source at the latest 15 years after the importation of the source if the activity of the source exceeds 10 MBq ten years after the importation thereof into the country.

Additional obligations of holders of radiation practice licences in case of activities related to radioactive waste management (§39 of KiS).

  • Ensure safety of the radioactive waste storage premises during the entire of use thereof.
  • Organise the management of radioactive waste if this is necessary for modifying the properties of the radioactive waste prior to the release thereof into the environment, or the conditioning and intermediate storage and final disposal thereof.
  • Take into account other risks and various stages of generating radioactive waste and interaction of radioactive waste when planning activities and in the course of activities.
  • Transfer radioactive waste to a final disposal facility for radioactive waste within five years from the generation thereof.

Additional obligations of holders of radiation practice licences when carrying out medical radiological procedure (§42 (1) and (3) of KiS)

  • Procedures must be carried out in a justifiable and optimised manner, including ensuring that only the necessary amount of radiation is administered to the designated parts of the body and that the amount of radioactive substance administered to the patient is correct.
  • Patients must be informed of any risks of ionizing radiation.
  • It is necessary to find out, on the basis of the information available to the health care service provider, data of previous medical radiological procedures performed on the patient.
  • Ensure the safety of the radiation source and working order of protective systems.

Obligation to notify of changes in radiation practices (§78 (1)of KiS)

  • A holder of a radiation practice licence gives prior notice to the issuer of the licence if the holder intends to:
  • Commission new or additional radiation sources.
  • Terminate the use of the radiation source indicated in the radiation practice licence.
  • Deliver the radiation source to another person or dispose of it as radioactive waste.
  • Change the radiation practice, method of management, maximum quantities or storage facilities of produced radioactive waste determined in the radiation practice licence.
  • Change the location, facilities or premises where the radiation practice is carried out.
  • Employ a new radiation safety specialist.
  • Significantly change the radiation practice described in the licence in any other manner.

Requirements for radiation practices

Obligations of operators in case of accidents and incidents

In case of an accident or incident, which is likely to bring about significant adverse impact on the environment, human health, well-being, property and cultural heritage, an operator shall:

  • Take immediate measures to limit the consequences of accidents and incidents to the environment and prevent possible further accidents and incidents
  • Immediately inform the Environmental Board of the measures taken (§17 of THS).

Obligations of operator in case of non-compliance

In case of the requirements set out in the permit, an operator shall:

  • Immediately inform the Environmental Inspectorate and the Environmental Board thereof
  • Immediately take measures to ensure compliance of the activities of the operator with the permit requirements as soon as possible
  • Immediately inform the Environmental Inspectorate and the Environmental Board of the measures taken after the implementation thereof (§18 of THS).

General principles governing use of installations

An operator shall adhere to the following principles when using an installation required to hold an integrated permit:

  • Take appropriate preventive measures to prevent contamination.
  • In the event of contamination, immediately liquidate the contamination within the limits of its technical or economic possibilities, regardless of whether the contamination was intentional or was caused by negligence.
  • Use the best available techniques in an installation.
  • Avoid generation of waste, if possible.
  • In the event of waste generation, be guided by the waste hierarchy provided for in §221 of the Waste Act upon handling thereof.
  • Use energy as efficiently as possible in an installation.
  • Ensure that necessary measures are taken to prevent accidents and limit the consequences of accidents.
  • Take measures upon cessation of the operation of an installation which are required for avoiding any risk of contamination and return the site of the installation to a satisfactory environmental state in accordance with the requirements of §58 of THS.
  • If an operator fails to comply with the obligation to liquidate contamination, the Environmental Board shall organise the liquidation pursuant to the procedure provided for in the Substitutional Performance and Non-Compliance Levies Act (§ 26 of THS).

Requirements for self-monitoring of installations

  • Regular self-monitoring of groundwater contamination shall be carried out at least once every five years.
  • Regular self-monitoring of soil contamination shall be carried out at least once every ten years.
  • Monitoring of groundwater and soil do not apply in the case the monitoring is based on a systematic appraisal of the risk of pollution. (§47 of THS)

Change in nature and functioning of installation

  • An operator shall notify the issuer of permits of every change in the nature or functioning of an installation, including an extension of the installation, which might affect the environment or human health. The issuer of permits shall determine the significance of the changes within 21 days and, if necessary, initiate the procedure for issue or conversion of an integrated permit.
  • Any change in the nature or functioning of an installation, including an extension of the installation may be implemented only after the issuer of permits has informed the operator in writing that amendment of the requirements of the integrated permit is not required for implementation thereof or if the requirements of the integrated permit have already been converted. (§56 of THS).

Duty to preserve documentation and submit information

  • An operator shall preserve all the documentation and information belonging to the operator concerning the application for an integrated permit, issue of the permit, monitoring prescribed by the permit and inspection of compliance with the requirements during the term of validity and at least five years after the revocation of the integrated permit.
  • The documents shall be accessible at the request of the issuer of permit and Environmental Inspectorate.

An operator shall provide the issuer of permits with:

  • Information obtained in the process of monitoring prescribed by the integrated permit, in compliance with the requirements of the integrated permit
  • information concerning the proposed change of operator.
  • An operator is required to submit, at the request thereof, to the issuer of the permit the information required for issue, amendment, revocation of integrated permits and review of the requirements of integrated permits, and the information required for performance of environmental inspections. (§59 of THS).

Requirements for best available techniques

  • The best available techniques conclusions and BAT reference documents are available on the websites of the European Commission and the Ministry of the Environment.
  • The following BAT conclusions have been established by national legislation:

Veiste intensiivkasvatuse Eesti parima võimaliku tehnika juhendi põhjal koostatud PVT-järeldused (PDF) (BAT conclusions prepared based on instructions of the best available techniques for intensive cattle farming in Estonia)

Järeldused Eesti põlevkiviõli tootmise parima võimaliku tehnika kirjelduse põhjal (PDF) (Conclusions based on the description of the best available techniques for shale oil production in Estonia)

Järeldused Eesti põlevkivi energeetilise kasutamise parima võimaliku tehnika kirjelduse põhjal (PDF) (Conclusions based on the description of the best available techniques for energetic use of oil shale in Estonia).

Annual report must be submitted on activities related to waste activities, water use, ambient air pollution activities and greenhouse gas emissions. It is mandatory for all persons who have been granted an environmental protection permit. In addition to the above, a report on greenhouse gas emissions must also be submitted.

The annual reports collect necessary environmental information nationwide. On the basis of the collected data, an overview of the environmental state of Estonia is prepared and international and national reports and information materials are prepared.

As from 2020, all environmental reporting is carried out in the information system of environmental decisions called KOTKAS of (excl. emissions of greenhouse gases.)

Last updated: 01.12.2022

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