Riigikogu Adopts Amendments to Accelerate Environmental Permit Processes
On June 18, the Riigikogu adopted amendments to the General Part of the Environmental Code Act, the Waste Act, the Industrial Emissions Act, and other laws to make environmental permitting processes more efficient and faster. Among other changes, the amendments stipulate that environmental permits will no longer be required for minor activities, and in some cases, such activities will not even need to be registered. The amendments will come into force on September 1, 2025.
Updated Procedure for Modifying Environmental Permits
Currently, permit authorities do not have the right to request data from permit holders for modifying permits or to set deadlines and formats for data submission. In the future, if the Environmental Board initiates a permit modification, it will inform the company in writing of the reason and, if necessary, request the required data along with the submission format and deadline. For example, the authority may initiate a modification if new equipment is introduced that makes the activity non-compliant with the existing permit.
If a company plans changes at its facility that would diverge from current permit terms (e.g., installing new equipment), it must, before starting the activity, submit a modification request through the environmental decision information system KOTKAS. Currently, this obligation does not exist for permit holders.
The Environmental Board currently cannot suspend a permit, but in the future, it will have the right to fully or partially suspend a permit for up to one year if the company fails to submit a proper modification application or necessary data, and the activity no longer complies with the permit terms. If this situation persists for at least two years, the permit may be revoked.
Changes to the Industrial Emissions Act
Plywood production will no longer fall under the list of activities requiring an integrated permit, as EU industrial emissions directives do not mandate stricter requirements for this sector.
Currently, companies can voluntarily hold an integrated permit even if they don’t exceed threshold levels. In the future, if a facility’s operations do not exceed these thresholds, the permit must be converted to an environmental permit for those areas where thresholds are met. Since integrated permits impose more obligations than environmental permits, this change will reduce the administrative burden for businesses. The Environmental Board will also gain the authority to reclassify permits if it determines, for example through inspection, that the activity no longer exceeds the thresholds.
The statute of limitations for violations related to integrated permit obligations will be extended from two years to five. Additionally, a new fine of up to €200,000 is introduced for failure to properly notify of planned changes or expansions, and the maximum coercive penalty increases from €32,000 to €100,000.
Key Amendments to the Ambient Air Protection Act and Waste Act
The amendment to §91 of the Ambient Air Protection Act will remove the requirement to provide separate data on combustion plants with thermal input less than 1 MWth and the fuel used in them. This data will be included in the facility's total rated thermal input instead.
According to the amended §987 of the Waste Act, legal entities will no longer need to register with the Environmental Board for on-site bio-waste recycling if they handle up to one tonne of waste generated from their own activities annually. Instead, they must apply to the local municipality and record the amount in the Waste Holders Register.
Amendments to the Water Act
According to changes to §188 of the Water Act, a water permit will no longer be required for the construction, reconstruction, or demolition of bridges or culverts.
Previously, any aquaculture activity exceeding an annual production growth of one tonne required a water permit. Amendments to §187 of the Water Act clarify that a permit will now be required for fish and other aquatic life farming, as well as algae and shellfish cultivation not located in the sea, if the production increase exceeds one tonne per year. For sea-based algae and shellfish farming, the threshold is more than 100 tonnes per year.
The amendments will enter into force on September 1, 2025.
You can read more about the amendments adopted by the Riigikogu HERE.