Estonia

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Progress overview

Current status

Directive (EU) 2024/825 has been partially transposed into Estonian law. The Act Amending the Consumer Protection Act and the Explosives Act was adopted on 17 June 2026 and published in the Riigi Teataja on 3 July 2026 (RT I, 03.07.2026, 19). The relevant amendments addressing greenwashing and unfair commercial practices entered into force on 27 September 2026. The remaining consumer information requirements are being addressed through the Bill Amending the Law of Obligations Act (Bill 895 SE), which remains under parliamentary consideration. Estonia therefore did not complete transposition by the deadline of 27 March 2026.

Next steps

The parliamentary proceedings concerning Bill 895 SE remain ongoing. In its amendment proposals dated 28 September 2026, the Ministry of Justice and Digital Affairs proposed that the amendments enter into force on 1 February 2027. This date remains subject to adoption. For the rules already in force, § 77² of the Consumer Protection Act provides a transitional arrangement for goods and packaging manufactured before 27 September 2026. Manufacturers or traders may use a clear and unambiguous corrective marking to comply with the specific requirements listed in that provision for one year from 27 September 2026, provided that the marking is not misleading.

Documentation

  • Amending the Consumer Protection Act and the Explosives Act (RT I, 03.07.2026, 19);
  • Consolidated Consumer Protection Act, including the amendments applicable from 27 September 2026;
  • Legislative proceedings and supporting materials for Bill 779 SE;
  • Legislative materials for Bill 895 SE.

Additional information

The Consumer Protection Act amendments introduce definitions including “environmental claim”, “generic environmental claim”, “sustainability label”, “certification scheme” and “software update”, and strengthen the rules on unfair commercial practices. The list of practices considered misleading in all circumstances now includes generic environmental claims without demonstrated recognised excellent environmental performance relevant to the claim, certain misleading practices concerning software updates, and claims based on greenhouse gas emission offsetting that goods have a neutral, reduced or positive environmental impact in terms of greenhouse gas emissions. Separately, the amendments strengthen the rules governing claims about future environmental performance. These require clear, objective, publicly available and verifiable commitments set out in an implementation plan, with measurable and time-bound targets and regular verification by an independent third-party expert whose findings are available to consumers. During the legislative process, the term “administrative authority” was replaced with “public sector authority” in the provision concerning sustainability labels to reflect the broader scope of “public authority” in the Directive.

Key contact

erika tuvike

Erika Tuvike Associate E: erika.tuvike@eversheds-sutherland.ee

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