Tallinn, 30 June 2025 — The market for collection and recycling of packaging waste without deposit in Estonia is facing significant systemic challenges, according to a brief analysis released by the Estonian Competition Authority. The report highlights multiple barriers to competition and calls for urgent reforms as part of the ongoing waste reform process.
Kristin Truus, a lawyer with the Competition Authority, explained that 96% of packaging producers have transferred their extended producer responsibility to recycling organizations (TKO). This concentration has contributed to obstacles for new waste management companies attempting to enter the market and access packaging waste streams.
The analysis identified several critical issues, including:
- Restricted market entry and limited access to packaging waste for new competitors
- Low competition and transparency in procurement processes, with a tendency to favor waste managers legally linked to the procuring entities
- Risks of vertical integration and conflicts of interest arising from close legal and economic ties between waste managers and companies
- Concentration of waste transport rights largely in the hands of a single waste transporter, creating further competition concerns
- Insufficient availability and traceability of waste data, along with opaque distribution of packaging waste among waste management companies
“These findings reveal structural problems that hinder a fair and competitive environment in the packaging waste sector,” said Truus. “Addressing these issues is essential to fostering transparency, enhancing competition, and improving the overall efficiency of Estonia’s waste management system.”
The Authority has proposed several recommendations to reduce entry barriers, increase transparency in selecting waste handlers, and ensure independence and accountability of waste management companies. Additionally, the Competition Authority has urged legislative amendments to the Packaging Act within the broader waste reform framework to support these goals.
The report also notes that possible unequal treatment of waste management companies by the dominant waste carrier has triggered a state supervision procedure to investigate potential abuse of market power.
The Competition Authority’s analysis, conducted in the first half of 2025, aims to guide policymakers and stakeholders toward a more competitive, transparent, and sustainable packaging waste collection system.
The full report is available on the Estonian Competition Authority’s website.
