Clarification Request

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga. Tundmatu saatja korral palume linke ja faile mitte avada.

To whom it may concern,

I am writing on behalf of VinylPlus, the sustainability commitment of the European PVC value chain. We are currently assessing the legal and practical implications of Tallinn’s ban on PVC advertising materials and would like to better understand how this measure aligns with national and EU internal-market and competitiveness policies:

https://teele.tallinn.ee/documents/139607/view#metadata

https://www.tallinn.ee/en/news/tallinn-becomes-first-european-capital-ban-pvc-advertising-public-space

To ensure our understanding is correct, we would be grateful for clarification on the following points:

1. Municipal competence and business impact
   Does Estonian law permit municipalities to restrict the use of specific, lawfully marketed materials (e.g. PVC) in local advertising infrastructure?
   If so, under which legal basis and with what safeguards to ensure proportionality and to avoid unnecessary barriers for local SMEs (printers, banner producers, installers)?

2. Consistency with national/EU framework
   How does the Ministry view such municipal restrictions in light of Estonia’s national policy on competitiveness, trade, and the EU free movement of goods? Is there any guidance from the Ministry on maintaining a level playing field for businesses across municipalities?

3. Coordination with EU internal-market rules
   From the Ministry’s perspective, what procedures should local authorities follow to ensure compliance with EU internal-market and harmonised-product legislation before introducing such measures?

4. Oversight / supervisory review
   Where stakeholders consider a municipal measure to be ultra vires or economically restrictive, which administrative or coordination mechanisms exist for review (beyond court proceedings)?

5. Next steps and contact point
   Could you please indicate a contact person or department with whom we could follow up for further technical discussion?

Thank you in advance for your guidance.