Clarification request

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 wish to better understand how this measure aligns with national and EU law:

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, may I kindly ask:

1. Municipal competence

Does current 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 limits or conditions (e.g., proportionality, impact assessment, consultation requirements)?

2. Consistency with national/EU framework

How does the Ministry view such municipal restrictions in light of national waste/product legislation and EU internal-market rules (e.g., the free movement of goods, harmonised product law)? Is there any guidance from the Ministry on avoiding fragmentation of rules across municipalities?

3. Procedural safeguards

Are municipalities expected to carry out a written justification (impact or risk assessment) to demonstrate necessity and proportionality before adopting material-specific restrictions? If yes, are there minimum content/consultation standards?

4. Oversight / supervisory review

Where stakeholders consider a municipal measure to be ultra vires or insufficiently justified, which administrative oversight channels exist (e.g., Ministry review, guidance, or referral mechanisms), in addition to court proceedings?

5. Next steps and contact point

Could you indicate a contact person/unit for further technical discussion?

Thank you in advance for your guidance.

Kind regards,