Monitoring of block-exempted aid measures

Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.

EUROPEAN COMMISSION DG Competition Market and cases I – Energy and Environment State aid II

Brussels, 10/02/2026 COMP.B3/MBL/HA/comp(2026)1626609

Permanent Representation of

Estonia to the EU

Rue Guimard 11/13

1040 Brussels

Subject: Monitoring of block-exempted aid measures

SA.103299 (2025/MX) – Erimärgistatud diislikütuse aktsiisisoodustus

põllumajandussektoris (muutmine)

Dear Madam, dear Sir,

I thank you for the letter dated 26 January 2026 in which your authorities provided

information on the above-mentioned scheme.

On the basis of the information sent by your authorities, DG Competition considers that

the scheme under reference and the individual aid granted by your authorities on the

basis of this scheme are, prima facie, in line with the provisions of the General Block

Exemption Regulation (GBER)1.

At the same time, we would like to draw your authorities' attention to the fact that there is

no reference to any cumulation rules in the legal basis.

Estonia should include all conditions of the scheme in the legal basis. Experience has

shown that a complete national legal basis helps avoiding irregularities and the grant of

unlawful aid. Therefore, Estonia is encouraged to have a complete legal basis in order to

ensure that interested parties have no doubt as to the conditions on which aid can be

granted. We will also remind Estonia that it is the Member State’s responsibility to

ensure that all conditions are complied with.

1 Commission Regulation (EC) No 800/2008 of 6 August 2008 declaring certain categories of aid

compatible with the common market in application of Articles 87 and 88 of the Treaty (now Articles

107 and 108 TFEU) OJ L 214, 9.8.2008, p. 3, as from 1 July 2014 replaced by Commission Regulation

(EU) No 651/2014 of 17 June 2014 declaring certain categories of aid compatible with the internal

market in application of Articles 107 and 108 of the Treaty, OJ L 187, 26.6.2014, p. 1.

2

In particular, we recommend Estonia to expressly include the condition on cumulation in

the legal basis. We would also suggest that the condition on companies in difficulties is

verified by the granting authorities ex post, as well as the condition on cumulation.

In this context, DG Competition has decided not to ask your authorities for any

additional information regarding the above measures.

However, please note that the aid scheme concerned, or its successor may be subject to

subsequent monitoring.

The officials in charge of this file in DG Competition are Hannes Ackert,

[email protected], +32 229-83396, and Magdalena Brenning Louko,

[email protected], +32 229-84051.

Please mention the reference to this case file, as provided in the subject SA.103299

(2025/MX), in any future correspondence.

Yours sincerely,

Peer Ritter

Head of Unit