Europaudvalget 2025
KOM (2025) 0420
Offentligt
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EUROPEAN
COMMISSION
Brussels, 7.7.2025
SWD(2025) 319 final
COMMISSION STAFF WORKING DOCUMENT
2025 Environmental Implementation Review
Country Report - THE NETHERLANDS
Accompanying the document
Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions
2025 Environmental Implementation Review for prosperity and security
{COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} -
{SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} -
{SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} -
{SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} -
{SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} -
{SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} -
{SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 320 final} -
{SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} -
{SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}
EN
EN
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Contents
EXECUTIVE SUMMARY ........................................................................................................................................... 2
PART I: THEMATIC AREAS ...................................................................................................................................... 4
1. C
IRCULAR ECONOMY AND WASTE MANAGEMENT
............................................................................................................. 4
Transitioning to a circular economy ..................................................................................................................... 4
Waste management............................................................................................................................................. 6
2. B
IODIVERSITY AND NATURAL CAPITAL
........................................................................................................................... 12
Global and EU biodiversity frameworks ............................................................................................................. 12
Nature protection and restoration
–
Natura 2000 ............................................................................................. 13
Recovery of species ............................................................................................................................................ 14
Recovery of ecosystems ..................................................................................................................................... 16
Prevention and management of invasive alien species ...................................................................................... 22
Ecosystem assessment and accounting ............................................................................................................. 23
3. Z
ERO POLLUTION
..................................................................................................................................................... 26
Clean air ............................................................................................................................................................. 26
Industrial emissions ............................................................................................................................................ 27
Major industrial accidents prevention
–
Seveso ................................................................................................. 29
Mercury Regulation ............................................................................................................................................ 31
Noise .................................................................................................................................................................. 31
Water quality and management ........................................................................................................................ 31
Chemicals ........................................................................................................................................................... 36
4. C
LIMATE ACTION
..................................................................................................................................................... 39
The EU emissions trading system ....................................................................................................................... 39
Effort sharing ..................................................................................................................................................... 40
Land use, land-use change and forestry ............................................................................................................. 41
Adaptation to climate change ............................................................................................................................ 41
PART II: ENABLING FRAMEWORK
–
IMPLEMENTATION TOOLS ............................................................................ 42
5. F
INANCING
............................................................................................................................................................. 42
Climate finance landmarks ................................................................................................................................. 42
Environmental financing and investments ......................................................................................................... 42
Public financial management ............................................................................................................................. 47
6. E
NVIRONMENTAL GOVERNANCE
................................................................................................................................. 51
Information, public participation and access to justice...................................................................................... 51
Compliance assurance ........................................................................................................................................ 54
EU-supported environmental capacity building ................................................................................................. 56
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The Netherlands 2
Executive summary
In May 2016, the European Commission launched the
Environmental Implementation Review (EIR), a regular
reporting tool based on analysis, dialogue and
collaboration with EU Member States to improve the
implementation of existing EU environmental policy and
legislation (
1
). Following previous cycles in 2017, 2019 and
2022, this report assesses the progress made while
describing the main outstanding challenges and
opportunities
regarding
environmental
legal
implementation in the Netherlands. The purpose of this
report is to provide information on the implementation
performance and highlight the most effective ways to
address the implementation gaps that impact human
health and the environment and hamper the economic
development and competitiveness of the country. The
report relies on detailed sectoral implementation reports
collected or issued by the Commission under specific
environmental legislation.
The main challenges set out below have been selected
from Part I of this report,
‘Thematic
areas’, considering
factors such as the gravity of the environmental
implementation issue in light of the impact on the quality
of life of citizens, the distance to target and financial
implications.
The Netherlands is one of the EU’s best performers on the
circular economy
as regards resource productivity,
secondary material use and
waste management.
It is not
considered at risk of missing the municipal and packaging
waste targets. However, further progress could be made
by introducing new economic instruments to prevent
waste by avoiding the incineration of reusable or
recyclable waste and by making reuse and recycling more
economically attractive.
The Netherlands did not submit its national
biodiversity
strategy and action plan and therefore did not respect its
international commitment as regards the Kunming–
Montreal global biodiversity framework. Protecting
biodiversity presents major challenges, since over three
quarters of protected habitats and species still have an
unfavourable conservation status. One main reason for
the deterioration of habitats is the continued significant
pressure from agriculture, in particular due to nitrogen
deposition affecting many sensitive habitats, from bogs to
forests, and changes in the water regime (drainage).
Furthermore, the situation for forested areas protected
under the Nature Directives is severe, as more than half of
assessments show a bad conservation status. At the same
time, the share of habitats with a bad conservation status
has increased to 53.85 % and the share of species with a
bad conservation status has decreased to 38.75 %. The
main pressures are agriculture, human-induced changes in
water regime and natural succession.
The analysis of river basin management plans of the
Netherlands has identified
nutrients from agriculture
as
an important pressure on groundwaters and surface
waters, impacting their good status, and therefore as one
of the main factors in their failure to meet the Water
Framework Directive objectives. It is estimated that
4.44 % of utilised agricultural land area in the Netherlands
is used for organic farming. This is the fifth-worst result in
the EU, and substantially lower than the EU average of
10.50 %. The Netherlands is not sufficiently contributing
to achieving the target of using 25 % of the EU’s
agricultural land for organic farming by 2030. The main
contributor to emissions to water in the Netherlands is the
waste management sector; emissions from this sector
include heavy metals, nitrogen, total organic carbon and
phosphorus.
Urban waste water
collected in the
Netherlands is being properly treated (100 %) as required
by EU law.
The overall
environmental investment
needed to enable
the Netherlands to meet its objectives in the main
environmental areas is EUR 4.1 billion per year, broken
down as follows: circular economy (EUR 1.5 billion),
pollution prevention and control (EUR 2.3 billion), and
water (EUR 1.0 billion). To meet environmental objectives
beyond climate change, the additional investment needed
over the current level
–
the investment gap
–
per year in
the Netherlands represents around 0.4 % of the national
gross domestic product, being lower than the EU average
(0.77 %).
With regard to
environmental governance,
the
Netherlands needs to ensure that relevant information on
environmental impact assessment and strategic
environmental assessment procedures (including on
opportunities for public participation and on the
publication of final decisions) is electronically accessible,
and provide information on the average duration of all
steps in the environmental impact assessment process. On
a
positive note,
the Netherlands continues to properly
implement the Inspire Directive, and ensures access to
courts in national environmental cases by the public
concerned through eliminating practical barriers, such as
excessive costs.
(
1
)
Communication from the Commission to the European
Parliament, the Council, the European Economic and Social
Committee and the Committee of the Regions
–
Delivering the
benefits of EU environmental policies through a regular
environmental implementation review, COM(2016) 316
final of 27 May 2016,
http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN.
2025 Environmental Implementation Review
–
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The Netherlands 3
2025 Environmental Implementation Review
–
The Netherlands
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The Netherlands 4
Part I: Thematic areas
1. Circular economy and waste management
Transitioning to a circular economy
Advancing the transition to a circular economy in the EU
will reduce the environmental and climate impact of our
industrial systems by reducing input materials, keeping
products and materials in the loop for longer and reducing
waste generation, thus decoupling economic growth from
resource consumption. A circular economy has
considerable potential to increase competitiveness and
job creation and will also promote innovation and provide
access to new markets. With the 2020 circular economy
action plan (CEAP) (
2
) measures either in place or
legislatively advanced, EU Member States will now have to
focus on a swift and effective implementation.
The 2020 CEAP launched the legislative process for a set
of initiatives that will now have to be implemented by
national governments across the EU. These initiatives
were all introduced following a holistic life-cycle approach,
with measures addressing the different stages of a
product’s life cycle, from design through use to end of life.
In the CEAP, the EU sets as its overarching objective the
doubling of its circular material use rate (CMUR) by 2030.
The CMUR is a measure of one aspect of circularity: the
share of the total amount of material used in the economy
that is accounted for by recycled waste. A higher CMUR
value means that more secondary materials were used as
a substitute for raw materials, thus reducing the
environmental impacts of extracting primary material.
The circular use of material in the Netherlands was 30.6 %
in 2023. Despite a slight decrease in 2016–2019, the
country’s rate
is the highest in the EU, against the EU
average of 11.8 % (Figure 1).
Figure 1: CMUR (%), 2013–2023
40
30
20
10
0
2013
2015
2017
Netherlands
2019
2021
EU-27
2023
Source:
Eurostat, ‘Circular material use rate’, env_ac_cur,
last updated
13 November
2024,
accessed
10 December
2024,
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cur.
Resource productivity measures the total amount of
materials directly used by an economy in relation to gross
domestic product (GDP). Improving resource productivity
can help to minimise negative impacts on the environment
and reduce dependency on volatile raw material markets.
As shown in Figure 2, with EUR 5.46 generated per kg of
material consumed in 2023,
the Netherlands’
resource
productivity is well above the EU average of EUR 2.23 per
kg, and is the highest in Europe.
Figure 2: Resource productivity (EUR/kg), 2013–2023
6,0
4,0
2,0
0,0
2013
2015
2017
2019
2021
EU-27
2023
Netherlands
NB: The unit of measurement used is EUR/kg chain-linked volume (2015).
Chain-linked volumes focus on changes on quantities and prices of
commodities in previous years, taking account of inflation, and are
indexed to the nearest appropriate year, in this case 2015.
Source:
Eurostat, ‘Resource productivity’, env_ac_rp,
last updated
7 August
2024,
accessed
9 December
2024,
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp.
(
2
)
Communication from the Commission to the European
Parliament, the Council, the European Economic and Social
Committee and the Committee of the Regions
–
A new circular
economy action plan for a cleaner and more competitive Europe,
COM(2020) 98 final of 11 March 2020,
https://eur-
lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:52020DC0098.
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The Netherlands 5
Policies and measures
In parallel with European initiatives under the CEAP,
Member States are encouraged to adopt and implement
circular strategies at the national, regional and city levels.
These should be tailored to each national and local reality,
to harness the proximity economy’s (
3
) potential, while
following the principles of a holistic whole-value-chain
approach.
Since the launch of the European Circular Economy
Stakeholder Platform in 2017 (
4
), national, regional and
local authorities have used the platform to share their
strategies, roadmaps and good practices, for example
alternative business models and innovative technologies.
In 2023, the Netherlands put in place the 2023–2030
national programme for circular economy (
5
), following up
on the broader 2016 programme on a fully circular
economy by 2050 (
6
), under which the country’s objective
was to achieve a 50 % reduction in the use of primary raw
materials by 2030.
To achieve the ambitious objectives from 2016, the 2023–
2030 programme introduces measures to improve the
economy of raw materials, with a focus on the reduction
and substitution of raw materials, the extension of
product lifetimes, high-grade processing and circular
design. Dedicated initiatives have been developed for the
more impactful product groups, namely some consumer
goods, plastics, construction products and certain
manufacturing practices.
Supporting measures are also introduced, such as
initiatives for circular entrepreneurship, consumer
behaviour change and education.
The Netherlands’ regions and cities are particularly active
in promoting the transition to a circular economy.
In 2024, a new infringement case was opened by the
Commission, as in 2021 the Netherlands did not achieve
the agreed collection recycling rate for waste electronic
and electric equipment (INFR(2024)2125).
Green public procurement
Public procurement accounts for a large proportion of
European consumption, with public authorities’
purchasing power representing 14 % of EU GDP. Public
procurement using green or circular criteria (life-cycle
analysis, PaaS (platform as a service), second hand) can
(
3
)
European Commission,
‘Proximity
and social economy ecosystem’,
European
Commission
website,
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en.
Circular
Economy
Stakeholder
Platform
(https://circulareconomy.europa.eu/platform/en/strategies).
Ministry of Infrastructure and Water Management,
National
Circular
Economy
Programme
2023–2030,
2023,
help drive the demand for sustainable products that meet
reparability and recyclability standards.
The Netherlands has a long tradition of sustainable public
procurement (SPP) policy. However, an evaluation has
shown broad support for green public procurement, but
still too little structural uptake.
To address this and significantly boost the impact of public
procurement, a new national plan on SPP was adopted in
2021. This plan aims to create more political commitment,
activate key decision-makers in organisations and create
more impact in key sectors. The Sustainable Public
Procurement Manifesto (2022–2025) was signed by all
Dutch ministries, a third of Dutch provinces, 50
municipalities and all Dutch regional water authorities,
among others. It covers social return, diversity and
inclusion, international supply chain responsibility, the
environment and biodiversity, the circular economy and
climate.
For circular procurement specifically, a number of
activities are relevant. The Netherlands has so far set up
around 30 so-called buyer groups to leverage collective
procurement power in a relevant sector and provide a
platform for sharing knowledge and learning experiences.
Specifically for infrastructure, extensive transition paths
have been worked out as part of the climate-neutral and
circular infrastructure programme. These are supported
by buyer groups for the procurement angle. The national
buyer group for ICT has been linked to the Circular and Fair
ICT Pact, initiated by the Netherlands, together with seven
other countries.
An increasing number of circular procurement best
practices are shared as part of a free online SPP criteria
tool. The Netherlands promotes the use of internal carbon
pricing, especially in the infrastructure sector. In addition,
a growing number of organisations use the Dutch CO
2
Performance Ladder, which provides both a procurement
tool and a plan–do–check–act management system. This
approach speeds up carbon emission reduction in
companies and governments certified on this ladder,
including (at the higher levels) emissions resulting from
procurement. This provides a powerful impetus for
circular procurement.
To boost political support for sustainable (and circular)
procurement, a new political manifesto is being drawn up
that focuses on boosting SPP, and providing support and
(
6
)
(
4
)
(
5
)
https://www.government.nl/documents/reports/2023/09/27/na
tional-circular-economy-programme-2023-2030.
Ministry of Infrastructure and Water Management,
National
Agreement
on
the
Circular
Economy,
2016,
https://www.government.nl/documents/discussion-
documents/2017/01/24/national-agreement-on-the-circular-
economy.
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The Netherlands 6
creating a stronger foundation for SPP, within signatory
organisations.
The EU Ecolabel and the eco-management and audit
scheme
The number of EU Ecolabel product groups and the
number of eco-management and audit scheme (EMAS)-
licensed organisations in each country provide some
indication of the extent to which the private sector and
national stakeholders in that country are actively engaged
in the transition to a circular economy. The EU Ecolabel is
awarded to products with best-in-class environmental
performance. EMAS is a voluntary environment
management scheme aimed at reducing the
environmental impacts of organisations.
As of September 2024, the Netherlands had 2 019
products out of 98 977 and 106 licences out of 2 983
registered in the EU Ecolabel scheme , which is an increase
from previous years (
7
). One organisation from the
Netherlands is currently registered in EMAS, the same as
in October 2021 (
8
).
While no circular-economy-specific priority actions were
suggested in the 2022 report, the Netherlands has made
progress on priority actions suggested for the circular
economy in previous reports. The country has introduced
a wide-ranging and comprehensive policy framework and
has successfully included local and regional authorities in
the process.
—
limiting energy recovery to non-recyclable materials;
and
—
phasing out landfilling of recyclable or recoverable
waste.
One of the main objectives of the EU Waste Law is to
decouple economic growth from its environmental
impacts.
The EU’s approach to waste management is based on the
waste treatment hierarchy: prevention, preparing for
reuse, recycling, recovery and, as the least preferred
option, disposal (which includes landfilling and
incineration without energy recovery).
All legislative proposals in the field of waste management
put forward by the Commission since 2021 are intended
to encourage Member States to promote better product
design, to require producers to cover the costs of
managing the waste resulting from their products and to
ensure that waste is managed at the higher levels of the
waste hierarchy.
The total amount of waste generated in the Netherlands
was increasing until 2018, when it began to decrease
significantly (Figure 3). This trend is primarily driven by
dredging spoils included in the mineral waste categories.
Without those, the overall waste generation trend would
stabilise, and from 2020 onward a slight decoupling of
total waste generation from economic growth could be
observed.
Figure 3: Generation of waste (total and excluding major
mineral wastes), population and GDP, 2010–2022
Waste management
Turning waste into a resource is supported by:
—
addressing the full life cycle of products, from
conception to end of life, by setting requirements on
the design of products to ensure that they are more
sustainable;
—
fully implementing EU waste legislation, which
includes the waste hierarchy, the obligation to ensure
separate collection of waste, landfill diversion targets,
etc.;
—
reducing waste generation per capita and in absolute
terms;
—
increasing the recycling rates of waste containing
critical raw materials, with a view to reducing
dependencies and building resilient value chains, and
stimulating demand for recycled content in all
products;
Sources:
Eurostat,
‘GDP and main components (output, expenditure and
income)’,
nama_10_gdp,
accessed
15
October
2024,
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table;
Eurostat, ‘Generation of waste by waste
category, hazardousness and NACE Rev.
2 activity’, env_wasgen, last
updated 30 September 2024, accessed 22 October 2024,
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/default/
table?lang=en;
Eurostat, ‘Population change –
Demographic balance and
crude rates at national level’, demo_grind, accessed 15
October 2024,
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default/t
able?lang=en&category=demo.demo_ind.
(
7
)
European Commission,
‘EU Ecolabel facts and figures’,
European
Commission
website,
http://ec.europa.eu/environment/ecolabel/facts-and-
figures.html.
(
8
)
As of October 2024. European Commission,
‘Eco-management
and
audit scheme (EMAS)’, European Commission website, November
2021,
http://ec.europa.eu/environment/emas/emas_registrations/stati
stics_graphs_en.htm.
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Critical raw materials
The national circular material plan (NCEP) (
9
) will come
into force in 2025. It focuses on waste management and
minimum standards for the quality and methods of
recycling of critical raw materials from waste streams.
Construction and demolition waste
Construction and demolition waste accounts for almost
40 % of all waste generated in the EU. A recent study (
10
)
by the Joint Research Centre shows that preparing for
reuse and recycling operations are preferred over
incineration and landfilling from an environmental
perspective for most of the individual fractions of
construction and demolition waste. However, the
economics are often not right to favour preparing for
reuse and recycling over incineration and landfilling. If
available technology were to be applied, it is estimated
that the increase in preparing for reuse and recycling
would lead to an additional 33 Mt of GHG emission savings
annually (more than, for example, the combined annual
GHG emissions from Estonia, Latvia and Luxembourg).
The rate of recycling and preparation for reuse of mineral
construction and demolition waste in the Netherlands in
2022 was high, at 99.3 % compared with the EU average
of 79.8 %. Construction and demolition waste is collected
separately at construction sites. In the Netherlands, the
vast majority of building and construction waste is
recycled. The national policy targets separate raw material
with minimal requirements for recycling with the aim of
ensuring recycling higher up the value chain.
Boosting implementation
–
the 2023
Waste Early
Warning Report
This section focuses on the management of municipal
waste (
11
), for which EU law sets mandatory recycling
targets. In June 2023, the Commission published the
Waste Early Warning Report
(
12
) identifying the general
trends in waste management and the Member States at
risk of missing 2025 waste targets (see Figure 4). The
Netherlands is not at risk of missing the municipal waste
target or the packaging waste target.
Figure 4:
Member States’ prospects
of meeting the
preparing for reuse and recycling targets for municipal
waste and packaging waste
Member States not at risk of missing the 55 %
preparing for reuse and recycling target for
municipal waste and the 65 % recycling target for
packaging waste
Member States at risk of missing the preparing for
reuse and recycling target for municipal waste but
not at risk of missing the recycling target for
packaging waste
Member States at risk of missing both targets
Outside coverage
Source:
European Environment Agency (EEA), ‘Many EU Member States
not on track to meet recycling targets for municipal waste and packaging
waste’, briefing No
28/2022, Copenhagen, 2023. Reference data © ESRI.
Under certain conditions, EU waste legislation enables
some Member States to postpone the deadlines for
reaching certain waste management targets for municipal
and packaging waste. Member States that want to use this
possibility have to notify the Commission 24 months in
advance of the deadline and submit an implementation
plan laying down the steps they envisage to reach the
postponed targets within a new time frame. Regarding the
(
9
)
(
10
)
(
11
)
https://www.rijksoverheid.nl/onderwerpen/circulaire-
economie/nederland-circulair-in-2050.
European Commission: Joint Research Centre,
Techno-economic
and environmental assessment of construction and demolition
waste management in the European Union,
Publications Office of
the European Union, Luxembourg, 2024,
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70.
Municipal waste consists of (i) mixed waste and separately
collected waste from households, including paper and cardboard,
(
12
)
glass, metals, plastics, biowaste, wood, textiles, packaging, waste
electrical and electronic equipment, waste batteries and
accumulators, and bulky waste, including mattresses and
furniture; and (ii) mixed waste and separately collected waste
from other sources, where such waste is similar in nature and
composition to waste from households (Directive 2008/98/EC,
Article 3.2b).
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en.
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The Netherlands 8
2025 targets, 11 Member States, not including the
Netherlands, have used this prerogative.
In the
Waste Early Warning Report,
the Commission
recommended that Member States accelerate their
efforts to improve their recycling performance. The
Commission is, on one hand, working together with the
national authorities and stakeholders to speed up the
implementation of measures necessary to meet the
targets, including through dedicated financing. On the
other hand, the Commission is pursuing enforcement
actions against those Member States that, based on data
submitted to the Commission, do not achieve the targets
of the Waste Framework Directive (
13
), the Packaging and
Packaging Waste Directive (
14
) and the Directive on Waste
Electrical and Electronic Equipment (
15
).
Municipal waste
Municipal waste generation in the Netherlands decreased
between 2010 and 2022 (Figure 5). In 2022, the country
generated 473 kg of municipal waste per capita, which is
significantly below the estimated EU-27 average of 513 kg
per capita.
Figure 5: Municipal waste management and recycling
(including preparation for reuse), 2010–2022
years (Figure 6), while at the same time the incineration
rate has decreased (see Figure 5). In 2022, the rate of
preparing for reuse and recycling was 58 %, which is
slightly above the estimated EU-27 average of 49 % in the
same year. The incineration rate decreased by 8
percentage points to 41 % in 2022. The landfill rate
remained below 2 % throughout the time frame
considered (Figure 6).
Figure 6: Recycling (including preparation for reuse) and
landfill rates (%), 2010–2022
NB: Note that the data slightly differ from the data reported by the Dutch
authorities to show compliance with the preparing for reuse and
recycling target of 55 % to be met by 2025, as set out in the Waste
Framework Directive. The Netherlands reported a (provisional) preparing
for reuse and recycling rate in response to the target that was in the
range of 1–5 percentage points below the (voluntary) data shown in the
figure for the reference year 2022. These data are still awaiting final
validation by Eurostat.
Source:
Eurostat,
‘Municipal waste by waste management operations’,
env_wasmun,
accessed
22 October
2024,
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table.
Packaging waste
Packaging waste generation in the Netherlands has
stagnated since 2010 (Figure 7). The country generated
169 kg per capita in 2022, which is slightly below the
estimated EU average of 186 kg per capita in the same
year (
16
). The higher amounts of wooden packaging in
2015–2017 can be explained by a change in the reporting
method for repaired wooden packaging in 2015 and again
in 2018.
NB: As of the reference year 2020, new reporting rules applied for
calculating recycling of municipal waste pursuant to the targets set out
in Article 11.2(c–e) of Directive 2008/98/EC. However, it is unclear based
on the information available whether these new reporting rules have
been implemented in the Netherlands yet.
Source:
Eurostat,
‘Municipal waste by waste management operations’,
env_wasmun,
accessed
22 October
2024,
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table.
The rate of preparing for reuse and recycling of municipal
waste in the Netherlands has increased slightly in recent
(
13
) Directive 2008/98/EC of the European Parliament and of the Council
of 19 November 2008 on waste and repealing certain Directives,
Directive - 2008/98 - EN - Waste framework directive - EUR-Lex.
(
14
) European Parliament and Council Directive 94/62/EC of 20
December 1994 on packaging and packaging waste (OJ L 365,
31/12/1994, p. 10–23),
Directive - 94/62 - EN - EUR-Lex.
(
15
)
(
16
)
Directive 2012/19/EU of the European Parliament and of the
Council of 4 July 2012 on waste electrical and electronic
equipment (WEEE) (OJ L 197, 24.7.2012, p. 38),
Directive -
2012/19 - EN - EUR-Lex.
The EU average might have been influenced by not all Member
States fully applying the reporting rules for packaging waste set
out in Commission Implementing Decision (EU) 2019/665.
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The Netherlands 9
Figure 7: Packaging waste generation, 2010–2022
Figure 8: Packaging waste recycling rates (%), 2010–2022
NB: As of the reference year 2020, the Netherlands applied the new
calculation rules for calculating recycled packaging waste pursuant to
Article 6c of Directive 94/62/EC.
Source:
Eurostat,
Packaging waste by waste management operations’,
env_waspac, last updated 23 October 2024, accessed 28 October 2024,
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en.
Source:
Eurostat,
‘Packaging waste by waste management operations’,
env_waspac, last updated 23 October 2024, accessed 28 October 2024,
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en.
The country’s overall packaging waste recycling rate, as
well as the recycling rates for paper/cardboard and glass
packaging, were already above the 2025 target in 2010
(Figure 8). The overall recycling rate has stagnated, and in
2022 was 75 %. The overall recycling rate is mainly
influenced by paper and cardboard, as this constitutes the
largest share of recyclable waste. In 2020, the recycling
rates dropped for all materials, which slightly reduced the
overall recycling rate and can be attributed to the
application of the new calculation points. The trend for
wooden packaging recycling shows a significant increase
from 2014 to 2018, when it began to decrease. This was
due to the introduction of wooden packaging to the
measurements in the reference year 2015. From 2020
onwards, it was mandatory to report steel and aluminium
packaging separately. The recycling rates of both fractions
exceeded the 2025 target.
In 2023 and 2024, significant attention was paid to the
functioning of the packaging collection system. Since
2022, the deposit refund system for packaging waste has
covered small plastic bottles and beverage cans (deposit
of EUR 0.15/piece), with a national collection target of
90 % for plastic bottles (higher than the EU target of 65%).
The national targets were not achieved in 2022, with a
68 % collection rate reported. This has resulted, over the
last three years, in EUR 370 million in deposits not being
reimbursed. The Human Environment and Transport
Inspectorate announced five penalties with a potential
maximum sum of EUR 140 million to improve
compliance (
17
).
Policies to encourage waste prevention
Waste management plans and waste prevention
programmes are instrumental to the full implementation
of EU waste legislation. They set out key provisions and
investments to ensure compliance with existing and new
legal requirements (e.g. on waste prevention, on separate
collection for certain waste streams, on recycling and on
landfill targets).
In the Netherlands, the management of waste, including
packaging waste, is organised at the national level through
the Central Environmental Law (Wet Milieubeheer) (
18
)
and the Dutch Law on Packaging Waste (
19
). Both the
Dutch national waste prevention plan and the national
waste management plan (NWMP) were updated to
accommodate the Waste Framework Directive, amended
in 2018. The NWMP also includes national targets for
(
17
)
(
18
)
https://www.ilent.nl/actueel/nieuws/2024/07/12/inleveren-
plastic-flesjes-moet-aantrekkelijker-5-lasten-onder-dwangsom-
voor-verpact.
European Environment Agency (EEA),
Early warning assessment
related to the 2025 targets for municipal and packaging waste
–
Netherlands,
2022,
(
19
)
https://www.eea.europa.eu/publications/many-eu-member-
states/early-warning-assessment-related-to.
Ministerie van Infrastructuur en Waterstaat,
‘Besluit beheer
verpakkingen 2014’,
Overheid.nl website, 2021, accessed
16 December
2024,
https://wetten.overheid.nl/BWBR0035711/2021-07-03.
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The Netherlands 10
packaging waste. Additionally, an action plan is in place to
implement a circular economy by 2050 (
20
).
The Ministry of Infrastructure and Water Management
adopted the second amendment to the 2017–2029
NWMP, entitled
‘Smarter
use of raw materials’ (2017–
2029 Landelijk afvalbeheerplan (LAP3) (
21
)). In 2022, it was
decided that the validity of LAP3 would be extended by
two years, until the end of 2025. LAP3 will be followed by
a circular materials plan in 2025. The NWMP covers both
household and industrial waste and has dedicated
sections for targeted waste streams (e.g. biowaste,
textiles, paper and cardboard). The plan provides a set of
measures to be implemented by the municipalities to
improve separate household waste collection. The NWMP
is complemented by sectoral plans including minimum
standards for and information on cross-border transport
covering 85 waste streams (Sectorplannen LAP 3, 2021). In
addition, regarding packaging waste, the NWMP refers to
the 2014 Packaging Management Decree and the
packaging management regulations, alongside sectoral
plan 41, which encompasses the packaging policy (LAP3,
2021).
The Netherlands’ national waste prevention programme is
a stand-alone document (
22
). Waste prevention measures
are included in the NCEP published in 2016 and updated
in 2023. The updated NCEP focuses on sustainable
production and consumption practices, along with
product reusability and repairability. The programme has
three overarching strategic objectives:
—
—
—
reducing the utilisation of raw materials within
existing supply chains;
transitioning away from fossil fuels, critical
materials and non-sustainable resources;
driving innovation in production methods and
circular product design.
to a circular economy by 2050, with a goal of reducing the
use of primary raw materials by 50 % by 2030.
EPR schemes have been implemented in the Netherlands
for various product groups (electric and electronic
equipment, batteries, scrap vehicles, packaging and car
tyres). An EPR scheme for textiles was implemented in
2023, and the government is exploring options for other
product chains.
Policies to encourage separate collection and recycling
The Dutch municipalities design their own separate waste
collection systems through municipal ordinances. For
residual waste and biowaste, door-to-door collection is
applied throughout the whole country. By law, all
municipalities should do their best to collect biowaste
from all households, and around 90 % of Dutch
households are served by biowaste collection services (
24
).
Regarding the collection of other recyclable materials,
larger cities favour collection points and municipal
container parks, while smaller towns prefer door-to-door
collection. Some materials are frequently collected
commingled, for example plastics, metals and beverage
cartons; plastics and beverage cartons; or glass and
metals.
Only about 41 % of the Dutch households are incentivised
to sort their waste at the source through a pay-as-you-
throw system. These systems are mainly based on the
volume and/or frequency of waste collection. The success
of separate collection for certain materials is fading,
posing a challenge for meeting the EU waste targets in the
future. The Dutch authorities aim to enhance separate
collection systems, especially for high-rise buildings.
Policies to discourage landfilling or incineration
A landfill ban has been in place in the Netherlands since
1995 for, among others, combustible and biodegradable
waste (waste with a total organic carbon content of > 5 %),
thus practically banning landfilling of mixed municipal
waste. In 2018, this ban was extended to additional waste
streams (
25
).
The Netherlands strongly relies on incineration for the
disposal of mixed municipal waste. The Dutch disposal tax
(EUR 39/t in 2024) is equal for landfilling and incineration
and adjusted annually. This tax is levied on all Dutch waste,
including waste that is exported for these purposes and
outputs from mechanical biological treatment or sorting
In the NCEP, priority waste streams are food waste,
construction and demolition waste, hazardous waste and
critical raw materials, packaging waste, electrical waste
(including batteries) and bulky waste. The document
outlines waste prevention measures, such as extended
producer responsibility (EPR), circular design and circular
purchasing, as well as measures to increase reuse.
Monitoring of the programme’s implementation will be
conducted by the Netherlands Environmental Assessment
Agency in collaboration with seven other institutions (
23
),
as part of the government’s monitoring of the transition
(
20
)
https://www.government.nl/documents/reports/2023/09/27/na
tional-circular-economy-programme-2023-2030.
https://lap3.nl/sectorplannen/
https://lap3.nl/sectorplannen/sectorplannen/verpakkingen/
https://www.rijksoverheid.nl/documenten/rapporten/2021/
02/18/afvalpreventieprogramma-nederland.
(
23
)
(
24
)
(
21
)
(
22
)
(
25
)
https://www.pbl.nl/publicaties/werkprogramma-monitoring-en-
sturing-ce-2023-2024.
National Institute for Public Health and the Environment; Dutch
Ministry of Infrastructure and Water Management, information
provided during the Eionet review of the draft country profile on
waste
management
for
the
Netherlands,
2024.
https://www.rivm.nl/en
https://wetten.overheid.nl/BWBR0009094/2024-01-01.
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The Netherlands 11
plants going to incineration (
26
). Overall, this disposal tax
is close to the EU average of landfill taxes across those
Member States applying such taxes (EUR 39–46/t).
In the 2022 EIR, the Netherlands had two priority actions.
With regard to the first objective,
‘to
introduce new policy
instruments, including economic instruments, to (i)
promote waste prevention and (ii) make preparing for
waste reuse and recycling more economically attractive’,
the Netherlands made significant progress with the
comprehensive NCEP.
Regarding the second objective,
‘shift
reusable and
recyclable waste away from incineration with energy
recovery’,
there has been no downward trend in the
volumes of waste sent for incineration.
2025 priority actions
•
Further shift reusable and recyclable waste away from
incineration, including through economic instruments.
•
Increase the collection and recycling rate of waste
electronic and electric equipment (WEEE).
•
Invest in waste prevention measures to reduce the
total amount of waste generated.
•
Extend a pay-as-you-throw system to all households,
and fully introduce the cost-coverage rules as part of
extended producer responsibility for packaging.
(
26
)
https://iplo.nl/thema/bodem/nieuws-bodem/2023/tarief-
afvalstoffenbelasting-per-1-januari-
2024/#:~:text=2024%3A%20%E2%82%AC%2039%2C23%20per,%
E2%82%AC%2033%2C15%20per%20ton
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The Netherlands 12
2. Biodiversity and natural capital
Global and EU biodiversity frameworks
Biological diversity and healthy ecosystems are critical
for our societies, underpin our economies and well-being
and are essential for climate change adaptation and
mitigation. The Kunming–Montreal global biodiversity
framework (GBF), adopted in December 2022, sets
comprehensive and measurable targets to tackle
biodiversity loss by 2030. To implement this global
framework and integrate biodiversity considerations into
national decision-making, the EU
–
as well as all Member
States
–
had to submit national biodiversity strategies
and action plans (NBSAPs), or to communicate national
targets aligned with the global targets, by the end of
2024. The EU biodiversity strategy for 2030 (BDS) aims to
put EU biodiversity on a path to recovery by 2030. It sets
quantified targets intended to protect and restore nature
and manage ecosystems in a sustainable manner, as well
as measures to enable implementation and
commitments to support global biodiversity. A BDS
actions tracker (
27
) and a dashboard of indicators (
28
)
provide information on implementation progress. The
recently adopted EU Nature Restoration Regulation
(
29
)
is
the first EU-wide, comprehensive law of its kind and a key
instrument for the EU to deliver on the global
biodiversity targets for 2030. It lays down an overarching
objective at the EU level to put in place effective
restoration measures on 20% of EU land and sea by 2030
and for all ecosystems in need of restoration by 2050. To
achieve this, it sets binding targets for Member States to
restore and maintain ecosystems, as well as an effective
implementation framework based on national
restoration plans.
The BDS is the main instrument used by the EU to deliver
on its obligation under the GBF. The Commission has
submitted to the Convention on Biological Diversity
(CBD) (tbc)] its report on GBF-aligned EU targets that
stem from the BDS and from other policy instruments
under the European Green Deal.
Member States’ NBSAPs need to provide coherent
frameworks for national delivery on the global and EU
2030 biodiversity targets. In line with the global
obligations, NBSAPs should also include a biodiversity
financing plan and a capacity-building plan, based on
(
27
)
(
28
)
EU
Biodiversity
Strategy
Actions
Tracker
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/).
EU
Biodiversity
Strategy
Dashboard
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1).
Regulation (EU) 2024/1991 of the European Parliament and of
the Council of 24 June 2024 on nature restoration and amending
Regulation (EU) 2022/869 (OJ L, 2024/1991, 29.7.2024),
http://data.europa.eu/eli/reg/2024/1991/oj;
see also
Commission
web
page
on
the
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en).
(
30
)
https://www.rijksoverheid.nl/documenten/kamerstukken/
2020/10/16/kamerbrief-programma-versterken-biodiversiteit.
the
law
needs assessments, as well as an overview of the
national indicators used to measure progress.
In 2020, the Netherlands launched a national programme
for strengthening biodiversity (
30
) that builds on the BDS
and strives to achieve 100 % of the objectives of the Birds
and Habitats Directives by 2050. It identifies goals for
2030 that are reflected in more than 100 measures, each
with corresponding indicators, priorities, deadlines,
verification means, tools and responsible entities. The
Netherlands has not yet submitted to the CBD an
updated NBSAP or national targets aligned with the GBF.
This programme was launched under the previous
government and, inter alia, builds on the national
programme for rural areas (Nationaal Programma
Landelijk Gebied), and aims to improve nature, soil and
water quality and combat climate change. The new
government that came into office in 2024 has scrapped
the national programme for rural areas and cut the
budget for environmental measures in rural areas by
80 %. It is unclear at this stage whether and by when the
programme will be replaced to achieve the
environmental targets.
The Dutch government did not submit a NBSAP and did
thus not respect its international commitment as regards
the GBF.
The EU aims to allocate to biodiversity objectives at least
7.5 % of annual spending under the EU budget in 2024,
rising to 10 % in 2026 and 2027. For details on
biodiversity financing and investments in the
Netherlands, see Chapter 5.
2025 priority action
•
Submit to the CBD an updated NBSAP or national
targets following the adoption of the Kunming-
Montreal Global Biodiversity Framework.
(
29
)
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Nature protection and restoration
–
Natura
2000
Natura 2000 (
31
), the largest coordinated network of
protected areas in the world, is key to the achievement
of the objectives set out in the Birds and Habitats
Directives. These objectives are to ensure the long-term
protection, conservation and survival of Europe’s most
valuable and threatened species and habitats and the
ecosystems they underpin. Key milestones towards
meeting the objectives of the Birds and Habitats
Directives are (i) the setting up of a complete and
coherent Natura 2000 network; (ii) the designation of
sites of community importance (SCIs) as special areas of
conservation (SACs) (
32
); and (iii) effective management
of all Natura 2000 sites through the setting of site-
specific conservation objectives and measures.
Setting up a complete and coherent network of Natura
2000 sites
The setting up of a complete and coherent network of
Natura 2000 sites is a cornerstone of the EU’s
international commitments, under the BDS and GBF, to
legally protect a minimum of 30 % of its land area and
30 % of its sea area.
Meeting these commitments requires the full
implementation of Article 3 of the Habitats Directive. The
Natura 2000 network should represent a complete and
coherent ecological network composed of sites hosting
natural habitat types and species of community interest.
The Natura 2000 network enables the natural habitat
types and the species’ habitats concerned to be
maintained or, where appropriate, restored to a
favourable conservation status in their natural range.
The Netherlands hosts 52 habitat types (
33
) and 80
species (
34
) covered by the Habitats Directive. The
country also hosts populations of 70 bird taxa listed in
the Birds Directive Annex I (
35
).
In 2023, 14.7 % of the national land area of the
Netherlands was covered by Natura 2000 sites (EU
coverage: 18.6 %), with special protection areas (SPAs)
classified under the Birds Directive covering 12.8 % (EU
coverage: 12.8 %) and SCIs and SACs under the Habitats
Directive covering 8.3 % and 9.9 %, respectively (totalling
10.06 %) (EU coverage: 14.3 %) of the Netherlands’
territory. The coverage of the Dutch marine part of the
North Sea by Natura 2000 sites is 16 456 km
2
(26 % of the
Dutch marine area) (EU coverage: 10.7 %) (
36
).
The latest assessment of the SCIs in the Natura 2000
network shows that there are potential insufficiencies in
designation (even though there is no need to designate
additional sites), as some habitats and species do not
appear in the designation decrees for some sites. The
amendment decree covering 100 SACs has been
published, yet its adoption has been pending since 2018
due to several ongoing appeal cases. In addition, the
coverage by the network of three species should be
ensured by adding them to the standard data forms of
the relevant sites. As regards SPAs, while good progress
has been made (with a new site designated on
8 December 2021), the classification of one marine site is
still pending. Furthermore, a number of terrestrial SPAs
are not designated for breeding populations of meadow
bird species that are present in high numbers on the
sites, such as the black-tailed godwit. In light of the
infringement
procedure
on
meadow
birds
(INFR(2024)4014), launched in July 2024, additional SPAs
would need to be classified for (breeding) populations.
Therefore, the Netherlands still has to complete its
Natura 2000 network, in particular its marine network
and its SPA network.
Considering both Natura 2000 and other nationally
designated protected areas, the Netherlands legally
protects 22.7 % of its terrestrial areas (EU-27 average:
26.1 %) and 26.8 % of marine areas (EU-27 average:
12.3 %). It strictly protects 1 % of terrestrial and marine
areas (
37
).
Noteworthy is the transformation of Millingerwaard, an
area that is located in the Natura 2000 site Rijntakken.
This public–private partnership project successfully
(
31
)
(
32
)
(
33
)
(
34
)
Natura 2000 comprises sites of community importance (SCIs),
designated pursuant to the Habitats Directive, as well as special
protection areas (SPAs), classified pursuant to the Birds
Directive. Numbers of protected areas in Figure 7 do not add up
to the total of SCIs plus SPAs, because some SCIs and SPAs
overlap. An SAC is an SCI designated by a Member State.
SCIs are designated pursuant to the Habitats Directive, whereas
SPAs are designated pursuant to the Birds Directive. Figures of
coverage do not add up because some SCIs and SPAs overlap.
EEA, ‘Number of habitats and species per Member State’,
Article 17 dashboard, Annex I total, 19 December 2019,
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species
EEA, ‘Number of habitats and species per Member State’,
Article 17
dashboard,
19 December
2019,
(
35
)
(
36
)
(
37
)
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species.
EEA, ‘Winter population trends’,
Article 12 dashboard, last
updated
11 May
2023,
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations.
https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1
.
Eurostat dataset env_bio4, protected area percentage for 2022,
accessed
March
2025,
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en.
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reconciled the different interests of all parties to allow
the conversion of intensively farmed land for large-scale
nature development to provide protection for citizens
that need to be evacuated frequently due to the flooding
of the nearby river Waal. The project was selected as a
finalist for the coveted Natura 2000 Award in 2024, and
is regarded as an excellent practical example of the
benefits of the Natura 2000 network (
38
).
Figure 9: Natura 2000 terrestrial protected area
coverage per Member State (%), 2023
Overall, three SCIs have not yet been designated as SACs.
Definitive site-specific conservation objectives have been
established for all sites, except for those where
designation is still pending. Two of them already have
draft objectives, while for the third site where the six-
year deadline has not yet expired there are no objectives
yet.
2025 priority actions
•
Complete the Natura 2000 site designation process.
•
Ensure the effective implementation of Natura 2000
management plans and sufficient administrative
capacity and financing for both Natura 2000 and the
implementation of the Nature Restoration
Regulation. Ensure the implementation of Prioritised
Actions Framework 2021-2027 (PAFs)..
•
Enhance efforts to collect reliable data on the
conservation status of habitats and species as well as
their prevalence at the site level. In view of this,
consider the creation of a body in charge of
monitoring and reporting, to ensure that data are not
provided only ad hoc on a contract basis.
Source:
European Environment Agency (EEA), ‘Natura 2000 Barometer’,
2023 data, accessed March 2025,
https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer.
Recovery of species
One objective set by the BDS is that, by 2030, there
should be no further deterioration in conservation trends
or the status of any protected species. The BDS also
states that Member States should ensure that at least
30 % of species not currently in favourable conservation
status achieve that status or show progress towards
doing so (e.g. by exhibiting positive population dynamics
or stable or increasing range and habitat size), by 2030.
According to the European Environment Agency (EEA),
based on reporting required under Article 17 of the
Habitats Directive, a quarter of species in the EU were of
good conservation status as of 2018 (
39
).
One of the primary objectives of the Habitats Directive is
the maintenance of or restoration to favourable
conservation status of all species of community interest.
Moreover, the Birds Directive also aims to ensure that all
wild birds in the EU enjoy a secure status. In order to
achieve these objectives, it will be necessary to address
key pressures and threats. The Birds Directive and the
Habitats Directive lay down a framework of species
protection rules and rules on the conservation of habitats
and species in order to combat these threats.
Designating special areas of conservation and setting
site-specific conservation objectives and measures
In order to ensure that SCIs contribute to the objectives
of the Habitats Directive, Member States must designate
them as SACs, setting site-specific conservation
objectives based on the ecological needs of the species
and habitats present on the sites. The site-specific
conservation objectives must be defined in terms of
attributes and targets that cover the properties of the
feature of interest that are necessary to describe its
condition as either favourable or unfavourable. These
objectives must address the key pressures and threats
present on the site. Article 6 of the Habitats Directive
requires Member States to establish and implement
conservation measures for the realisation of the
objectives of the site.
The six-year deadline set by the Habitats Directive to
designate SCI as SAC and establish appropriate
conservation objectives and measures has expired for
two sites in the Netherlands.
(
38
)
(
39
)
https://environment.ec.europa.eu/news/transformation-
millingerwaard-intensive-agriculture-and-clay-extraction-
natural-flood-protection-2024-03-14_en.
EEA,
State of Nature in the EU: Results from reporting under the
Nature Directives
(2013–2018), Publications Office of the
European
Union,
Luxembourg,
2020,
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020.
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Under Article 17 of the Habitats Directive, Member
States are required to report on the conservation status
of habitats and species every six years. The current
reporting cycle, covering 2019–2024, is due for
submission in July 2025. Figures 10 and 11 show the
latest available data on conservation status.
The results of reports under Article 17 of the Habitats
Directive and Article 12 of the Birds Directive on progress
towards maintaining or restoring the favourable
conservation status of species and habitats are key to
measuring the performance of Member States.
According to the report submitted by the Netherlands on
the conservation status of habitats and species covered
by the Article 17 of the Habitats Directive for 2013–
2018
(
40
)
, the share of assessments for habitats with a
good conservation status in 2018 is more than the 3.85 %
reported during the previous reporting period (2007–
2012). As regards protected species, the share of
assessments of good conservation status in 2018 was
26.25 %, more than the 22.78 % reported in the previous
reporting period. The shares of assessments of poor or
bad conservation status in 2018 were 39 % and 30 %,
respectively (5 % are unknown), and are mostly wetland
dependant. Of the forest habitats protected under the
EU Nature Directives, none have a favourable
conservation status. As far as birds are concerned, 58 %
of the breeding species showed short-term increasing or
stable population trends (for key wintering species, this
figure was 62 %).
At the same time, the share of habitats with a bad
conservation status has increased to 53.85 %, and the
share of assessments for species of bad conservation
status has decreased to 38.75 %. The main pressures are
agriculture, human-induced changes in water regime and
natural succession (
41
).
Figure 10: Assessments of conservation status of
habitats for the 2007–2012 and 2013–2018 reporting
periods
Source:
EEA, ‘Conservation
status and trends of habitats and species’,
19 December
2019,
accessed
in
February
2025,
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived.
NB: The values shown for 2007–2012 and 2013–2018 are not
necessarily directly comparable because changes in area conservation
status in a Member State may result from changes to methods or use
of better data, rather than reflecting genuine changes.
Figure 11: Assessments of conservation status of
species for the 2007–2012 and 2013–2018 reporting
periods
Source:
EEA, ‘Conservation
status and trends of habitats and species’,
19 December
2019,
accessed
in
February
2025,
https://www.eea.europa.eu/en/analysis/maps-and-
(
40
)
(
41
)
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/conservation-status-and-trends.
The Netherlands indicates that the pressures under
‘natural
processes’ is mainly
due to ‘natural
succession’; this exerts
pressures because succession is accelerated due to high nitrogen
deposition. The country also indicates that
‘human-induced
changes to the water regime’ relate to abstraction from
groundwater, surface water or mixed water, as well as
agricultural activities generating diffuse pollution to surface
water or groundwater. In addition, the Netherlands states that
invasive species and climate change, although not in the top
three pressures, are also very relevant, because they are hard to
deal with.
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charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived.
NB: The values shown for 2007–2012 and 2013–2018 are not
necessarily directly comparable because changes in area conservation
status in a Member State may result from changes to methods or use
of better data, rather than reflecting genuine changes.
and based on the latest scientific insights on meadow
birds’ species in the Netherlands, notably the continuing
decline of meadow bird populations, the Commission
decided to open an infringement procedure on 24 July
2024, based on Articles 2, 3 and 4 of the Birds Directive.
In 2022 the Commission also started an infringement
case concerning the Netherlands' failure to comply with
its obligations under the Habitats Directive to monitor
bycatch of harbour porpoises by fishing vessels.
45
The Netherlands made minor progress in improving the
conservation status of habitats and species, and as a
result the percentage of Annex I habitat types with a
favourable status tripled (from two types to six types)
compared with the previous reporting period under
Article 17. With a total of 88 % of habitat types without a
favourable conservation status, the Netherlands is still
very far behind. At the same time, while there was a
considerable decrease in the percentage of species with
a bad status, dropping from over 50 % to below 39 %, the
trend for habitats was the opposite, as the percentage
with a bad status increased from 46 % to 54 %. One main
reason for the deterioration of habitats is the continued
very significant pressure from agriculture leading, for
instance, to acidification and/or overfertilisation. In 2019
alone, 80 % of unused nitrogen (equal to 419 million
kilograms) leached to the environment (
42
). In particular,
excessive nitrogen deposition is affecting many sensitive
habitats protected under the directive, from bogs to
forests (
43
), as well as changes in the water regime
(drainage and/or pollution). In the case of birds, the
Article 12 report indicates a minimal 1 % improvement in
species with an increasing population trend, while the
population of 5 % more species is decreasing. This is in
particular of major concern for meadow birds,
dependent on the agricultural landscape, and for which
the Netherlands is a key breeding and wintering area. By
2020, the breeding population of the flagship species and
national bird, the black-tailed godwit, had dropped by
50 % since 2001. An EU pilot investigation was launched
in 2017 on the decline of meadow birds and the alleged
insufficiency of the measures taken. According to a 2021
report by the Dutch Court of Audit, the decline has still
not been halted despite measures being put in place and
eight times more budget being made available to reverse
the birds’ continued declining population trend (
44
). The
Court of Audit’s report points to a major weakness: most
measures are financial in nature and based on voluntary
uptake by farmers. This means that the measures
implemented are not necessarily the best. On this basis
2025 priority action
•
Reinforce action for habitats and species with
unfavourable conservation status through, for
example,
restoration
measures,
increased
connectivity, better policy coordination and
integration, and increased funding.
Recovery of ecosystems
Agricultural ecosystems
The BDS works alongside the common agricultural policy
(CAP) to support the transition to sustainable agriculture.
The strategy has set five common agriculture-related
targets for 2030, namely to:
—
reduce by 50 % the overall use of
–
and risk from
–
chemical pesticides;
—
reduce by 50 % the use of more hazardous
pesticides;
—
reduce by 50 % losses of nutrients from fertilisers
(which will result in a 20 % reduction in the use of
fertilisers) while ensuring that there is no
deterioration of soil fertility;
—
restore at least 10 % of agricultural area to have
high-diversity landscape features; and
—
increase the area under organic farming to at least
25 %.
The “Vision for agriculture and food”(
46
), adopted by the
European Commission in February 2025, sets a roadmap
to an agri-food system that is attractive, competitive,
sustainable and fair for current and future generations.
(
42
)
(
43
)
(
44
)
https://longreads.cbs.nl/nederland-in-cijfers-2021/hoeveel-
stikstof-produceert-de-veehouderij/.
Scientific reports show that 17 habitat types are
‘sensitive’
to
nitrogen and 28 habitat types are considered ’very sensitive’ to
nitrogen (Wamelink, W., van Dobben, H., van der Zee, F. et al.,
Overzicht van kritische depositiewaarden voor stikstof,
toegepast op habitattypen en leefgebieden van Natura 2000,
Wageningen
University
&
Research,
2023,
https://edepot.wur.nl/633179).
Partly as result of the Water Framework Directive, and related
directives, such as the Nitrates Directive, water quality improved
(
45
)
(
46
)
significantly, as did biodiversity in the water; see H
2
O,
‘Eindelijk
goed nieuws over biodiversiteit: diversiteit watergebonden
insecten neemt toe’, H
2
O website, 23 August 2021,
https://www.h2owaternetwerk.nl/h2o-actueel/eindelijk-goed-
nieuws-over-biodiversiteit-diversiteit-watergebonden-insecten-
neemt-toe.
INFR(2021)4062.
https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en.
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In 2024, the CAP basic regulations were amended (
48
)
regarding, inter alia, the standards for good agricultural
and environmental condition of land. These changes
removed the obligation for farmers benefiting from CAP
area-related support to have a minimum share of 3–4 %
of non-productive area or landscape features in their
farms. The amended regulations do not remove the
obligation under the GAEC 8 to maintain existing
landscape features and set out, however, an obligation
for Member States to establish and provide support for
eco-schemes covering practices for the maintenance of
non-productive areas, such as land lying fallow, and for
the establishment of new landscape features on arable
land.
The recently adopted Nature Restoration Regulation
focuses on the restoration of agricultural ecosystems and
requires Member States to put in place measures that
aim to achieve an increasing trend at the national level in
at least two out of three indicators for agricultural
ecosystems (
49
). One of these indicators is the
‘share
of
agricultural land with high-diversity landscape features’.
Organic farming practices are highly beneficial to
biodiversity. As shown in the Figure 12, it is estimated
that 4.44 % of the Netherlands’ agricultural land area is
used for organic farming. This is the fifth worst result in
the EU and substantially lower than the EU average of
10.50 % (
50
). The Netherlands is not sufficiently
contributing to achieving the target of 25 % of the EU’s
agricultural land being used for organic farming by 2030.
To ensure a sustainable future for EU agriculture, it is
crucial that these four priority areas are pursued
together, and that public and private support are
adequately targeted toward this objective.
The CAP and national CAP strategic plans (SPs) are key
instruments to facilitate and strengthen the efforts of
European farmers to protect biodiversity and the
environment at large. The Commission approved
Member States’ SPs in 2022 for the programming period
2023–2027. The CAP is the largest source of funding for
contributing to the implementation of EU environment
policy, this is particularly true for biodiversity. SPs should
continue to support the protection of soil, water, air
quality and biodiversity.
While certain CAP result indicators focus on
interventions favouring sustainable agriculture practices
that regenerate ecosystems, the impact of these
measures is difficult to be assessed ex ante. The eco-
schemes, agri-environmental measures and climate
commitments, as well as investments related to natural
resources and biodiversity, are voluntary for farmers.
However, at the level of Member States, at least 25 % of
the funding allocation provided for must be reserved for
each calendar year from 2023 to 2027 for eco-schemes.
The utilised agricultural area in the Netherlands
increased from 1 841 600 ha in 2012 to 1 845 750 ha in
2015 and decreased to 1 804 370 ha in 2022 (
47
).
Landscape features are small fragments of non-
productive and typically
–
but not exclusively
–
semi-
natural vegetation present in or adjacent to agricultural
land. They provide ecosystem services and support for
biodiversity. The indicator
‘share
of agricultural land
covered with landscape features’ is the ratio between
the area covered by landscape features and the area
covered by agricultural land. Based on the Land
Use/Cover Area Frame Survey landscape features
estimates, the share of agricultural land covered by non-
productive landscape features in the Netherlands is
7.2 %, above the EU average. At the EU level, landscape
features cover 5.6 % of agricultural land.
(
47
)
(
48
)
Eurostat,
‘Utilised agricultural area by categories’,
tag00025,
accessed
5 December
2024,
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en.
Regulation (EU) 2024/1468 of the European Parliament and of
the Council of 14 May 2024 amending Regulations (EU)
2021/2115 and (EU) 2021/2116 as regards good agricultural and
environmental condition standards, schemes for climate,
environment and animal welfare, amendment of the CAP
strategic plans, review of the CAP strategic plans and exemptions
from controls and penalties (OJ L, 2024/1468, 24.5.2024),
http://data.europa.eu/eli/reg/2024/1468/oj.
(
49
)
(
50
)
The three indicators are
‘grassland butterfly index’, ‘stock of
organic carbon in cropland mineral soils’ and ‘share of
agricultural land with high-diversity
landscape features’.
This is based on the latest available information from Eurostat,
which is currently under review; European Commission,
Agriculture biologique au sein de l’union européenne,
factsheet,
Brussels,
2024,
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en.
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Figure 12: Share of total utilised agricultural area
occupied by organic farming per Member State (%),
2022
—
taking action for ecosystem restoration.
The proposed directive on soil monitoring and
resilience (
51
) aims to introduce the first comprehensive
legislation on the protection of all soils in the EU. Should
the directive be adopted, Member States will have to
transpose it into national legislation and implement it,
starting with putting in place the governance systems
and a sound monitoring framework building on existing
national soil monitoring frameworks. The objective of
the proposed directive is to provide better and more
comparable soil health data with the view of attaining
healthy soils by 2050.
Degradation of soil ecosystems encompasses several
aspects. The proposed directive requires Member States
to assess soil health according to a set of common
indicators and to define the necessary regeneration
measures. The area of soil that is sealed is an important
factor in monitoring land-use change and represents an
important pressure on nature and biodiversity. Other soil
issues related to land degradation are soil erosion, soil
compaction, loss of soil organic carbon, soil
contamination, soil salinisation and the presence in soil
of nitrogen and phosphorus in excess. The impact
assessment accompanying the proposal, which builds on
the data available in the EU Soil Observatory, points to
the following soil degradation issues in the
Netherlands (
52
).
The greatest contributor to the Netherlands’ unhealthy
soils is excessive nutrient concentrations, which impacts
roughly 88 % of the total agricultural area, with 69 % of
the national territory containing phosphorus
concentrations above 50 mg/kg and 63 % containing
nitrogen concentrations above 50 kg/ha. 16% of the
national territory also experiences unsustainable soil
erosion by water, wind, tillage and harvest, representing
63 % of the Netherlands’ cropland area.
Grasslands
Grasslands are among the most diverse ecosystems in
the EU; they can contain as many as 80 different plant
species per square metre and are home to a large variety
of animals, ranging from small insects, birds and rodents
to large herbivores. Grasslands are essential for
agriculture and livestock herding. Natural grasslands also
play an important role in storing carbon. However,
changes in agricultural practices and land uses have
caused grasslands to disappear at an alarming rate,
Source:
Eurostat, ‘Area under organic farming’, sdg_02_40, accessed
5 December
2024,
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en.
2025 priority actions
•
Step-up efforts to further reduce nitrogen
deposition, in particular in Natura 2000 sites with
nitrogen-sensitive species and habitats.
Implement eco-schemes and agri-environmental
measures and practices to address the
environmental needs of the Netherlands.
Implement and scale up the uptake of organic
farming practices.
•
•
Soil ecosystems
Soil is an essential, finite and extremely fragile resource.
Its increasing degradation poses a threat to EU food
security and climate resilience, adaptation and
mitigation.
The EU soil strategy, adopted in November 2021, aims to
support soil protection, sustainable soil management
and the restoration of degraded soils to achieve the
Green Deal objectives as well as land degradation
neutrality by 2030.
This entails:
—
preventing further soil degradation;
—
making sustainable soil management the new
normal;
(
51
)
Proposal for a directive of the European Parliament and of the
Council on soil monitoring and resilience (Soil Monitoring Law),
COM(2023) 416
final
of
5 July
2023,
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416.
Commission staff working document
–
Impact assessment
report: Annexes
–
Accompanying the proposal for a directive of
(
52
)
the European Parliament and of the Council on soil monitoring
and resilience (Soil Monitoring Law), SWD(2023) 417 final of
5 July
2023,
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT
ASSESSMENT
REPORT_ANNEXES_SWD_2023_417_part4.pdf.
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making them one of Europe’s most threatened
ecosystems. Extensively managed grasslands include
meadows, mountain pastures, dry calcareous grasslands
and steppic grasslands.
According to the latest reports, all (eight) Annex I
grassland habitat types present in the Netherlands have
an unfavourable conservation status and only a quarter
have a positive status (
53
). This is mainly due to a
combination of different pressures and threats, such as
agriculture (activities generating air pollution,
application of fertiliser), human-induced changes in the
water regime, abandonment of grassland management,
or natural processes (vegetation succession). All
grassland habitat types are considered sensitive or very
sensitive to (impacts of excessive) nitrogen
deposition (
54
).
Wetlands/peatlands
The Netherlands hosts seven freshwater habitat types
covered by the Habitats Directive and seven habitat
types belonging to the group
‘bogs,
mires and fens’.
According to the most recent report produced in
accordance with Article 17 of the Habitats Directive, only
1 (out of the 14) of these habitat types has a favourable
conservation status in the Netherlands. The main
pressures and threats identified by the report to
freshwater habitat types are agriculture (generating
pollution), invasive alien species (IAS) or human-induced
changes in the water regime (water abstraction); five
freshwater habitat types are considered sensitive to
nitrogen deposition. For bogs, mires and fens, the
pressures and threats are human-induced changes in the
water regime (water abstraction), mixed-source air
pollution, natural processes or agriculture. All bogs,
mires and fens are considered sensitive to nitrogen
deposition.
Forest ecosystems
Wetlands act as water sources and purifiers; they are the
planet’s greatest natural carbon stores and they are
crucial to agriculture and fisheries. Peatlands are a
special type of wetland dominated by peat-forming
plants such as
Sphagnum
mosses. Nearly all peatlands in
the EU are habitat types listed in Annex I of the habitats
directive. Drained peatlands under intensive agricultural
use constitute only 3 % of the EU’s utilised agricultural
area. At the same time, they are responsible for 25 % of
the greenhouse gas (GHG) emissions from the EU’s
agricultural sector. Restoring peatlands brings multiple
benefits, as peatlands improve water retention and
quality, store carbon, reduce GHG emissions and
increase biodiversity.
Forests are important carbon sinks, and conserving them
is vital if the EU is to achieve climate neutrality by 2050.
The EU forest strategy for 2030, adopted in July 2021, is
a plan of actions to promote the many services that
forests provide. Its key objective is to ensure healthy,
diverse and resilient EU forests that contribute
significantly to the achievement of the EU’s biodiversity
and climate ambitions. About 27 % of the forest area in
the EU is covered by habitat types listed in Annex I to the
Habitats Directive. Moreover, forests host several
species protected under the Birds and Habitats
Directives, including those for which there is a
requirement to designate Natura 2000 sites and to
protect breeding sites and resting places.
Several guidelines on forestry management were
published in 2023. They covered biodiversity-friendly
afforestation, reforestation and tree planting; closer-to-
nature forest management; and defining, mapping,
monitoring and strictly protecting primary and old-
growth forests. Further guidance on payment schemes
for ecosystems services has also been published.
In 2023, the Commission proposed a new forest
monitoring law (
55
) that aims to create a comprehensive
forest knowledge base, address information gaps and
enable a better response to growing pressures on
(
53
)
(
54
)
(
55
)
nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Grasslands&country=NL&region=.
https://wetten.overheid.nl/BWBR0036751/2021-07-01.
Proposal for a Regulation of the European Parliament and of the
Council on a monitoring framework for resilient European
forests,
COM(2023)728,
22
November
2023,
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en
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territory in 2020 (
59
). The situation of forest habitats
protected under the Habitats Directive is particularly
worrying, as 100 % have a bad or poor status (
60
). The
report under the directive indicates that this is mainly
due to agriculture, non-native species, removal of
dead/dying trees or changes in the water regime.
Figure 13: Conservation status of forests protected
under the Habitats Directive per Member State (% of
assessments), 2013–2018
forests.
Assessments show that, of the 27 % of EU forest area
protected under the Habitats Directive, less than 15 % is
of favourable conservation status (
56
). The share of
forested areas in the EU with a bad conservation status
increased from 27 % in 2015 to 31 % in 2018.
Contamination can severely reduce soil quality and
threaten human health and the environment. The latest
available estimates based on information from Member
States (
57
) indicate that potentially polluting activities
have taken or are still taking place on approximately
2.8 million sites in the EU. At the EU level, 650 000 of
these sites have been registered in national or regional
inventories. 65 500 contaminated sites have already
been remediated. The Netherlands has registered 181
sites with either current or past potentially polluting
activities and has already remediated or applied
aftercare measures to 83 of these.
Soil organic matter plays an important role in the carbon
cycle and in climate change. Soils are the second largest
carbon sink in the world after oceans.
As regards capacity building on this issue, the
Netherlands attended a Technical Assistance and
Information Exchange Environmental Implementation
Review (TAIEX-EIR) PEER 2 PEER workshop on sustainable
urban development on 26–27 March 2019 in Belgium. In
addition, a TAIEX-EIR PEER 2 PEER workshop on
maintaining and enhancing ecosystem services in urban
regions was carried out on 4–5 July 2019 in the
Netherlands.
Forests are important carbon sinks and conserving them
is vital if the EU is to achieve climate neutrality by 2050.
Of the 27 % of EU forest area protected under the
Habitats Directive, fewer than 15 % of assessments result
in favourable conservation status (
58
). The percentage
identifying habitats with a bad conservation status
increased from 27 % to 31 % in the EU, compared with
2015. In the Netherlands, forests covered 11 % of
Source:
Commission staff working document
–
New EU forest strategy
for 2030, SWD(2021) 652 final of 16 July 2021, p. 24,
eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652
.
.
The EU Timber Regulation (EUTR) (
61
) prohibits the
placing on the EU market of illegally harvested timber.
(
56
)
(
57
)
(
58
)
EEA,
State of Nature in the EU: Results from reporting under the
Nature Directives 2013–2018,
Publications Office of the
European Union, Luxembourg, 2020,
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020.
European Commission: Joint Research Centre,
Status of Local
Soil Contamination in Europe: Revision of the indicator
‘Progress
in the management contaminated sites in Europe’,
Publications
Office of the European Union, Luxembourg, 2018,
https://publications.jrc.ec.europa.eu/repository/handle/JRC107
508.
EEA,
State of Nature in the EU: Results from reporting under the
Nature Directives 2013–2018,
Publications Office of the
European Union, Luxembourg, 2020,
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020.
(
59
)
(
60
)
(
61
)
EEA,
forest information system for Europe, ‘Countries –
FISE
country factsheets’, forest information system for Europe
website,
https://forest.eea.europa.eu/countries.
Commission staff working document
–
Stakeholder consultation
and evidence base: Accompanying the document
Communication from the Commission to the European
Parliament, the Council, the European Economic and Social
Committee and the Committee of the Regions
–
New EU forest
strategy for 2030, SWD(2021) 652 final of 16 July 2021,
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652.https://ec.europa.eu
/environment/pdf/forests/swd_forest_strategy.pdf
Regulation (EU) No 995/2010 of the European Parliament and of
the Council of 20 October 2010 laying down the obligations of
operators who place timber and timber products on the market
(OJ L 295, 12.11.2010, p. 23),
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995.
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On 29 June 2023, the Regulation on Deforestation-free
Products (EUDR) (
62
) entered into force (
63
). The
regulation seeks to guarantee that products in the EU
that are made using any of seven listed commodities
have no links to deforestation. The EUDR repeals the
EUTR.
may have been established in cooperation with other
Member States at the EU or regional level (
66
).
The Commission assessed the updated monitoring
programme reported by Member States in 2020 (
67
). At
that time their updates on the elements, features and
parameters identified monitoring gaps. The Commission
recommended that Member States should prioritise
work to address those gaps at all levels of
implementation of the MSFD.
Member States also reported their updated programmes
of measures, which are required under Article 13 of the
MSFD and which must be updated every six years. The
Commission has assessed Member States’ programmes
of measures.
Figure 14: Level of adequacy of the Netherlands’
updated programme of measures under Article 13 of
the MSFD (2022 reporting exercise)
2025 priority actions
•
Improve conservation status of forests by promoting
sustainable forest management and ensuring
compliance with the Habitats Directive before
granting/renewing permits for forest logging.
Implement peatland conservation and restoration
measures and include such measures and objectives
in the national restoration plans.
Bring levels of nitrogen deposition (
64
) under the
critical threshold to allow forest habitat types
protected under the Habitats Directive to
recover.ion
51
•
•
Marine ecosystems
The Marine Strategy Framework Directive (MSFD)
requires Member States to achieve good environmental
status (GES) for their marine waters. To that end,
Member States must draw up marine strategies for their
marine waters and cooperate with other Member States
sharing the same marine region or subregion. These
marine strategies comprise different steps to be
developed and implemented over six-year cycles.
Since the 2022 EIR report, no additional data regarding
Member States’ set of GES characteristics for each
descriptor in the MSFD have become available.
Nevertheless, Member States had to report updates by
October 2024, and these are being assessed by the
Commission. In the context of this next round of
reporting, in accordance with the MSFD and the
Commission GES decision (
65
), Member States must
include as part of their set of GES characteristics any
threshold values for the descriptors in the MSFD that
NB: Technical assessment carried out by the European Commission,
pursuant to Article 16 of the MSFD, based on the data reported by the
Member State in June 2022.
The Netherlands’ updated programme of measures
shows varying levels of adequacy across descriptors.
(
62
)
(
63
)
(
64
)
(
65
)
Regulation (EU) 2023/1115 of the European Parliament and of
the Council of 31 May 2023 on the making available on the Union
market and the export from the Union of certain commodities
and products associated with deforestation and forest
degradation and repealing Regulation (EU) No 995/2010 (OJ
L 150, 9.6.2023, p. 206),
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461.
The law will apply to large and medium-sized companies starting
on December 30, 2025, and to micro and small enterprises
starting on June 30, 2026.
https://wetten.overheid.nl/BWBR0036751/2021-07-01.
Commission Decision (EU) 2017/848 of 17 May 2017 laying down
criteria and methodological standards on good environmental
status of marine waters and specifications and standardised
(
66
)
(
67
)
methods for monitoring and assessment, and repealing Decision
2010/477/EU (OJ L 125, 18.5.2017, p. 43),
https://eur-
lex.europa.eu/eli/dec/2017/848/oj/eng.
Communication from the Commission
–
Commission notice on
the threshold values set under the Marine Strategy Framework
Directive 2008/56/EC and Commission Decision (EU) 2017/848
(OJ C, C/2024/2078, 11.3.2024),
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=OJ:C_202402078.
Communication from the Commission
–
Commission notice on
recommendations on the 2020 updated reports for Article 11 of
the Marine Strategy Framework Directive (2008/56/EC) (OJ C,
C/2023/2203,
10.5.2023),
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF.
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Notable progress was achieved for sea-floor integrity
(D6) and hydrographical changes (D7), while gaps
remained unaddressed for eutrophication (D5),
contaminants (D8) and, in particular, food webs (D4).
Except for biodiversity (D1), sea-floor integrity (D6) and
marine litter (D10), no new measures were put in place.
Therefore, progress depended solely on measures arising
from other legislative and policy frameworks.
For D4, while the Netherlands stated that GES would be
achieved through the implementation of D1 and D6
measures, there is a need for descriptor-specific
measures, as key pressures remain insufficiently
covered.
The
third update of the Union list
entered into force on
2 August 2022 (
70
). The fourth update is in preparation.
The IAS Regulation (
71
) currently lists 88 species subject
to restrictions on keeping, importing, selling, breeding,
growing and releasing into the environment. Member
States are required to take measures to (i) prevent the
introduction of IAS, (ii) ensure early detection and rapid
eradication of IAS and (iii) manage species that are
already widespread on their territory.
This aligns with target 6 of the GBF to reduce the
introduction of IAS by at least 50 % by 2030 and minimise
their impact.
Preventing the introduction and spread of IAS, and
managing them, including through eradication and
control, can result in a substantial cost saving. Studies
estimate that the total cost of IAS in Europe (damages
and management) amounted to EUR 116.61 billion
between 1960 and 2020 (
72
). More recent studies have
put this cost at USD 28 billion per year in the EU,
increasing to USD 148.2 billion by 2040 (
73
), and at
USD 423 billion annually at the global level (
74
).
The BDS aims to manage recognised IAS and decrease the
number of
‘red
list’ species they threaten by 50 %.
According to a report (
75
) on the review of the application
of the IAS Regulation for 2015–2018, the implementation
of the IAS Regulation is already starting to deliver on its
objectives, such as creating a coherent framework for
addressing IAS at the EU level and increased awareness
of the problem of IAS, including among the public. At the
same time, the above report identified some challenges
and areas for improvement. Given that the deadlines for
implementing the various obligations of the IAS
Regulation applied gradually between July 2016 and July
2019, it is premature to draw conclusions on several
aspects of the implementation of the IAS Regulation.
The total number of IAS of Union concern in the country
is 59. This includes 37 species recorded in the previous
2025 priority action:
•
Report updates on the assessment of the state of the
Netherlands’
marine waters, its targets and its
determinations of GES (
68
), which are expected to
include any threshold values for the descriptors in
the MSFD that may have been established in
cooperation with other Member States at the EU or
regional level.
Prevention and management of invasive alien
species
IAS are a major cause of biodiversity loss in the EU.
Besides inflicting direct and indirect damage on nature
and the economy, some IAS also carry and spread
infectious diseases, posing a threat to humans and
wildlife. Regulation (EU) No 1143/2014 (the IAS
Regulation) aims to prevent, minimise and mitigate the
adverse impacts of IAS on biodiversity. It focuses action
on a list of IAS of EU concern (the
‘Union
list’), which is
regularly updated (
69
).
(
68
)
(
69
)
(
70
)
(
71
)
In accordance with Article 17 of Directive 2008/56/EC.
Commission Implementing Regulation (EU) 2016/1141 of 13 July
2016 adopting a list of invasive alien species of Union concern
pursuant to Regulation (EU) No 1143/2014 of the European
Parliament and of the Council (OJ L 189, 14.7.2016, p. 4), as
amended by Commission Implementing Regulations (EU)
2017/1263, (EU) 2019/1262 and (EU) 2022/1203,
https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN.
Commission Implementing Regulation (EU) 2022/1203 of 12 July
2022 amending Implementing Regulation (EU) 2016/1141 to
update the list of invasive alien species of Union concern (OJ
L 186, 13.7.2022, p. 10),
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203.
Regulation (EU) No 1143/2014 of the European Parliament and
of the Council of 22 October 2014 on the prevention and
management of the introduction and spread of invasive alien
species (OJ L 317, 4.11.2014, p. 35).
(
72
)
(
73
)
(
74
)
(
75
)
Haubrock, P. J., Turbelin, A. J., Cuthbert, R.
N. et al., ‘Economic
costs of invasive alien species across Europe’,
NeoBiota,
Vol. 63,
2021, pp. 153–190.
Henry, M., Leung, B., Cuthbert, R.
N. et al., ‘Unveiling the hidden
economic toll of biological invasions in the European Union’,
Environmental Sciences Europe,
Vol. 35, No 1, 2023, p. 43.
IPBES (Intergovernmental Science-Policy Platform on
Biodiversity and Ecosystem Services),
Summary for
Policymakers
–
Invasive alien species assessment,
2023,
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment.
Report from the Commission to the European Parliament and
the Council on the review of the application of Regulation (EU)
No 1143/2014 of the European Parliament and of the Council of
22 October 2014 on the prevention and management of the
introduction and spread of invasive alien species,
COM(2021) 628 final of 13 October 2021,
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52021DC0628.
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EIR (2021) and 22 additions. Of these 22 additions, 12
were already on the Union concern list in 2021, and 10
were added later under Commission Implementing
Regulation (EU) 2022/1203.
For the distribution of IAS of EU concern, see Figure 15.
Figure 15: Number of IAS of EU concern, based on
available georeferenced information for the
Netherlands, 2024
biodiversity observation and reporting on ecosystem
condition in the EU (
77
).
The amended Regulation (EU) No 691/2011 on European
environmental economic accounts (
78
) introduces new
requirements for Member States to report on the
condition of ecosystems including urban ecosystems,
croplands, grasslands, forest and woodlands, coastal
beaches, dunes and wetlands. Data reported by the
Member States will feed into the second European
ecosystem assessment, due in 2027, and can also be used
to support policy decisions.
An ecosystem assessment is an analysis of the condition
of ecosystems and the pressures acting on them, as well
as the benefits that they provide to people, either
directly or indirectly through the economy.
The Dutch Atlas of Natural Capital was launched in 2015.
All content has now been translated into English. To
improve the quality of data, the Netherlands natural
capital model was developed based on a national land
cover and ecosystem units map. The model consists of a
set of input maps, a simulation tool and output maps,
which define the relationship between the ecosystems
and the services they provide. The services are simulated
at a 100 m and a 10 m grid scale. The applicability of the
maps was tested in various pilots studies, in cooperation
with various stakeholders. For communication purposes,
a brochure on the Dutch Atlas of Natural Capital has been
developed.
In 2016, the TEEB City project delivered a tool that
calculates the monetary value of green areas in cities.
The tool has been further developed into a high-
resolution map-based tool
–
the Green Benefits
Planner
–
to analyse and predict the benefits (and costs)
of different scenarios for green infrastructure in an urban
environment (
79
), which is being implemented in green
infrastructure planning in a growing number of cities. The
Netherlands Environmental Assessment Agency
conducted an extensive programme from 2014 to 2016
involving conceptual analysis, cross-sectoral evaluations
and case studies, all focusing on the application of The
Economics of Ecosystems and Biodiversity model in
practice. After successful pilots (phase I) in some
municipalities and provinces, the Central Bureau for
Statistics, together with Wageningen University &
Research, developed a national natural capital account in
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en.
Proposal for a regulation of the European Parliament and of the
Council amending Regulation (EU) No 691/2011 as regards
introducing new environmental economic accounts modules,
COM(2022) 329 final of 11 July 2022,
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN.
https://atlasnatuurlijkkapitaal.nl/groene-baten-planner.
2025 priority actions
•
Step up implementation of the IAS Regulation,
including with regard to enforcement and the
capacity of inspection authorities.
Ensure regional cooperation with neighbouring
Member States to address predominant pressures.
•
Ecosystem assessment and accounting
The BDS calls on Member States to better integrate
biodiversity considerations into public and business
decision-making at all levels and to develop natural
capital accounting.
Similarly, target 14 of the GBF (
76
) aims to ensure the full
integration of biodiversity and its multiple values into
policy and planning and, as appropriate, national
accounting. This requires effective and coherent
(
76
)
Decision 15/4 adopted by the Conference of the Parties to the
Convention on Biological Diversity: Kunming–Montreal global
biodiversity
framework
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf).
European Commission: Joint Research Centre and EEA,
EU
Ecosystem Assessment
–
Summary for policymakers,
Publications Office of the European Union, Luxembourg, 2021,
https://op.europa.eu/en/publication-detail/-
(
78
)
(
77
)
(
79
)
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Experimental Ecosystem Accounting is an integrated and
comprehensive statistical framework that is based on five core
accounts: ecosystem extent, ecosystem condition, ecosystem services
and monetary ecosystem assets.
Source:
Mapping and Assessment for Integrated Ecosystem Accounting
(EU Horizon 2020 project) portal, 2022.
2018, building on the System of Environmental Economic
Accounting (SEEA)
–
Experimental Ecosystem Accounting
and MAES frameworks. This account was the first of its
kind in the Netherlands, and was updated in 2021.
Further work is under way to improve and extend this
account, to test its applicability to national and regional
planning and to populate indicators in the national
Monitor of Well-being and the Sustainable Development
Goals.
In 2016, an international conference on natural capital
(‘Let’s talk business!’) took place in The Hague. In
addition, the Wealth Accounting and the Valuation of
Ecosystem Services policy forums in 2016 and 2017 took
place in The Hague.
In 2018, a national guide was published on accounting for
impacts on ecosystems and ecosystem services in
societal cost–benefit analyses.
The Netherlands has provided up-to-date information
and progress has been recorded since January 2016
(Figure 16). This assessment is based on 27
implementation questions and is updated every six
months.
Figure 16: Esmeralda MAES barometer, January 2016–
March 2021
The Netherlands has a high level of expertise in
ecosystem accounting. This is reflected in the high
number of accounts published. The extent and condition
accounts are available at the regional and national levels.
A wide variety of ecosystem services are incorporated in
the
Netherlands’
accounts on (i) ecosystem assets, (ii)
biophysical assets and (iii) monetary supply and use for
ecosystem services. These accounts were set up in 2013,
2018 and 2020, thus enabling trend analyses. On specific
issues, accounts are published on carbon and
biodiversity, and a marine account at the national level is
being developed.
The Netherlands faces difficulties similar to those often
highlighted in international meetings, for example during
the revision process for the SEEA
–
Ecosystem
Accounting guidelines. It is actively trying to engage
policymakers and other stakeholders in the accounting
process and looking for relevant key indicators and
information on the usage of the accounts. Their marine
and biodiversity accounts need further development and
still have some data gaps.
An increasing number of platforms, networks and
communities of practice involve businesses in protecting
biodiversity, including the EU Business & Biodiversity
Platform (
77
). These platforms and communities are key
tools for promoting and facilitating natural capital
assessments among businesses and financial services
providers.
Source:
European Commission: Joint Research Centre, Publications
Office
of
the
European
Union,
Luxembourg,
2021,
https://data.europa.eu/doi/10.2760/846428,
p. 80.
Figure 17: SEEA
–
Ecosystem Accounting barometer,
September 2021
Natural capital assessments help private businesses to
better understand both the negative and positive
impacts that they have on nature, and to appreciate how
nature contributes to their success. Such understanding
contributes to the implementation of the EU’s BDS.
An important line of action has been to stimulate
business and financial institutions to account for natural
capital impacts, dependencies and risks in their
operations, in order to fulfil their corporate social
responsibilities and to develop innovative and more
sustainable services and supply chains. From 2017
onwards, a government-funded
‘societal
natural capital
programme’ was set up and implemented by CSR
Netherlands to inspire, stimulate and facilitate
businesses in different economic sectors to respond to
these challenges. Moreover, the development of
cooperation on protocols, tools and data for natural
capital and biodiversity accounting in the financial sector
has been strongly supported. To this end, the Dutch
government has also invested in improving the quality,
NB: The Mapping and Assessment for Integrated Ecosystem Accounting
uses the SEEA
–
Experimental Ecosystem Accounting as the
methodological basis for ecosystem accounting. The SEEA
–
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usability and number of certified data in the Ecosystem
Services Valuation Database (
80
) (or The Economics of
Ecosystems and Biodiversity database).
The MAIA project can facilitate the exchange of methods
and knowledge between members and the Netherlands
is eager to support other partners. Other specific needs
include developing an improved data viewer for
interested stakeholders who are unable to use the GIS
datasets.
Three Dutch organisations are members of the EU
Business & Biodiversity Platform, one business
sustainability network and two business-linked public
authorities.
(
80
)
https://www.esvd.info/.
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3. Zero pollution
Clean air
EU clean air policies and legislation have successfully
reduced emissions of key air pollutants and significantly
improved air quality, which is now moving towards the
levels recommended by the World Health Organization
(WHO). This has resulted in clear health benefits and
reduced adverse impacts on ecosystems and biodiversity.
However, to achieve the WHO-recommended levels, more
efforts are needed, including full compliance with EU
legislation. To guide these efforts, the EU zero pollution
action plan sets targets for 2030 relative to 2005. These
are to reduce the health impacts of air pollution by 55 %
and to reduce the EU ecosystems threatened by air
pollution by 25 %.
The EU has developed a comprehensive suite of air quality
policies (
81
). These set health-based EU air quality
standards (
82
) and stipulate Member States’ national
emission reduction commitments (
83
) for several air
pollutants.
The air quality in the Netherlands is generally good with
some exceptions.
The latest available annual estimates (for 2021) by the
European Environment Agency (
84
) for the Netherlands
attribute 5 700 deaths each year (or 59 000 years of life
lost (YLL)) to fine particulate matter (PM
2.5
) (
85
); 1 800
deaths each year (or 18 300 YLL) to nitrogen dioxide
(NO
2
) (
86
); and 430 deaths each year (or 4 700 YLL) to
ozone (
87
).
The emissions of several air pollutants have decreased
significantly in the Netherlands since 2005, while GDP
growth has continued (see Figure 18). According to the
inventories submitted under Article 10(2) of the National
Emission Reduction Commitments Directive (NECD) (
88
) in
2024, the Netherlands met its emission reduction
commitments for 2020–2029 for air pollutants nitrogen
(
81
)
(
82
)
European Commission,
‘Air’, European Commission website,
https://environment.ec.europa.eu/topics/air_en.
European Commission,
‘EU air quality standards’,
European
Commission
website,
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en.
European Commission,
‘Reducing emissions of air pollutants’,
European
Commission
website,
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en.
EEA,
Harm to human health from air pollution in Europe: Burden
of disease 2024,
briefing No 21/2024, Copenhagen, 2024,
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024.
Particulate matter (PM) is a mixture of aerosol particles (solid and
liquid) covering a wide range of sizes and chemical compositions.
PM
10
refers to particles with a diameter of 10 µm or less. PM
2.5
oxides (NO
x
), non-methane volatile organic compounds
(NMVOC), sulphur dioxide (SO
2
), ammonia (NH
3
) and
PM
2.5
. According to the latest projections submitted under
Article 10(2) of the NECD, the Netherlands is projected to
meet its emission reduction commitments for 2030
onwards for NO
x
, NMVOC, SO
2
, NH
3
and PM
2.5
.
The Netherlands submitted its updated national air
pollution control programme (NAPCP) to the Commission
on 5 December 2023.
Figure 18: Emission trends of main pollutants / GDP in
the Netherlands (%), 2005–2022
200%
150%
100%
50%
0%
NH₃
PM2.5
NMVOC
SO₂
NOₓ
GDP
Source:
EEA, ‘National air pollutant emissions data viewer 2005–2022’,
25 June 2024,
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022.
(
86
)
(
83
)
(
87
)
(
84
)
(
88
)
(
85
)
refers to particles with a diameter of 2.5 µm or less. PM is emitted
from many human sources, including combustion.
Nitrogen dioxide (NO
2
) here pertains to a group of gases called
NO
x
, which also comprises nitrogen monoxide (NO). NO
x
is emitted
during fuel combustion
–
for example, from industrial facilities and
the road transport sector.
Low-level ozone is produced by photochemical action on
pollution. This year, for the first time, the impact of long-term
exposure to ozone has also been taken into account. In previous
analysis by the EEA, only the impact of short-term exposure was
estimated.
Directive (EU) 2016/2284 of the European Parliament and of the
Council of 14 December 2016 on the reduction of national
emissions of certain atmospheric pollutants, amending Directive
2003/35/EC and repealing Directive 2001/81/EC (OJ L 344,
17.12.2016,
p. 1),
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG.
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Figure 19: PM
2.5
and NO
x
emissions by sector in the
Netherlands (%), 2022
100%
80%
60%
2025 priority actions
•
As part of the NAPCP, take action to reduce emissions
of air pollutants.
•
Ensure full compliance with the current AAQD
standards, also in light of future stricter requirements
under the revised AAQD.
Industrial emissions
40%
20%
0%
Waste
Transport
Residential,
commercial &
institutional
Manufacturing
and extractive
industry
Energy supply
Agriculture
PM2.5
PM
2.5
3,51%
23,31%
33,56%
NOₓ
0,15%
56,47%
6,40%
34,23%
1,81%
3,59%
10,30%
10,03%
16,64%
The main objectives of EU policy on industrial emissions
are to:
—
protect air, water and soil and to prevent harmful
effects on human health and the environment;
—
prevent and manage waste;
—
improve energy and resource efficiency, including
water;
—
contribute to decarbonisation.
The cornerstone of the policy is the Industrial Emissions
Directive (IED), which was revised in 2024 (
91
). The revision
improves the directive’s contribution to the zero pollution
objective. It has a strong focus on innovation, and builds
solid links between depollution, decarbonisation and
circularity, making it a key regulatory tool to accompany
the green transformation of EU industry by 2050.
The overview of industrial activities regulated by the IED
below is based on data reported to the EU Registry in
2022 (
92
).In the Netherlands, about 4 400 installations
were covered by the IED in 2022, with more than half of
them (61 %) being installations for intensive rearing of
poultry or pigs. The other main sectors covered are the
waste management sector (21 %), the food and drink
industry (6 %), the chemical sector (4 %) and the metals
sector (3 %).
Figure 20 shows the damage to health and the
environment due to the main industrial air pollutants. As
this depends on, among other factors, the size of the
industrial sector in each Member State, the figure also
shows the ratio between the damage and the industrial
activity (expressed in gross value added (GVA)), which
gives an indication of the emissions
‘intensity’.
The
Netherlands has the eighth highest damage in the EU and
comes 10th for the emissions intensity, below the EU
average of EUR 27.5/EUR 1 000 GVA. The main industrial
Source:
EEA, ‘National air pollutant emissions data viewer 2005–2022’,
25 June 2024,
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022.
In 2023, no exceedances above the limit values
established by the Ambient Air Quality Directive
(AAQD) (
89
) were registered in the Netherlands (
90
).
In the 2022 EIR, the Netherlands received two priority
actions. The first priority action was to further reduce
emissions in the context of the NAPCP. The Netherlands
has made substantial progress on this, as the latest
reported data show that the 2020–2029 emission
reduction commitments have been met, and the emission
reduction commitments for 2030 onwards are projected
to be reached. The second priority action was to ensure
full compliance with EU air quality standards and maintain
downward emission trends. Based on the latest data, the
Netherlands has fulfilled this priority action. Full
compliance has been ensured for all limit values and target
values. Additionally, since 2019, downward emission
trends have been reported for all main pollutants.
(
89
)
(
90
)
(
91
)
Directive 2008/50/EU of the European Parliament and of the
Council of 21 May 2008 on ambient air quality and cleaner air for
Europe
(OJ
L 152,
11.6.2008,
p. 1),
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050.
EEA,
Eionet
Central
Data
Repository
(https://cdr.eionet.europa.eu/).
Directive 2010/75/EU of the European Parliament and of the
Council of 24 November 2010 on industrial and livestock rearing
(
92
)
emissions (integrated pollution prevention and control) (OJ L 334,
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the
European Parliament and of the Council of 24 April 2024,
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299.
EEA,
European
Industrial
Emissions
Portal,
https://industry.eea.europa.eu/,
2022 being the baseline year for
all reports.
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The Netherlands 28
contributors to emissions to air (
93
) are the energy and
chemicals sector for NO
X
emissions, the energy-refining
sector for SO
2
and the metals sector for heavy metals.
Figure 20: Industrial air pollution damage and intensity
per Member State, 2021
below the EU average intensity of 0.864 kg /billion EUR
GVA). As shown in Figure 23, the main industrial
contributor to emissions to water in the Netherlands is the
waste management sector for heavy metals, nitrogen,
total organic carbon and phosphorus.
Figure 22: Industrial releases and intensity of heavy
metals to water per Member State, 2022
Source:
EEA, ‘Industrial pollution intensity indicators –
EU large industry
air pollution damage costs intensity’, European Industrial Emissions
Portal,
2024,
https://industry.eea.europa.eu/analyse/industrial-
emissions-indicator.
Overall, the industrial emissions to water in the EU have
decreased over time for all the main pollutants. On
average in the EU, they appear to be decoupled from the
industrial activity which has increased over the same
period (expressed in GVA), as shown in Figure 20.
Figure 21: Industrial releases of pollutants to water and
industrial activity in the EU-27
Source:
EEA, ‘Industrial pollution intensity indicators –
EU large industry
water pollution intensity’, European Industrial Emissions Portal, 2024,
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator.
Figure 23: Relative releases to water from industry in
the Netherlands (%), 2022
100%
75%
50%
25%
0%
Heavy Metals Heavy Metals Polycyclic Total nitrogen Total organic
Total
Ecotoxicity
Human
aromatic
carbon (TOC) phosphorus
Toxicity
hydrocarbons
(PAHs)
Chemicals
Ferrous metal
Food and drink
Incineration with energy recovery
Landfill
Other waste management
Pulp, paper and wood
Refineries
NB: Cd, cadmium; Hg, mercury; Ni, nickel; Pb, lead; TOC, total organic
carbon; total N, total nitrogen; total P, total phosphorous.
Source:
EEA, ‘Industrial pollutant releases to water in Europe’, 30
May
2024,
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water.
Source:
EEA, ‘Industrial reporting under the Industrial Emissions Directive
2010/75/EU and European Pollutant Release and Transfer Register
Regulation (EC) No 166/2006
–
ver.
12.0 Sep. 2024 (tabular data)’, EEA
Geospatial
Data
Catalogue,
13 September
2024,
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0.
Concerning the Netherlands in particular, Figure 21 shows
the industrial emissions of heavy metals to water, taking
into account the human toxicity of each metal, as well as
emissions
‘intensity’,
based on the ratio with the industrial
activity (expressed in GVA). The Netherlands has the 8th
highest amount of emissions of heavy metals to water,
and is in 12th position for emission intensity (slightly
IED provisions on public information and participation
require Member States to adopt transposition legislation
enabling members of the public to have access to relevant
information and participate in the approval process for
potentially polluting installations. Thus, the public and
non-governmental organisations (NGOs), alongside
competent authorities, play a role in ensuring compliance
of these permits with EU legislation. The IED contains
mandatory requirements on environmental inspections,
requiring a site visit to take place at least every 1–3 years,
using risk-based criteria. In addition, IED enforcement
(
93
)
European Environment Agency, LRTAP, Air pollutant
emissions data viewer (Gothenburg Protocol, LRTAP Convention) 1990-
2022,
https://www.eea.europa.eu/en/topics/in-depth/air-pollution/air-
pollutant-emissions-data-viewer-1990-2022.
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•
Ensure effective public participation and access to
justice in relation to the IED.
provisions require Member States to determine effective,
proportionate, and dissuasive penalties applicable to
infringements of IED-based national provisions. In the
revised directive, the provisions set that worst
infringements can be sanctioned by fines of at least 3% of
the annual EU turnover of the legal person. The revised
IED also introduces a right to compensation for people
whose health has been harmed by such infringements.
The development of best available techniques (BATs), BAT
reference documents and BAT conclusions ensures
effective collaboration between stakeholders and enables
better implementation of the IED.
Since the 2022 EIR, the Commission has adopted BAT
conclusions on (i) ferrous metal processing, (ii) the textiles
industry, (iii) common waste gas management and
treatment systems in the chemical sector and (iv)
smitheries and foundries.
The Commission relies on the efforts of national
competent authorities to implement the legally binding
BAT conclusions and associated BAT emission levels in
environmental permits. This should result in considerable
and continuous reductions in pollution.
In 2022, the Netherlands received priority actions to
address pollution from the metal sector, especially from
the Tata Steel plant, and to improve reporting to the
European Pollutant Release and Transfer Register.
Data are not yet available to assess progress towards the
first priority action; nevertheless, Tata Steel remained
among the 30 (19th) iron and steel plants with the highest
damage costs due to pollution in 2021 (
94
). As regards
reporting under the Industrial Emissions Portal
Regulation (
95
) (replacing the European Pollutant Release
and Transfer Register Regulation), the priority action has
been fulfilled, as the data are reported on time.
Major industrial accidents prevention
–
Seveso
The main objectives of EU policy on the prevention of
major industrial accidents are to:
—
control major-accident hazards involving dangerous
substances, especially chemicals;
—
limit the consequences of such accidents for human
health and the environment;
—
continuously
improve
the
prevention
of,
preparedness for and response to major accidents.
The cornerstone of the policy is Directive 2012/18/EU (the
Seveso III Directive)
(
96
)
.
The overview below of industrial plants regulated by the
Seveso III Directive (‘Seveso establishments’) is based on
data reported on eSPIRS (e-Seveso Plants Information
Retrieval System) for 2022–2024 (
97
) and the report by the
Netherlands on the implementation of the Seveso III
Directive for 2019–2022 (
98
).
In the Netherlands, in 2024, among the 384 Seveso
establishments, 163 were categorised as lower-tier
establishments and 221 as upper-tier establishments
(UTEs), based on the quantity of hazardous substances
likely to be present. UTEs are subject to more stringent
requirements. The change in the number of Seveso
establishments is presented in Figure 24.
Figure 24: Number of Seveso establishments in the
Netherlands, 2018, 2022 and 2024
2025 priority actions
•
Reduce industrial air pollution damage and intensity.
•
Reduce industrial releases to water and their intensity.
•
Engage with industry and environmental NGOs to
ensure proper contribution to and implementation of
BAT conclusions; and ensure timely updates to permits
following the publication of BAT conclusions.
NB: LTE, lower-tier establishment.
(
94
)
(
95
)
EEA,
The costs to health and the environment from industrial air
pollution in Europe
–
2024 update,
briefing No 24/2023,
Copenhagen,
2024,
https://www.eea.europa.eu/publications/the-cost-to-health-
and-the.
Regulation (EU) 2024/1244 of the European Parliament and of the
Council of 24 April 2024 on reporting of environmental data from
industrial installations, establishing an industrial emissions portal
and repealing Regulation (EC) No 166/2006 (OJ L, 2024/1244,
2.5.2024),
https://eur-lex.europa.eu/eli/reg/2024/1244/oj/eng.
(
96
)
(
97
)
(
98
)
Directive 2012/18/EU of the European Parliament and of the
Council of 4 July 2012 on the control of major-accident hazards
involving dangerous substances, amending and subsequently
repealing Council Directive 96/82/EC (OJ L 197, 24.7.2012, p. 1),
https://eur-lex.europa.eu/eli/dir/2012/18/oj.
https://espirs.jrc.ec.europa.eu/en/espirs/content;
data extracted
in September 2024.
As provided for by Article 21(2) of the Seveso III Directive.
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Sources: European Commission: Directorate-General for Environment,
Assessment and summary of Member States’ implementation reports for
Implementing Decision 2014/896/EU (implementing Directive
2012/18/EU on the control of major accident hazards involving
dangerous substances), Publications Office of the European Union,
Luxembourg,
2022,
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;
eSPIRS data, extractions from 2022 and
2024; Analysis and summary of Member States' reports on
implementation of Directive 2012/18/EU on the control of major accident
hazards involving dangerous substances according to the format
established by Commission Implementing Decision 2014/896/EU -
Publications Office of the EU,
https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en.
behaviour to take in the event of a major accident; and the
date of the last site visit.
The shares of UTEs for which information on safety
measures and requisite behaviours was actively made
available to the public in 2022 in the EU-27 are presented
in Figure 26(
99
). This provision on knowledge is an
important provision of the Seveso III Directive, as
awareness by the public of this information may
ameliorate the consequences of a major industrial
accident.
Figure 26: Share of UTEs for which information on safety
measures and requisite behaviours were actively made
available to the public per Member State (%), 2022
Member States are required to draw up external
emergency plans (EEPs). These EEPs are essential to allow
proper preparation and effective implementation of the
necessary actions to protect the environment and the
population should a major industrial accident occur.
According to the Netherlands, in 2022, an EEP was
required for 214 UTEs. In the same year, 194 UTEs had a
plan and 186 of these had been tested over the previous
three years. The summary is shown in Figure 25.
Figure 25: Situation regarding EEPs in the Netherlands,
2022
NB: No data available for Greece.
Sources: European Commission: Directorate-General for Environment,
Assessment and summary of Member States’ implementation reports for
Implementing Decision 2014/896/EU (implementing Directive
2012/18/EU on the control of major accident hazards involving
dangerous substances), Publications Office of the European Union,
Luxembourg,
2022,
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;
eSPIRS data, extractions from 2022 and
2024; Analysis and summary of Member States' reports on
implementation of Directive 2012/18/EU on the control of major accident
hazards involving dangerous substances according to the format
established by Commission Implementing Decision 2014/896/EU -
Publications Office of the EU,
https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en.
Sources: European Commission: Directorate-General for Environment,
Assessment and summary of Member States’ implementation reports for
Implementing Decision 2014/896/EU (implementing Directive
2012/18/EU on the control of major accident hazards involving
dangerous substances), Publications Office of the European Union,
Luxembourg,
2022,
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;
eSPIRS data, extractions from 2022 and
2024; Analysis and summary of Member States' reports on
implementation of Directive 2012/18/EU on the control of major accident
hazards involving dangerous substances according to the format
established by Commission Implementing Decision 2014/896/EU -
Publications Office of the EU,
https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en..
In 2022, the Netherlands received a priority action to
strengthen control and enforcement to ensure
compliance with Seveso III Directive provisions, especially
those on EEPs. Data reported on the implementation of
the directive for 2019–2022 show that the number of EEPs
established for UTEs in the Netherlands is still insufficient,
as well as the number of EEPs tested.
The information for the public referred to in Annex V to
the Seveso III Directive is permanently available for all
UTEs in the Netherlands. This applies especially to
information on how the public concerned will be warned
in the event of a major accident; the appropriate
2025 priority action
•
Strengthen compliance with requirements on safety
measures to prevent major accidents and ensure
appropriate preparedness and response in relation to
UTEs, in particular as regards reviewing, testing and
(
99
) No data available for Greece
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The Netherlands 31
updating EEPs, at intervals of no more than three
years.
the zero pollution action plan sets as a 2030 target a 30 %
reduction compared with 2017 in the share of people
chronically disturbed by transport noise.
Excessive noise from aircraft, railways and roads is one of
the main causes of environmental health‐related issues in
the EU. It can cause ischaemic heart disease, stroke,
interrupted sleep, cognitive impairment and stress (
101
).
In the Netherlands, environmental noise is estimated to
cause at least around 680 cases of ischaemic heart disease
annually (
102
) and some 130 000 people to suffer from
disturbed sleep(
103
).
Based on the latest set of information analysed, the
Netherlands have completed its noise mapping of roads,
railways and airports, while noise mapping of
agglomerations remains incomplete.
Action plans for noise management for agglomerations,
roads, railways and airports must be updated and
submitted to the Commission every five years. The
deadline for reporting noise action plans under the most
recent reporting cycle was 18 January 2025: these plans
have not been assessed yet.
Mercury Regulation
The Mercury Regulation establishes measures and
conditions concerning the use and storage of and trade in
mercury, mercury compounds and mixtures of mercury,
the manufacture and use of and trade in mercury-added
products and the management of mercury waste, in order
to ensure a high level of protection of human health and
the environment from anthropogenic emissions and
releases of mercury and mercury compounds. The revision
of the Mercury Regulation adopted in 2024 sets out rules
to address the last intentional uses of mercury in the EU
by phasing out the use of dental amalgam by 1 January
2025 except when deemed strictly necessary by the dental
practitioner based on the specific medical needs of the
patient, and prohibiting the manufacture and export of
additional mercury-containing lamps from 1 January 2026
or 1 January 2027 (depending on the lamp category).
Measures should have been put in place in the
Netherlands to ensure a socially and economically sound
phase-out of dental amalgam, including the adequate
reimbursement of the alternatives through the health
insurance scheme and the training of dental practitioners.
The Commission is monitoring whether the phase-out has
taken place under the terms and conditions of the
regulation. The Netherlands will also need to ensure that
the manufacture and export of mercury-containing lamps
are prohibited by the deadlines set out in the Mercury
Regulation.
2025 priority actions
•
Complete noise mapping
•
Complete and implement action plans on noise
management.
Water quality and management
EU legislation and policy requires that the impact of
pressures on transitional, coastal and fresh water
(including surface waters and groundwater) be
significantly reduced. Achieving, maintaining or enhancing
a good status of waterbodies as defined by the Water
Framework Directive will ensure that EU citizens and the
environment benefit from good quality and safe drinking
and bathing water. It will further ensure that the nutrient
cycle (nitrogen and phosphorus) is managed in a more
sustainable and resource-efficient way.
Noise
The Environmental Noise Directive (
100
) requires a
common approach to avoid, prevent and reduce the
harmful effects of noise. The designated authorities are
responsible for making and approving noise maps and
action plans for agglomerations, major roads, major
railways and major airports. Member States decide on
noise limits that are not set at the EU level. Nevertheless,
(
100
)
(
101
)
(
102
)
Directive 2002/49/EC of the European Parliament and of the
Council of 25 June 2002 relating to the assessment and
management of environmental noise
–
Declaration by the
Commission in the Conciliation Committee on the directive
relating to the assessment and management of environmental
noise (OJ L 189, 18.7.2002, p. 12),
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049.
WHO,
Environmental Noise Guidelines for the European Region,
Copenhagen,
2018,
https://www.who.int/europe/publications/i/item/978928905356
3.
These figures are an estimation by the EEA based on (i) the data
reported by Member States on noise exposure covered by
Directive 2002/49/EC for the round of noise mapping of 2022 ; (ii)
(
103
)
European Topic Centre on Air Pollution, Transport, Noise and
Industrial Pollution (ETC/ATNI),
Noise Indicators under the
Environmental Noise Directive 2021: Methodology for estimating
missing data,
Eionet report ETC/ATNI No 2021/06, Kjeller, 2021;
and (iii) the methodology for health impact calculations in
European Topic Centre on Air Pollution and Climate Change
Mitigation (ETC/ACM),
Implications of environmental noise on
health and wellbeing in Europe,
Eionet report ETC/ACM
No 2018/10,
Bilthoven,
2018,
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise.
More information on the adverse health effects of noise pollution
is available at:
https://www.eea.europa.eu/themes/human/noise/noise-2
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Water Framework Directive
The Water Framework Directive (
104
) is the cornerstone of
EU water policy (
105
). The Water Framework Directive and
other water-related directives (
106
)
form the basis of
sustainable and integrated water management in the EU.
They aim to achieve a high level of protection of water
resources, prevention of further deterioration and
restoration to good status. These objectives are very
important for the EU’s competitiveness, strategic
autonomy and security, yet have become even more
challenging in the face of climate change affecting our
precious water resources.
The Water Framework Directive establishes a procedural
framework for reaching good surface water ecological and
chemical status and good groundwater quantitative and
chemical status. This implies monitoring and classification
of all waterbodies, assessment of pressures and impacts
and identification of the most cost-effective measures to
achieve the objectives of the directive. The directive dates
from 2000 and set an initial deadline of 2015 for achieving
its objectives, with the option to extend the deadline to
the end of 2027. Every six years, Member States must
report their river basin management plans (RBMPs) to the
Commission. They should cover river basin districts in their
countries, some of which may be shared with other
countries. The Commission has assessed the third cycle of
RBMPs, which were to be submitted by March 2022, and
reported its findings to the European Parliament and to
the Council on 4
th
February 2025(
107
).
The Netherlands’ four river basin districts include 745
surface waterbodies and 23 groundwater bodies. Most
surface waterbodies are heavily modified (286) or artificial
(435), while only 24 are natural.
Figures 27–30 show the change in ecological
status/potential and chemical status of surface waters,
and the quantitative and chemical status of groundwater
in 2010, 2015 and 2021. Heavily modified water and
artificial waterbodies must reach good ecological
potential rather than have a good ecological status, which
means that all measures must be taken to mitigate the
adverse impact of the sustainable human development
activities causing the waterbody to be heavily
modified/artificial, while not significantly affecting these
activities
It follows from the assessment of the third RBMPs that the
ecological status/potential of surface waterbodies and
their chemical status have deteriorated compared with
the statuses reported in the second RBMPs (covering
2015–2021).
Figure 27: Ecological status/potential of surface
waterbodies in each RBMP cycle (%)
None of the surface waterbodies is in good or better
ecological status/potential.
The main pressures are a dense population, land use,
economic/agricultural activities, past pollution and
transboundary pollution. These affect hydromorphology
(canalisation, flood protection, agriculture), and result in
pollution from nitrates, fertilisers/pesticides and river-
basin-specific pollutants. The Netherlands regulate a
considerable amount of river-basin-specific pollutants
(about 80), a small subset of which cause failure to achieve
good status or potential (including ammonium, cobalt,
arsenic, selenium, silver and zinc).
(
104
)
(
105
)
(
106
)
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060.
https://environment.ec.europa.eu/topics/water_en.
These include the Groundwater Directive (https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118),
the Environmental Quality Standards Directive (https://eur-
lex.europa.eu/eli/dir/2008/105/oj),
the
Floods
Directive
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060),
the Bathing Water
Directive
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32006L0007),
the
Urban
Wastewater
Treatment
Directive
(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271),
the
new
Drinking
Water
Directive
(https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184),
the
Nitrates
Directive
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=celex%3A31991L0676),
the Marine Strategy
Framework
Directive
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056)
and the IED
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075).
(
107
)
ENV - Bibliothèque
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Figure 28: Chemical status of surface waterbodies in
each RBMP cycle (%)
Figure 30: Chemical status of groundwater bodies in
each RBMP cycle (%)
Failure to achieve good chemical status is mostly due to
exceedances of the EU environmental quality standards of
about 10 % of regulated priority substances, the most
relevant being polybrominated diphenyl ethers (79 %),
fluoranthene (27 %), mercury (26 %), benzo(g,h,i)perylene
(24.7 %), benzo(b)fluoranthene (20 %), tributyltin (15 %),
Benzo(a)pryene (6 %) and benzo(k)fluoranthene (5.8 %).
Mercury is responsible for failure in 25 % of waterbodies.
The ubiquitous presence of mercury and other ubiquitous
bioaccumulative persistent and toxic chemicals is common
to many Member States, including as a result of long-
range air deposition from other continents.
Figure 29: Quantitative status of groundwater bodies in
each RBMP cycle (%)
Compared with surface waters, a much better situation
can be seen for groundwater, partly because groundwater
is more shielded and less vulnerable to depositions of air
pollutants. As for surface waters, a small subset of
compounds is causing the problem, with all of them largely
linked to agriculture: nitrates and pesticides, chloride and
total phosphorous.
Until the end of 2027, Member States can still apply time-
related exemptions, subject to providing evidence of
compliance with the strict criteria set out in the Water
Framework Directive. After 2027, the possibilities for
applying exemptions will be much more limited.
The 2022 EIR identified the following priority actions.
•
Assess new physical modifications of waterbodies in
line with Article 4(7) of the water framework
Directive;
Continue current efforts to further reduce nitrates
pollution from agriculture in groundwater and step up
efforts to ensure the timely achievement of the
objective under the Water Framework Directive.
•
Only 1 out of 23 groundwater bodies does not have a good
quantitative status, due to water balance. Three others
are at risk of not achieving good status by 2027.
The prolonged period of drought in 2018 played a
significant role in the deterioration of the status of
groundwater bodies, as the abstraction rate was much
higher than the recharge rate. Climate-change-related
effects are likely to increase in the future and require
specific controls on abstractions and water efficiency.
The Netherlands has made some progress and seeks to
improve the link between water quality objectives and
permitting, control and enforcement systems, which have
become too decentralised and fragmented. It is also
positive that the Netherlands has a long-standing
programme
–
the delta programme
–
to combat the
consequences of and cope with climate change focusing
on (i) protection against flooding, (ii) the adequate supply
of fresh water for both drinking and agriculture and (iii)
climate-resilient spatial planning.
In 2024, the Commission opened a legal case
(INFR(2024)2161) alleging that Article 11(3) of the Water
Framework Directive must be understood as requiring
that authorisations for abstraction of and discharge into
water are always subject to periodic review and that the
review interval should not exceed 12 years. Dutch law
does not always require review or has too long review
intervals. In their response to the Commission, the Dutch
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The Netherlands 34
authorities agree that requiring review and setting review
intervals is useful for achieving the objectives of the
directive.
2025 priority actions
Without prejudice to the list of recommended actions in
the Commission report to the European Parliament and to
the Council on the assessment of the third RBMPs, the
following priority actions can be highlighted.
•
Improve river continuity and ecological flows,
boosting efforts to introduce nature-based solutions
to reduce hydromorphological pressures.
Ensure periodic reviews of permits for discharges,
abstractions and other water uses, including
hydropower pressures.
Reduce pollution from nutrients, chemicals, metals
and saline discharges.
Better justify exemptions to the achievement of good
status.
Improve the classification of water bodies and
strengthen monitoring systems;
Develop more robust programmes of measures,
tackle obstacles identified in the implementation of
measures and ensure adequate financing for
implementation, including through better use of the
cost recovery and polluter pays principle.
objectives that are tailored to the different types of flood
areas, including some measurable elements. Flood risk
management is better linked to the national climate
strategy and pluvial flooding (expected to increase due to
climate impacts) is included.
2025 priority actions
•
FRMPs should provide details on how FHRMs are used
in the choice of measures and how pluvial flooding
should be taken into account.
Better explain the choice and implementation of flood
prevention and protection measures (prioritisation,
monitoring, costs of measures).
Improve public
involvement.
consultation
and
stakeholder
•
•
•
•
•
•
•
Drinking Water Directive
The recast Drinking Water Directive is now applicable, and
Member States were required to transpose its provisions
into their national legal systems by 12 January 2023. Since
the entry into force of the recast directive, the
Commission has adopted several delegated and
implementing acts establishing (i) a watch list of
substances and compounds of concern for drinking
water (
108
), (ii) a methodology for measuring microplastics
in drinking water (
109
) and (iii) an EU system for testing and
approving materials that will be allowed to be in contact
with drinking (
110
). Member States will have to take these
various Commission acts into account when implementing
the recast directive.
Finally, the Commission has now received data from
Member States on the quality of drinking water in 2017–
2019. At this stage, the quality of drinking water (supplied
by large water suppliers) in Netherlands does not give rise
to concern (
111
).
From January 2026, the European quality standards for
per- and polyfluoroalkyl substances in drinking water will
apply, ensuring harmonised reporting by Member States
of monitoring data for per- and polyfluoroalkyl substances
in the future.
Floods Directive
Every six years, following the same reporting cycle as the
RBMPs, all Member States also report their flood risk
management plans (FRMPs), based on the flood risk
hazard maps (FRHMs) and the preliminary flood risk
assessments drawn up during the second cycle (2016–
2021).
The Commission assessed the FRMPs and reported its
findings to the European Parliament and to the Council on
4
th
February 2025, together with the assessment of the
RBMPs.
The main progress resulting from the assessment of the
second FRMP is found in more detailed, area-specific
(
108
)
(
109
)
Link eur-lex to be provided once published in OJ.
Commission Delegated Decision (EU) 2024/1441 of 11 March 2024
supplementing Directive (EU) 2020/2184 of the European
Parliament and of the Council by laying down a methodology to
measure microplastics in water intended for human consumption
(notified under document C(2024) 1459) (OJ L, 2024/1441,
21.5.2024),
http://data.europa.eu/eli/dec_del/2024/1441/oj.
OJ L,
2024/365,
23.4.2024,
http://data.europa.eu/eli/dec_impl/2024/365/oj;
OJ L, 2024/367,
23.4.2024,
http://data.europa.eu/eli/dec_impl/2024/367/oj;
OJ L,
2024/369,
23.4.2024,
http://data.europa.eu/eli/reg_del/2024/369/oj;
OJ L, 2024/368,
(
110
)
(
111
)
23.4.2024,
http://data.europa.eu/eli/dec_impl/2024/368/oj;
OJ L,
2024/370,
23.4.2024,
http://data.europa.eu/eli/reg_del/2024/370/oj;
OJ L, 2024/371,
23.4.2024,
http://data.europa.eu/eli/reg_del/2024/371/oj;
see
the Commission web page on all six delegated acts for more
information
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en).
In summary, the compliance for all parameter groups in the
Netherlands was at least 99.97 % in 2017, 99.96 % in 2018 and
99.97 % in 2019.
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The Netherlands 35
Bathing Water Directive
The bathing water directive requires Member States to
monitor and assess bathing water. It requires that, during
the bathing season, Member States disseminate to the
public information on bathing water quality actively and
promptly. In particular, notices banning or advising against
bathing should be rapidly and easily identifiable.
Figure 31 shows that in 2023, out of the 746 Dutch bathing
waters, 539 (72.3 %) were of excellent quality, 127 (17 %)
were of good quality and 31 (4.2 %) were of sufficient
quality. A total of 32 (4.3 %) bathing waters were found to
be of poor quality.
Figure 31: Bathing water quality per Member State (%),
2023
The report on the implementation of the Nitrates
Directive covering 2020–2023 will be available in 2025.
The analysis of
the Netherlands’
RBMPs has identified
nutrients from agriculture as an important pressure on
groundwater / surface waters that is affecting these
waters’
good status and as one of the main factors in not
meeting the Water Framework Directive objectives.
2025 priority action
•
Tackle nutrient pollution, especially nitrates from
agriculture, through the implementation of the
Nitrates Directive.
Urban Wastewater Treatment Directive
The Urban Wastewater Treatment Directive (UWWTD)
aims to protect human health and the environment from
the effects of untreated urban waste water. It therefore
requires Member States to collect and treat (secondary or
biological treatment) waste water in all urban areas of
more than 2 000 people, and to apply a more stringent
treatment than secondary, with nitrogen and/or
phosphorus removal, to the waste water generated in
urban areas, also known as agglomerations, of more than
10 000 people, before they are discharged into waters and
their catchments, when they are sensitive to nitrogen
and/or phosphorus (i.e. eutrophic or tending to become
eutrophic).
In the Netherlands, the compliance rate was 100 % in
2020.
Figure 32: Proportion of urban waste water that fully
complies with the UWWTD (%), 2020
Source:
EEA,
European Bathing Water Quality in 2023,
briefing
No 04/2024,
Copenhagen,
2024,
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/.
Nitrates Directive
The Nitrates Directive
112
aims to protect water quality
across Europe by preventing nitrates from agricultural
sources that can pollute groundwater and surface waters
and by promoting the use of good farming practices.
The latest Commission report on the implementation of
the Nitrates Directive (
113
), dating back to 2022, warns that
nitrates are still causing harmful pollution to water in the
EU. Excessive nitrates in water are harmful to both human
health and ecosystems, causing oxygen depletion and
eutrophication. Cleaning of waters by national authorities
or farmers, where it has been undertaken, has had a
positive impact on the drinking water supply and on
biodiversity. It has also benefited the sectors
–
such as
fisheries and tourism
–
that depend on biodiversity and on
a good supply of drinking water. Nevertheless, excessive
fertilisation remains a problem in many parts of the EU.
Source:
European Commission: Directorate-General for Environment,
Fribourg-Blanc, B., Dhuygelaere, N., Berland, J. and Imbert, F.,
12th
technical assessment of UWWTD implementation
–
Final version,
Publications Office of the European Union, 2024,
12th technical
assessment of UWWTD implementation - Publications Office of the EU.
(112)
https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211.
(
113
)
https://environment.ec.europa.eu/topics/water/nitrates_en.
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The directive has been revised(
114
). The revised directive
builds on the current
acquis,
strengthens existing
treatment standards and establishes an additional
treatment of micropollutants in urban waste water. Other
new requirements relate to moving towards the energy
neutrality of the sector, establishing an EPR system to
ensure sustainable financing of micropollutant treatment
by the most polluting industries and ensuring access to
sanitation, especially for vulnerable and marginalised
groups. The Netherlands has until 31 July 2027 to
incorporate the new directive into its national legal
system.
The Netherlands’ evaluation
of the 2022 priority action is
as follows: despite some progress being made, the
Netherlands has not fully implemented the UWWTD.
ensures stability and predictability for businesses
operating in the internal market.
Since 2007, the Commission has gathered information on
the enforcement of the Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH)
Regulation and the Classification, Labelling and Packaging
(CLP) Regulation. In December 2020, the Commission
assessed the Member States’ reports
(
117
)
on the
implementation
and
enforcement
of
these
118
regulations ( ). It is apparent from the Commission’s
report that there are still many disparities in the
implementation of the REACH and CLP Regulations,
notably in the area of law enforcement. Recorded
compliance levels in Member States, generally quite stable
over time, appear to be getting slightly worse. This may be
because (i) enforcement authorities are becoming more
effective in detecting non-compliant products/companies;
and (ii) more non-compliant products are being placed on
the EU market.
In August 2021, the Commission published a measurable
assessment of the enforcement (
119
) of the two main EU
regulations on chemicals using a set of indicators on
different aspects of enforcement. Since 2021, the list of
chemicals subject to restrictions has been expanded as
new entries have been added to Annex XVII to the REACH
Regulation (
120
).
In 2023, new hazard classes were added to the CLP
Regulation, and the revision of the regulation was tabled
(published on 20 November 2024) (
121
). The new hazard
Chemicals
The EU seeks to ensure that chemicals are produced and
used in a way that minimises any significant adverse
effects on human health and the environment. In October
2020, the Commission published its chemicals strategy for
sustainability towards a toxic-free environment (
115
),
which led to some systemic changes in EU chemicals
legislation. The strategy is part of the EU’s zero pollution
ambition
–
a key commitment of the European Green
Deal.
The EU’s chemicals legislation (
116
) provides a baseline
protection for human health and the environment. It also
(
114
)
(
115
)
(
116
)
Directive (EU) 2024/3019 of the European Parliament and of the
Council of 27 November 2024 concerning urban wastewater
treatment (recast).
Communication from the Commission to the European
Parliament, the Council, the European Economic and Social
Committee and the Committee of the Regions
–
Chemicals
strategy for sustainability: Towards a toxic-free environment,
COM(2020) 667 final of 14 October 2020,
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;
Regulation
(EC) No 1272/2008 of the European Parliament and of the Council
of 16 December 2008 on classification, labelling and packaging of
substances and mixtures, amending and repealing Directives
67/548/EEC and 1999/45/EC, and amending Regulation (EC)
No 1907/2006
(OJ
L 353,
31.12.2008,
p. 1),
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2.
Namely, Regulation (EC) No 1907/2006 of the European
Parliament and of the Council of 18 December 2006 concerning
the registration, evaluation, authorisation and restriction of
chemicals (REACH), establishing a European Chemicals Agency,
amending Directive 1999/45/EC and repealing Council Regulation
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as
well as Council Directive 76/769/EEC and Commission Directives
91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC (OJ L 396,
30/12/2006,
p. 1),
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907;
and Regulation (EC)
No 1272/2008 of the European Parliament and of the Council of
16 December 2008 on classification, labelling and packaging of
(
117
)
(
118
)
(
119
)
(
120
)
(
121
)
substances and mixtures, amending and repealing Directives
67/548/EEC and 1999/45/EC, and amending Regulation (EC)
No 1907/2006 (OJ L 353, 31.12.2008, p. 1),
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217.
European Commission,
Technical assistance to review the existing
Member States reporting questionnaire under Articles 117(1) of
REACH and 46(2) of CLP
–
Final report,
Publications Office of the
European
Union,
Luxembourg,
2020,
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details.
In line with Article 117(1) of the REACH Regulation and
Article 46(2) of the CLP Regulation.
European Commission: Directorate-General for Internal Market,
Industry, Entrepreneurship and SMEs,
REACH and CLP
Enforcement: EU-level enforcement indicators,
Publications Office
of
the
European
Union,
Luxembourg,
2021,
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/.
These are substances in tattoo inks and permanent make-up,
N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers),
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally,
microplastics.
Regulation (EU) 2024/2865 of the European Parliament and of the
Council of 23 October 2024 amending Regulation (EC) No
1272/2008 on classification, labelling and packaging of substances
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation
- EU -
2024/2865 - EN - EUR-Lex).
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The Netherlands 37
classes cover endocrine disruptors and persistence-
related hazards while the revision of the regulation
encompasses new rules on online sales to better tackle
non-compliances observed over the years. Also in 2023,
the Conference of the Parties of the Stockholm
Convention (COP) decided to include, in its Annex A (which
lists banned substances), three new chemicals (
122
). The
Commission is working on the delegated acts to include
these substances in Annex I to the Persistent Organic
Pollutants Regulation by 2025 at the latest.
Responsibility for checking compliance with the REACH
Regulation in the Netherlands lies with the following
authorities (
123
):
•
the Netherlands Food and Consumer Product Safety
Authority (as with the CLP Regulation),
•
the Human Environment and Transport Inspectorate
(as with the CLP Regulation),
•
the labour inspectorate (Inspectorate SZW),
•
State Supervision of Mines,
•
Customs Administration of the Netherlands.
The Netherlands has devised and fully implemented
enforcement strategies for both the REACH Regulation
and the CLP Regulation (
124
).
The Member States’ reporting exercise set out in
Article 117 of the REACH Regulation and Article 46 of the
CLP Regulation is conducted every five years. The results
of the coming one are expected in 2025, hence the
absence of new country-specific data on enforcement
since 2022.
In 2022, some 20–25 inspectors were (partly) involved in
REACH Regulation enforcement.
In 2020, the Netherlands participated in an EU
coordinated enforcement project on products sold online,
called the REACH-EN-FORCE (REF)-8 project (
125
). The
report was adopted in November 2021, so it could not be
taken into account in the previous EIR.
Figure 33: Compliances of imported products
–
results of
the REF-8 project
A risk approach was used for the targeting of control
measures in order to maximise the chances of identifying
non-compliances. Therefore, the non-compliance rates
presented above cannot be considered the average non-
compliance rates of products in the EU. However, the
proportion of non-compliance cases found in the REF-8
project are of concern.
(
122
)
(
123
)
These are methoxychlor, dechlorane plus and UV-328. In the case
of the pesticide methoxychlor, there are no exemptions from the
ban. However, for the two plastic additives, dechlorane plus and
UV-328, the COP decision lists some time-limited specific
exemptions.
European Commission,
Technical assistance to review the existing
Member States reporting questionnaire under Articles 117(1) of
REACH and 46(2) of CLP
–
Final report,
Publications Office of the
European
Union,
Luxembourg,
2020,
p. 70,
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details.
(
124
)
(
125
)
European Commission,
Technical assistance to review the existing
Member States reporting questionnaire under Articles 117(1) of
REACH and 46(2) of CLP
–
Final report,
Publications Office of the
European
Union,
Luxembourg,
2020,
p. 76,
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details.
European Chemicals Agency, REF-8 project report on enforcement
of the CLP, REACH and BPR duties related to substances, mixtures
and
articles
sold
online,
Helsinki,
2021,
p. 20,
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475.
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The Netherlands 38
Figure 34: Number of REF-8 checks performed per
100 000 inhabitants (EU average = 1.24)
From this project and others conducted with the help of
the European Chemicals Agency in recent years, online
sales have been proved to correspond consistently to
higher non-compliance rates in checks performed across
the EU, in particular when related to imported products.
In 2022, the Netherlands received a priority action related
to upgrading administrative capacities in implementation
and enforcement to move towards a policy of zero
tolerance of non-compliance. In the absence of reporting
since 2022, no progress has been shown and this priority
action remains valid in 2025, partly because of the
experience with the REF-8 project.
2025 priority actions
•
Upgrade
the
administrative
capacities
in
implementation and enforcement to move towards a
policy of zero tolerance of non-compliance.
•
Increase involvement in the activities of the Forum for
Exchange of Information on Enforcement of the
European Chemicals Agency, including in the
coordinated enforcement projects, called REF projects.
•
Increase customs checks and checks of products sold
online with regard to
compliance with
chemicals
legislations.
The Netherlands’ participation in the REF-8 coordinated
enforcement project was below the EU average, which is
rather low because of the lack of involvement of certain
large Member States.
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4. Climate action
The impacts of climate change have continued to increase
in recent years, inflicting damage and suffering in the EU
and around the world. Globally, 2023 was the hottest year
on record, while Europe has been warming twice as
quickly as the global average, and is now the fastest-
warming continent. The frequency and severity of
extreme climate events are also increasing. Against this
backdrop, the EU has demonstrated its determination to
implement the European Green Deal and to become
climate neutral and resilient by 2050, ensuring sustainable
competitiveness and supporting EU industry in the net-
zero transition. The European Climate Law is the EU’s
response to the need for action. It sets the objective of
achieving climate neutrality by 2050 and a midterm target
of a reduction in GHG emissions of at least 55 % by 2030,
and outlines the adaptation efforts necessary to adjust to
climate change’s present and future impacts. Almost all
the
‘Fit
for 55’ proposals set out in the European Green
Deal have been agreed in law, and the European
Commission recommended a new intermediate climate
target of a 90 % reduction in emissions by 2040. In 2024,
the Member States submitted updated national energy
and climate plans for 2021–2030, reflecting the increased
ambition of the revised EU legislation. In 2024, the
European Commission also released, jointly with the EEA,
the first-ever European climate risk assessment.
Over the last three decades, since 1990, the EU has
achieved steady decreases in its emissions, reaching a
running total in 2022 of
–32.5
% (
126
). However, the EU and
its Member States need to step up their implementation
efforts and accelerate emissions reduction to stay on track
to reach their targets of a 55 % reduction in net GHG
emissions by 2030 and climate neutrality by 2050.
Between 1990 and 2022, net GHG emissions of the
Netherlands decreased by 31 %, making it one of the
countries with a below-average decrease.
The
‘Fit
for 55’ legislative package reflects the need to
speed up the green transition. It includes (i) strengthening
and expanding the EU emissions trading system (ETS),
with the creation of a new, second, ETS for transport and
buildings together with a dedicated Social Climate Fund to
help citizens during the transition; (ii) increasing targets
under the effort sharing regulation; and (iii) a revised
regulation for Land Use, Land Use Change and
Forestry (
127
). The package has been fully adopted, and the
Member States have been implementing the legislation.
A key strategic document at country level is the National
Energy and Climate Plan (NECP) (
128
). Netherlands
submitted its updated plan on 24 June 2024, which was
ahead of the deadline set by the regulation. The European
Commission assessed the plan and the extent to which the
Netherlands has followed the recommendations for the
draft version. The findings from the assessment are:
•
Emissions under the Effort Sharing Regulation will
decrease by 39% in 2030 compared to 2005 which is
below its target of 48%. But the Netherlands is on
track to stay within its cumulative emissions cap.
The Netherlands is in line with its LULUCF target,
target for the share of renewable energy and final
energy consumption target.
•
To minimise the impacts of climate policies on vulnerable
people and sectors, the Netherlands is using the Just
Transition Fund and will use Social Climate Fund from
2026 (for more information, see Chapter 5, on Finance).
Figure 35: Total GHG emissions (excluding international
aviation) (%), 1990–2022
The EU emissions trading system
The EU ETS is the key tool for reducing GHG emissions
cost-effectively across all Member States. It is the world’s
2019-2024/european-green-deal/delivering-
european-green-deal/fit-55-delivering-proposals_en.
More information about NECP is on the dedicated
website
https://energy.ec.europa.eu/topics/energy-
strategy/national-energy-and-climate-plans-necps_en
(
126
)
(
127
)
EU net domestic emissions, including the land use, land-use
change and forestry (LULUCF) sector and excluding international
aviation.
A full overview of the Fit for 55 package is available at
https://commission.europa.eu/strategy-and-policy/priorities-
(
128
)
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The Netherlands 40
biggest carbon market, covering around 40 % of the EU’s
total GHG emissions from electricity and heat generation,
the manufacturing industry, aviation within Europe (
129
)
and, from 2024, maritime transport also.
The system sets a limit or cap on the total amount of GHGs
that can be emitted at the EU level. Within this limit,
companies buy emissions allowances (one allowance gives
the right to emit 1 t of CO
2
eq (carbon dioxide equivalent)),
in auctions or through trading allowances with others. The
cap is reduced annually to ensure that overall emissions in
the sectors covered decrease over time.
The emissions under the ETS decreased by 32 % from 2005
to 2023 in the Netherlands.
In 2023, about 39 % of greenhouse gases emitted by ETS
installations in the Netherlands came from power
generation (EU average: 57 %). Refineries accounted for
about 20 %, chemicals for 24 %, the metals industry for
8 %, while 9 % came from other industries. Between 2019
and 2023, overall ETS emissions declined by about 30 %.
Greenhouse gas emissions from refineries slightly rose, by
4 %. All other ETS sectors saw their emissions decline, by
between 18 % and 44 %. In the Netherlands, the EU ETS is
supplemented by a CO
2
levy.
From 2027, a new emissions trading system, called ETS2,
for buildings, road transport and additional sectors
(mainly industry not covered by the current ETS) will
become fully operational (
130
). Member States should
have notified full transposition the provisions of the
revised EU ETS directive related to the new ETS2 into
national law by 30 June 2024. The Netherlands did not
communicate full transposition into national law by this
deadline. The Commission therefore opened an
infringement procedure against the Netherlands on
25 July 2024, by sending a letter of formal notice for failing
to fully transpose the provisions into national law.
The Netherlands had two months to respond and address
the shortcomings raised by the Commission. In the
absence of a satisfactory response, the Commission may
decide to issue a reasoned opinion.
The Commission also opened infringement procedures
against the Netherlands on 25 January 2024, by sending a
letter of formal notice for failing to fully transpose
previous revisions of ETS directive (
131
) into national law.
The Netherlands has since notified full transpositions of
the abovementioned directives to the Commission.
Effort sharing
The Effort Sharing Regulation (ESR) (
132
) covers GHG
emissions from domestic transport (excluding CO₂
emissions from aviation), buildings, agriculture, small
industry and waste. Emissions from these sectors account
for around 60 % of the EU’s domestic emissions. The
regulation sets the EU-wide target to reduce emissions
from the effort sharing sectors by 40 % by 2030 compared
to 2005 levels. This overall target for the EU translates to
binding national emission reduction targets for each
Member State. The Netherlands’ target is
–48
%.
In addition to the 2030 targets, Member States have
annual GHG emissions limits (annual emission
allocations), reducing every year until 2030.
There is some flexibility to take account of annual
fluctuations in emissions, by trading emissions and
transfers from the ETS and LULUCF.
Based on historical emissions and the most updated
projections the Netherlands is on track to achieve its 2030
ESR target.
Projected gap is 9.3 percentage points to the 2030 target.
The largest contributor are buildings, which accounted for
32 % of all effort sharing emissions in 2022. Emissions
have decreased by 30 % since 2005 and Netherlands
should keep up the positive contribution of the residential
sector to its 2030 buildings’ targets. The share of
renewable energy in heating and cooling remains very low
(8.5 %) compared to the EU average (25 %).
Transport accounted for 30 % of effort sharing emissions
and have decreased by 28 % since 2005. The Netherlands
is an EU frontrunner in sustainable transport, but still has
room to improve. Standing at 5 % in 2023, the Netherlands
has one of the EU’s highest shares of battery electric
vehicles in its passenger car fleet (EU average is 1.2 %). In
2023, its 144 100 publicly accessible charging points
provided a charging point for every four e-vehicles, above
the EU average of 1:10. Car trips account for 87 % of
distances travelled. For freight, road transport plays a
lesser role, accounting for 49 % of tonnes transported,
while 40 % of freight is carried on inland waterways, far
higher that the EU average. Railways account for 8 % of
(
131
)
(
132
)
Directive - 2023/959 - EN - EUR-Lex
and
Directive - 2023/958 - EN
- EUR-Lex
Regulation (EU) 2018/842 (https://eur-
lex.europa.eu/eli/reg/2018/842).
(
129
)
(
130
)
Flights between the EU Member States including departing
flights to Norway, Iceland, Switzerland and the United Kingdom.
Directive (EU) 2023/959 (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG)
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passenger transport, slightly above the EU average (6 %),
as well as 6 % of freight transport. 74 % of the rail network
is electrified (EU average: 56 %).
Figure 36: Effort-sharing emissions by sector (%), 2022
Therefore, adaptation to climate change is also a key
component of climate policy.
The Netherlands has one out of three regions identified as
a hotspots of climate risks most affected by climate
change
–
namely, low-lying coastal regions (
133
).
The Netherlands is vulnerable to climate impacts, in
particular sea level rise and a higher intensity and
frequency of rainfall, heatwaves and prolonged droughts.
Economic damage caused by weather and climate-related
extreme events stood at almost EUR 10 billion in 1980–
2020. The Netherlands has a high climate protection gap
for coastal floods and a medium-high gap for floods.
The Netherlands adopted its national adaptation strategy
in 2007 and updated it in 2016. It also has a national
adaptation plan, but there are no sectoral or regional
adaptation plans.
This climate adaptation framework provides a good basis
for climate resilience, but it could be strengthened by a
legal basis for adaptation and new programmes for
specific climate threats such as changes in wind regimes,
lightning, wildfires and the spread of invasive species and
tropical diseases. There is also scope to further
mainstream adaptation across governmental policies and
long-term plans.
The European Commission identified three priority actions
in the
2022 edition
of the review. Concerning progress on
those actions, the Netherlands has made major efforts to
accelerate the deployment of renewables and renewable
power generation capacity is growing. But the overall
share of renewables remains below EU average. There is
progress in sustainable transport and the Netherlands is
the frontrunner. Energy efficiency of buildings is on the
good pathway, but the share of renewables in heating and
cooling remains below the EU average.
Land use, land-use change and forestry
The LULUCF sector plays a significant role in achieving the
EU’s climate neutrality goal. In the EU, this sector absorbs
more GHGs than it emits, removing significant volumes of
carbon from the atmosphere. Thus, it is the only sector
with negative emissions.
But that is not the case in the Netherlands. The
Netherlands’ LULUCF sector has had relatively high
emissions compared to its total land area, and has not had
negative emissions since 1990. The main source of these
emissions is agricultural land. Since 2018, there has been
a modest decline in LULUCF emissions.
The Netherlands’ target in 2030 is to enhance land
removals by an additional
−0.4
Mt of CO
2
equivalent
compared to the yearly average of the period 2016–2018.
The latest available projections show a surplus to the
target of
−1.2
Mt of CO
2
equivalent in 2030. Therefore, the
Netherlands is on track to meet its 2030 target.
2025 priority action
•
Implement all polices and measures that are needed
to achieve targets laid down in the Effort Sharing
Regulation (ESR) and the Land Use and Land-Use
Change and Forestry (LULUCF) Regulation. More
detailed priority actions are set out in the assessment
of the final National Energy and Climate Plan
(NECP)(
134
).
Adaptation to climate change
Halting all greenhouse gas emissions would still not
prevent climate impacts that are already occurring.
(
133
)
European Climate Risk Assessment (europa.eu).
(
134
)
National energy and climate plans.
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Part II: Enabling framework
–
implementation tools
5. Financing
The EU budget supports climate investment in The
Netherlands with significant amounts in 2021–2027, with
revenues from the EU ETS also feeding into the national
budget. During 2020–2022, The Netherlands’ revenues
from auctioning reached EUR 2 471 million in total, 100 %
of which was spent on climate action in 2020.
In addition, the annual investment needed to meet its
environmental objectives in the areas of pollution
prevention and control, the circular economy and waste,
water protection and management, and biodiversity and
ecosystems is estimated to be EUR 20 billion per year in
the Netherlands.
These four environmental areas currently receive total
funding of around EUR 15.9 billion per year; thus, there is
a gap of EUR 4.1 billion per year.
Of the annual environmental investment gap, the most
significant gap concerns pollution prevention and control,
at EUR 2.3 billion per year.
The RRF contributes to climate finance in the Netherlands
with EUR 2.99 billion up to 2026, representing 54.9 % of
the national RRP (
137
).
The European Investment Bank (EIB) provided
EUR 109.9 billion financing across the EU-27 between
2021 and mid 2024 to support energy, transport and
industry projects that are aligned with the EU’s climate
objectives. Of this amount, EUR 2 billion was assigned to
the Netherlands in the reference period (
138
).
National financing, including EU emissions trading
system revenues
Revenues from the auctioning of emission allowances
under the EU ETS, which feed directly into national
budgets, amounted to EUR 441 million in 2020,
EUR 894 million in 2021 and EUR 1 136 million in 2022 in
the Netherlands, totalling EUR 2 471 million in the three-
year period. Auctioning revenues go to the national
general budget, which is used for, among other things,
climate and energy purposes. Amounts spent are higher
than 100 % of revenues, but it is not possible to link
auctioning revenues to specific projects funded (
139
).
From the remaining part of the EU ETS revenues that feed
into the Innovation Fund and the Modernisation Fund,
further support is available to climate action at the EU
level.
It should be noted that investment in climate action also
supports the environment and, therefore, the
environmental investments described in the following
sections cannot be regarded as entirely additional to
climate investment (
140
).
Climate finance landmarks
EU funding for climate action
The EU budget supports climate action in the EU-27 with
EUR 657.8 billion in the 2021–2027 budgetary period
across the various programmes and funds, representing
an overall 34.3 % contribution level. Of this, cohesion
policy provides EUR 120 billion (over half of it through the
European Regional Development Fund (ERDF)), the
recovery and resilience facility (RRF) EUR 275.7 billion,
and CAP EUR 145.9 billion (
135
).
In the Netherlands, the EU cohesion policy (considering EU
contribution amounts) provides EUR 0.8 billion for climate
action in 2021–2027 (with around one fifth via the ERDF
and three quarters from the Just Transition Fund), with a
further EUR 75.1 million from the European Maritime,
Fisheries and Aquaculture Fund (
136
).
Environmental financing and investments
This section describes the Netherlands’ investment needs,
current financing and gaps as they relate to the four
environmental objectives beyond climate objectives,
namely tackling pollution, the circular economy and
(
135
)
(
136
)
(
137
)
European Commission,
Statement of Estimates of the European
Commission
–
For the financial year 2025,
Publications Office of
the European Union, Luxembourg, 2024, pp. 94–96,
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf.
See
the
Cohesion
Open
Data
Platform
(https://cohesiondata.ec.europa.eu/).
EU Commission datasets and the Recovery and Resilience
Scoreboard (https://ec.europa.eu/economy_finance/recovery-
and-resilience-scoreboard/index.html).
(
138
)
(
139
)
(
140
)
A list of financed projects is provided by the EIB
(https://www.eib.org/en/projects/loans/index.htm).
European Commission: Directorate-General for Climate Action,
Progress Report 2023
–
Climate action,
Publications Office of the
European
Union,
Luxembourg,
2023,
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-
24_enhttps://climate.ec.europa.eu/news-your-
voice/news/climate-action-progress-report-2023-2023-10-24_en.
NB: Indirect investments (from climate and other policies) in
support of the environment are accounted for via the tracking.
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The Netherlands 43
waste, water protection and
biodiversity and ecosystems (
141
).
The environment overall
Investment needs
management,
and
RRF
(
d
)
(2021–2026)
(
a
)
2 590
The overall environmental investment needs to be
sufficient to enable the Netherlands to meet its objectives
in the areas of pollution prevention and control, the
circular economy and waste, water protection and
management, and biodiversity and ecosystems. The
required investment is estimated to be EUR 20 billion per
year (in 2022 prices).
A significant part of the estimated requirement, around
EUR 11.5 billion per year, can be attributed to the need to
support circular economy. A total of EUR 4.6 billion per
year is required for water, EUR 2.8 billion for pollution
prevention and control, and EUR 1.1 billion for
biodiversity and ecosystems (in 2022 prices).
Current investments
To implement the environmental investments needed, the
available financing is estimated to currently reach an
annual EUR 15.9 billion in the Netherlands from EU and
national sources combined (in 2022 prices).
Total environmental funding from the multiannual
financial framework is estimated to reach around
EUR 2.5 billion for the Netherlands in total, during 2021–
2027 (or EUR 363.4 million per year).
Table 1: Key environmental allocations from EU funds to
the Netherlands (million EUR), 2021–2027
Instrument
Cohesion policy
ERDF
Just Transition Fund
CAP
European
Agricultural
Guarantee Fund
European Agricultural Fund
for Rural Development
European
Maritime,
Fisheries and Aquaculture
Fund
Other MFF sources
Allocations
192.7
(
a
)
108.5
84.2
1 531.8
(
b
)
767.9
763.9
European Commission, 2021-2027 cohesion policy (planned)
allocations in
EU amount
excluding national co-financing, based on
the tracking in the Common Provisions Regulation (CPR, 2021)
Annex . Please note potential data changes that may have arisen
between the EIR preparation cut-off date (31 October 2024) and
its publication date. Note that the Netherlands is not eligible for
the Cohesion Fund. Source and
further information:
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data.
Regulation (EU) 2021/2115 of the European Parliament and of the
Council of 2 December 2021 establishing rules on support for
strategic plans to be drawn up by Member States under the
common agricultural policy (CAP strategic plans) and financed by
the European Agricultural Guarantee Fund (EAGF) and by the
European Agricultural Fund for Rural Development (EAFRD) and
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013
(OJ
L 435
6.12.2021,
p. 1),
Annex XI,
https://eur-
lex.europa.eu/eli/reg/2021/2115.
Note that 2021-2027 combines factual data for 2021 and 2022 and
expenditure under the relevant specific objectives (SOs) of the
CAP strategic plans from 2023, using the EU biodiversity tracking
methodology (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.
(
b
)
(
c
)
(
d
)
Space Fund, Horizon Europe, financial instrument for the
environment and the Connecting Europe Facility.
Outside the MFF. Note that the RRF applies a similar
environmental tracking scheme (set in the RRF Regulation, Annex
VI) as the EU’s cohesion policy. RRF dataset version used: July
2024, prior to 2025 revisions. Data source: European Commission.
The Netherlands, in addition to receiving EU funds
earmarked specifically for it in 2021–2027, can also
benefit from funding programmes that can be accessed at
the EU level and which are open to all Member States.
These include the financial instrument for the
environment (LIFE) programme (EUR 5.4 billion) (
142
),
Horizon Europe (EUR 95.5 billion) (
143
), the Connecting
Europe Facility (EUR 33.7 billion) (
144
) and funds that can
be mobilised through the InvestEU programme (
145
).
The Netherlands’ RRP supports climate objectives through
funding of EUR 3 billion (55 % of total), with an additional
EUR 0.89 billion (16.3 %) for the environment.
The EIB provided around EUR 1.26 billion in environment-
related financial contributions to the Netherlands from
2021 to mid 2024, most of which, EUR 180.8 million
(56 %), was in the area of sustainable energy, transport
and industrial projects, which provides significant co-
(
144
)
The Connecting Europe Facility Transport part also includes
EUR 11.3 billion transferred from the Cohesion Fund, of which
30 % will be made available, on a competitive basis, to all Member
States eligible for the Cohesion Fund. The remaining 70 % will
respect the national envelopes until 31 December 2023.
The InvestEU Fund is set to mobilise over EUR 372 billion of
investment through an EU budget guarantee of EUR 26.2 billion to
back the investment of financial partners such as the EIB group
and others.
79.1
740.1 (
c
)
(
141
)
(
142
)
(
143
)
Research, development and innovation is accounted for under
each environmental objective. The financing needs, baselines and
gap estimates are based on the Directorate-General for
Environment’s internal analysis (of 2024). Throughout this
chapter, specific references are provided to the most important
data sources used.
https://cinea.ec.europa.eu/programmes/life_en.
European Commission, Horizon Europe,
https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en.
(
145
)
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The Netherlands 44
benefits to reducing air pollution, environmental noise
and other pollution.
The EU’s total national expenditure on environmental
protection (operating plus capital expenditure) was
EUR 298 billion in 2020 and EUR 321 billion in 2021,
representing around 2.2 % of EU-27 GDP. In the
Netherlands, the total national environmental protection
expenditure was EUR 15.6 billion in 2020 and
EUR 16.4 billion in 2021, representing 2 % and 1.9 % of
GDP, respectively.
Of the total environmental expenditure, the national
capital expenditure (investment) on environmental
protection amounted to EUR 54.5 billion in 2020 and
EUR 59.9 billion in 2021 in the EU-27, representing around
0.4 % of the EU’s GDP. In the Netherlands, the national
environmental
protection
investment
reached
EUR 3.5 billion in 2020, rising to EUR 3.8 billion in 2021,
representing around 0.4 % of GDP.
Split by institutional sector, 78 % of the Netherlands’
national environmental protection investment (capital
expenditure) comes from the general government budget,
with 22 % coming from specialist private-sector producers
(of environmental protection services, such as waste and
water companies). Data from the business sector, whose
environmental activities are usually ancillary to its main
activities, were not available. At the EU level, 38 % of
environmental protection investment comes from
governments, 40 % from specialist private-sector
producers and 22 % from the general business sector (
146
).
The Netherlands’ total financing for environmental
investment reaches an estimated EUR 15.9 billion per year
(in 2022 prices), including EU funding and national public
and national private expenditure. Of the total, the share
of EU fund (including EIB funds) reaches 5 %, with around
95 % national financing. The total public financing (EU plus
national public) represents 79 % of the total.
The gap
To meet its four environmental objectives beyond climate
change, the additional investment need over the current
levels (i.e. the gap) reaches an estimated EUR 4.1 billion
per year in the Netherlands, representing around 0.4 % of
the national GDP, being lower than the EU average
(0.77 %).
Figure 37: Environmental financing, needs and gaps per
Member State (% of GDP)
Source:
Analysis of Directorate-General for Environment.
The following table provides the distributions of the
Netherlands’ environmental investment gap (expressed in
various forms) by environmental objective.
Table 2: Summary of environmental investment gaps in
the Netherlands, 2021–2027, per year
Environmental
objective
Investment gap per year
Million
EUR
(2022
prices)
2 312
1 507
% of
total
% of GDP
Pollution prevention
and control
Circular economy and
waste
Water management
and water industries
Biodiversity and
ecosystems
Total
56.2
36.6
0.3
0.2
945
22.7
0.1
—
4 117
—
100.0
—
0.4
(
146
)
Eurostat,
‘Environmental
protection expenditure accounts’,
env_ac_epea.
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The Netherlands 45
NB: For biodiversity and ecosystems, no significant gap is observed,
based on currently available data.
Source:
Directorate-General for Environment analysis.
Pollution prevention and control
Investment needs
In pollution prevention and control, the Netherlands’
investment needs are estimated to reach EUR 2.8 billion
per year (including baseline investments) in 2021–2027.
Most of this, EUR 2.4 billion relates to air pollution control,
to comply with the clean air requirements for the five main
air pollutants under the NECD by 2030. The estimated
needs to reduce environmental noise reach EUR 1.4 billion
per year, most of which is delivered by the (same)
sustainable energy and transport investments that also
benefit clean air (
147
). Industrial site remediation requires
an estimated EUR 173 million per year. Microplastics
pollution and the chemicals strategy require around
EUR 100–130 million per year (each) (
148
).
Current investments
The current investment levels supporting pollution
prevention and control reach an estimated
EUR 528 million per year in the Netherlands in 2021–2027.
Most of the financing concerns clean air (EUR 311 million
per year). Protection from environmental noise receives
around EUR 65 million, the chemicals EUR 60 million per
year, with a further EUR 20 million for site remediation.
In the Netherlands, the EU MFF provides an estimated
12.4 % of the clean air financing (mostly via cohesion
policy), with a further 27.6 % from the RRF, adding up to
40 % of the total. EIB financing contributes 18 % and
national sources reach 42 % (
149
).
The gap
To meet its environmental objectives concerning pollution
prevention and control (towards zero pollution), the
Netherlands needs to provide an additional EUR 2.3 billion
per year (0.25 % of GDP), mostly related to clean air and
(
147
)
2021
Phenomena
project
assessment
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)
and the
Commission’s
2023
Environmental
Noise
Directive
implementation
report
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf).
European Commission,
Third Clean Air Outlook,
Brussels, 2022,
https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en.
See also the impact assessment for the revision of the
AAQD, available from the Commission web page on the proposed
revision
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en).
Through the tracking of EU funds, EIB projects and national
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean
air financing is provided as a contribution from climate (energy
and transport) measures, as per the tracking schemes in the
noise. The adequate implementation of the NECP with the
investments included for sustainable energy and transport
would largely deliver this, while in many Member States
additional measures and investments may be required to
comply with the ammonia reduction requirements.
According to the latest (2023) NAPCP review report (
150
),
the Netherlands complied with ammonia reduction
requirements in 2020 and 2021, and it is not at risk of non-
compliance with ammonia concerning the NECD’s 2030
emission reduction commitments, based on the policies
and measures in its NAPCP that take into account climate,
energy and CAP plans and financing baselines.
Circular economy and waste
Investment needs
The Netherlands’ investment needs in circular economy
and waste reach EUR 11.5 billion per year (including
baseline investments). Most of this, around EUR 9.8 billion
per year, relates to circular economy measures in the
mobility, food and built environment systems, with a
further EUR 1.7 billion necessary for waste management
(municipal and packaging waste), covering waste
collection, biowaste treatment, recycling reprocessors,
waste-sorting facilities, and digitalisation of the waste
registry. The amount for waste excludes the investments
needed for the uptake of circularity and waste prevention
across the economy (
151
).
Current investments
Circular economy investments across the economy reach
around EUR 8.4 billion per year in the Netherlands in
2021-2027, with a further EUR 1.6 billion provided for
waste management that does not constitute circular
economy.
Around 0.3 % of this combined financing for circularity and
waste comes from the EU MFF, with no further
contribution from the RRF. EIB loans identified in support
of circularity and waste represent 0.2 % of the total. The
(
150
)
(
148
)
(
151
)
(
149
)
Common Provisions Regulation Annex I and the RRF Regulation
Annex VI. Further information on clean air tracking:
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf
European Commission,
‘National air pollution control programmes
and
projections’,
European
Commission
website,
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en.
See Systemiq and Ellen MacArthur Foundation,
Achieving ‘Growth
Within’,
2017; and European Commission: Directorate-General for
Environment,
Study on investment needs in the waste sector and
on the financing of municipal waste management in Member
States,
Publications Office of the European Union, Luxembourg,
2019,
https://op.europa.eu/en/publication-detail/-
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1.
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The Netherlands 46
share of national sources is absolutely overwhelming,
reaching 99.5 % of the total financing (
152
).
The gap
To meet its environmental objectives concerning the
circular economy and waste, the Netherlands needs to
increase circular economy investments by an estimated
EUR 1 402 million per year, with an additional
EUR 105 million concerning waste management action,
not belonging to circular economy. Combined, this
amounts to EUR 1 507 million per year, representing
0.16 % of the Netherlands’ GDP.
Of the circular economy gap, EUR 367 million relates to
recent initiatives, such as the eco-design for sustainable
products, packaging and packaging waste, labelling and
digital tools, CRM recycling, and measures proposed
under the amendment of the Waste Framework Directive,
and EUR 1 035 million constitutes further investment
need to unlock the Netherlands’ circular economy
potential.
Water protection and management
Investment needs
The annual water investment needs reach an estimated
EUR 4.6 billion (in 2022 prices) in the Netherlands. This
comprises investment needs both for the water industry
and for the protection and the management of water. Of
the total annual need, EUR 1.9 billion, relates to the
management of waste water (also including additional
costs associated with the revised UWWTD). A further
EUR 2.7 billion is necessary for drinking-water-related
investments and around EUR 64 million for the protection
and management of water (
153
).
Current investments
Water investments in the Netherlands are estimated to be
around EUR 3.7 billion per year (in 2022 prices) in 2021–
2027. Of this, EUR 1.3 billion supports wastewater
management, EUR 2.3 billion drinking water and around
EUR 71 million the other aspects of the Water Framework
Directive (water management and protection).
Of the total financing, 0.4 % is provided by the EU MFF
(mostly through cohesion policy), with further support of
0.3% from the RRF. EIB financing is around 1.4 % of the
total, while the bulk of financing comes from national
sources (98 %) (
154
).
The gap
To meet the various environmental targets under the
Water Framework Directive and the Floods Directive, the
Netherlands’
water
investment
gap
reaches
EUR 935 million per year (0.1 % of GDP), with
EUR 567 million linked to wastewater measures. Drinking
water measures require an additional EUR 367 million per
year over the existing levels of financing.
Biodiversity and ecosystems
Investment needs
The investment needs for biodiversity and ecosystems are
estimated to be EUR 1.1 billion per year (in 2022 prices) in
the Netherlands in 2021–2027. This includes the following
financing needs:
•
•
•
the Netherlands’ prioritised action framework (
155
)
concerning the Natura 2000 areas: EUR 902 million
per year, mostly running costs;
additional BDS costs (
156
): this is not possible to
quantify, as the financing needs estimated for the
strategy are lower than those in the prioritised action
framework;
sustainable
soil
management
costs (
157
):
EUR 154 million per year.
Current investments
The current level of biodiversity financing is estimated to
be EUR 1.7 billion per year (in 2022 prices) in 2021–2027.
97 % of this is considered direct financing to biodiversity
and ecosystems, with a 100 % coefficient in the tracking
schemes.
(
155
)
European Commission,
‘Financing Natura 2000 –
Prioritised action
frameworks’,
European
Commission
website,
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en.
See European Commission: Directorate-General for Environment,
Biodiversity Financing and Tracking
–
Final report,
Publications
Office of the European Union, Luxembourg, 2022,
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en.
See
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_enProposal
for
a
directive of the European Parliament and of the Council on soil
monitoring and resilience (Soil Monitoring Law) COM(2023) 416
final
of
5 July
2023,
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en.
(
152
)
(
153
)
(
154
)
Waste management and circular economy expenditure tracking in
the EU funds, EIB projects and in the national expenditure
(Eurostat). Datasets: EPEA accounts (env_epi) and circular
economy private investments (cei_cie012).
See European Commission,
‘Estimating investment needs and
financing capacities for water-related investment in EU Member
States’,
28
May
2020,
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;
and OECD,
Financing Water
Supply, Sanitation and flood Protection: Challenges in EU Member
States and policy options,
OECD Publishing, Paris, 2020,
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en.
Water investment levels are estimated through tracking EU funds,
EIB projects and national expenditure (EPEA accounts, Eurostat).
(
156
)
(
157
)
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The Netherlands 47
No financing is estimated to come from EU cohesion
policy, 12 % from CAP, 1 % from Horizon Europe, around
0.4 % from LIFE and 0.4 % from the European Maritime,
Fisheries and Aquaculture Fund. The EU MFF altogether
accounts for 14 % of the financing and the RRF for 11.4 %,
adding up to a total of 25.4 % from the EU budget. The
rest, 75 %, comes from national sources (
158
).
The Netherlands envisages dedicating to biodiversity
investments 27.5 % of its CAP budget for 2021–2027, and
an estimated 26.5 % of its RRF funds. This is the highest
share of CAP and RRF investments in biodiversity for this
period of all Member States. However, nothing from the
cohesion policy EU contribution amount is planned to
contribute to biodiversity (see Figure 38).
Figure 38: 2021–2027 contributions to biodiversity from
the main EU instruments per Member State (% of policy
total)
Public financial management
Green budgeting practices
Green budgeting refers to the use of budgetary tools to
achieve climate and environmental goals. Some Member
States, including the Netherlands, already use green
budgeting tools for identifying and tracking green
expenditures and/or revenues(
159
). Green budgeting
practices provide increased transparency on the
environmental implications of budgetary policies
The Commission has developed a non-mandatory green
budgeting reference framework that brings together
methodologies for assessing the impacts of budgets on
climate and environmental goals
(
160
)
.
To help Member States develop national green budgeting
and thereby improve policy coherence and support the
green transition, the Commission facilitated a technical
support instrument (TSI) project on green budgeting from
2021 to 2024
(
161
)
.
The Netherlands did not participate.
At the subnational level, under the 2024 TSI, the city of
Amsterdam is developing methodologies jointly with
other European cities to align local budgeting processes
with the sustainable development goals (
162
).
The regional dimension of the European Green Deal has
been emphasised by the Committee of the Regions
through the Green Deal Going Local initiative
(
163
)
.
NB: ESF+, European Social Fund Plus.
The gap
To meet the environmental objectives concerning the
protection and restoration of biodiversity and ecosystems
and other relevant cross-cutting measures, based on the
available data and estimates, a significant investment gap
cannot be observed in the case of the Netherlands.
Beyond green budgeting, to improve policy outcomes, the
Commission has also drawn up climate-proofing and
sustainability-proofing guidance (
164
), as tools to assess
project eligibility and compliance with environmental
legislation and criteria.
Green taxation and tax reform
Total environmental taxes amounted to EUR 22.8 billion in
the Netherlands in 2022, representing 2.4 % of its GDP (EU
average: 2.0 %). Energy taxes formed the largest
(
158
)
(
159
)
(
160
)
Based on biodiversity tracking in the EU budget
(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde),
and national expenditure into biodiversity from the Classification
of the Functions of Government accounts.
European Commission,
Green Budgeting in the EU. Key Insights
from the 2023 European Commission Survey of Green Budgeting
Practices,
2023,
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0.
European Commission,
‘European Union green
budgeting
reference
framework’,
2022,
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en.
(
161
)
(
162
)
(
163
)
(
164
)
https://reform-support.ec.europa.eu/what-we-do/revenue-
administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en.
Technical support is received under the TSI project 24NL03.
European Committee of the Regions, ‘Green Deal going local:
Cities and regions put forward economic and social measures to
support citizens and businesses to overcome the energy crisis’,
press release, European Committee of the Regions website,
30 June
2022,
https://cor.europa.eu/en/news/Pages/gdgl-
economic-social-measures-support-energy-crisis.aspx.
Commission notice
–
Technical guidance on the climate proofing
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021,
p. 1),
https://op.europa.eu/en/publication-detail/-
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en.
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The Netherlands 48
component of environmental taxes, accounting for 1.2 %
of GDP, which is lower than the EU average of 1.6 %.
Transport taxes, at 0.8 % of GDP, were above the EU
average (0.4 %), while taxes on pollution and resources, at
0.39 %, were above the EU average (0.08 %). In 2022,
environmental taxes in the Netherlands accounted for
6.2 % of total revenues from taxes and social security
contributions (above the EU average of 5.0 %) (
165
).
Figure 39: Environmental taxes per Member State, 2022
manure tax), product charges (vehicle tax, levies on
plastics) and user charges (water abstraction volumes,
waste volumes). There is a tax on tap water (EUR 0.359/m
3
of tap water delivered up to 300 m
3
) (
167
) and incineration
taxes complemented by bans on the landfill of specific
substances. However, water for agriculture or industrial
uses is taxed at a lower rate of EUR 0.08/m
3
, with this rate
only applying to irrigation users abstracting over
40 000 m
3
per year (
168
). The Netherlands taxes waste at
EUR 35.70/t for waste going to landfill or mixed waste
incineration plants in and outside the Netherlands (
169
).
Vehicle registration taxes have been designed to promote
the purchase of low-carbon vehicles. Tax on mineral
extraction charged per volume (m
3
) or weight (kg or t) of
materials extracted cover the extraction of various natural
resources, for example coal, lignite or peat. The same
study proposes the introduction of air pollution tax and
intensive agriculture tax (
170
).
Green bonds and sustainable bonds
In 2023, the total value of green bonds issued by the
Member States was USD 245 billion (EUR 227 billion), up
from USD 234 billion (EUR 198 billion) in 2021 (
171
).
During 2021–2023 combined, the Netherlands issued
green bonds worth USD 76.8 billion (EUR 64.9 billion). Of
this, the issuance in 2023 amounted to USD 20.6 billion
(EUR 19 billion).
During 2014–2023, 83 % of the green bonds issued by
European countries (excluding supranational entities)
served objectives in energy, buildings or transport, while
5 % supported objectives in water, 5.1 % related to land
use (with links to nature and ecosystems) and 3.8 %
applied to waste management. By 2023, the combined
share of energy, buildings and transport had decreased to
73 %, the shares of waste management and land use had
increased (to 5.9 % and 8.4 %, respectively) and the share
of water had remained around 5 %.
In 2021–2023, 31.7 % of the European green bonds
(excluding supranational issuances) were issued by
The European Green Deal emphasises the role of well-
designed tax reforms (e.g. shifts from taxing labour to
taxing pollution) to boost economic growth and resilience,
and to foster a fairer society and a just transition through
the right price signals. The Green Deal promotes the
‘polluter-pays
principle’, which makes polluters bear the
costs to prevent, control and remedy pollution.
According to a 2024 study (
166
), the Netherlands applies
emission charges (e.g. aircraft noise emissions, water
biochemical oxygen demand, solid waste landfill fee,
(
165
)
(
166
)
(
167
)
(
168
)
Eurostat, ‘Environmental
taxes accounts’, env_eta.
European Commission: Directorate-General for Environment,
Candidates for Taxing Environmental Bads at National Level,
Publications Office of the European Union, Luxembourg, 2024,
Annex 1,
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en.
European Commission: Directorate-General for Environment,
Candidates for Taxing Environmental Bads at National Level,
Publications Office of the European Union, Luxembourg, 2024,
Annex 2,
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en.
Berbel, J., Borrego-Marín, M. and Expósito, A. et al.,
‘Analysis
of
irrigation water tariffs and taxes in Europe’,
Water Policy,
Vol. 21,
Issue 4,
2019,
pp. 806–825,
https://doi.org/10.2166/wp.2019.197.
(
169
)
(
170
)
(
171
)
European Commission: Directorate-General for Environment,
Candidates for Taxing Environmental Bads at National Level,
Publications Office of the European Union, Luxembourg, 2024,
p. 10,
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
e.
European Commission: Directorate-General for Environment,
Candidates for Taxing Environmental Bads at National Level,
Publications Office of the European Union, Luxembourg, 2024,
p. 17,
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
e.
Climate bonds initiative (https://www.climatebonds.net/). NB.
Additionally (and not included in this), national sources indicated
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly
higher amount for Slovenia (+0.27 billion) during 2021-2023 in
total.
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The Netherlands 49
financial corporates, 29.1 % by sovereign governments
and 23.1 % by non-financial corporates. 8.3 % of the
issuances were linked to government-backed entities,
6.4 % to developments banks and 1.4 % to local
governments.
Figure 40: Value of green bonds issued per Member State
(billion EUR), 2021, 2022 and 2023
For the majority of the Member States (16), the year 2022
saw a peak in the amount of overall FFS. A decline was
then observed in 2023 (
174
). In particular, FFS for coal and
lignite, natural gas and oil increased in 2022 and a strong
increase was observed for natural gas subsidies.
In the Netherlands, the energy subsidies were relatively
stable between 2015 and 2019, and have shown increases
since then, which accelerated in 2022 and 2023. FFS grew
from EUR 0.6 billion in 2015 to EUR 1 billion in 2017 and
stayed around that level until 2021. In 2022, FFS
amounted to EUR 2.5 billion, and in 2023, 2.9 billion.
As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia
to less than 0.1 % in Denmark and Sweden. The
Netherlands’ value reached 0.3 %, above the EU average
(0.8 %) (
175
).
Figure 41: Energy subsidies by energy carrier (billion
EUR), 2015–2023
Data source: Climatebonds.net, with some additional data from national
sources (e.g. Croatia, Slovenia).
Environmentally harmful subsidies
Addressing and phasing out environmentally harmful
subsidies, in particular fossil fuel subsidies (FFS), is a
further step towards achieving the eighth environment
action programme objectives and the enabling
conditions (
172
). FFS are costly for public budgets and make
it difficult to achieve European Green Deal objectives.
The overall downward trend of FFS mentioned in past EIRs
was disrupted from 2022 due to the European response to
the 2021 energy crisis and subsequent increase in energy
prices.
As a direct consequence, annual FFS in the EU increased to
EUR 103 billion in 2023 from EUR 57 billion in 2020. From
2021 to 2023, there was a marked increase in annual FFS
of 72 % in the EU (
173
).
NB: RES, renewable energy source.
Source:
analysis of Directorate-General Energy
The 2022 EIR included the following recommendations for
the Netherlands.
•
Devise an environmental financing strategy to
maximise opportunities for closing environmental
implementation gaps, bringing together all relevant
administrative levels.
Ensure an increased level of financing for the
environment, in particular further exploring private
financing flows (currently around a fourth of the
total), to cover the level of investment needs across
16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT,
PT, RO and SE.
European Commission, 2024 Report on Energy Subsidies in the
European Union, COM(2025).
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en
•
(
172
)
(
173
)
Article 3(h) and 3(v) of the eighth environmental action
programme.
European Commission, 2024 Report on Energy Subsidies in the
European Union, COM(2025).
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en
(
174
)
(
175
)
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the environmental
investment gaps.
objectives
by
closing
the
2025 priority action
In light of the observation of similar overall investment
gaps to those in 2022, one recommendation from 2022 is
maintained for the Netherlands.
•
Use more national funding (for instance by increasing
taxes in favour of the environment and reducing
environmentally harmful subsidies), EU funding and
private funding to help close the investment gap.
Important to note is that the Netherlands organised a
conference on the 30 March 2023 (
176
) on the European
Commission’s vade mecum for environmental
financing (
177
), which is considered an element of a
strategy.
The overall level of financing for the environment for the
Netherlands remains, however, similar to that at the time
of the 2022 EIR, at around 0.4 % of GDP, which is lower
than the EU average.
(
176
)
(
177
)
https://environment.ec.europa.eu/events/second-vademecum-
online-event-environmental-funding-netherlands-30th-march-
2023-2023-03-30_en.
European Commission: Directorate-General for Environment,
Find
Your EU Funding Programme for the Environment
–
Supporting the
environment under the 2021–2027 multiannual financial
framework and NextGenerationEU,
Publications Office of the
European
Union,
Luxembourg,
2022,
https://op.europa.eu/en/publication-detail/-
/publication/33b54f0d-0251-11ed-acce-01aa75ed71a1.
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6. Environmental governance
Table 3: Netherlands dashboard on implementation of
the Inspire Directive, 2016–2023
2016
2023
Legend
■
Implementation of
this provision is well
advanced or (nearly)
completed.
Outstanding issues
are minor and can
be addressed easily.
Percentage > 89 %
■
Implementation of
this provision has
started and made
some or substantial
progress but is still
not close to being
complete.
Percentage = 31–
89 %
■
Implementation of
this provision is
falling significantly
behind.
Serious
efforts
are
necessary to close
the implementation
gap.
Percentage < 31 %
Information, public participation and access to
justice
Citizens can more effectively protect the environment if
they rely on the three
‘pillars’
of the Aarhus Convention:
(i) access to information, (ii) public participation in
decision-making and (iii) access to justice in environmental
matters. It is of crucial importance to public authorities,
the public and businesses that environmental information
is shared efficiently and effectively (
178
). Public
participation allows authorities to make decisions that
take public concerns into account. Access to justice is a set
of guarantees that allows citizens and NGOs to use
national courts to protect the environment, safeguard the
rights of citizens and ensure accountability of
authorities (
179
). It includes the right to bring legal
challenges (‘legal standing’) (
180
).
Environmental information
This section focuses on the implementation of the
Infrastructure for Spatial Information in the European
Community (Inspire) Directive. The Inspire Directive aims
to set up a European spatial-data infrastructure for sharing
environmental spatial information between public
authorities across Europe. It is expected that this will help
policymaking across boundaries and facilitate public
access to this information. Geographical information is
needed for good governance at all levels and should be
readily and transparently available (Table 3).
Effective coordination and data sharing
Ensure effective
coordination
Data
sharing
without obstacle
■
■
■
■
■
■
■
■
■
■
Inspire performance indicators
(i) Conformity of
metadata 0
(ii) Conformity of
spatial datasets
(iii) Accessibility of
spatial datasets
through view and
download
services
(iv) Conformity of
network services
■
■
Source:
European Commission,
‘Netherlands’,
Inspire Knowledge Base,
https://knowledge-base.inspire.ec.europa.eu/netherlands_en.
The Netherlands’ performance in implementing the
Inspire Directive is substantial and has been reviewed
based on its 2023 country fiche (
181
) (see Table 3).
The Netherlands received a priority action in the 2019 EIR
on the need to improve access to spatial data and services.
It is making stronger links to the country’s Inspire portals
and better informing the public about their access to
justice rights, notably in relation to air pollution and
nature, where substantial progress can be seen.
(
178
)
(
179
)
The Aarhus Convention (https://unece.org/environment-
policy/public-participation/aarhus-convention/text),
the Access
to Environmental Information Directive (Directive 2003/4/EC)
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32003L0004)
and the Inspire
Directive (Directive 2007/2/EC) (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002)
together create a legal
foundation for the sharing of environmental information between
public authorities and with the public.
These guarantees are explained in the
European Commission’s
2017 notice on access to justice in environmental matters
(
180
)
(
181
)
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))
and a related
2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF).
This EIR focuses on the means used by Member States to
guarantee rights of access to justice and legal standing and to
overcome other major barriers to bringing cases on environmental
protection.
European Commission,
‘Netherlands’,
Inspire Knowledge Base,
https://knowledge-base.inspire.ec.europa.eu/netherlands_en.
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In 2022, the Netherlands received a priority action on the
need to make spatial data more widely accessible and
prioritise environmental datasets (
182
). Netherlands has
made good progress on improving the accessibility of
spatial data, but more efforts are needed. Therefore, the
2022 priority action is repeated in 2025.
Public participation
Public involvement at both the planning and the project
phase maximises transparency and social acceptance of
programmes and projects. Consultation with the public
(including NGOs) and environmental, local and regional
authorities is a key feature of an effective impact
assessment procedure. Such consultation also provides an
opportunity for public authorities and project promoters
to engage with the public actively and meaningfully by
making information on the likely significant effects widely
available. If carried out with due diligence and taking into
consideration useful public input, this process leads to
better-informed decision-making and can promote public
acceptance. Making information available increases
stakeholder involvement, thus lessening resistance and
preventing (or minimising) litigation. On the other hand, it
is paramount that the procedure is effective.
This section examines how public involvement and
transparency are ensured under two instruments, namely
the Environmental Impact Assessment (EIA) Directive (
183
)
and the Strategic Environmental Assessment (SEA)
Directive (
184
).
EU law provides for a flexible framework concerning EIAs.
The aim of this framework is to ensure the application of
the necessary environmental safeguards, while enabling
speedy approval of projects. The Commission has
contributed to simplifying and accelerating permitting for
renewable energy projects and continues to support the
Member States in this regard(
185
).
The Netherlands has already taken steps aiming to
accelerate permit-issuing procedures taking advantage of
the broad flexibilities offered by the EU legal framework,
(
182
)
See the European Commission’s list of high-value spatial datasets
(https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx).
Directive 2011/92/EU of the European Parliament and of the
Council of 13 December 2011 on the assessment of the effects of
certain public and private projects on the environment (OJ L 26,
28.1.2012,
p. 1),
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32011L0092.
Directive 2001/42/EC of the European Parliament and of the
Council of 27 June 2001 on the assessment of the effects of certain
plans and programmes on the environment (OJ L 197, 21.7.2001,
p. 30),
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042.
such as the establishment of one-stop shops and
accelerated short deadlines for issuing permits for
renewable energy projects. The acceleration of the
permitting process is implemented through two
processes: the multiannual programme for infrastructure,
energy and climate and the federal coordination
procedure (Rijkscoördinatieregeling/projectprocedure). In
addition, the support provided in 2023 through the TSI by
the Commission included projects to help the authorities
supervise artificial intelligence, improve the permitting
process for renewable energy projects and improve
policies for attracting and retaining highly skilled talent.
The average speed in the EU for issuing permits involving
an EIA procedure is 20.6 months, with a minimum
duration of 11.4 months and the maximum duration of
75.7 months (
186
). The duration of each step in an EIA
process (screening, scoping, EIA report, public
consultation, reasoned conclusion, development consent)
varies considerably between Member States and projects.
The available data for the Netherlands
do not allow any
conclusions to be drawn.
A priority action is included for
2025 to provide more detailed information on the
different stages of the EIA process. Effective use of EU
procedures can positively influence the timely approval of
activities underpinning the decarbonisation of the
economy on the way to net zero by 2050.
A new report is not yet available on the application and
effectiveness of the SEA Directive in the EU. Nevertheless,
a support study has been published with information by
Member State (
187
).
In the 2022 EIR, the Netherlands received a priority action
to collect and publish data on public participation in EIA
and SEA processes, including information on the extent to
which final decisions are affected by public comments.
Extensive information and electronic tools are available in
the Netherlands to facilitate public participation in EIA and
SEA procedures. A Dutch government web page collects all
official notifications and publications regarding the
initiation of plans and projects to which EIA or SEA
(
185
)
Commission Staff Working Document (SWD/2022/0149
final),
18
May
2022,
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229953).
(
186
)
European Commission: Directorate-General for Environment,
Collection of information and data on the implementation of the
revised Environmental Impact Assessment (EIA) Directive
(2011/92/EU) as amended by 2014/52/EU),
Publications Office of
the European Union, Luxembourg, 2024, Tables 5 and 6,
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/.
187
( ) European Commission: Directorate-General for Environment,
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al.,
Study
supporting the preparation of the report on the application and
effectiveness of the SEA Directive (Directive 2001/42/EC)
–
Final
study,
Publications Office of the European Union, 2025,
https://data.europa.eu/doi/10.2779/1615072
(
183
)
(
184
)
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The Netherlands 53
procedures apply (
188
). In addition, the Ministry of
Infrastructure and Water Management provides an online
participation platform (
189
) and quick scan facility (
190
) for
citizens and developers to determine whether an EIA
procedure applies. Furthermore, public participation in
EIA and SEA procedures is embedded in national
environmental law, providing rules for participation in
national,
provincial
and
municipal
planning
191
procedures ( ) including information obligations,
obligatory public consultation and a duty to explain to
what extent public feedback was considered. However, to
date, there is no information available on public
participation in EIA and SEA.
A new Environment and Planning Act (Omgevingswet)
entered into force in the Netherlands on 1 January 2024,
consolidating various areas of environmental law to make
decision making more effective and efficient and further
improve public participation in environmental decision
making (
192
). An environment platform is being developed
as part of the digital infrastructure to facilitate the entry
into force of the new Environment and Planning Act and
stimulate participation by citizens (
193
). Some data on
public participation in EIA and SEA procedures and the
extent to which public views are considered are published,
but only for procedures in which the Netherlands
Commission for Environmental Assessment is specifically
requested to take public views into account (
194
).
Access to justice
Access to justice, guaranteed by Article 19(1) of the Treaty
on European Union and Article 47 of the EU Charter of
Fundamental Rights, is a fundamental right and part of the
democratic process. It is vital to ensure the full application
of EU law in all Member States and the legal protection of
the rights of individuals, including in environmental
matters. Access to justice is essential to enable judicial
review of the decisions of public authorities and to allow
the correction of any wrongdoing committed by these
authorities.
This section provides a snapshot of the state of play of
access to courts by the public, particularly when it comes
to challenging plans, or the non-adoption of plans, under
EU law, in the areas of water, waste, air quality and noise,
irrespective of the form of the legal act (i.e. regulatory act
or administrative decision).
As mentioned in the 2022 EIR, the Netherlands provides
for access to justice in environmental matters regarding
certain administrative acts, particularly EIAs. NGOs do not
have to demonstrate an interest to have standing in an
administrative environmental court case or in cases that
have significant effects on the environment, but they do
have to meet some conditions regarding their legal status
and operation. For citizens, the requirement is to have a
sufficient interest in the decision. In practice, meeting that
standard in environmental cases may be more demanding
on citizens than on NGOs.
Under Dutch administrative law, only final decisions can
be subject to legal review and appeal to the courts.
Decisions are defined in Article 1:3 of the Dutch General
Administrative Law Act (Algemene wet bestuursrecht).
Administrative review and judicial review are not available
against general binding rules or policy rules, but only
against the decisions based on them. Article 120 of the
Dutch Constitution does not allow the judge to check the
validity of laws adopted by parliament against the
constitution:
‘The
constitutionality of Acts of Parliament
and treaties shall not be reviewed by the courts.’ The
judge is allowed, though, in a dispute over the (formal or
material) legality of a decision, to raise arguments calling
into question the legality of the legal basis on which the
decision is based. So it is possible to check whether a
decision is compatible with EU law, including
environmental law. It is also possible for the national judge
to check whether national law complies with binding
international law. Where it does not, the judge can leave
aside national law.
More specific rules apply on challenging EIAs. The EIA
report itself can only be made subject to review together
with the decision (e.g. on the application for a permit). If
the EIA report is found to be flawed, the decision will be
ruled to be flawed as well (because it is not substantiated
by the EIA report) and will therefore
–
typically
–
be
annulled (Article 3:46 of the Dutch General Administrative
Law Act).
(
188
)
(
189
)
(
190
)
(
191
)
(
192
)
https://zoek.officielebekendmakingen.nl/uitgebreidzoeken.
Platform
Participatie
(https://www.platformparticipatie.nl/default.aspx).
EIA-scan
(https://iplo.nl/regelgeving/instrumenten/milieueffectrapportag
e/)
in the knowledge database of the Ministry of Infrastructure
and Water Management.
Chapter 7 (SEA and EIA) and Chapter 4 of the Environmental
Management Act.
More information on the new Environment and Planning Act and
its entry into force is available on the dedicated government
(
193
)
(
194
)
website
(https://www.rijksoverheid.nl/onderwerpen/omgevingswet) and
at
https://iplo.nl/regelgeving/omgevingswet/english-
environment-and-planning-act/.
More information on the Digital System for the Environment Act
and the Environment Platform (Omgevingsloket) is available at
https://aandeslagmetdeomgevingswet.nl/ontwikkelaarsportaal/
dso/dso/digitaal-stelsel/.
Facts and figures from the Netherlands Commission for
Environmental
Assessment’s
annual
report
(https://www.eia.nl/annualreport2020/).
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There is a general website on SEA/EIA (
195
), but it does not
provide an overview of consultations (
196
).
A case on access to justice in the Netherlands was
launched in 2023 (
197
), mainly seeking clarification on
whether administrative or regulatory decisions in the field
of the environment, particularly in areas of planning
related to water, nature, air quality and noise, can be
legally challenged at the national level (as is required by
the Aarhus Convention and EU law). The reply is under
assessment.
criminality. Compliance promotion activities help duty-
holders to comply by providing information, guidance and
other support. This is particularly important in areas
where new and complex legislation is put in place.
When inspections and other control activities identify
problems, a range of responses may be appropriate,
including the use of administrative and criminal
enforcement tools.
While centralised online publication of non-compliance
statistics remains limited, recent government reforms and
regional authorities increasingly focus on ensuring
transparency by providing public access to decisions on
environmental violations and sanctions through various
regional platforms (
200
).
As mentioned in the 2022 EIR, every four years, a national
threat assessment on environmental crime is carried out
by the Strategic Environmental Chamber, involving all
parties involved in the enforcement of environmental
legislation in the Netherlands, both administrative and
criminal enforcement services as well as specialised
inspectorates (
201
). Since the last national threat
assessment, the Dutch government has intensified its
focus on environmental crime.
The 2022 EIR recommended that the Netherlands (i)
publishes inspection plans, inspection reports and annual
activity reports/statistics linked to environmental
inspections of industrial installations under the IED, in the
same manner as is done for installations under the
Seveso III Directive; (ii) improves cooperation between
enforcement authorities on environmental crime, for
example by improving information exchange, resources,
level of expertise and cooperation systems of
administrative and criminal authorities involved.
However, such actions concerning compliance promotion,
monitoring and criminal and administrative enforcement
are not assessed here due to a lack of systematic
information.
The new EU Environmental Crime Directive
The EU has recently strengthened its legal framework on
tackling the most serious breaches of environmental
obligations, notably by the adoption of the Environmental
2025 priority actions
•
Make spatial data more widely accessible and
prioritise environmental datasets in implementing the
Inspire Directive, especially those identified as high-
value spatial datasets for implementing environmental
legislation (
198
).
•
Ensure that relevant information on EIA and SEA
procedures (including on public participation
opportunities and on publication of final decisions) is
electronically accessible, through at least a central
portal or easily accessible points of access, at the
appropriate administrative level
•
Provide information on the average duration of all
steps in the EIA process.
Compliance assurance
Environmental compliance assurance covers all work
undertaken by public authorities to ensure that industries,
farmers and others fulfil their obligations to protect water,
air and nature, to manage waste (
199
) and to remedy any
environmental damage. It includes measures such as (i)
compliance promotion, (ii) compliance monitoring (i.e.
inspections and other checks), (iii) enforcement, that is
steps taken to stop breaches and impose sanctions, and
(iv) ensuring damage prevention and remediation in line
with the polluter-pays principle.
Compliance promotion, monitoring and enforcement
Non-compliance with environmental obligations may
occur for different reasons, including poor understanding
or lack of acceptance of the rules, opportunism or even
(
195
)
https://iplo.nl/regelgeving/instrumenten/milieueffectrappor
tage/.
https://www.commissiemer.nl/english.
European Commission infringement decision INFR(2023)2149.
European Commission’s list of high-value spatial datasets
(https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx).
The concept is explained in detail in the European Commission’s
2018 communication on EU actions to improve environmental
compliance and governance (https://eur-lex.europa.eu/legal-
(
196
)
(
197
)
(
198
)
(
200
)
(
201
)
(
199
)
content/EN/TXT/?uri=CELEX%3A52018DC0010)
and the related
Commission
staff
working
document
(https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010).
For example, the regional agency Omgevingsdienst
Noordzeekanaalgebied
makes
information
concerning
enforcement measures publicly accessible at
https://odnzkg.nl/.
Openbaar
Ministerie,
Omgevingsdienst
NL,
Inspectie
Leefomgeving
en
Transport
et
al.,
Dreigingsbeeld
Milieucriminaliteit
2021,
2021,
https://www.om.nl/onderwerpen/milieucriminaliteit/dreigingsb
eeld-milieucriminaliteit.
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Crime Directive (ECD) (Directive (EU) 2024/1203)(
202
) and
new sectoral legislation with stronger provisions on
compliance monitoring, enforcement and penalties.
Issues important for the transposition and the
implementation of the relevant new instruments are
highlighted below; a detailed assessment of these topics
will be included in the next EIR once more implementation
measures are put in place and more systematic
information is available.
The new ECD replaced the 2008 ECD and introduced
several new offence categories, such as unlawful ship
recycling, unlawful water abstraction, and serious
breaches of EU legislation on chemicals, mercury,
fluorinated GHG and IAS of EU concern. It also covered the
establishment of qualified offences, subject to more
severe penalties where one of the offences defined in the
directive leads to serious widespread and substantial
damage or destruction of the environment. Concrete
provisions on the types and levels of penalties that can be
imposed for natural and legal persons who commit an
offence were also introduced. Other provisions will help
considerably to improve the effectiveness in combating
environmental crime of all actors along the enforcement
chain. These include obligations to ensure adequate
resources and investigative tools, specialised regular
training and the establishment of cooperation
mechanisms within and between Member States as well
as national strategies on combating environmental crime.
Member States are required to transpose the new ECD
into national law by 21 May 2026 and to take additional
measures to more effectively combat environmental
crime, in particular through training, coordination,
cooperation and strategic approaches. The Commission
will provide support, including by facilitating the
identification and sharing good practices. Member States
are expected to ensure the necessary resources and
specialised skills required and they are invited to
encourage their authorities to support and cooperate with
the recognised EU-level networks of environmental
enforcement practitioners, such the EU Network for the
Implementation and Enforcement of Environmental
Law (
203
), EnviCrimeNet (
204
), the European Network of
Prosecutors for the Environment (
205
) and the EU Forum of
Judges for the Environment (
206
). The European Union
Agency for Law Enforcement Cooperation and European
Union Agency for Criminal Justice Cooperation
mechanisms for cooperation on cross-border cases should
be used more systematically for environmental offences.
Environmental Liability Directive
The Environmental Liability Directive (ELD)(
207
) aims to
ensure that environmental damage is remediated in kind
at the expense of those who have caused it, in line with
the polluter-pays principle. It helps to halt the net loss in
biodiversity, as well as reducing the number of
contaminated sites and protecting the environmental
quality of groundwater and surface waters. The ELD is a
cross-cutting tool and a key enabler for better
implementation of EU environmental law.
The ELD addresses cases of significant environmental
damage to protected species and natural habitats, and,
when caused by operators carrying out certain potentially
hazardous activities, also damages to water and to soil.
The Commission has the legal obligation to periodically
evaluate the ELD. The ELD has undergone the second
evaluation (
208
), which will be finalised in 2025, and which
was supported by an external study (
209
), containing,
among other things, evidence, views, reports and other
relevant information gathered from different stakeholder
groups, including Member States.
One of the most relevant indicators in assessing
implementation and enforcement of the ELD is the
number of environmental damage cases handled under
the ELD, especially when this number is compared with
the previous reporting period. Fewer ELD cases were
reported in the second reporting period (2013–2022) than
in the first one (2007–2013). However, the downward
tendency in the number of ELD occurrences and their
overall low number do not necessarily mean that the ELD
has achieved its objectives, as it needs to be compared
with the overall number of environmental damage cases,
some of which may have been handled under the other
liability instruments.
The ELD has not always been effective in ensuring that the
polluter pays, because the liable operators often lack
(
207
)
Directive 2004/35/EC on environmental liability with regard to the
prevention and remedying of environmental damage (https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626).
Commission staff working document - Evaluation of the
Environmental Liability Directive, forthcoming 2025.
European Commission: Directorate-General for Environment and
Fogleman, V.,
Study in support of the evaluation of the
Environmental Liability Directive and its implementation
–
Final
report,
Publications Office of the European Union, Luxembourg,
2024,
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en.
(
202
) Directive 2024/1203/EU on the protection of the environment
through
criminal
law
(https://eur-
lex.europa.eu/eli/dir/2024/1203/oj/eng).
(
203
)
https://www.impel.eu/en.
(
204
) LIFE+SATEC
project
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations).
205
)
(
https://www.environmentalprosecutors.eu.
(
206
)
https://www.eufje.org/index.php?lang=en.
(
208
)
(
209
)
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financial capacity to carry out remediation measures.
While the ELD does not provide for a mandatory financial
security system, it explicitly calls for Member States to
encourage the development of financial security
instruments and markets, with the aim of enabling
operators to use financial guarantees to cover their
responsibilities under this directive.
From 1 May 2013 to 31 December 2021, the Netherlands
did not identify any occurrences of environmental damage
under the ELD. Moreover, in the previous reporting
period, no environmental damage occurrences were
reported under the ELD.
The Netherlands has not introduced a mandatory financial
security system for ELD liabilities. Environmental
insurance policies that provide cover for all on-site and off-
site ELD liabilities, sometimes including complementary
and compensatory remediation, are widely available and
demand is good. Environmental extensions to general
liability policies are available but they generally only
provide cover for ELD liabilities if such liabilities overlap
with requirements under other national environmental
legislation to remediate off-site land/soil pollution from a
sudden and accidental incident on an insured site. The
extensions, which tend to be included automatically in the
body of the policy, rarely provide cover for remediating
biodiversity damage under the ELD.
The 2022 EIR recommended that the Netherlands improve
its financial security system for environmental liability to
meet the costs of environmental damage. The
Netherlands achieved some progress. The efforts to
implement 2022 priority actions should continue along
with those for the 2025 priority action.
of the EIR reporting tool in improving environmental
governance. The two main capacity-building opportunities
for the environment provided by the European
Commission are the TSI (
211
) and the TAIEX-EIR PEER 2
PEER tool (
212
). The technical assistance available through
the cohesion policy is subject to shared management and
is not dealt with in this subsection.
The Commission’s technical support instrument
The TSI provides Member States with tailor-made
technical expertise on the design and implementation of
reforms. The support is demand driven and does not
require national co-financing.
The
Commission’s
TSI had annual calls in 2021, 2022, 2023,
2024 and 2025. The following environment-related
projects have been selected for the Netherlands:
•
•
Digitalising monitoring of East Atlantic Flyway (2022),
a multi-country project with Denmark and Germany;
Tackling greenwashing risk in the German and Dutch
sustainable investment fund market, run by the Dutch
Authority for the Financial Markets (2023);
Technical support for the implementation of the RRP,
run by the Ministry of Finance (2023);
Accelerating permitting for renewable energy, run by
the Ministry of Economic Affairs and Climate Policy,
and the Directorate-General for Climate and Energy,
Department of Strategy Energy System (2023).
Support for the assessment of environmentally
harmful subsidies and for the preparation of national
biodiversity plans in Belgium, the Netherlands and
Finland, run
by Belgium’s
Federal Public Service
Health, Food Chain Safety and Environment (two calls
in 2024);
Identify financial solutions to mobilise resources for
the implementation of the GBF, through the
preparation of a national biodiversity finance plan,
run by the Ministry of Agriculture, Nature and Food
Quality (2024);
The assessment of net-zero commitments by financial
corporates in the Netherlands, run by De
Nederlandsche Bank (2024);
Support to the development of the National
Restoration Plans; multi-country project with HR, NL
and PL - Ministry of Climate and Environment (2025)
Integrated environmental monitoring informs
adaptive management of coastal wetlands, Ministry
of Agriculture, Nature and Food Quality (2025).
•
•
•
2025 priority action
•
Encourage the use of training programmes provided
by the Commission (or developed at the national
level) and covering the ELD and its interactions with
the other national liability related instruments, to
ensure more efficient ELD implementation, improve
the expertise of the competent authorities and raise
awareness among all stakeholder groups.
•
•
EU-supported environmental capacity building
The Commission’s 2023 Compact (
210
) initiative to enhance
the administrative space identifies the capacity to lead the
green transition as one of three key pillars, along with the
public administration skills agenda and the capacity for
Europe’s Digital Decade. Compact also recognises the role
(
210
)
See the European Commission web page on Compact
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en).
See the European Commission web page on the TSI
(https://commission.europa.eu/funding-tenders/find-
•
•
(
212
)
(
211
)
funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en).
See the European Commission web page on the TAIEX-EIR PEER 2
PEER
tool
(https://environment.ec.europa.eu/law-and-
governance/environmental-implementation-review/peer-2-
peer_en).
TAIEX: Technical Assistance and Information Exchange.
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•
•
The Commission’s TAIEX-EIR PEER 2 PEER tool
The Commission launched the TAIEX-EIR PEER 2 PEER tool
in 2017. It aims to facilitate peer-to-peer learning among
Member States’ environmental authorities through
workshops (single or multi-country), expert missions
(where a delegation of experts travels to the requesting
institution) and study visits (where a delegation from the
requesting institution travels to a host country). Flagship
multi-country workshops are those requested by the
European Commission to present new and upcoming
environmental legislation and policy in all Member
States (
213
).
Workshops involving the Netherlands are as follows:
•
Climate adaptation and blue infrastructures:
Examples across European regions (31 May 2022–
1 June 2022);
Circular procurement (7 June 2022), hosted by the
Public Service of Wallonia, Belgium;
Good practices on noise abatement measures and
noise mapping: Directive 2002/49/CE (26–
27 September 2022);
•
•
•
•
•
Circular economy in the Irish midlands (4–6 October
2022);
Future challenges in the air protection in Europe
(24 November 2022), with the Czech Presidency of
the Council of the European Union;
Make space for biodiversity: Regional action to
mainstream biodiversity and empower stakeholders
(21–23 March 2023);
Circular public procurement and circular public
investments (7–8 November 2023);
Biodiversity, nature conservation and large
predators: Examples across European regions (4–
6 June 2024), hosted by the Netherlands;
Online platforms: EU Batteries, Packaging and
Packaging Waste Regulation (28–29 October 2024);
New aspects in the cross-border cooperation against
environmental crime (19–20 November 2024) (
214
).
•
•
2025 priority action
•
Improve overall national environmental governance,
in particular administrative capacity to support the
green transition and coordination at the regional and
local levels.
(
213
)
Flagship multi-country workshops in the reporting period are:
Recast Drinking Water Directive (3 April 2025); Environmental
compliance and governance (18 March 2025); Planning of
Renewable Energy Projects (20 February 2025); Air Quality:
Implementation of the revised Air Quality Directive (16 January
2025); Industrial safety: awareness raising of emerging risks linked
with climate change and decarbonation (12 December 2024); Air
quality: implementation of the NEC Directive to further
mainstream air and broader pollution reduction in agricultural
policy (25 September 2024); Industrial emissions transposition
and implementation of the revised Directive (12 September 2024);
Noise:
progress towards meeting Member States’ noise
limit
values and EU reduction targets (5 June 2024); Best practice use
of environmental footprint methods on the EU market (30 May
2024); Sustainable finance (9 November 2023); Textile waste
separate collection, treatment and markets (3 October 2023); EU
environmental funding and support (13 June 2023); Advisory
service for businesses to go circular (24 April 2023); Digital
product passport implementation (6 December 2022); Public
involvement in planning and approval of renewable energy
projects (17 November 2022); Environmental compliance and
governance (14 November 2022); Biowaste management (19-20
September 2022); Renewable energy projects: permitting granting
processes (13 June 2022)). N.B. the first flagship workshop on Zero
Pollution for Air, Water and Soil, took place 9 February 2022.
(
214
)
https://webgate.ec.europa.eu/TMSWebRestrict/resources/js
/app/#/library/detail/90076?hasBackBtn=false.
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Annex
2025 priority actions
Circular economy and waste management
Waste management
•
•
•
•
Further shift reusable and recyclable waste away from incineration, including through economic instruments.
Increase the collection and recycling rate of waste electronic and electric equipment (WEEE).
Invest in waste prevention measures to reduce the total amount of waste generated.
Extend a pay-as-you-throw system to all households, and fully introduce the cost-coverage rules as part of extended
producer responsibility for packaging
Biodiversity and natural capital
Global and EU biodiversity frameworks
•
Submit to the Convention on Biological Diversity an updated NBSAP or national targets following the adoption of the
Kunming-Montreal Global Biodiversity Framework.
Nature protection and restoration –
Natura 2000
•
•
Complete the Natura 2000 site designation process
Ensure the effective implementation of Natura 2000 management plans and sufficient administrative capacity and
financing both for Natura 2000 and the implementation of the Nature Restoration Regulation. Ensure implementation
of Prioritised Actions Framework 2021-2027 (PAFs).
Recovery of species
•
Enhance efforts to collect reliable data on the conservation status of habitats and species as well as their occurrence
at site level. In view of this, consider the creation of a body in charge of monitoring and reporting, to ensure that data
are not provided only ad hoc on a contract basis.
Reinforce action for habitats and species with unfavourable conservation status through, for example, restoration
measures, increased connectivity, better policy coordination and integration, and increased funding
•
Recovery of ecosystems
•
•
•
Step-up efforts to further reduce nitrogen deposition, in particular in Natura 2000 sites with nitrogen-sensitive species
and habitats..
Implement eco-schemes and agri-environmental measures and practices to address the environmental needs of
Belgium.
Implement and scale up the uptake of organic farming practices.
Forest ecosystems
•
•
•
Improve conservation status of forests by promoting sustainable forest management and ensuring compliance with
the Habitats Directive before granting/renewing permits for forest logging.
Implement peatland conservation and restoration measures and include such measures and objectives in the national
restoration plans.
Bring levels of nitrogen deposition under the critical threshold to allow forest habitat types protected under the Habitats
Directive to recover
Marine ecosystems
•
Report updates on the assessment of the state of the Netherlands’ marine waters, its targets and its determinations
of GES, which are expected to include any threshold values for the descriptors in the MSFD that may have been
established in cooperation with other Member States at the EU or regional level.
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Prevention and management of invasive alien species
•
•
Step up implementation of the IAS Regulation, including with regard to enforcement and capacity of inspection
authorities.
Ensure regional cooperation with neighbouring Member States to address predominant pressures.
Zero pollution
Clean air
•
•
As part of the NAPCP, take action to reduce emissions of air pollutants.
Ensure full compliance with the current AAQD standards, also in light of future stricter requirements under the revised
AAQD.
Industrial emissions
•
•
•
•
Reduce industrial air pollution damage and intensity.
Reduce industrial releases to water and their intensity.
Engage with industry and environmental NGOs to ensure proper contribution to and implementation of BAT
conclusions and ensure timely updates to permits following the publication of BAT conclusions.
Ensure effective public participation and access to justice in relation to the IED.
Major industrial
accidents prevention –
Seveso
•
Strengthen compliance with requirements on safety measures to prevent major accidents and ensure appropriate
preparedness and response in relation to UTEs, in particular as regards reviewing, testing and updating EEPs, at
intervals of no more than three years.
Noise
•
•
Complete noise mapping.
Complete and implement action plans on noise management.
Water quality and management
Water Framework Directive
•
•
•
•
•
•
Improve river continuity and ecological flows, boosting efforts on nature-based solutions to reduce hydromorphological
pressures.
Ensure periodic reviews of permits for discharges, abstractions and other water uses, including hydropower pressures.
Reduce pollution from nutrients, chemicals, metals and saline discharges.
Better justify exemptions to the achievement of good status.
Improve the classification of water bodies and strengthen monitoring systems.
Develop more robust programmes of measures, tackle obstacles identified in the implementation of measures and
ensure adequate financing for implementation, including through better use of the cost recovery and polluter pays
principle.
Floods Directive 
•
•
•
FRMPs should provide details on how the FHRMs were used in the choice of measures and how to consider pluvial
flooding.
Better explain the choice and implementation of flood prevention and protection measures (prioritisation, monitoring,
costs of measures).
Improve public consultation and stakeholder involvement.
Nitrates Directive 
•
Tackle nutrients pollution, especially nitrates from agriculture, through the implementation of the Nitrates Directive
.
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Chemicals
•
•
Upgrade administrative capacities in implementation and enforcement to move towards a policy of zero tolerance of
non-compliance.
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement of the European
Chemicals Agency, including in the coordinated enforcement projects, called REF projects.
Increase customs checks and checks of products sold online with regard to compliance with chemicals legislation
.
•
Climate action
•
Implement all polices and measures that are needed to achieve targets laid down in the Effort Sharing Regulation
(ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) Regulation. More detailed priority actions are
set out in the assessment of the final National Energy and Climate Plan (NECP) .
Financing
•
Use more national funding (for instance by increasing taxes in favour of the environment and reducing environmentally
harmful subsidies), EU funding and private funding to help close the investment gap.
Environmental governance
Information, public participation and access to justice 
•
•
Make spatial data more widely accessible and prioritise environmental datasets in implementing the Inspire Directive,
especially those identified as high-value spatial datasets for implementing environmental legislation.
Ensure that relevant information on EIA and SEA procedures (including on public participation opportunities and on
the publication of final decisions) is electronically accessible on a timely basis, through at least a central portal or easily
accessible points of access, at the appropriate administrative level.
Provide information on the average duration of all steps in the EIA process.
Encourage the use of training programmes provided by the Commission (or developed at the national level) and
covering the ELD and its interactions with the other national liability-related instruments, to ensure more efficient ELD
implementation, improve the expertise of the competent authorities and raise awareness among all stakeholder
groups.
•
•
Compliance assurance 
EU-supported environmental capacity building
•
Improve overall national environmental governance, in particular administrative capacity to support the green transition
and coordination at the regional and local levels.
2025 Environmental Implementation Review
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