REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on evaluating the implementation of Decision No. 406/2009/EC pursuant to its Article 14
Date: 2016-07-20
Institutions: Directorate-General for Climate Action, European Commission
Subjects: EU Member State, EU emission allowance, EU environmental policy, Kyoto Protocol, adaptation to climate change, climate change, environmental monitoring, greenhouse gas, pollution control, reduction of gas emissions

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 20.7.2016  COM(2016) 483 final   REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on evaluating the implementation of Decision No. 406/2009/EC pursuant to its Article 14 {SWD(2016) 251 final}  
 
 
1.  Introduction   

Adopted in 2009 as part of the Climate and Energy package, Decision No. 406/2009/EC1 (also called 
the Effort Sharing Decision, ESD) establishes greenhuse gas (GHG) emission limits for all Member 
States for 2020. It covers emissions in the transport, buildings, agriculture, small industry and waste 
sectors.  These  sectors  accounted  for  more  than  55%  of  total  EU  GHG  emissions  in  2013.2  The 
objective of the ESD is to reduce GHG emissions in the EU by 10% by 2020 compared to 2005 and 
promote reductions of GHG emissions within its scope in a fair and cost-effective manner. The ESD 
entered into force in June 2009. 

This report fulfils Article 14 of the Effort Sharing Decision which requires the Commission to draw 
up a report evaluating the implementation of the ESD and submit it to the European Parliament and to 
the Council by 31 October 2016. It presents how the Effort Sharing Decision has performed so far and 
what lessons can be learned with respect to actions taken by Member States to limit greenhouse gas 
emissions  in  the  sectors  covered  by  the  Decision,  and  the  effect  on  their  national  emissions.  The 
results  of  the  evaluation  are  presented  in  more  detail  in  the  Commission  staff  working  document 
accompanying this report.3 

While the first year of reporting by Member States under the Decision was 2015, at the time of the 
evaluation, most of the provisions of the Decision had not yet been applied, making it more difficult 
to draw conclusions about their appropriateness and to consider any changes based on lessons learned. 
However,  the  evaluation  could  use  valuable  evidence  deriving  from  the  process  of  legal 
implementation of the Decision and the preparatory work undertaken by Member States. 

2.  Background 

The Climate and Energy Package sets targets for 2020, requiring a 20% reduction in its greenhouse 
gas  emissions  from  1990  levels,  a  20%  share  of  EU  final  energy  consumption  from  renewable 
sources, and a 20% improvement in its energy efficiency. 

The  20%  GHG  emission  reduction  target  for  the  European  Union  by  2020  compared  to  1990  is 
equivalent  to  a  14%  reduction  compared  to  2005.  This  effort  has  been  divided  between  the  sectors 
covered by the Emission Trading System (ETS) and sectors under the ESD. In the EU ETS emissions 
are  required  to  decrease  by  21%  relative  to  2005  levels,  while  from  sectors  in  the  ESD  a  10% 
reduction relative to 2005 is required.  

To share the required EU-wide effort of 10 % GHG emission reduction by 2020, national targets for 
2020 were set for Member States according to economic capacity on the basis of their relative wealth 
(measured by 2005 Gross Domestic Product per capita) They range from a 20% emissions reduction 
by 2020 (from 2005 levels) for the richest Member States to a 20% increase for the least wealthy one. 
(See Figure 1).   

The  ESD  does  not  set  specific  emission  targets  for  the  individual  sectors  covered  by  the  ESD,  but 
leaves it to Member States to choose where and how to achieve the necessary reductions. Emissions 
and removals from LULUCF are not included in the ESD. 

To meet their commitments Member  States are supposed to limit their greenhouse gas emissions in 
the sectors covered by the ESD, and they are expected to implement national policies and measures to 
fulfil their obligations. Member States can also apply flexibility instruments to meet their obligations 
and enhance cost-effectiveness, if needed.  

1 Decision No. 406/2009/EC of the European Parliament and of the Council of 23 April 2009 on the effort of Member States 
to reduce their greenhouse gas emissions to meet the Community's greenhouse gas reduction commitment up to 2020; 
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009D0406&from=EN  
2 The current ESD covers the same greenhouse gases as the Kyoto Protocol, with the exception of nitrogen trifluoride NF3. 
Emissions  and  removals  from  land  use,  land-use  change  and  forestry  (LULUCF)  are  not  included  in  the  ESD.  GHG 
emissions from international shipping are not covered by the ESD. 
3 SWD(2016) 251 

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The ESD also  defines a linear trajectory of corresponding binding emission limits (annual  emission 
allocations,  AEAs)  for  each  year  from  2013  to  2020.  Progress  towards  the  2020  targets  is  ensured 
through  annual reporting obligations and compliance checks.  Member  States  are  obliged  to  report  on 
their greenhouse gas emissions and projected progress towards meeting their ESD obligations. 

Member  States  are  responsible  for  implementing  policies  and  measures  to  meet  their  obligations 
under the ESD and are supported by a number of EU measures4, some of which also are expected to 
help achieving the EU’s 2020 renewable energy and energy efficiency targets. These supporting EU 
policies are important to stimulate EU-wide emission reductions in the sectors under the ESD. But it 
is  clear  that  emission  reductions  have  to  be  delivered  through  national  policies  and  measures,  in 
particular in sectors such as transport and buildings.  

Figure 1: Member State greenhouse gas emission limits in 2020 under the ESD 

Emission limits in 2020 are set in relation to 2005 emission levels. Source:  Decision No. 406/2009/EC.  

In  order  to  provide  for  flexibility  for  Member  States  in  implementing  their  commitments  and  as  a 
means  to  enhance  the  overall  cost-effectiveness  of  reaching  the  EU-wide  2020  target,  the  ESD 
provides  a  range  of  flexibility  instruments.  These  concern  Member  States’  possibilities  to  manage 
their  own  AEAs  within  the  compliance  period  and  engage  in  transfers  of  AEAs  among  each  other. 
Should a Member State’s GHG emissions exceed its AEAs for a given year, then it can borrow 5% of 
its  AEAs  from  the  next  year  or  buy  AEAs  from  other  Member  States  or  use  international  project 
credits in order to meet its annual limits. Should a Member State reduce its emissions by more than 
needed,  thus  overachieving  its  target  for  a  given  year,  it  can  keep  the  surplus  AEAs  for  later  use 
within the commitment period or transfer it to other Member States.5  

The ESD has an annual reporting and compliance cycle consisting of Member States reporting their 
GHG  emissions  in  national  inventory  reports,  emissions  inventory  reviews  to  validate  the  reported 
emissions,  and  compliance  checks  (i.e.,  comparing  the  actual  emission  of  Member  States  with  their 
annual  emission  allocations  for  a  given  year).  If  a  Member  State's  emissions  exceed  its  annual 

4  Examples  of  relevant  EU  legislation  are  the  regulation  of  CO2  emissions  from  passenger  cars  and  vans,  the  Landfill 
Directive,  the  Energy  Performance  of  Buildings  Directive,  the  Energy  Efficiency  Directive,  the  Renewable  Energy 
Directive,  the  F-gas  Regulation  and  Mobile  Air-Conditioning  Systems  Directive,  the  eco-design  framework,  the  Nitrates 
Directive, and the greening of the Common Agricultural Policy.  
5 For more details of the existing flexibility instruments, see annex 4 of SWD(2016) 251 ,  

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emission  allocation,  even  after  accounting  for  flexibility  instruments,  they  will  be  subject  to  certain 
penalties and have to take corrective measures. 

3.  Scope and method of the evaluation 

The  evaluation  of  the  Effort  Sharing  Decision  was  performed  in  2015  by  the  Commission  and  was 
guided  by  a  steering  group  consisting  of  members  from  the  concerned  directorate-generals  in  the 
Commission. The European Environment Agency also participated in this group. The evaluation was 
supported by an external study of the implementation of the Effort Sharing Decision.6  

The  evaluation  explored  the  impacts  of  the  Effort  Sharing  Decision  both  at  EU  and  Member  State 
level with a focus on actions in Member States from 2009 onwards to meet their ESD obligations. It 
covered  the  period  from  when  the  ESD  entered  into  force  in  June  2009  to  November  2015.  In 
accordance with the requirement in Article 14 of the ESD, the scope of the evaluation included all the 
provisions and requirements of the Decision, including how the implementation affected competition.  

The evaluation assessed the relevance, effectiveness, efficiency, coherence and EU value added with 
respect of ESD implementation so far. It used evidence from reported emissions and emission trends, 
adopted policies and measures, as well as questionnaires and structured interviews with Member State 
experts and other key stakeholders involved in implementing ESD on national level.7 It also drew on 
the results of a public consultation on the preparation of a legislative proposal on reducing Member 
States’ GHG emissions in sectors under the ESD from 2021 to 2030.8 

The  results  of  the  evaluation  were  used  when  preparing  the  impact  assessment  accompanying  the 
legislative proposal the Commission to continue ESD after 2020 within the 2030 Climate and Energy 
Framework. 

4.  Implementation - State of play 

The  ESD  is  still  in  an  early  stage:  most  reporting  requirements  for  Member  States  under  the  ESD 
occurred for the first time in 2015, and the compliance check for the first two years of the compliance 
period  (2013-2014)  is  due  in  2016.  However,  thanks  to  existing  annual  reporting  of  emissions  it  is 
possible to discern the main emission trends in Member States and on EU level. 

Under  the  ESD,  Member  states  must  each  year  report  their  GHG  emissions.  They  must  also,  every 
second  year,  report  on  their  implemented  national  policies  and  measures  and  submit  updated 
projections in 2015 with expected progress to their 2020 targets. Each year the Commission compiles 
the  information  reported  by  Member  states  and  publishes  a  progress  report  where  it  analyses  and 
presents Member States’ progress towards their 2020 ESD targets. An assessment of Member States’ 
progress towards their targets is also part of the European Semester country report published by the 
Commission every spring. Emission trends and projections in the EU and its Member States are also 
published  each  year  by  the  European  Environment  Agency  which  assists  the  Commission  with  the 
implementation of the ESD. 

Member States have so far fulfilled their reporting obligations and the exchange of information with 
the  Commission  is  working  well.  The  Commission  and  Member  States  expert  meet  several  times 
every year in working groups under the Climate Change Committee to follow up the implementation 
of the reporting obligations under the ESD.  

Total emission reductions between 2005 and 2013 were achieved in all sectors, ranging from -3 % in 
agriculture  to  -25  %  in  the  waste  sector.  (Figure  2)  In  this  period  there  was  also  a  convergence  of 
GHG emission intensities across Member States, both per capita and per GDP.  

6 A presentation of the methodology applied for the evaluation, and the evidence used, is provided in annex 3 of SWD(2016) 
251. For the external study, see Supporting study for the Evaluation of Decision No. 406/2009/EC (Effort Sharing Decision), 
Ricardo Energy and Environment with Trinomic and Vito. 
7 The results of the stakeholder consultation are presented in annex 2 of SWD(2016) 251. 
8 For more information on this consultation, see http://ec.europa.eu/clima/consultations/articles/0025_en.htm 

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ESD emissions per Member State have also decreased significantly since 2005. In all Member States 
ESD  emission  were  below  their  annual  limits  in  2013  and  2014.9  Overachievements  were  typically 
larger  in  those  countries  that  were  allowed  to  increase  emissions  compared  to  2005.  Countries  that 
experienced  a  particularly  severe  economic  recession  (e.g.,  Greece,  Portugal  and  Spain)  also  had 
emissions significantly below their 2014 limits. 

Figure 2: Achieved EU-wide ESD emission reductions 2005-2013 

According to Member State projections submitted in 2015, total ESD emissions are expected to keep 
decreasing until 2020 (Figure 3), continuously being below target at the EU level. 24 Member States 
are  projected  to  meet  their  national  targets  domestically,  while  four  Member  States  are  expected  to 
need additional measures or use flexibility instruments within the ESD to reach their targets.10 

So  far,  no  Member  State  has  used  any  of  the  flexibility  instruments  provided  in  the  ESD  as  all 
countries appear to be meeting their annual emission limits for the first two years of the compliance 
period. In the future it can be expected that flexibility instruments, such as trade with other Member 
States,  will  be  used  by  some  Member  States  that  are  projected  to  emit  above  their  limits  by  2020. 
Although  the  flexibility  instruments  under  the  ESD  are  untested  they  remain  widely  supported  and 
were further endorsed by Member States in the stakeholder consultation. 

9 Based on emission reports submitted in 2015. See also SWD(2016) 251, p.17. 
10 Climate action progress report, COM(2015) 576 final. 

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Figure 3: Actual and projected total ESD emissions 2005-2020 

Source: EEA (2015) Trends and projections in Europe 2015, updated with March 2016 emission inventory 
figures. The black dotted line represents the linear trajectory of the annual emission limits under the ESD for the 
period 2013-2020. 

5.  Results of the evaluation 

In  accordance  with  the  Commission’s  evaluation  guidelines,  the  evaluation  assessed  the  relevance, 
efficiency,  effectiveness,  coherence  and  EU  added  value  of  the  Effort  Sharing  Decision.  It  also 
examined whether there were any effect on competition as this was a requirement of Article 14 in the 
ESD.  

5.1 

Relevance 

The objectives of the ESD remain relevant, and still correspond strongly with the needs of the EU. In 
particular, there remains a need to continue to limit anthropogenic GHG emissions, and put in place 
appropriate  mechanisms  to  reflect  the  full  social  cost  of  climate  change.  The  ESD  remains  relevant 
also for addressing market failures as the binding nature of the Decision helps to provide appropriate 
price signals for emissions abatement. 

The  European  Council  Conclusions  in  October  2014  on  the  2030  Climate  and  Energy  Policy 
Framework confirmed the importance of the ESD and of its continuation to 2030 with all the elements 
as applied in the Effort Sharing Decision for 2020.  

The adoption in December 2015 of the Paris Agreement confirms the commitment at the highest level 
of  the  EU  to  implement  domestically  steep  greenhouse  gas  emissions  reductions  also  for  2030  and 
beyond. As laid down in its intended nationally determined contribution (INDC), the EU commits to 
cut emissions in its territory by at least 40% below 1990 levels by 2030.  

5.2 

Effectiveness 

The EU is on track to meet its 2020 GHG emissions reduction target in the ESD  sectors. Based  on 
Member  States’  reports  submitted  in  2015,  GHG  emissions  in  2013  and  2014 in  all  Member  States 
were below their annual limits for these years. Total 2013 emissions covered by the ESD at EU level 

6 

 
 
 
 
 
 
were  9.7%  lower  than  the  2005  emissions.  In  2014  EU  emissions  covered  by  the  ESD  further 
decreased to a level 12.9% below 2005 levels, which was below the EU-wide ESD target for 2020. 
This means that the EU is on track to meet its ESD target in 2020 and that all Member States have 
contributed to the reduction in GHG emissions.  

The  achieved  emission  reduction  represents  a  large  improvement  in  performance  relative  to  the 
business-as-usual scenario when the 2020 targets were first agreed. Emission reductions have so far 
been  much  deeper  than  expected  in  2007  when  the  European  Council  agreed  on  the  overall  EU 
climate  targets  for  2020  and  the  Commission  performed  the  impact  assessment  of  the  Climate  and 
Energy  Package.  According  to  the  business  as  usual  scenario  in  that  impact  assessment,  EU-wide 
ESD emissions were expected to increase by 2.4% between 2005 and 2020.11  

The  economic  recession  has  also  had  an  effect  on  GHG  emissions  in  some  ESD  sectors  to  date 
(especially  freight  transportation),  and  these  effects  are  expected  to  resonate  until  2020.  However, 
many sectors (such as buildings and agriculture) covered by the ESD are not directly impacted by the 
fluctuations  in  GDP  and  are  more  prone  to  policy  influence  which  gives  reasons  to  conclude  that 
some of the GHG reductions in the ESD sectors can be attributed to policy interventions at EU and 
Member State level.  

In  other  words,  the  achieved  emission  reductions  can  be  in  part  attributed  to  climate  and  energy 
policies  and measures  that  have  already  been  implemented  by  Member  States  (of  which  some  have 
been in response to the ESD) and are expected to continue limiting emissions in future years. 

This observation is further supported by a decomposition analysis that was carried out for the 2005-
2012 period covering CO2 emissions from fossil fuel combustion, which account for about 80 % of 
total  GHG  emissions,  in  both  ETS  and  ESD  sectors.  The  analysis  concluded  that  technological 
changes  contributed  most  to  drive  down  emissions,  by  far  outweighing  the  contribution  of  the  shift 
within and between economic sectors, and by far overcompensating GDP related emission drivers in 
times of economic crisis. 

The  results  showed  that  CO2  emissions  decreased  overall  by  11.5  %  between  2005  and  2012. 
Technological changes had the most significant effect on driving down emissions, leading to an 18.5 
% decrease and by far outweighing the contribution of the shift between economic sectors. Overall, 
the policies implemented in the field of climate and energy contributed significantly to the take-up of 
less carbon-intensive technologies, including renewable energy. Growth in economic activity (GDP) 
caused a 6.8 % increase in emissions. Structural changes in the economy (at constant GDP and CO2 
intensity in every economic sector) caused a small increase in emissions, by 1.7 %.12  

It was not possible to quantify the extent to which the observed trend in historical emissions, and the 
expected  future  emissions  trends,  can  reasonably  be  credited  to  specific  policies.  In  particular,  it  is 
difficult to isolate the impact of the ESD on national climate and energy policies, and from other EU-
wide  initiatives  under  the  Climate  and  Energy  Package,  which  have  a  more  direct  impact  on  the 
different drivers of emissions. 

While  some  stakeholders  considered  that  the  ESD  has  been  an  important  driver  for  new  national 
policies and measures in certain Member States, others considered that the ESD may have had little or 
no influence on national policy developments so far. The level of influence of the ESD also appears to 
vary by Member State, which may reflect the different situation of Member States in relation to their 
ESD targets, i.e. whether they need to take further action or not. 

The evaluation of the ESD showed an increase in the implementation of national policies in the ESD 
sectors  in  most  years  starting  from  2007,  when  the  European  Council  agreed  on  the  overall  EU 
climate  targets  for  2020.  Without  the  ESD,  actions  to  mitigate  emissions  in  the  ESD  sectors  at 
Member States level may not have been taken, or may have been taken at a slower pace.  

5.3 

Efficiency 

11  SEC  (2008)  85/3  EC.  See  also  Supporting  study  for  the  Evaluation  of  Decision  No.  406/2009/EC  (Effort  Sharing 
Decision),  p.12. 
12 Climate action progress report, COM(2015) 576 final, p.9. 

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The costs and benefits due to the implementation of measures in ESD sectors are hard to quantify, as a 
direct  link  between  many  national  climate  and  energy  policies  and  emission  reductions  in  sectors 
under the ESD so far is difficult to establish. This is also due to the fact that policies and measures 
reported  by  Member  States  provide  insufficient  information  on  their  expected  and  actual  costs  and 
benefits. 

The  main  benefit  associated  with  the  ESD  relates  to  the  GHG  emissions  reductions  in  the  sectors 
covered  by  the  Decision.  In  addition  to  any  direct  costs,  the  implementation  of  the  ESD  has 
potentially also delivered a number of economic co-benefits, such as improvements in air quality and 
energy security. 

Another more qualitative benefit of the ESD is that it helps Member States in setting up institutional 
frameworks, targets and data collection and reporting procedures for reducing emissions in the ESD 
sectors. This benefit is more apparent in those Member States where the policies reducing emissions 
in these sectors are devolved to a regional level. 

Costs from the implementation of the ESD come from two main sources – implementation of policies 
and measures in relevant sectors and ESD reporting. 

With respect to reporting costs, the ESD was found to deliver the outcomes efficiently, although there 
may  still  be  some  opportunities  for  reducing  administrative  burdens.  Costs  related  to  reporting  and 
compliance are modest and mostly fall on the Commission and the European Environment Agency. 
There  was  no  major  variation  apparent  between  Member  States.  There  may  be  opportunities  for 
reducing  administrative  costs  at  EU  level,  for  example  by  simplified  or  less  frequent  compliance 
controls. 

With respect to the flexibility instruments provided by the ESD, three Member States indicated that 
they were planning to purchase AEAs from others, whereas ten Member States intended to sell AEAs. 
The low demand for such transfers might be due to the fact that the ESD is still in the early years of 
the  implementation  and  that  there  might  be  other  drivers,  not  investigated  by  the  evaluation,  that 
would  prompt  Member  States  to  prefer  the  implementation  of  domestic  actions  rather  than  buying 
AEAs from other Member States.  

5.4 

Coherence 

Evidence  from  stakeholder  interviews,  and  to  a  lesser  extent  the  literature  review,  suggests  that  the 
objectives  of  the  ESD  are  largely  coherent  with  other  EU  climate  and  energy  policies,  such  as  the 
ETS, energy efficiency and renewable energy. Stakeholders identified a strong coherence with the EU 
objectives relating to energy efficiency and renewable energy, although some stakeholders queried the 
coherence of the targets themselves.  

By providing flexibility as to how Member States deliver their emission  limits, the objectives of the 
ESD was found to be largely coherent with national policy making.  

There  is  a  potential  lack  of  coherence  between  the  ESD  and  other  interventions  in  relation  to 
agriculture and land use, land use change and forestry  (LULUCF).  Part of the issue with coherence 
relates  to  other  international  commitments,  rather  than  coherence  with  EU  policies;  agriculture  is 
included in the ESD and Kyoto Protocol, while LULUCF is in the Kyoto Protocol but not the ESD.  

Coherence with other reporting obligations was also identified as strong especially with EU internal 
and international reporting requirements. However, streamlining opportunities of reporting obligations 
under the ESD and under EU energy-focused legislation were identified. 

5.5 

EU added value 

For a large majority of EU Member States there were no or only weak domestic policy drivers before 
the ESD, which suggests that without the ESD the actions may not have been taken, or may have been 
taken at a slower pace.  

The evaluation indicated that those Member States having more ambitious GHG targets than the ones 
under the ESD enshrined in their own national legislation may have taken action anyway in response 

8 

 
 
to those national laws. However, this does not take into account the fact that the discussions around 
the  EU  2020  targets  may  have  helped  support  the  setting  of  national  targets  in  the  first  place,  by 
providing  certainty  that  other  EU  Member  States  will  be  taking  a  minimum  level  of  action.  Even 
where other drivers of action were in place within Member States, the ESD was considered to exert an 
additional positive influence, even if it was not a primary driver. 

Another  important  added  value  of  the  ESD  to  date  has  been  the  improvement  in  the  quality  of  the 
emissions data and projections relating to ESD sectors at a national level, which has helped improving 
policy  preparation.  The  annual  reporting  of  emissions,  combined  with  biennial  requirements  for 
reporting  of  policies  and  measures,  and  projections,  keep  Member  State  better  informed  about  the 
progress not only of GHG emissions but also of climate and energy policies. The reporting obligations 
also  give  them  and  other  EU  stakeholders  a  tool  to  compare  their  performance  with  that  of  other 
countries in the EU.  

There was strong consensus from stakeholders that there was a continued need for an instrument such 
as the ESD also for the period after 2020. 

5.6 

Competition  

The evaluation examined whether domestic policies and measures implemented by Member States in 
response  to  the  ESD  may  have  distorted  the  internal  EU  market.  Due  the  lack  of  specific  data 
regarding the impact of such national measures on the EU internal market, the evaluation outcome is 
based solely on stakeholder's opinions. 

The  majority  of  stakeholders  indicated  that  the  ESD  has  had  no  or  limited  impact  on  competition 
within  the  EU.  Two  respondents  indicated  that  the  national  mitigation  policies  induced  by  the  ESD 
may restrict the potential for growing output from the agriculture sector because of a perceived lower 
mitigation  potential  in  that  sector.  However,  no  stakeholders  offered  examples  of  where  national 
policies and measures resulting from the ESD had any adverse impact on specific enterprises or parts 
of a sector. 

6.  Conclusions 

The ESD is still in the early stages of implementation. Nevertheless, it seems clear from the evidence 
gathered so far that ESD targets have been effective in stimulating new national policies and measures 
promoting  effective  reductions  of  GHG  emissions  within  the  ESD  scope.  Most  emission  reductions 
since  2009  have  come  from  technological  changes  and  policies  which  have  resulted  in  increased 
uptake of less carbon-intensive technology. This effect has been reinforced by the fact that the ESD 
was launched together with a number of other EU climate and energy initiatives as part of the 2020 
package,  in  particular  on  energy  efficiency  and  renewable  energy.  For  several  of  the  ESD  sectors, 
including buildings, transport, agriculture and waste, part of the emissions reductions to date can be 
attributed to factors that are influenced by policy interventions related to the 2020 package.  

Whilst  it  was  possible  to  identify  that  the  ESD  has  had  some  effect  in  stimulating  new  national 
policies in some Member States, there was insufficient evidence to quantify the overall impact of the 
ESD on GHG emissions at this stage. Evidence on the direct costs of national policies implemented in 
response to the ESD is very limited; it was not possible to assess these costs with confidence. This is 
partly  due  to  the  fact  that  national  policies  and  measures  reported  by  Member  States  so  far  have 
provided insufficient information on expected and actual costs and benefits.  

The  ESD  was  found  to  have  resulted  in  limited  additional  administrative  burden  on  Member  State 
level, although there may be opportunities for reducing administrative costs at EU level, for example 
by simplified or less frequent compliance controls. 

The  ESD  remains  coherent  with  other  EU  climate  and  energy  policies.  The  public  consultation 
showed strong consensus among stakeholders that there continues to be a need for an instrument such 
as the ESD after 2020.  

The ESD was found to add value through EU action. There was a strong level of agreement among 
Member State stakeholders that the ESD raised awareness of mitigation potential in ESD sectors and 

9 

 
 
contributed  to  establishing  new  national  institutional  and  legal  frameworks.  It  also  improved 
coordination on GHG mitigation across the ESD sectors and between national and regional or local 
governments.  

Stakeholders did not present any evidence that national policies resulting from the ESD have unduly 
distorted competition in the EU internal market. 

10