COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019 Country Report - FINLAND 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 Environmental Implementation Review 2019: A Europe that protects its citizens and enhances their quality of life
Date: 2019-04-04
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Finland, application of EU law, climate change policy, environmental law, environmental protection, governance, green economy, public health, quality of the environment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.4.2019  SWD(2019) 136 final  COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019     Country Report - FINLAND           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 Environmental Implementation Review 2019:  A Europe that protects its citizens and enhances their quality of life   {COM(2019) 149 final} - {SWD(2019) 111 final} - {SWD(2019) 112 final} - {SWD(2019) 113 final} - {SWD(2019) 114 final} - {SWD(2019) 115 final} - {SWD(2019) 116 final} - {SWD(2019) 117 final} - {SWD(2019) 118 final} - {SWD(2019) 119 final} - {SWD(2019) 120 final} - {SWD(2019) 121 final} - {SWD(2019) 122 final} - {SWD(2019) 123 final} - {SWD(2019) 124 final} - {SWD(2019) 125 final} - {SWD(2019) 126 final} - {SWD(2019) 127 final} - {SWD(2019) 128 final} - {SWD(2019) 129 final} - {SWD(2019) 130 final} - {SWD(2019) 131 final} - {SWD(2019) 132 final} - {SWD(2019) 133 final} - {SWD(2019) 134 final} - {SWD(2019) 135 final} - {SWD(2019) 137 final} - {SWD(2019) 138 final} - {SWD(2019) 139 final}  
 
 
This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
Comments are welcome, please send them to: ENV-EIR@ec.europa.eu 

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1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table of Contents 

EXECUTIVE SUMMARY ................................................................................................................................... 3 

PART I: THEMATIC AREAS .............................................................................................................................. 4 

1. 

TURNING  THE  EU  INTO  A  CIRCULAR,  RESOURCE-EFFICIENT,  GREEN  AND  COMPETITIVE  LOW-
CARBON ECONOMY .............................................................................................................................. 4 

Measures towards a circular economy ................................................................................................. 4 
Waste management .............................................................................................................................. 7 
Climate change ...................................................................................................................................... 8 

2. 

PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL .................................................. 11 

Nature and biodiversity ....................................................................................................................... 11 
Maintaining and restoring ecosystems and their services .................................................................. 12 
Estimating natural capital ................................................................................................................... 13 
Invasive alien species .......................................................................................................................... 14 
Soil protection ..................................................................................................................................... 15 
Marine protection ............................................................................................................................... 16 

3. 

ENSURING CITIZENS’ HEALTH AND QUALITY OF LIFE ........................................................................ 17 

Air quality ............................................................................................................................................ 17 
Industrial emissions ............................................................................................................................. 18 
 ................................................................................................................................................. 19 
Noise 
Water quality and management ......................................................................................................... 19 
Chemicals ............................................................................................................................................ 21 
Making cities more sustainable ........................................................................................................... 22 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................... 25 

4. 

GREEN  TAXATION,  GREEN  PUBLIC  PROCUREMENT,  ENVIRONMENTAL  FUNDING  AND 
INVESTMENTS ................................................................................................................................ 25 

Green taxation and environmentally harmful subsidies ..................................................................... 25 
Green public procurement .................................................................................................................. 26 
Environmental funding and investments ............................................................................................ 26 

5. 

STRENGTHENING ENVIRONMENTAL GOVERNANCE ......................................................................... 30 

Information, public participation and access to justice ...................................................................... 30 
Compliance assurance ......................................................................................................................... 31 
Effectiveness of environmental administrations................................................................................. 32 
International agreements ................................................................................................................... 33 
Sustainable development and the implementation of the UN SDGs .................................................. 34 

2 

 
 
 
 
Environmental Implementation Review 2019 – Finland 

Executive summary 

habitats through agricultural management. However, it is 
currently  unclear  whether  these  measures  are  sufficient 
to  offset  the  agricultural  intensification  and  resulting 
eutrophication occurring in the wider countryside. 

Finland  has  continuously  demonstrated  high  levels  of 
eco-innovation in the EU. One of the main drivers of eco-
innovation  is  the  country’s  outstanding  performance  in 
the circular economy. 

Finland has put a lot of effort into improving its recycling 
rate. However, despite these efforts, the country is at risk 
of  missing  the  2020  municipal  waste  recycling  target  of 
50 %.  Finland  will  also  have  to  do  more  to  comply  with 
the  recycling  targets  after  2020.  This  will  in  particular 
require  action  to  cut  back  on  the 
incineration  of 
municipal waste. 

in 

its  marine  environment.  Although 

For  marine  protection,  Finland  has  reported  new 
measures  for  all  descriptors  and  therefore  taken  the 
initiatives  to  address 
opportunity  to  develop  new 
pressures 
its 
programme  of  measures  addresses  the  most  relevant 
pressures and targets, the measures do not cover certain 
pressures and activities and associated impacts identified 
as important at the subregional level. Finland also reports 
that  it  does  not  expect  to  achieve  good  environmental 
status  by  2020  for  a  number  of  aspects.  Finland’s 
programme of measures thus constitutes only a partially 
appropriate programme to meet EU requirements. 

Examples of good practice 

  Education  plays  an 

in  developing 
experts  in  the  circular  economy.  Finland  is  paving  the 
way by including circularity in university curricula. 

important  role 

  Habitat  banking 

in  Finland  may  help  to  protect 
biodiversity  and  offset  losses.  The  ‘Habitat  Bank  of 
Finland’  project  is  analysing,  developing  and  piloting 
the  principles  of  ecological  compensation.  The  project 
aims  to  develop  a  new  market-based  mechanism  for 
biodiversity  conservation  to  complement  the  existing 
policy instrument mix. The Habitat Bank will operate as 
an 
requiring  and 
supplying ecological compensations. 

intermediary  between  actors 

  Finland  has  introduced  a  national  strategy  on  green 
public procurement  and set  ambitious  specific targets 
for  central,  regional  and  local  government;  targets 
have also been set which gradually increase over time. 

Finland and the Environmental Implementation Review 
(EIR) 

In  the  2017  EIR,  the  main  challenges  Finland  faced  with 
implementing EU environmental policy and law were: 

 
 

improving air quality (NO2) around Helsinki; and 
reducing diffuse pollution from agriculture that was 
lowering the quality of water.  

Finland organised an EIR country dialogue on water and 
the  circular  economy.  It  took  place  in  a  constructive 
atmosphere with the participation of the Ministry of the 
Environment,  other  ministries,  state,  regional  and  local 
authorities,  NGOs,  business,  research,  academia  and 
trade  unions.  Finland  stressed  its  support  for  efforts  to 
reinforce 
law, 
which it saw as important for EU economies. 

implementation  of  EU  environmental 

In 2017, the Commission launched the TAIEX-EIR Peer-to-
Peer (EIR P2P) tool as a practical way to support peer-to-
peer 
learning  between  environmental  authorities. 
Finland participated in a multi-country workshop in 2018 
on  the  preparations  of  national  circular  economy  action 
plans. 

Progress in meeting challenges since the 2017 EIR 

The  2019  EIR 
implementation in Finland remains at a high standard.  

that  environmental  policy 

shows 

For  air  quality,  the  emission  of  numerous  air  pollutants 
has  decreased  significantly  in  Finland  since  2014-2016, 
continuing the previous downward trend. NOx emissions 
especially have declined by over 10 per cent since 2014-
2016. 

For  water  quality,  Finland  states  that  good  progress  in 
reducing pollution from point sources has been achieved 
in  urban  and  industry  sectors  and  that  there  has  also 
been  progress  with  measures  associated  with  forestry, 
in  managing 
rehabilitation  of  watercourses  and 
hydromorphological pressures as well as in groundwater 
protection.  However,  more  measures  are  needed  for 
example regarding agriculture. 

For  industrial  emissions,  the  2019  EIR  report  identifies 
two  potential  future  challenges:  (i)  complying  with 
recently  adopted  best  available  techniques  associated 
emissions  levels  for  large  combustion  plants  for  existing 
boilers using biomass and peat and (ii) issuing permits for 
and monitoring new types of biorefineries in the pulp and 
paper industry. 

For nature conservation, thanks to an effective use of EU 
funding,  some  measures  are  being  taken  to  restore  and 
manage Natura 2000 sites. Some progress has also been 
made in better applying measures to protect species and 

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Environmental Implementation Review 2019 – Finland 

Part I: Thematic areas 

1. 

Turning the EU into a circular, resource-efficient, green and 

competitive low-carbon economy 

Measures towards a circular economy 

The  Circular  Economy  Action  Plan  emphasises  the  need 
to  move  towards  a  life-cycle-driven  ‘circular’  economy, 
reusing  resources  as  much  as  possible  and  bringing 
residual  waste  close  to  zero.  This  can  be  facilitated  by 
developing  and  providing  access  to  innovative  financial 
instruments and funding for eco-innovation. 

Following  the  adoption  of  the  Circular  Economy  Action 
Plan in 2015 and the setting up of a related stakeholder 
platform  in  2017,  the  European  Commission  adopted  a 
new  package  of  deliverables  in  January  20181.  This 
included  additional  initiatives  such  as:  (i)  an  EU  strategy 
for plastics; (ii) a Communication on how to address the 
interplay  between  chemical,  product  and  waste 
legislation; (iii) a report on critical raw materials; and (iv) 
a  framework  to  monitor  progress  towards  a  circular 
economy2. 

Among the 10 indicators covering the four dimensions of 
the  circular  economy,  the  monitoring  framework3  for  a 
circular  economy  indicates  that  Finland  performs  lower 
than  the  average  rate  in  the  EU  for  the  use  of  circular 
material  (5.3 % 
in  Finland,  11.7 %  EU-28).  Finland 
performs  slightly  below  the  EU-28  average  in  terms  of 
the number of people employed in the circular economy 
(1.66 %  of  total  employment  in  2016,  EU-28  average  is 
1.73 %). 

In  the  2017  Eurobarometer  on  attitudes  of  EU  citizens 
towards  the  environment4,  89 %  of  Finnish  people  said 
they  were  highly  concerned  about  the  effects  of  plastic 
products on the environment (EU-28 average 87 %), and 
84 % were concerned about the impact of chemicals (EU-
28 average 90 %). There appears to be strong support for 
environmental 
initiatives 
circular 
protection actions in Finnish society. 

economy 

and 

Finland is performing below the EU average for resource 
productivity  (how  efficiently  the  economy  uses  material 

resources  to  produce  wealth)5,  with  EUR  1.10  per  kg  in 
2017 (EU average is EUR 2.04 per kg). Figure 1 shows that 
this represents a slight decrease since 2016. 
Figure 1: Resource productivity 2010-20176 

In  the  2017  circular  economy  action  plan,  the  Finnish 
Innovation  Fund,  Sitra,  and  the  relevant  ministries 
pledged to examine to what extent ‘impact investing’ and 
‘social impact bonds’ were suitable for attaining the goals 
set for the circular economy. The aim is to start Europe’s 
first ‘environmental impact bond’ project in 2019. 

Finland  is  active  in  moving  the  circular  economy  higher 
up on the international agenda: the 2017 first-ever World 
Circular  Economy Forum in Helsinki  was a  success and a 
source  of  inspiration  for  the  circular  community  in 
Europe. 

for  Finland,  published 

in 
The  Plastics  Roadmap 
September  2018 
is  the  first  step  towards  a  new, 
sustainable  plastic  economy.  Of  the  more  than  100 
proposals made, the roadmap now presents a set of key 
actions to find solutions to challenges caused by plastics7. 

Currently,  out  of  a  total  of  71 707  EU  Ecolabel  products 
and 2167 licences in the EU, over 2 613 products and 18 
licences come from Finland. This shows a high take-up on 
these  licences8.  Unlike  EU  Ecolabel  registrations,  the 

1 European Commission, 2018 Circular Economy Package. 
2 COM(2018) 029. 
3 COM(2018)029   
4 European Commission, 2017, Special 468 Eurobarometer, ‘Attitudes of 
European citizens towards the environment’. 

5 Resource productivity is defined as the ratio between gross domestic 
product (GDP) and domestic material consumption (DMC). 
6 European Commission, Resource productivity. 
7 Finish Ministry of the Environment, The Plastics Roadmap for Finland  
8 European Commission, Ecolabel Facts and Figures. 

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Environmental Implementation Review 2019 – Finland 

country  does  not  have  a  high  number  of  organisations 
participating 
in  the  EU  Eco-Management  and  Audit 
Scheme  (EMAS),  a  premium  management  instrument 
developed  by  the  European  Commission  for  companies 
and other organisations to evaluate, report, and improve 
their  environmental  performance9.  Nevertheless,  the 
coverage of these EMAS registrations in Finland is broad 
given large company participation. 

Education  plays  an  important  role  in  developing  experts 
in  circularity.  Finland  is  paving  the  way  by  including 
circularity in curricula: Sitra is currently cooperating with 
11 universities, 14 universities of applied sciences, and 12 
vocational  colleges  to  bring  circularity 
into  higher 
education.  Finland’s  target  is  to  train  60 000  future 
circular economy experts in 2018. 

to  2  years  earlier.  Also,  the  outlook  is  not  positive,  with 
fewer companies intending to invest in all dimensions. 

Only 22 % of Finnish companies (EU average 22 %, range 
3 %-38 %) relied on external support in their efforts to be 
more resource-efficient. For them, private sector finance 
and consulting became more significant  (41 % of Finnish 
companies  used  private  sector  finance  and  43 %  used 
private  sector  consulting).  However,  the  use  of  public 
sector  advice  and  funding  declined  and  is  at  the  EU 
average  of  around  25 %.  Advice 
from  business 
associations 
increased  significantly 
compared to 2015. 
Figure 2: Environmental performance of SMEs12  

(21 %  to  31 %) 

Municipalities  are  also  active  in  circular  economy.  Fisu 
(Finnish Sustainable Communities) is a network of Finnish 
municipalities  committed  to  working  towards  becoming 
carbon 
curbing 
overconsumption  by  2050.  Today,  the  network  consists 
of 11 municipalities10. 

and  waste-free 

neutral 

and 

SMEs and resource efficiency 

Finnish  SMEs  performed  above  the  EU  average  in  the 
environmental  dimension  of  the  Small  Business  Act7,  as 
shown in Figure 2. 

Compared  to  2013  when  its  performance  was  on  a  par 
with  the  EU  average,  Finland  strongly  improved  its 
position.  A  large  increase  in  the  number  of  companies 
producing green products and services was accompanied 
by a rise in the proportion of SMEs benefiting from public 
support. 

Companies  taking  resource-efficiency  measures  benefit 
more from public support than the EU average. However, 
the percentage of SMEs that have benefited from public 
support measures for their production of green products 
is significantly lower than the EU average. 

The  latest  Eurobarometer  on  ‘SMEs,  resource  efficiency 
and green markets’11 asked companies about both recent 
resource-efficiency actions they had taken and additional 
resource-efficiency  actions  they  planned  to  take  in  the 
next  2  years.  The  Eurobarometer  then  compared  these 
responses with responses given to the same questions in 
2015. For recent investment, Finnish companies are at or 
below the EU average, and they invested less compared 

9 European Commission, Eco-Management and Audit Scheme 
10 Finnish Sustainable Communities  
11 Flash Eurobarometer 456 ‘SME, resource efficiency and green 
markets’ January 2018. The 8 dimensions were Save energy; Minimise 
waste; Save materials; Save Water; Recycle by reusing material 
internally; Design products easier to maintain, repair or reuse; Use 
renewable energy; Sell scrap materials to another company. 

To be more resource-efficient, 33 % of Finnish companies 
(highest of all countries compared to EU average of 20 %) 
consider  assistance  for  better  cooperation  between 
companies across sectors as helpful, 24 % (+7 %) mention 
grants  and  subsidies  as  helpful,  and  23 %  (stable)  say 
consultancy is helpful. 

The performance of Finnish SMEs on resource efficiency 
has  improved  significantly  in  the  last  few  years,  but 
investment  and  ambitions  appear  to  have  reached  a 
plateau.  

Academic  excellence  like  at  Aalto  University  and  local 
actions  for  the  circular  economy  like  the  ‘resource 

12 European Commission, 2018 SBA fact sheet - Finland, p. 13. 

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Environmental Implementation Review 2019 – Finland 

wisdom’  project  in  Jyväskylä  provide  a  good  starting 
point for this. 

2014 to its current position of second). 

Figure 4: Finland’s eco-innovation performance 

Eco-innovation 

ranked  3rd  on 

Finland 
Innovation 
Scoreboard 2018, up 2.8 percentage points since 201013. 

the  European 

According  to  the  latest  eco-innovation  index,  Finland  is 
one  of  the  leading  eco-innovation  countries  in  the  EU 
(see Figure 3). 
Figure 3: 2017 Eco-innovation index (EU=100)14 

Finland  has  continuously  demonstrated  high  levels  of 
eco-innovation  in  the  EU,  progressing  from  fourth  in 
2014 to its current position of second. 

Accordingly, Finland’s policy landscape can be considered 
supportive  of  eco-innovation.  A  multitude  of  different 
policies,  directives,  and  policy  documents  have  been 
agreed  upon  in  recent  years,  the  ultimate  goal  being  to 
make Finland a global leader in eco-innovation. 

One of the main drivers of eco-innovation is the country’s 
outstanding  performance  in  the  circular  economy.  It  is 
estimated that by 2030 this will benefit Finland’s overall 
national economy with a volume of 2 to 3 billion euros in 
added-value potential15. 

Finland  has  continuously  demonstrated  high  levels  of 
eco-innovation  in  the  EU,  progressing  from  fourth  in 

13 European Commission, European Innovation Scoreboard 2018, p. 15. 
14 European Commission, Eco-innovation Observatory: Eco-Innovation 
scoreboard 2017. 
15 European Commission, Eco-Innovation Observatory, Country profile 
2016-2017: Finland. 

Accordingly, Finland’s policy landscape can be considered 
supportive  of  eco-innovation.  A  multitude  of  different 
policies,  directives,  and  policy  documents  have  been 
agreed  upon  in  recent  years,  the  ultimate  goal  being  to 
make Finland a global leader in eco-innovation. 

One of the main drivers of eco-innovation is the country’s 
outstanding  performance  in  the  circular  economy.  It  is 
estimated that by 2030 this will benefit Finland’s overall 
national economy with a volume of 2 to 3 billion euros in 
added-value potential16. 

Finland’s  share  in  the  global  cleantech  market  exceeds 
the  1 %  mark,  which  is  about  twice  as  much  as  the 
country’s contribution to global GDP. Approximately 68 % 
of  the  cleantech  companies  operating  in  Finland  are 
either  micro-organisations  or  SMEs  and  have  less  than 
250 employees. 

Barriers  to  eco-innovation  are:  (i)  a  lack  of  nontechnical 
skills, (ii) an insufficient focus on internationalisation, and 
(iii) too little risk-taking readiness in Finnish business and 
academic spheres. 

the 

for  2015-2019 

investments  are  being  made 

The  government  programme 
sets 
additional  R&D  policy  objectives,  and  specifically 
highlights 
importance  of  university-business 
collaboration.  More  specifically,  new  growth  sectors 
where 
the 
bioeconomy,  clean  and  green  technologies,  healthcare, 
and  digitalisation.  Finland  has  experienced  substantial 
cuts  in  funding  for  R&D  and  R&I  in  recent  years, 
potentially  hampering  further development  for actors in 
this domain. 

include 

The  Finnish  authorities  have  also  forced  a  trend  of 
increasing  public  procurement  for  innovation  (PPI).  The 
government’s overarching goal is that by 2019 5 % of all 
public procurement would be allocated to PPI. 

16 European Commission, Eco-Innovation Observatory, Country profile 
2016-2017: Finland. 

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Environmental Implementation Review 2019 – Finland 

Waste management 

Turning waste into a resource is supported by: 
(i)  fully 
legislation,  which 
implementing  EU  waste 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets, etc.; 
(ii) reducing waste generation and waste generation per 
capita in absolute terms; and  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 

This  section  focuses  on  management  of  municipal 
waste17  for  which  EU  law  sets  mandatory  recycling 
targets18. 

The  amount  of  municipal  waste  generated  in  Finland 
amounted  to  510  kg  per  capita  in  2017,  above  the  EU 
average  (487  kg  per  year  per  capita  in  2017)19  and  has 
fluctuated over past years. 

Figure  5  depicts  the  municipal  waste  by  treatment  in 
Finland  in  terms  of  kg  per  capita.  It  shows  a  significant 
steady decrease in landfilling since 2013 and an increase 
in  recycling.  In  2017,  more  than  half  (59 %)  of  waste  in 
Finland was incinerated, a level that has remained rather 
stable since 2014. 

The landfilling rate in Finland is among the lowest in the 
EU (1 % in 2016) and far below the EU average (24 %). 

Since  2014,  a  sizeable  increase  of  8  points  has  been 
achieved for the recycling of municipal waste, arriving at 
41 %  in  2017  (composting  accounts  for  13 %).  This  is 
slightly below the EU average of 46 % shown in Figure 6. 
This  resulted  from:  (i)  Finland’s  focus  on  separate 
collection  in  environmentally  conscious  urban  areas, 
including  in  apartment  blocks,  (ii)  a  deposit  refund 
increased 
scheme  for  beverage  containers,  (iii)  the 
separate  collection  of  biowaste  since  201220,  and  (iv)  a 
correction  of  data  in  2015  to  include  cardboard  from 
commercial  enterprises  (responsible  for  around  7 %  of 
the  increase).  A  ban  on  landfilling  biodegradable  and 
other organic  waste  stimulated significant investment  in 
waste-to-energy  (WtE)  plants  and  in  biowaste  collection 
and treatment. 

17 Municipal waste consists of mixed waste and separately collected 
waste from households and from other sources, where such waste is 
similar in nature and composition to waste from households. This is 
without prejudice to the allocation of responsibilities for waste 
management between public and private sectors. 
18 See Article 11.2 of Directive 2008/98/EC. This Directive was amended 
in  2018  by  Directive  (EU)  2018/851,  and  more  ambitious  recycling 
targets were introduced for the period up to 2035. 
19 Eurostat, Municipal waste and treatment, by type of treatment 
method 
20 Biowaste has been separately collected in Finland since 1990’s. 

Figure 5: Municipal waste by treatment in Finland 2010-
201721 

Finland has put a lot of effort into improving its recycling 
rate.  However,  despite  this  progress,  the  country  was 
listed in the Commission’s ‘Early Warning report’22 as one 
of  the  Member  States  at  risk  of  missing  the  2020 
municipal waste recycling target of 50 %23. 

Parts  of  Finland  are  very  rural,  with  low  population 
densities.  Collection  in  these  areas  has  not  been  a 
priority  because  of  the  low  collection  volumes  and  long 
distances  between  properties.  Door-to-door  recycling 
collections in more suburban areas have also not been a 
priority,  while  the  extended  producer  responsibility 
schemes  have  been  fragmented.  In  addition,  the  roles 
and  responsibilities  of  the  municipalities  have  changed 
repeatedly  in  recent  years.  This  has  created  uncertainty 
and lack of investment. 

in 

The  Early  Warning  report  delivered  a  set  of  key  priority 
actions  for  Finland  to  help  bridge  the  remaining 
implementation  gap.  Most  importantly,  the  Commission 
recommended  that  Finland  should  set  mandatory 
recycling  targets  for  municipalities 
line  with  the 
national  targets  of  50 %.  It  also  recommended  greater 
between 
cooperation 
responsibility 
organisations 
(PROs),  municipalities  and  collection 
companies  to  drive  efficiency  savings  and  to  reduce 
fragmentation.  In  addition,  more  focus  on  economic 
instruments is needed to ensure the cost of disposal and 
energy  recovery 
incentivise 
recycling. The Commission concluded that Finland should 
introduce 
for  sorting  waste, 
including  the  requirement  to  sort  business  waste,  with 
door-to-door recycling services. 

is  sufficiently  high  to 

further  requirements 

producer 

21 Eurostat, Municipal waste by waste management operations  
22 SWD(2018) 417 final. 
23 Finland uses calculation method 4. 

7 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Figure 6: Recycling rate of municipal waste 2010-201724 

Climate change 

The EU has committed to undertaking ambitious climate 
action internationally as well as in the EU, having ratified 
the Paris Climate Agreement on 5 October 2016. The EU 
targets are to reduce greenhouse gas (GHG) emissions by 
20 % by 2020 and by at least 40 % by 2030, compared to 
1990.  As  a  long-term  target,  the  EU  aims  to  reduce  its 
emissions  by  80-95 %  by  2050,  as  part  of  the  efforts 
required by developed countries as a group. Adapting to 
the adverse effects of climate change is vital to  alleviate 
its  already  visible  effects  and  improve  preparedness  for 
and resilience to future impacts. 

The EU emissions trading system (EU ETS) covers all large 
greenhouse  gas  emitters  in  the  industry,  power  and 
aviation  sectors  in  the  EU.  The  EU  ETS  applies  in  all 
Member States and has a very high compliance rate. Each 
year,  installations  cover  around  99  %  of  their  emissions 
with the required number of allowances. 

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  the  Effort  Sharing 
legislation.  Finland  had  lower  emissions  than  its  annual 
emission  allocations  (AEAs)  in  each  of  the  years  2013-
2015,  while  in  2016  emissions  where  higher  than  the 
AEA.  According  to  preliminary  data,  emissions  in  2017 
exceeded  the  AEA  by  2  percentage  points.  For  2020, 
Finland's  national  target  under  the  EU  Effort  Sharing 
Decision  is  to  reduce  emissions  by  16  %  compared  to 
2005. For 2030, Finland's national target under the Effort 
Sharing  Regulation  is  to  reduce  emissions  by  39  % 
compared  to  2005.  Finland  has  projected  that  without 
additional  measures  it  may  miss  its  2020  target  by  1  pp 
and its 2030 target by 17 pp.  

The  Finnish  NECP  is  prepared  on  the  basis  of  the 
Government  Report  on  Energy  and  Climate  Strategy  for 
2030  (autumn  2016),  Medium  Term  Climate  Policy  Plan 
(autumn  2017)  and  other  relevant  documents.  Finland’s 
long-term goal is to be a  carbon-neutral society by  mid-
century.  Finland  will  be  preparing  a  long-term  strategy, 
with a view to carbon neutrality and with a time-frame of 
up to 2050. This strategy should be finalized during 2019. 

Transport  represents  almost  a  quarter  of  the  EU’s  GHG 
emissions and is the main cause of air pollution in cities. 
Transport  emissions  in  Finland  increased  by  3  %  from 
2013 to 2016. 

The  F-gas  Regulation  requires  Member  States  to  run 
training and certification programmes, introduce rules for 
penalties  and  notify  these  measures  to  the  Commission 
by  2017.  Finland  has  notified  the  Commission  of  both 
measures. 

and  out-of-home 

Investments 
in  waste  management  should  prioritise 
projects  in  waste  prevention,  including  re-use  projects 
and  awareness  raising.  Other  elements  would  include 
introduction  of  Pay-As-You-Throw  schemes,  separate 
improve  at  home  waste 
collection,  in  particular  to 
separation 
collection 
(recycling centres or civic amenity sites), sorting facilities 
for 
recycling 
collected  waste, 
infrastructure for dry and wet recyclables. The collection 
and  treatment  of  bio-waste  should  also  be  prioritised. 
Moreover,  projects  improving  waste  data  reporting  and 
extended  producer  responsibility  would  be  crucial,  as 
well  as  capacity  building  projects  for  municipalities  to 
realise the necessary waste management reforms.  

separately 

separate 

and 

Despite  these  steps  that  need  to  be  taken  in  the  short 
term,  Finland  will  also  have  to  do  more  to  comply  with 
recycling targets after 202025. This will especially require 
action to reduce the incineration of municipal waste. 

2019 priority actions 

  Introduce  new  policy  instruments,  including  economic 
instruments,  to  promote  prevention,  make  reuse  and 
recycling  more  economically  attractive.  Reduce 
fragmentation  of  responsibilities  within  the  EPR 
schemes and improve their functioning.  

  Shift  reusable  and  recyclable  waste  away 

from 

incineration. 

  Set  mandatory  recycling  targets  for  municipalities  and 
shift  responsibilities  back  to  the  municipalities,  with 
measures 
Introduce 
in  case  of  non-compliance. 
mandatory  minimum  service  standards  on  separate 
collection. 

24 Eurostat, Recycling rate of municipal waste 
25  Directive  (EU)  2018/851,  Directive  (EU)  2018/852,  Directive  (EU) 
2018/850  and  Directive  (EU)  2018/849  amend  the  previous  waste 
legislation and set more ambitious recycling targets for the period up to 
2035. These targets will be taken into consideration to assess progress 
in future Environmental Implementation Reports. 

8 

 
                                                                 
Environmental Implementation Review 2019 – Finland 

Figure  7:  Change  in  total  greenhouse  gas  emissions 
1990-2017 (1990=100%)26. 

Figure 9: Greenhouse gas emissions by sector (Mt. CO2-
eq.). Historical data 1990-2016. Projections 2017-203028.  

The  accounting  of  GHG  emissions  and  removals  from 
forests and agriculture is governed by the Kyoto Protocol. 
Reported quantities under the Kyoto Protocol for Finland 
show  net  removals  of,  on  average,  -49.2  Mt  CO2-eq  for 
the  period  2013  to  2016. 
In  this  regard,  Finland 
contributes  with  12.8%  to  the  annual  average  sink  of  -
384.4  Mt  CO2-eq  of  the  EU-28.  Accounting  for  the  same 
period depicts net debits of, on average, 0.8 Mt CO2-eq, 
which corresponds to a negative contribution of -0.7% of 
the EU-28 accounted sink of -115.7 Mt CO2-eq. Finland is 
one  of  six  EU  Member  States,  which  show  net  debits  in 
this  preliminary  accounting  exercise.  Finland  is  one  of 
eight  EU  Member  States,  which  exceed  the  cap  of  3.5% 
from emissions of the base year (1990).29 

The  EU  Strategy  on  adaptation  to  climate  change, 
adopted  in  2013,  aims  to  make  Europe  more  climate-
resilient, by promoting action by Member States, better-
informed  decision  making,  and  promoting  adaptation  in 
key vulnerable sectors. By adopting a coherent approach 
and  providing  for  improved  coordination,  it  seeks  to 
enhance the preparedness and capacity of all governance 
levels to respond to the impacts of climate change.  

In  Finland,  a  National  Adaptation  Strategy  (NAS)  was 
adopted in 2005 as an independent element of the wider 
National  Energy  and  Climate  Strategy.  The  NAS  revision 
resulted  in  2014  in  the  publication  of  a  new  national 
climate  change  adaptation  framework  known  as  the 
National  Adaptation  Plan  for  Climate  Change  2022.  The 
key  principle  of  the  adaptation  plan  concerns  the 
incorporation  of  climate  change  adaptation  into  the 
regular planning, implementation and development of all 

28  Annual  European  Union  greenhouse  gas  inventory  1990–2016  (EEA 
greenhouse  gas  data  viewer).  Proxy  GHG  emission  estimates  for 
2017Approximated  EU  greenhouse  gas 
inventory  2017  (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 
29 COM (2018) 716 final and SWD (2018) 453 final. 

Figure  8:  Targets  and  emissions  for  Finland  under  the 
Effort Sharing Decision and Effort Sharing Regulation27. 

26  Annual  European  Union  greenhouse  gas  inventory  1990–2016  (EEA 
greenhouse  gas  data  viewer).  Proxy  GHG  emission  estimates  for 
2017Approximated  EU  greenhouse  gas 
inventory  2017  (European 
Environment Agency). Member States national projections, reviewed by 
the European Environment Agency. 
27 Proxy GHG emission estimates for 2017Approximated EU greenhouse 
gas  inventory  2017  (European  Environment  Agency).  Member  States 
national projections, reviewed by the European Environment Agency. 

9 

 
 
 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

sectors  and  actions.  A  national  monitoring  group  is 
appointed to follow and evaluate the implementation of 
the  adaptation  plan,  with  representatives  from  the 
relevant  ministries,  research  institutions,  and  regional 
indicators 
and 
related  to  risks  to  human  health  and  adaptation 
measures  executed 
in  flood  risk  areas  have  been 
developed, with a report released in 2017.  

local  bodies  and  actors.  Monitoring 

The  total  revenues  from  the  auctioning  of  emission 
allowances  under  the  EU  ETS  over  the  years  2013-2016 
were  EUR  295  million.  43%  of  the  auctioning  revenues 
has been spent on climate and energy purposes. 

2019 priority action 

In this report, no priority actions have been included on 
climate action, as the Commission will first need to assess 
the  draft  national  energy  and  climate  plans  which  the 
Member  States  needed  to  send  by  end  of  2018.  These 
plans  should  increase  the  consistency  between  energy 
and climate policies and could therefore become a good 
example  of  how  to  link  sector-specific  policies  on  other 
interlinked themes  such as agriculture-nature-water and 
transport-air-health.  

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Environmental Implementation Review 2019 – Finland 

2. 

Protecting, conserving and enhancing natural capital 

Nature and biodiversity 

in  the  EU  by  2020. 

The  EU  biodiversity  strategy  aims  to  halt  the  loss  of 
biodiversity 
full 
implementation  of  the  Birds  and  Habitats  Directives  to 
achieve  favourable  conservation  status  of  protected 
species and habitats. It also requires that the agricultural 
and  forest  sectors  help  to  maintain  and 
improve 
biodiversity. 

It  requires 

Biodiversity strategy 

Finland  has  a  comprehensive  biodiversity  strategy  for 
2014-2020,  and  its  action  plan  for  2013-202030  covers 
many  issues  relevant  to  the  implementation  of  the 
Nature Directives. 

Setting-up a coherent network of Natura 2000 sites 

The Birds and Habitats Directives require Member States 
to establish a coherent national network of Natura 2000 
sites.  The  Commission  assesses  compliance  with  this 
requirement  individually  for  each  species  and  habitat 
type  occurring  on  the  national  territory  of  the  Member 
States.  The latest  update of this assessment  was  carried 
out  by  the  Commission  with  the  assistance  of  the 
European Environment Agency. On the basis of this latest 
update,  Finland’s  terrestrial  Natura  2000  network  under 
the Birds and Habitats Directives is now considered to be 
complete. 

By the end of 2017, there were 468 Birds Directive SPAs 
and  1 721  Habitats  Directive  SCIs  in  Finland.  Due  to 
overlaps,  that  amounts  to  1 865  marine  and  terrestrial 
Natura  2000  sites,  87  of  which  are  located  in  the  Åland 
Islands.  The  terrestrial  part  of  the  network  covers 
14.45 %  of  the  Finnish  national  territory  (EU  average 
18.17 %),  with  the  SPAs  covering  7.3 %  (EU  average 
12.4 %) and the SCIs covering 14.4 % (EU average 13.9 %). 

Designating Natura 2000 sites and setting conservation 
objectives and measures 

Based  on  an  assessment  of  the  sufficiency  of  the  SCI 
network31  for  Annex  II  species  and  Annex  I  habitats 

30 The Republic of Finland, Suomen luonnon monimuotoisuuden 
suojelun ja kestävän käytön strategia ja sen toimintasuunnitelma 
31 For each Member State, the Commission assesses whether the 
species and habitat types on Annexes I and II of the Habitats Directive 
are sufficiently represented by the sites designated to date. This is 
expressed as a percentage of species and habitats for which further 
areas need to be designated in order to complete the network in that 
country. The current data, which were assessed in 2014-2015, reflect 
the situation up until December 2013. 

occurring in Finland, the Natura 2000 network in Finland 
is  considered  complete  in  the  Alpine  region  and  almost 
complete 
in  the  Boreal  and  Marine  Baltic  region. 
However, there are insufficiencies in designation for the 
marine  components  of  the  SCIs  network,  as  shown  in 
Figure 532. 

The  process  of  designating  the  sites  as  special  areas  of 
conservation  (SAC)  is  almost  complete,  except  in  the 
Åland Islands. 

Outside  the  autonomous  region  of  the  Åland  Islands 
where  the  legal  framework  and  management  tools  for 
Natura  2000  still  have  to  be  stabilised,  Finland  has 
developed a new planning and monitoring system for its 
protected  areas.  This  system  includes  a  specific  periodic 
assessment  of  the  status  of  the  habitats  and  species  of 
the  Natura  2000  sites.  Management  plans  are  linked  to 
the  system.  As  80 %  of  the  Natura  2000  sites  are  state-
owned,  most  of  the  Finnish  Natura  2000  sites  are 
organisation, 
managed 

state-owned 

one 

by 

32 The percentages in Figure 5 refer to percentages of the total number 
of assessments (one assessment covering 1 species or 1 habitat in a 
given biographical region with the Member State); if a habitat type or a 
species occurs in more than 1 Biogeographic region within a given 
Member State, there will be as many individual assessments as there 
are Biogeographic regions with an occurrence of that species or habitat 
in this Member State. 

11 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Metsähallitus,  which  is  responsible  for  the  use  of  state-
owned land and waters. 

restoring 
in  maintaining  or 
Progress 
conservation status of species and habitats 

favourable 

The  number  of  nature-related 
and 
infringements  is  low  in  Finland.  Most  complaints  and 
infringement  cases  relate  to  the  derogations  under 
Articles 9 (Birds Directive) and 16 (Habitats Directive). 

complaints 

The  2017  EIR  referred  to  the  latest  report  on  the 
conservation status of habitats and species; new data will 
be available for the next EIR. 

There  is  good  knowledge  of  the  species  present  on  the 
Finnish territory. Of the 45 000 species living in Finland, it 
has  been  possible  to  evaluate  the  threat  status  for  over 
21 000  species.  The  conclusion  is  that  one  tenth  of  the 
species evaluated in Finland is endangered. 
The latest Red List of Birds (2015)33 indicates that out of 
245  bird  species,  36 %  are  threatened,  9 %  are  nearly 
threatened  and  55 %  are  of  least  concern.  Targeted 
conservation  actions  are  bringing  results,  as  shown  by 
the increasing populations of golden eagles, white-tailed 
sea  eagles,  white-backed  woodpeckers  and  peregrine 
falcons.  On  the  other  hand,  there  have  been  concerns 
recently surrounding the decline of common forest birds 
in  managed  forests  in  southern  Finland.  The  Red  List 
assessment of mammals (2015) shows that the Arctic fox 
is  critically  endangered  and  the  Saimaa  ringed  seal, 
wolverine,  wolf  and  natterer’s  bat  are  endangered. 
However,  the  mountain  hare  and  otter  are  no  longer 
threatened. For  birds, the most  important  threats are in 
breeding areas when there are changes, along migration 
routes  and  in  wintering  areas.  For  mammals,  the  main 
threats  are  hunting  (including  illegal  killing),  climate 
change and random factors linked to small populations. 

Member  States  report  every  6  years  on  the  progress 
made  under  both  Directives.  Therefore,  since  the  2017 
EIR,  no  new  information  is  available  on  the  state  of 
natural  habitats  and  species,  nor  on  progress  made  in 
improving the conservation status of species and habitats 
in Finland. 

Overall,  and  given  the  forest  coverage  in  Finland,  it  is 
acknowledged  that  the  favourable  conservation  status 
for the forest- and peatland-related species and habitats 
will  not  be  achieved  unless  commercial  forestry  better 
pursues  biodiversity  goals,  including  outside  the  Natura 
2000  network.  For  example,  the  legal  framework  for 
felling  operations  during  the  nesting  season  might  need 
to  be  adjusted  to  better  take  into  account  the  needs  of 
the  species  and  European  legal  requirements.  It  is  also 
acknowledged  that  action  has  to  be  taken  to  develop 
coexistence  with  some  protected  species,  such  as  some 
large  carnivores  and  some  bird  species  that  are 
developing large colonies. Doing so will ensure that their 
conservation status is improved or maintained in the long 
term. 

2019 priority actions 

  Complete the designation of the Natura 2000 network, 
especially  for  marine  sites,  establish  the  necessary 
conservation measures for all the sites, including in the 
Åland Islands and ensure they maintain/restore species 
and  habitats  of  community  interest  to  a  favourable 
conservation status across their natural range. 

  Better 

integrate  biodiversity  concerns 

into  other 
policies  and  promote  better  communication  between 
actors. 

  Develop  a  strategy  with  the  forest  sector  in  order  to 
integrates 

ensure 
biodiversity goals, including outside Natura 2000.  

sector  better 

forestry 

the 

Maintaining  and  restoring  ecosystems  and 
their services 

The EU biodiversity strategy aims to maintain and restore 
ecosystems  and  their  services  by 
including  green 
infrastructure  in  spatial  planning  and  restoring  at  least 
15 %  of  degraded  ecosystems  by  2020.  The  EU  green 
infrastructure  strategy  promotes  the  incorporation  of 
green infrastructure into related plans and programmes. 

The EU has provided guidance on the further deployment 
of  green  and  blue  infrastructure  in  Finland34  and  a 

34 European Commission, The recommendations of the green 
infrastructure strategy review report and the EU Guidance on a 
strategic framework for further supporting the deployment of EU-level 
green and blue infrastructure. 

Some  78 %  of  Finland’s  surface  is  forest  land.  However, 
only  about  9 %  of  the  forest  area  is  strictly  protected 
from  any  forestry  measures,  and  most  of  the  protected 
areas are in northern Finland. The country currently has 
an  ambitious  bioeconomy  target  which  also  foresees  an 
increasing use of timber. 

33 IUCN, Red List 

12 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – Finland 

country page on the Biodiversity Information System for 
Europe  (BISE)35.  This  information  will  also  contribute  to 
the  final  evaluation  of  the  EU  Biodiversity  Strategy  to 
2020. 

In  Finland,  green  infrastructure  is  incorporated  through 
sector-specific  and 
instruments.  Sector-
integrative 
specific  instruments  include  legislation  on  agriculture, 
forestry,  mining,  land  extraction  and  the  utilisation  of 
water resources. Integrative instruments can be found in 
spatial planning and impact assessment procedures. 

The Finnish biodiversity strategy and action plan for 2020 
provides  the  basis  for  the  country’s  policy  on  green 
infrastructure and sets measures for incorporating green 
infrastructure  into  spatial  planning.  Several  objectives 
related  to  biodiversity  and  green  infrastructure  are  part 
of the Land Use and Building Act36 and the National Land 
Use  Guidelines.  A  national  strategy  for  the sustainable 
and  responsible  use  of  mires  and  peatlands37 was 
adopted  in  2012,  directing  the  use  of  peatlands  to  non-
pristine  areas.  Green  infrastructure  is  also  incorporated 
in  forestry  and  landscape  planning  through  ecosystem-
based  natural  resource  plans  (ENRP)  and  landscape 
ecological plans. 

joined  by 

(2017-2018), 

the 
The  EnRoute  project 
municipality  of  Helsinki,  offers  opportunities  to  make 
green  infrastructure  a  mainstream  part  of  urban  policy 
and  city  governance.  The  SustainBaltic  project  (2016-
2018)38,  which  deals  with  marine  and  coastal  policy, 
focuses  on  the  development  of  integrated  coastal  zone 
management 
(ICZM)  plans  sustaining  human  and 
ecological  networks.  In  the  area  of  health  care,  Finland 
has  developed  nature-based  preventive  measures  to 
increase the wellbeing of vulnerable social groups. 

In future, habitat banking in Finland may help to protect 
biodiversity  and  offset  losses.  The  ‘Habitat  Bank  of 
Finland’  project  (2016-2017)39  analysed,  developed  and 
piloted  the  principles  of  ecological  compensation.  The 
project aims to develop a new market-based mechanism 
for biodiversity conservation, to complement the existing 
policy instrument mix. The ‘habitat bank’ will operate as 
an  intermediary  between  actors  requiring  and  supplying 
ecological compensations. 

Green infrastructure activities are funded by biodiversity 
and  nature  conservation  instruments  and  by  sector-
specific 
financial 
instruments  and  a  mix  of  EU 
instruments.  However,  it  is  estimated  that  there  is  a 
funding  gap  for  biodiversity  funding.  For  example,  it  is 

estimated  that  an  additional  EUR 46  million  are  needed 
annually  to  implement  the  national  biodiversity  action 
plan (2016-2020). 

incorporating  green 
There  are  still  challenges  with 
infrastructure  in  policy-making.  These  relate  to  political 
ownership,  policy  coherence  and  coordination  across 
sectors,  as  there  are  no  policy  tools  for  systematic  and 
comprehensive  action  to  preserve  and  improve  green 
infrastructure. 
be 
incorporated  by  making  more  efficient  and  systematic 
use  of  the  available  instruments,  such  as  land  use 
planning.  However,  this  requires  more  sharing  of 
information and dialogue between authorities, a stronger 
knowledge  base  and  the  development  of  monitoring 
systems. 

infrastructure 

Green 

could 

infrastructure  and  making 

Finland is encouraged to continue its efforts in deploying 
green  and  blue 
it  a 
mainstream  part  of  other  policies,  consistent  with  the 
MAES  framework.  It  is  also  encouraged  to  consider  the 
recommendations  of  the  green  infrastructure  strategy 
review report and to make full use of the EU Guidance on 
a  strategic 
further  supporting  the 
for 
deployment of EU-level green and blue infrastructure  40. 
invited  to  provide  regular  updates  on 
Finland 
developments  relating  to  its  green  infrastructure  via  its 
infrastructure  country  page  on  BISE41.  This 
green 
information will also feed into the final evaluation of the 
EU biodiversity strategy to 2020 to be communicated to 
the Council and European Parliament in 2020. 

framework 

is 

Finland  is  invited  to  provide  information  about  progress 
on a prioritisation framework for restoration as provided 
for  under  action  6a  of  the  EU  biodiversity  strategy.  It  is 
also  asked  to  report  on  other  strategic  approaches  to 
restoration  or  on  anything 
to  practical 
implementation. 

relating 

Estimating natural capital 

The  EU  biodiversity  strategy  calls  on  Member  States  to 
map  and  assess  the  state  of  ecosystems  and  their 
services42 in their national territories by 2014, assess the 
economic  value  of  such  services  and  integrate  these 
values  into  accounting  and  reporting  systems  at  EU  and 
national level by 2020. 

Finland  has  actively  participated  in  the  ESMERALDA 
project39.  This  project  has  continued  the  previous 
assessment  work  done  on  the  value  and  social 

35 Biodiversity Information System for Europe. 
36The Republic of Finland, the Land Use and Building Act  
37The Republic of Finland, A national strategy for the sustainable and 
responsible use of mires and peatland   
38 University of Turku, EU project SustainBaltic     
39 Finnish Environment Institute, Habitat Bank of Finland 

40  The  recommendations  of  the  green  infrastructure  strategy  review 
report  and  the  EU  Guidance  on  a  strategic  framework  for  further 
supporting the deployment of EU-level green and blue infrastructure. 
41 BISE, Finland profile  
42  Ecosystem  services  are  benefits  provided  by  nature  such  as  food, 
clean water and pollination on which human society depends. 

13 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Finland 

significance of ecosystem services in Finland and pursued 
the  development  of  the  Finish  ecosystem  services 
indicators.  The  project 
is  close  to  completing  the 
implementation.  However,  a  comprehensive  national 
report on ecosystems and their services is lacking. 
Finland  has  developed  an  internet  portal43  to  bring 
together  the  knowledge  on  the  status  of  biodiversity, 
ecosystem services, genetic resources and biosafety. The 
portal  serves  as  a  Finnish  national  clearing  house 
mechanism under the Convention on Biological Diversity. 

The  Corporate Responsibility  Network (FIBS)45 in Finland 
aims  to  raise  awareness  of  biodiversity  and  introduce 
tools  for  companies  to  help  them  discover  their 
dependencies  on  ecosystem  services.  It  is  also  helping 
them to manage their impact on nature and has set up a 
training programme for companies on the application of 
the natural capital protocol. In addition to public events, 
selected  companies  are  participating  in  Master  Class 
training  to  deepen  their  insight  into  biodiversity  and 
share information between the companies. 

MAES-related developments fall into four categories: 

Invasive alien species 

1.  Networking and information sharing: in 2016, a first 
networking  meeting  was  organised  for  volunteers 
and 
interested  stakeholders  to  discuss  recent 
findings  and  report  on  the  MAES  process.  The 
intention is to repeat this yearly. 

2.  Supporting 

individual 
land-use  planning:  several 
mapping  projects  have  been  carried  out  in  several 
regions in Finland by interested country planners and 
integrated 
natural  resource  managers,  e.g.  for 
coastal zone management or carbon storages. 
Integrated  natural  capital  accounting:  The  Finnish 
Environment Institute, the Natural Resource Institute 
and  Statistics  Finland  have  discussed  the  possibility 
of collaborating to integrate MAES and INCA work. A 
pilot study was conducted in 2017. 

3. 

Under  the  EU  biodiversity  strategy,  the  following  are  to 
be achieved by 2020:  
(i) invasive alien species identified;  
(ii) priority species controlled or eradicated; and  
(iii)  pathways  managed  to  prevent  new  invasive  species 
from disrupting European biodiversity.  
This  is  supported  by  the  Invasive  Alien  Species  (IAS) 
Regulation, which entered into force on 1 January 2015. 

Figure  11:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Finland46 

4.  Preparing  for  assessment  of  ecosystem  conditions: 
the  ENVIBASE  project  has  improved  facilities  to  use 
new  earth  observation  data 
(e.g.  Sentinels, 
Copernicus  data  services)  in  monitoring  ecosystem 
conditions.  The  Finnish  Environment 
Institute 
explored  various  remote  sensing  options  and  other 
environmental  monitoring  techniques  and  tested 
them in 2017. 

Figure 10: Implementation of MAES (September 2018) 

The  report  on  the  baseline  distribution  (Figure  11),  for 
which  Finland  reviewed  its  country  and  grid-level  data, 
shows  that  of  the  37  species  on  the  first  EU  list,  seven 
have been observed in the environment in Finland, all of 
them are established, but none of them seems to be very 
widely  distributed.  The  Chinese  mittencrab  (Eriocheir 
sinensis) is widely spread along the coast. 

Between  the  entry  into  force  of  the  EU  list  and  18 May 
2018, Finland did not notify any new appearances of IAS 

45 The Corporate Responsibility Network.  
46 Tsiamis K; Gervasini E; Deriu I; D`amico F; Nunes A; Addamo A; De 
Jesus Cardoso A. Baseline Distribution of Invasive Alien Species of Union 
concern. Ispra (Italy): Publications Office of the European Union; 2017, 
EUR 28596 EN, doi:10.2760/772692. 

At  the  MAES  working  group  meeting  held  in  Brussels  in 
September  2018,  it  was  noted  that  Finland  had  made 
substantial progress in implementing MAES since January 
2016  (Figure  10).  This  assessment  was  made  by  the 
ESMERALDA  project44  and  based  on  27  implementation 
questions. The assessment is updated every six months.  

43 The Republic of Finland, Finnish ecosystem service indicators. 
44 EU project, Esmeralda.  

14 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Soil erosion by water is a natural process, but this natural 
process can be aggravated by climate change and human 
activities  such  as  inappropriate  agricultural  practices, 
deforestation,  forest  fires  or  construction  works.  High 
in 
levels  of  soil  erosion  can  reduce  productivity 
agriculture  and  can  have  negative  and  transboundary 
impacts  on  biodiversity  and  ecosystem  services,  as  well 
as  on  rivers  and  lakes  (increased  volume  of  sediments, 
transport of contaminants). According to the RUSLE2015 
model50, Finland has an average soil loss rate by water of 
0.06  tonnes  per  hectare  per  year  (t ha−a yr−y),  compared 
to the EU mean of 2.46 t ha−a yr−y. This indicates that soil 
erosion in Finland is under control. It is important to note 
that  these  figures  are  the  output  of  a  model  and 
therefore should not  be considered values  measured in-
field.  The  actual  soil  loss  rate  can  vary  widely  within  a 
Member State depending on local conditions. 
Figure 12: Proportion of artificial land cover, 2015 51 

of  Union  concern,  pursuant  to  Article 16(2)  of  the  IAS 
Regulation. 

responsible 

implementing 

Finland  has  notified  the  Commission  of  its  competent 
IAS 
for 
authorities 
Regulation,  as  required  by  Article 24(2)  of  the  IAS 
Regulation. It has communicated to the Commission the 
national  provisions  on  penalties 
to 
infringements,  as  required  by  Article 30(4)  of  the  IAS 
Regulation,  and  has  therefore  fulfilled  its  notification 
obligations in this regard. 

applicable 

the 

Soil protection 

The  EU  soil  thematic  strategy  underlines  the  need  to 
ensure a  sustainable use of soils.  This  entails preventing 
further  soil  degradation  and  preserving  its  functions,  as 
well as restoring degraded soils. The 2011 Roadmap to a 
Resource Efficient Europe states that by 2020, EU policies 
must  take  into  account  their  direct  and  indirect  impact 
on land use. 

is  a  finite  and  extremely  fragile  resource  and 

Soil 
increasingly degrading in the EU. 
The  percentage  of  artificial  land47  in  Finland  (Figure  12) 
can  be  seen  as  a  measure  of  the  relative  pressure  on 
nature  and  biodiversity,  as  well  as  the  environmental 
pressure  on  people  living  in  urbanised  areas.  A  similar 
measure is population density. 

Finland  ranks  below  the  EU  average  for  artificial  land 
coverage,  with  1.6 %  of  artificial  land  (EU-28  average: 
4.1 %). The population density is 18.1/km2, which is also 
below the EU average of 11848. 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  A  recent 
report  of  the  European  Commission49  estimated  that 
potentially  polluting  activities  have  taken  or  are  still 
taking place on approximately 2.8 million sites in the EU. 
At EU level,  650 000 of these sites have been registered 
in national or regional inventories. 65 500  contaminated 
sites  already  have  been  remediated.  Finland  has 
registered  26 200  sites  where  potentially  polluting 
activities have taken or are taking place, and already has 
remediated or applied aftercare measures on 5 700 sites. 

47 Artifical land cover is defined as the total of roofed built-up areas 
(including buildings and greenhouses), artificial non built-up areas 
(including sealed area features, such as yards, farmyards, cemeteries, 
car parking areas etc. and linear features, such as streets, roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and viaducts, mobile homes, solar panels, power plants, electrical 
substations, pipelines, water sewage plants, and open dump sites). 
48 Eurostat, Population density by NUTS 3 region. 
49 Ana Paya Perez, Natalia Rodriguez Eugenio (2018), Status of local soil 
contamination  in  Europe:  Revision  of  the  indicator  “Progress  in  the 
management Contaminated Sites in Europe”. 

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 the oceans. 

50 Panagos, P., Borrelli, P., Poesen, J., Ballabio, C., Lugato, E., 
Meusburger, K., Montanarella, L., Alewell, C., The new assessment of 
soil loss by water erosion in Europe, (2015) Environmental Science and 
Policy, 54, pp. 438-447. 
51 Eurostat, Land covered by artificial surfaces by NUTS 2 regions. 

. 

15 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Marine protection 

2019 priority actions 

the 

  Determine 

good 
environmental  status  when  these  have  not  been 
reported. 

achieving 

timelines 

for 

  Ensure  regional  cooperation  with  Denmark,  Estonia, 
Germany,  Latvia,  Lithuania,  Poland  and  Sweden  in  the 
Baltic Sea region to address predominant pressures. 

EU coastal and marine policy and legislation require that 
by  2020  the  impact  of  pressures  on  marine  waters  be 
reduced  to  achieve  or  maintain  good  environmental 
status (GES) and ensure that coastal zones are managed 
sustainably. 

The Marine Strategy Framework Directive (MSFD)52 aims 
to achieve good environmental status of the EU’s marine 
waters  by  2020.  To  that  end,  Member  States  must 
develop  a  marine  strategy  for  their  marine  waters,  and 
cooperate  with  the  EU  countries  that  share  the  same 
marine (sub)region. 

Member  States  have  to  develop  a  marine  strategy  for 
their  marine  waters  and  cooperate  with  those  Member 
States sharing the same marine (sub)region. 

For  Finland,  the  Baltic  Marine  Environment  Protection 
Commission  (Helsinki  Commission)  plays  an  important 
role  in  achieving  the  goals  required  by  the  Marine 
Strategy  Framework  Directive.  These  marine  strategies 
to  be  developed  and 
comprise  different 
implemented  over  six-year  cycles.  The 
latest  step 
required  Member  States  to  set  up  their  programme  of 
measures  and  report  it  to  the  Commission  by  31 March 
2016.  The  Commission  assessed  whether  Finnish 
measures  were 
Good 
appropriate 
Environmental Status53. 

reach 

steps 

to 

Finland  has  reported  new  measures  for  all  descriptors 
and  therefore  taken  the  opportunity  to  develop  new 
initiatives to address pressures in its marine environment 
specifically  under  the  MSFD.  For  example,  for  marine 
litter and underwater noise, a gradual roll-out of certain 
measures  is  planned.  This  is  positive  as  it  indicates 
detailed planning. In these cases, the  first  phases of the 
measures (2016-2017) will focus on addressing data gaps 
through  research  and  studies,  while  the  latter  phases 
(2018  and  beyond)  will  focus  on  implementing  specific 
action  plans  tackling  the  pressures 
in  the  marine 
environment (direct measures). 

Although  the  programme  of  measures  addresses  most 
relevant  pressures  and  targets,  the  measures  do  not 
cover  certain  pressures  and  activities  and  associated 
impacts  identified  as  significant  at  the  subregional  level 
(e.g.  heat  inputs  into  the  marine  environment  and  the 
impact  of  fisheries  on  the  biodiversity  of  fish).  Finland 
also  reports  that  it  does  not  expect  to  achieve  GES  by 
2020  for  a  number  of  aspects,  namely  commercial  fish 
and  shellfish,  eutrophication  and  contaminants 
in 
seafood.  Finland’s  programme  of  measures  is  partially 
appropriate in meeting the requirements of the MSFD. 

52 European Union, Marine Strategy Framework Directive 2008/56/EC 
53 COM(2018) 562 and SWD(2018) 393. 

16 

                                                                 
 
Environmental Implementation Review 2019 – Finland 

3. 

Ensuring citizens’ health and quality of life 

(NMVOCs) by 5.62 %, emissions of fine particulate matter 
PM2.5  by  4.24 %  and  emissions  of  nitrogen  oxides  (NOx) 
by  11.49 %  over  the  same  period  (see  also  Figure  13  on 
the total PM2.5 and NOx emissions per sector). 

Figure 13: PM2.5 and NOx emissions by sector in Finland 
57 

Air quality 

EU clean air  policy and legislation require the significant 
improvement  of  air  quality  in  the  EU,  moving  the  EU 
closer to the quality recommended by the World Health 
Organisation.  Air  pollution  and  its  impacts  on  human 
health,  ecosystems  and  biodiversity  should  be  further 
reduced with the long-term aim of not exceeding critical 
loads  and  levels.  This  requires  strengthening  efforts  to 
reach  full  compliance  with  EU  air  quality  legislation  and 
defining strategic targets and actions beyond 2020. 

The  EU  has  developed  a  comprehensive  body  of  air 
legislation54,  which  establishes  health-based 
quality 
standards and objectives for a number of air pollutants. 

According to a special report from the European Court of 
Auditors55,  EU  action  to  protect  human  health  from  air 
pollution has not had its expected impact. There is a risk 
that  air  pollution  is  being  underestimated 
in  some 
instances, because it may not always be monitored in the 
right  places.  Member  States  are  now  required  to  report 
both  real-time  and  validated  air  quality  data  to  the 
Commission56. 

attributable 

Nevertheless,  air  quality  in  Finland  continues  to  give 
cause for concern.. The European Environment Agency58 
estimated  that  in  2015  about  1 500  premature  deaths 
were 
particulate  matter 
concentrations59, 80 to ozone concentrations60, and 40 to 
Although 
nitrogen 
concentrations  above  EU  air  quality  standards  are  rare, 
significant health risks still exist. 

concentrations61. 

dioxide 

fine 

to 

For  2017,  no  exceedances  above  the  EU  air  quality 
standards have been reported.  

The  emission  of  several  air  pollutants  has  decreased 
significantly  in  Finland.  The  emission  reductions  from 
1990-2014,  mentioned  in  the  2017  EIR,  continued  in 
2014-2016.  Emissions  of  sulphur  oxides  (SOx)  fell  by 
10.08 % between 2014 and 2016, emissions of ammonia 
(NH3) by 6.28 %, emissions of volatile organic compounds 

54 European Commission, 2016. Air Quality Standards 
55 European Court of Auditors, Special report no 23/2018, Air pollution: 
Our health still insufficiently protected, p.41. 
56  Article 5  of  Commission  Implementing  Decision  2011/850/EU  of  12 
December2011  laying  down  rules  for  Directives  2004/107/EC  and 
2008/50/EC  of  the  European  Parliament  and of  the  Council  as  regards 
the  reciprocal  exchange  of  information  and  reporting  on  ambient  air 
quality (OJ L 335, 17.12.2011, p. 86) requires Member States to provide 
Up-To-Date data. 

57 2016 NECD data submitted by Member State to the EEA. 
58  European  Environment  Agency,  2016.  Air  Quality  in  Europe  —  2016 
Report  (Table  10.2,  please  see  details  in  this  report  as  regards  the 
underpinning methodology). 
59  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5) refers to  particles with a  diameter  of  10  (2.5) micrometres or 
less.  PM  is  emitted  from  many  anthropogenic  sources,  including 
combustion. 
60 Low level ozone is produced by photochemical action and it is also a 
greenhouse gas. 
61 European Environment Agency, Air Quality in Europe – 2018 Report, 
p.64. Please see details in this report as regards the underpinning 
methodology. 

17 

 
 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Figure  14:  Air  quality  zones  exceeding  EU  air  quality 
standards in 201762 

The  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  the  ‘industrial  emissions  policy 
country profiles’ project65. 

industrial 

installations  are 
In  Finland,  around  775 
required  to  have  a  permit  based  on  the  IED66.  The 
industrial  sectors 
IED 
in  Finland  with 
installations in 2015 (i.e. IED installations with a permit in 
2015) were the intensive rearing of poultry or pigs (30 % 
of total), followed by non-hazardous waste management 
(16 %) and power generation (16 %). 

the  most 

It is estimated that the health-related external costs from 
air  pollution  in  Finland  are  over  EUR 2  billion  per  year 
(income adjusted, 2010). These external costs include not 
only the intrinsic value of living a full healthy life but also 
direct costs to the economy. These direct economic costs 
relate to 542 000 workdays lost each year due to sickness 
from air pollution, with associated costs of EUR 74 million 
per  year  for  employers  (income  adjusted,  2010),  over 
EUR 8  million  per  year  for  healthcare  (income  adjusted, 
in 
2010),  and  EUR 29  million  per  year  for 
farmcrops (2010)63. 

losses 

2019 priority action 

 

Take,  in  the  context  of  the  National  Air  Pollution 
Control  Programme 
towards 
reducing the main emission sources - and meet all air 
quality standards. 

(NAPCP),  actions 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 
(i) protect air, water and soil; 
(ii) prevent and manage waste; 
(iii) improve energy and resource efficiency; and  
(iv) clean up contaminated sites.  
To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial Emissions Directive64 (IED). 

62 EEA, EIONET Central Data Repository. Data reflects the reporting 
situation as of 26 November 2018. 
63 These figures are based on the Impact Assessment for the European 
Commission Integrated Clean Air Package (2013). 
64  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers energy industry, metal production, mineral 
and chemical industry and waste management, as well as a wide range 
of  industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pig  and 
poultry, pulp and paper production, painting and cleaning). 

Figure  15:  Number  of  IED  industrial  installations  by 
sector, Finland (2015) 

industrial  sectors 

identified  as  contributing  the 
The 
largest  burden  to  the  environment  for  emissions  to  air 
are:  (i)  ‘energy-power’  mainly  for  heavy  metals,  sulphur 
oxides  (SOx)  and  nitrogen  oxides  (NOx);  (ii)  ‘energy-
refining’  for  heavy  metals  and  SOx;  (iii)  the  ‘metals’ 
sector for heavy metals; and (iv) ‘other activities’ (mostly 
the  intensive  rearing  of  poultry  or  pigs  and  surface 
treatment) for non-methane volatile organic compounds 
(NMVOC)  and  ammonia  (NH3).  The  breakdown  is  shown 
in the following graph. 

The industrial sectors of ‘other activities’, ‘metals  — iron 
and steel’, and ‘non-hazardous waste management’ were 
identified  as  making  a  significant  contribution  to 
emissions  to  water.  The 
industrial  sector 
generates  the  most  hazardous  waste  of  all  industrial 
sectors. 

‘metals’ 

The enforcement approach under the IED creates strong 
rights for citizens to have access to relevant information 
and  to  participate  in  the  permitting  process  for  IED 
installations. This empowers NGOs and the general public 
to  ensure  that  permits  are  appropriately  granted  and 
their conditions respected. 

65  European  Commission,  Industrial  emissions  policy  country  profile  – 
Finland. 
66 European Commission, Industrial emissions policy country profile – 
Finland. 

18 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Figure 16: Emissions to air from IED sectors and all other 
national air emissions, Finland (2015) 

Best  available  techniques  (BAT)  reference  documents 
(BREFs)  and  BAT  conclusions  are  developed  through  the 
information  between  Member  States, 
exchange  of 
industrial  associations,  NGOs  and  the  Commission.  This 
ensures good collaboration with stakeholders and better 
implementation of IED. 

Thanks  to  the  efforts  by  the  national  competent 
authorities  to  apply  the  legally  binding  BAT  conclusions 
and  associated  BAT  emission  levels  in  environmental 
permits,  pollution  has  decreased  considerably  and 
continuously in the EU. 

For  example,  by  applying  the  recently  adopted  BAT 
emission levels for large combustion plants, emissions of 
sulphur dioxide will be  cut  on average by between 25 % 
and 81 %, nitrogen oxide by between 8 % and 56 %, dust 
by  between  31 %  and  78 %  and  mercury  by  between 
19 %  and  71 %.  The  extent  of  the  reduction  depends  on 
the situation in individual plants. 

A  future  challenge  identified  was  complying  with  the 
recently adopted associated BAT emission levels for large 
combustion  plants  with  existing  boilers  using  biomass 
and peat. 

2019 priority actions 

  Review of permits to comply with new adopted BAT 

 

conclusions. 
Strengthen  monitoring  and  enforcement  to  ensure 
compliance with BAT conclusions. 

  Address  challenges  to  comply  with  the  recently 
adopted BAT conclusions for large combustion plants 
for existing boilers using biomass and peat by August 
2021. 

Noise 
The  Environmental  Noise  Directive67  provides  for  a 
common  approach  to  avoiding,  preventing  and  reducing 
the harmful effects of exposure to environmental noise. 

Excessive noise from aircrafts, railways and roads is one 
of the main causes of health problems in the EU68. 

In Finland, based on a limited set of data, environmental 
noise  causes  at  least  around  200  premature  deaths  and 
700  hospital  admissions  per  year69.  Noise  also  disturbs 
the sleep of some 170 000 people. The noise mapping for 
the previous reporting round for the reference year 2011 
is complete. The action plans for the reference year 2013 
are complete. 

These  instruments,  adopted  after  a  public  consultation 
had  been  carried  out,  should  include  the  measures  to 
keep noise low or reduce it.  

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive  will  ensure that EU citizens 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. 

The  existing  EU  water  legislation70  puts  in  place  a 
protective  framework  to  ensure  high  standards  for  all 
water  bodies  in  the  EU  and  addresses  specific  pollution 
sources  (for  example,  from  agriculture,  urban  areas  and 
industrial  activities).  It  also  requires  that  the  projected 
into  the 
impacts  of  climate  change  are 
corresponding  planning 
risk 
management  plans  and  river  basin  management  plans, 
including  programme  of  measures  which  include  the 
actions  that  Member  States  plan  to  take  in  order  to 
achieve the environmental objectives. 

instruments  e.g. flood 

integrated 

67 Directive 2002/49/EC. 
68 WHO/JRC, 2011, Burden of disease from environmental noise, 
Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), 
World Health Organisation, Regional Office for Europe, Copenhagen, 
Denmark. 
69 European Environment Agency, Noise Fact Sheets 2017. 
70 This includes the Bathing Waters Directive (2006/7/EC), the Urban 
Waste Water Treatment Directive (91/271/EEC) (on discharges of 
municipal and some industrial wastewaters), the Drinking Water 
Directive (98/83/EC) (on potable water quality), the Water Framework 
Directive (2000/60/EC) (on water resources management), the Nitrates 
Directive (91/676/EEC) and the Floods Directive (2007/60/EC). 

19 

 
                                                                 
Environmental Implementation Review 2019 – Finland 

Water Framework Directive 

Finland has adopted and reported the second generation 
of  River  Basin  Management  Plans  under  the  Water 
Framework  Directive  and  the  European  Commission  has 
assessed  the  status  and  the  development  since  the 
adoption  of  the  first  River  Basin  Management  Plans, 
including suggested actions in the EIR report 2017. 

The  most  significant  pressures  on  surface  water  bodies 
in  Finland  is  from  atmospheric  deposition  (53%)  diffuse 
agricultural  pressures  (24%)  and  diffuse  polution  from 
forestry  (17%).  For  groundwater  bodies  the  significant 
pressure was diffuse pollution from transport with 7% of 
groundwater bodies affected. 

Chemical  pollution  was  the  most  significant  impact  on 
surface water (51% of surface water bodies), followed by 
nutrient pollution (29%). For 97% of groundwater bodies 
the impact type was unknown. 

A large percentage of surface water bodies had unknown 
status/potential  in  the  first  River  Basin  Management 
Plans  (52.8%)  which  was  reduced  to  1.4%  in  the  second 
River  Basin  Management  Plans.  Significant  progress  has 
therefore  been  made.  The  ecological  status/potential  in 
Finland is illustrated in Figure 17. 

Figure 17: Ecological status or potential of surface water 
bodies in Finland71 

A significant proportion of surface water bodies included 
in  surveillance  monitoring  were  not  monitored  for  all 
required  biological  quality  elements.  There  is  still  a 
predominant  focus  on  the  monitoring  of  phytoplankton 
in coastal  waters and lakes,  and on the physicochemical 
quality elements in all  water  categories.  There has been 
some  progress  on  this  aspect  since  the  first  River  Basin 
Management Plans but Finland is still not consistent with 
the  Water  Framewrok  Directive  on  this  issue.Overall, 
there was a decrease in the proportion of surface water 
bodies  with  good  chemical  status  from  64%  down  to 
49%,  similar  decreases  occurred  across  all  water  body 
types  (artificial,  heavily  modified  and  natural).  In  the 
meantime,  the  proportion  of  surface  water  bodies  that 
fail  to  achieve  good  chemical  status  dramatically 
increased between the two cycles, from 0.44 % to 49 %, 
which  is  linked  to  the  considerable  reduction  in  surface 
water bodies at unknown status.The  quantitative status 
of  groundwater  bodies  deteriorated  slightly  overall  but 
98%  were  still  considered  to  be  in  good  quantitative 
status.  It  should  in  this  context  be  noted  that  96%  of 
groundwater  bodies  are  not  monitored  for  quantitative 
status. 

In  general,  the  amount  and  quality  of  readily  available 
information  regarding  the  Programmes  of  Measures  has 
improved  between  the  first  and  the  second  River  Basin 
management  Plan.  However,  some  significant  pressures 
identified  in  the  RBMPs  are  not  addressed  by  measures 
and  indicators  of  the  gaps  to  be  filled  for  significant 
pressures  were  reported  fairly  sporadically  across  River 
Basin Districts and only for 2015. 

Finland states for example that good progress in reducing 
pollution from point sources has been achieved in urban 
and  industry  sectors  and  that  there  has  also  been 
progress  with  measures  associated  with 
forestry, 
in  managing 
rehabilitation  of  watercourses  and 
hydromorphological pressures as well as in groundwater 
protection.  But  more  measures  are  needed  for  example 
regarding agriculture. 

Nitrates Directive 

that  nitrate  concentrations 

In accordance with the Nitrates Directive, Finland applies 
mandatory  measures  over  its  whole  territory.  Data  for 
2012-2015  showed 
in 
groundwater  and  surface  waters  did  not  raise  particular 
concern.  However,  issues  with  nutrients  should  not  be 
underestimated.  Finland 
the  countries 
bordering the Baltic Sea, which is still heavily affected by 
nutrients pollution, despite improvements in data on the 
trophic status for coastal waters. 

is  one  of 

Overall, there has been a 2.3 fold increase in the number 
of  monitoring  sites  in  Finland  between  the  first  and 
second River Basin Management Plans. 

71 EEA, WISE dashboard. 

20 

 
                                                                 
Environmental Implementation Review 2019 – Finland 

Drinking Water Directive 

Floods Directive 

On  drinking  water,  no  new  data  is  available  since  the 
previous EIR report72. 

Bathing Water Directive 

Figure  18  shows  that  in  2017,  out  of  the  299  Finnish 
bathing  waters,  85.6 %  were  of  excellent  quality,  7 %  of 
good quality and 1.7 % of sufficient quality (83.4 %, 9.3 % 
and  2.3 %  respectively  in  2016).  In  2017,  two  bathing 
in  Finland73.  Detailed 
waters  were  of  poor  quality 
information  on  Finnish  bathing  waters  is  available  on  a 
national portal74 and via an interactive map viewer of the 
European Environment Agency75. 
Figure 18: Bathing water quality 2014 – 201776 

Significant  investment  needs  still  exist  in  Finland  to 
accelerate  compliance  with  the  Water  Framework 
Directive and the Floods Directive, such as the removal of 
obstacles to fish migration, renaturalisation of the flow of 
rivers,  and  various  measures  for  flood  prevention  and 
mitigation. Finland has estimated its investment costs for 
99 measures  related to flood risk  management  planning 
at EUR 472 million. 

The  Floods  Directive  established  a  framework  for  the 
assessment and management of flood risks, aiming at the 
reduction  of  the  adverse  consequences  associated  with 
significant floods. 

Finland  has  adopted  and  reported  its  first  Flood  Risk 
Management Plans under the Directive and the European 
Commission conducted an assessment. 

The  Commission’s  assessment  found  that  good  efforts 
were made with positive results in setting objectives and 
devising  measures  focusing  on  prevention,  protection 
and  preparedness.  The  assessment  also  showed  that,  as 
was  the  case  for  other  Member  States,  Finland’s  Flood 
Risk  Management  Plans  do  not  yet  include  a  strong  link 
between  the  objectives  and  the  measures  and  do  not 
clarify  whether  the  planned  measures  are  sufficient  to 
reach  the  objectives  and  by  when.  In  addition,  there  is 
scope  for  ensuring  coordination  with  the  National 
Climate Change Adaptation Strategy. 

2019 priority actions 

 

 

 

Take steps to further improve monitoring of surface 
waters,  to  cover  all  water  bodies  for  all  relevant 
quality  elements, 
including  hydromorphological 
quality elements and River Basin Specific Pollutants 
in coastal waters 
Take effective basic and supplementary measures to 
address  diffuse  pollution  from  agriculture,  mainly 
phosphates  (e.g.  measures  to  prevent  soil  runoff 
and  sedimentation,  proper  disposal  of  manure, 
integrated pest management). 
Take  steps 
the  Flood  Risk 
Management  Plans  are  coordinated  with  the 
National Climate Change Adaptation Strategy. 

to  ensure 

that 

Chemicals 

The  EU  seeks  to  ensure  that  by  2020  chemicals  are 
produced and used in ways that minimise any significant 
adverse  effects  on  human  health  and  the  environment. 
An  EU  strategy  for  a  non-toxic  environment  that  is 
conducive  to  innovation  and  to  developing  sustainable 
substitutes,  including  non-chemical  options,  is  being 
prepared. 

Urban Waste Water Treatment Directive  

Finland  has  a  high 
level  of  compliance  with  the 
requirements  of  the  Urban  Waste  Water  Treatment 
Directive. Overall, in Finland, 100 % of the wastewater is 
collected, and 95.2 % of the load collected is subjected to 
secondary  treatment.  Finally,  91.1 %  of  the  wastewater 
load collected undergoes  more stringent  treatment.  The 
investment  needed  to  ensure  adequate 
estimated 
is 
treatment  of  the  remaining  urban  wastewater 
EUR 25.7 million77. 

72 Compliance with the Drinking Water Directive microbiological and 
chemical parameters as last reported was very high. 
73 European Environment Agency, 2017. European bathing water quality 
in 2016, p. 17. 
74 Valvira, National Supervisory Authority for Welfare and Health,  
Finnish bathing waters  
75 European Environment Agency,  State of bathing waters  
76European Environment Agency, 2018. European bathing water quality 
in 2017, p. 21. 
77 European Commission, Ninth Report on the Implementation Status 
and the Programmes for Implementation of the Urban Waste Water 
Treatment Directive (COM(2017) 749) and Commission Staff Working 
Document accompanying the report (SWD(2017)445). 

21 

 
                                                                 
Environmental Implementation Review 2019 – Finland 

legislation78  provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the internal market. 

The Ministry of Social Affairs and Health and the Ministry 
of  the  Environment  are  responsible  for  the  overall 
management  and  supervision  of  the  REACH,  CLP  and 
Biocide Product Regulations in Finland. 

In  2016,  the  European  Chemicals  Agency 
(ECHA) 
published  a  report  on  REACH  and  the  CLP  Regulation79 
that showed that enforcement activities are still evolving. 
Member  States  cooperate  closely  within  the  Forum  for 
Information  on  Enforcement  80.  This 
Exchange  of 
cooperation  has  shown  that  there  is  scope  to  increase 
the  effectiveness  of  enforcement  activities,  particularly 
for registration obligations and safety data sheets where 
the level of non-compliance is still relatively high. 

While progress has been made, there is room to further 
improve  and  harmonies  national  enforcement  activities 
across  the  EU,  including  controls  on  imported  goods. 
Enforcement  remains  weak  in  some  Member  States, 
particularly  for  controls  on  imports  and  supply  chain 
obligations.  The  enforcement  architecture  is  complex  in 
most  EU  countries,  and  enforcement  projects  reveal 
differences  in  compliance  between  Member  States  (e.g. 
some  tend  to  systematically  report  higher  compliance 
than the EU average and others lower). 

A  2015  Commission  study  already  highlighted  the 
importance  of  harmonised  market  surveillance  and 
enforcement  when  implementing  REACH  at  Member 
State  level,  deeming  it  to  be  a  critical  success  factor  in 
the operation of a harmonised single market81. 

In March 2018, the Commission published an evaluation 
of REACH82 underlining the need to improve enforcement 
in order to ensure a  level playing field, meet  the REACH 
objectives  and  ensure  consistency  with  measures  that 
aim 
compliance  and 
governance.  For  this,  consistent  reporting  of  Member 
States’  enforcement  activities  was  considered  of  key 
importance. 

improve  environmental 

to 

Various  authorities  are  responsible  for  the  enforcement 
of  the  REACH,  CLP  and  Biocide  Product  Regulations  in 
Finland83. 

78 Principally  for  chemicals:  REACH  (OJ  L  396,  30.12.2006,  p.1.);  for 
Classification,  Labelling  and  Packaging,  the  CLP  Regulation  (:  OJ  L  252, 
31.12.2006,  p.1.),  together  with  legislation  on  biocidal  products  and 
plant protection products. 
79 European Chemicals Agency, Report on the Operation of REACH and 
CLP 2016. 
80 ECHA, on the basis of the projects REF-1, REF-2 and REF-3. 
81 European Commission. (2015). Monitoring the Impacts of REACH on 
Innovation, Competitiveness and SMEs. Brussels: European 
Commission. 
82 COM(2018) 116 final: Commission General Report on the operation of 
REACH and review of certain elements. Conclusions and Actions. 
Brussels, 5.3.2018. 
83 ECHA, National Inspectorates - Finland  

22 

The  Finnish  Safety  and  Chemicals  Agency  (Tukes)  has 
been  appointed  as  the  Competent  Authority  of  REACH 
and  CLP  and  the  Competent  Authority  of  the  Biocides 
is  responsible  for 
Product  Regulation  (BPR).  Tukes 
enforcement of all REACH, CLP and BPR provisions on the 
marketing  of  chemicals,  biocides  and  treated  articles. 
Tukes is responsible for the national helpdesk for REACH, 
CLP and BPR. 

Making cities more sustainable 

EU policy on the urban environment encourages cities to 
put  policies  in  place  for  sustainable  urban  planning  and 
design.  These  should  include  innovative  approaches  to 
urban  public 
sustainable 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation. 

transport  and  mobility, 

living 

in  Europe 

in  urban  areas 

The  population 
is 
projected to rise to just over 80% by 205084. Urban areas 
pose  particular  challenges  for  the  environment  and 
human  health,  but  they  also  provide  opportunities  for 
using  resources  more  efficiently.  The  EU  encourages 
municipalities to become greener through initiatives such 
as  the  Green  Capital  Award85,  the  Green  Leaf  Award86 
and the Green City Tool87. 

Financing greener cities 

Finland  has  earmarked  EUR 39.5  million  or  5 %  of  its 
allocation  under  the  European  Regional  Development 
Fund 
in  sustainable  urban 
development actions (as part of its ‘integrated territorial 
investment’) mainly in the six biggest cities of Finland88. 

investment 

(ERDF) 

for 

Finland participates in the European Urban Development 
Network89.  The  network  includes  more  than  500  cities 
across  the  EU  responsible  for  implementing  integrated 
actions  based  on  sustainable  urban  development 
strategies financed by ERDF in the 2014-2020 period. 

Among  the  network’s  initiatives,  the  ERDF  is  supporting 
urban  innovative  actions  (UIA)  as  a  way  of  testing  new 
and unproven solutions to address urban challenges. The 

84 European Commission, Eurostat, Urban Europe, 2016, p.9. 
85 European Commission, European Green Capital  
86 European Commission, European Green Leaf Award  
87 European Commission, Green City Tool  
88 European Commission, Summary of the Partnership Agreement for 
Finland 2014-2020, 2014. 
89 European Commission, The Urban Development Network. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Finland 

UIA has a total ERDF budget of EUR 372 million for 2014-
2090. 

representing  Finland  in  a  common  effort  to  achieve 
cleaner and better transport in cities93. 

Finnish cities are also actively involved in initiatives such 
as Eurocities and the EU Covenant of Mayors (12 Finnish 
cities are participating in the EU Covenant of Mayors). By 
May  2018,  Helsinki,  Joensuu,  Lahti,  Oulu,  Tampere  and 
Vantaa  had  already  submitted  their  2020  action  plans 
and  their  results  are  now  being  monitored.  Another  3 
cities  have  presented  their  climate  action  plan  and 
commitments for either 2020 or 203094. 

These  urban 
initiatives  and  networks  should  be 
welcomed and encouraged, as they contribute to a better 
urban  environment.  In  2017,  10.3 %  of  the  Finnish 
population  living  in  cities  considered  their  residential 
area  to  be  affected  by  pollution,  grime  or  other 
environmental  problems,  up  from  8.6 %  in  2016  and 
10.1 % in 2015. These figures are significantly lower than 
the  EU-28  levels  (20%  in  2017  and  18.9 %  in  2016),  and 
similar to Sweden and Denmark95. 

Nature and cities 

Only 3 % of the Natura 2000 network in Finland is to be 
found  in  functional  urban  areas96,  well  below  the  EU 
average of 15 % (see Figure 19). 

Figure  19:  Proportion  of  Natura  2000  network 
Functional Urban Areas (FUA) 97 

in 

One  UIA  project  (CitiCAP,  with  a  budget  of  EUR 3.8 
million)  is  running  in  Lahti  and  deals  with  sustainable 
urban mobility. Its aim is to find the most inspiring ways 
of  getting  more  people  to  walk,  cycle  and  use  public 
transportation.  Through  CitiCAP,  Lahti  will  develop  a 
completely  new  public  incentive,  the  personal  carbon 
trade, 
revolutionise  people’s 
participation in climate change mitigation. 

it  hopes  will 

that 

Another  UIA  project  (EUR 3.4  million  budget)  is  being 
undertaken in Lappeenranta and deals with what is called 
the  urban  infra  revolution.  It  concerns  circular  economy 
materials  and  the  development  of  novel  methods  to 
produce  recyclable  and  functional  urban  construction 
products. The hope is that its circular economy and low-
carbon  solution  will  revolutionise  urban  construction 
engineering.  The  side  streams  from  industry  are  utilised 
in  urban  construction  by  combining  them  to  produce  a 
high-value  material  to  replace  concrete.  CO2  emissions 
are reduced by avoiding the use of cement and preferring 
local sources for materials. 

Participation in EU urban initiatives and networks 

Finnish  municipalities  are  generally 
in  EU 
environmental protection and climate change initiatives. 

involved 

Various  Finnish  cities,  communities  and  regions  are 
involved  in  the  URBACT  initiative  to  support  sustainable 
urban  development.  It  is  through  their  participation  in 
five  different  thematic  networks  that  they  are  doing 
this91. 

The Urban Agenda for the EU also provides a network for 
different 
the 
sustainability  of  cities.  The  city  of  Helsinki  is  a  lead 
partner in the partnership for Air Quality92. 

levels  of  government 

to  address 

is  becoming 

Urban  development  policy 
increasingly 
prominent  in  Finland.  The  major  cities  are  being  used 
more  systematically  as  engines  to  power  the  growth  of 
regions  and  the  whole  country. Major  cities  have  signed 
growth  agreements  to  increase  their  competitiveness 
and  economic  resilience,  to  improve  land  use,  housing 
and  transportation  and  to  become  more  socially 
sustainable. 

Urban sprawl 

Finland  had  a  weighted  urban  proliferation  rate,  at  0.61 
UPU/m2 98 in 2009 compared to a European average (EU-
28+4)  of  1.64  UPU/m2,  having  increased  by  3.4 %  from 
2006 to 200999. 

Several  Horizon  2020  network  projects  have  also 
contributed  to  the  sustainability  of  Finnish  cities.  The 
three  municipalities 
CIVITAS 

includes 

project 

90 European Commission, Urban Innovative Actions. 
91 URBACT, Associated Networks by country. 
92 European Commission, Urban Agenda for the EU  

93 European Commission, Horizon 2020 Civitas Project. 
94 Covenant of Mayors for Climate and Energy, Country signatories. 
95 European Commission, Eurostat, Pollution, grime or other 
environmental problems by degree of urbanisation. 
96 European Commission, Definition of Functional Urban Areas. 
97 European Commission, The 7th Report on Economic, Social and 
Territorial Cohesion, 2017, p. 121. 
98 Urban Permeation Units measure the size of the built-up area as well 
as its degree of dispersion throughout the region. 
99 EEA, Urban Sprawl in Europe, Annex I, 2014, pp.4-5. 

23 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Traffic congestion and urban mobility 

Traffic  congestion  is  not  one  of  the  main  environmental 
issues  affecting  Finland.  However,  many  of  the  topics 
addressed  in  this  report  are  to  some  extent  related  to 
traffic congestion, especially air quality and noise. 

The total number of road vehicles  in Finland  rose to  3.3 
million in 2016, increasing the rate of vehicles per 1 000 
inhabitants from 580 in 2014 to 604 in 2016. 

However, this increase has resulted in the average driver 
spending  a  lower  number  of  hours  annually  in  road 
congestion, from 19.9 in 2014 to 17.9 hours in 2016. This 
means that Finland was well below the worst performer 
in the EU (i.e. the UK with 45.1 hours)100. 

Road  traffic  intensity  per  unit  of  GDP  in  Finland  in  2014 
was  310  vehicle  kilometres  per  USD  1 000,  which  was 
above the OECD Europe average of 254 veh.-km per USD 
1 000101. 
The modal  split of passenger transport102 in 2015 shows 
that  passenger  cars  in  Finland  accounted  for  85 %  of 
inland  passenger  transport  (EU-28  83.4 %),  with  buses 
and  trolley  buses  accounting  for  around  9.7 %  (EU-28 
9.1 %) and trains for 5.3 % (EU-28 7.6 %)103. 

100 European Commission, Hours spent in road congestion annually. 
101 OECD, Road traffic intensity per unit of GDP, 2014 or latest available 
year », in Sectoral and Economic Trends of Environmental Significance, 
OECD publications, Paris, 2015. 
102 The relation between mode of transport and kilometres travelled 
(excluding bicycles and other alternative methods). 
103 Eurostat, Passenger transport Statistics by modal split. 

24 

 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Part II: Enabling framework: implementation tools 

4.  Green taxation, green public procurement, environmental 
funding and investments 

Figure  20:  Environmental  tax  revenues  as  %  of  GDP  in 
2017107 

Green  taxation  and  environmentally  harmful 
subsidies 

incentives, 

Financial 
taxation  and  other  economic 
instruments  are  effective  and  efficient  ways  to  meet 
environmental  policy  objectives.  The  circular  economy 
action  plan  encourages  their  use.  Environmentally 
harmful  subsidies  are  monitored  in  the  context  of  the 
European  Semester  and  the  energy  union  governance 
process. 

revenue 

from  environment-related 

Finland’s 
taxes 
remains  above  the  EU  average.  Environmental  taxes 
accounted  for  2.99 %  of  GDP  in  2017  (EU-28  average 
2.4 %) as shown in Figure 20, and energy taxes for 1.99 % 
of  GDP  against  an  EU  average  of  1.84 %104.  In  the  same 
year,  environmental  tax  revenues  were  6.88 %  of  total 
revenues  from  taxes  and  social  security  contributions 
(higher than the EU-28 average of 5.97 %). 

implicit  tax  burden  on 

The  taxation  structure  shows  that  the  proportion  of 
revenues from labour tax in relation to total tax revenues 
is higher than the EU average, with 51.3 % in 2016, while 
labour  was  40.7 %105. 
the 
Consumption taxes remained relatively low (32.7 %, 15th 
in  EU-28),  which  points  to  some  potential  for  shifting 
taxes  from  labour  to  consumption  and  in  particular  to 
environmental  taxes.  Nevertheless,  taxes  have  recently 
been  increased  on  transport  fuels  and  on  the  energy 
content tax and CO2 tax on heating fuels. 

The  Commission  has  repeatedly  noted  in  the  European 
Semester  that  revenue  from  environmental  taxes  in 
Finland  has  increased  in  recent  years  and  is  one  of  the 
highest in the EU. In the 2018 country report for Finland, 
the  Commission  pointed  out  that  the  composition  of 
environmental  taxes  has  changed,  with  taxes  on  CO2 
from  heating,  power  plants  and  machinery  gradually 
increasing  and  with  the  taxation  on  waste  also  rising106. 
Similarly,  the  report  suggests  introducing  new  policy 
instruments, such as taxes or charges, to promote waste 
prevention, make reuse and recycling more economically 
attractive  and  shift  reusable  and  recyclable  waste  away 
1  on  Waste 
from 
management). 

(see  Chapter 

incineration 

It  is  also  worth  mentioning  that  the  deposit  refund 
system and packaging tax are considered very successful 
thanks  to  close  cooperation  between  the  parties 
concerned108. 

Meanwhile,  fossil  fuel  subsidies  decreased  in  the  past 
decade  and  had  almost  disappeared  by  2016.  Tax 
exemptions, however, increased during the last years and 
were  in  place  in  2016  for  fossil  fuels  used  in  transport, 
leisure  flights,  mobile  machinery,  agriculture,  energy 
intensive  enterprises,  heating,  etc.  These  exceptions 
added up to EUR 1 600 million in 2016109. 

Substantial  progress  has  been  made  in  reducing  the 
‘diesel  differential’  (difference  in  the  price  of  diesel  in 

104 Eurostat, Environmental tax revenues, 2018. 
105 European Commission, Taxation Trends Report, 2017. 
106 European Commission, European Semester Country Report 2018, p. 
17. 

107 Eurostat, Environmental tax revenues, 2018. 
108 Institute for European Environmental Policy, Case Studies on 
Environmental Fiscal Reform, Deposit refund system in Finland. 
109 OECD, Inventory of Support Measures for Fossil Fuels, 2018. 

25 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

relation to petrol) since 2005. In 2016, there was a 32 % 
gap between petrol and diesel tax rates, while in 2005 it 
was 84 %110. Excise tax rates levied on petrol and diesel in 
2016  remained  constant  in  comparison  with  2015  rates 
(EUR 0.68 per liter for petrol and EUR 0.51 for diesel)111. 

CO2-based  motor  vehicle  taxes  are  in  place  in  the 
country.  The  registration  tax  and  the  annual  circulation 
tax for cars are based on emissions. The excise duties for 
road  traffic  fuels  are  dependent  on  the  energy  content 
and CO2 emissions112. 

Incentives to encourage the purchase of cars with lower 
CO2  emissions  were  in  place  in  2016.  These  incentives 
were linked to annual circulation taxes and subsidies and 
to road tolls, congestion and low emission zone charges. 
But  they  were  also  linked  to  the  acquisition  of  cleaner 
vehicles.  There  were  no  incentives  connected  to  the 
preferential  use  of  road  infrastructures113.  New  vehicles 
purchased  in  Finland  are  as  environmentally  friendly  as 
the average in the EU, with average CO2 emissions of 120 
grams per kilometre (EU average of 118 grams in 2016)114.  

The use of alternative fuels in new passenger cars sold in 
Finland  has  considerably  increased  in  recent  years.  The 
share  of  new  passenger  cars  using  alternative  fuels  was 
four  times  higher  in  2016  than  in  2013115.  A  growing 
number  of  charging  points  and  aid  for  acquiring  fully 
electric vehicles are also supporting the market uptake of 
electric cars. 

Green public procurement 

The  EU  green  public  procurement  policies  encourage 
Member  States  to  take  further  steps  to  apply  green 
procurement  criteria  to  at  least  50 %  of  public  tenders. 
The European Commission is helping to increase the use 
of  public  procurement  as  a  strategic  tool  to  support 
environmental protection. 

The purchasing power of public procurement amounts to 
around  EUR 1.8  trillion  in  the  EU  (approximately  14%  of 
GDP).  A  substantial  proportion  of  this  money  goes  to 
sectors  with  a  high  environmental 
impact  such  as 
construction  or  transport.  Therefore,  green  public 
procurement  (GPP)  can  help  to  significantly  lower  the 
negative  impact  of  public  spending  on  the  environment 

110 European Environment Agency 2017, Environmental taxation and EU 
environmental policies, p. 27. 
111 European Commission, Taxes in Europe Database, 2018. 
112 ACEA, CO2 based motor vehicle taxes in Europe. 
113 European Environmental Agency, Appropriate taxes and incentives 
do affect purchases of new cars, 18 May 2018. 
114 European Environment Agency, Average CO2 emissions from new 
passenger cars sold in EU-28 Member States plus Norway, Iceland and 
Switzerland in 2016. 
115 European Commission, Transport in the European Union Current 
Trends and Issues, 2018, pp.27-28. 

26 

and  can  help  support  sustainable  innovative  businesses. 
The Commission has proposed EU GPP criteria116. 

A  national  strategy  on  green  public  procurement  is 
included  in  the  Finnish  government’s  2013  Decision  on 
the  Promotion  of  Sustainable  Environmental  and  Energy 
Solutions (cleantech solutions) in Public Procurement. 

Finland  has  set  ambitious  targets  for  the  central 
government  but  also  for  regional  and  local  government, 
as  recommendations.  Targets  have  also  been  set  which 
increase  progressively  over  time  and  aim  to  achieve 
100 %  GPP  at  the  central  level117.  Finland  is  aiming  for 
in  the  new 
near-zero  energy  building  after  2017 
construction  of  public  buildings.  The  percentage  of  new 
motive  power  solutions  used  (e.g.  electric,  ethanol, 
natural  gas  or  hybrid)  must  account  for  at  least  30 %  of 
all vehicles in use. In addition, 10 % of the food served in 
public institutions must  be organic by 2015 and 20 % by 
2020. 

GPP criteria are developed at the national level. There is 
guidance and criteria for 16 procurement areas, including 
food  and  catering,  vehicles  and  transport,  construction, 
energy  services,  energy-related  products,  and  textiles 
(workwear). GPP criteria are also under development for 
kitchen 
cleaning 
furniture, 
appliances, and printing services. 

services,  professional 

To  support  the  strategic  use  of  public  procurement, 
Finland  set  up  a  national  competence  centre  for 
sustainable and innovative public procurement in March 
2018.  Core  services  include  implementing  innovative 
procurement  strategies,  piloting  Green  Deals,  sustaining 
a  national network for change and creating pathways to 
international procurements and funding. 

A  European  Parliament  study  notes  that  Finland  has 
partially implemented the GPP national action plan118. 

Environmental funding and investments 

European  Structural  and  Investment  Fund  (ESIF)  rules 
oblige  Member  States  to  promote  environment  and 
climate  in  their  funding  strategies  and  programmes  for 
economic, 
rural 
development and maritime policy. 

social  and 

territorial 

cohesion, 

In 

the  Communication 

‘Public  procurement 

116 
for  a  better 
environment’  (COM  (2008)  400)  the  Commission  recommended  the 
creation  of  a  process  for  setting  common  GPP  criteria.  The  basic 
concept  of  GPP  relies  on  having  clear,  verifiable,  justifiable  and 
ambitious environmental criteria for products and services, based on a 
life-cycle approach and scientific evidence base. 
117 Green public procurement and the EU action plan for the circular 
economy, European parliament, 2017. 
118 European Parliament, Green Public Procurement and the Action Plan 
for the Circular Economy, 2017, pp. 79-80. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Finland 

Achieving  sustainability  involves  mobilising  public  and 
private  financing  sources119.  Use  of  the  European 
Structural  and  Investment  Funds  (ESIFs)120  is  essential  if 
countries  are  to  achieve  their  environmental  goals  and 
into  other  policy  areas.  Other 
integrate 
instruments such as Horizon 2020, the LIFE programme121 
and the European Fund for Strategic Investments (EFSI)122 
may also support the implementation and spread of good 
practices. 

these 

For  2014-2020,  Finland  has  been  allocated  around 
EUR 1.47 billion in total cohesion policy funding of which: 

  EUR 999.1 million for more developed regions (all); 
  EUR 161.3 million for European territorial cooperation; 
  EUR 305.3  million  for  the  northern  sparsely  populated 

regions. 

Figure  21:  ESIF  2014-2020  –  EU  allocation  by  theme, 
Finland (EUR billion)124 

In the 2017 Eurobarometer123 on attitudes of EU citizens 
towards  the  environment,  87 %  of  Finnish  citizens 
support  greater  EU 
in  environmental 
protection in general (EU-28 average 85 %). 

investment 

European Structural and Investment Funds 2014-2020 

Finland  has  been  allocated  EUR 3.76  billion  from  ESIF 
over the period 2014-2020 for five national and regional 
programmes (See Figure 19). With this EU funding and a 
national  contribution  of  EUR 4.66  billion,  Finland  has  a 
total  budget  of  EUR 8.42  billion  for  investing  in  various 
improving  competitiveness,  boosting 
areas  such  as: 
research 
employment, 
creating 
innovation, 
and 
facilitating  education  and  training  and  transitioning  to  a 
low-carbon economy and protecting the environment. 

Cohesion policy 

Finland  is  managing  two  operational  programmes  under 
EU  cohesion  policy  for  2014-2020  (one  for  mainland 
Finland and one for the Åland Islands), which will receive 
funding  from  the  European  Regional  Development  Fund 
(ERDF) and the European Social Fund (ESF). 

119 See,  for  example,  Action  plan  on  financing  sustainable  growth 
(COM(2018) 97).  
120 i.e. the  European  Regional  Development  Fund  (ERDF),  the  Cohesion 
Fund  (CF),  the  European  Social  Fund  (ESF),  the  European  Agricultural 
Fund  for  Rural  Development  (EAFRD)  and  the  European  Maritime  and 
Fisheries Fund (EMFF). The ERDF, the CF and the ESF are referred to as 
the ‘cohesion policy funds’. 
121 European Commission, LIFE programme. 
122  European 
Investments, 2016. 
123 European Commission, 2017, Special 468 Eurobarometer, ‘Attitudes 
of European citizens towards the environment’. 

Investment  Bank,  European  Fund 

for  Strategic 

Of  this  cohesion  policy  funding,  ESF  in  Finland  will 
represent  a  minimum  of  EUR 515  million.  The  actual 
amount  will  be  determined  based  on  the  specific 
challenges  the  country  needs  to  address  in  the  areas 
covered by the ESF. 

technology, 

ERDF  funding  will  be  particularly  targeted  at  innovation 
and research on innovative energy technology, including 
offshore energy production and energy efficiency, smart 
the 
construction 
buildings,  wood 
development of models and processes and pilot projects. 
ERDF funding will focus on new, low-carbon products and 
services, which will also become available on the market 
through  the  low-carbon  strategies  of  towns  and  cities. 
SMEs  will  improve  their  energy  efficiency  through  new 
energy-efficient 
that 
support  sustainable  growth.  In  particular,  this  will  open 
up  opportunities  for  new  types  of  energy  services, 
promote  business  activities  in  rural  areas,  and  help  find 
solutions for decentralised energy production. 

innovations  and 

investments 

The  shift  to  a  low-carbon  economy  is  a  high  priority  for 
ERDF  in  Finland:  instead  of  allocating  20 %  to  this 
thematic objective (the regulatory requirement), Finland 
has allocated 25 %. 

124 European Commission, European Structural and Investment Funds 
Data By Country 

27 

 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

Rural development 

The rural development programme for mainland Finland 
outlines  Finland’s  priorities  for  using  around  EUR 5.7 
billion  of  public  money.  Of  this  package,  28 %  will  go 
toward  agri-environment  climate  measures  (EUR  1.6 
billion)  while  other  environmentally  focused  measures 
such  as  organic  farming  will  receive  about  6 %  of  the 
overall package (EUR 333 million). 

For  example,  Finland  has  recently  focused  on  the 
prevention  of  extensive  forest  damage  caused  by 
damaging  agents  already  existing  in  Finland  in  order  to 
provide  compensation  to  the  silviculture  and  forestry 
sector.  The  aim 
is  to  help  maintain/restore  forest 
ecosystems and biodiversity  or the traditional landscape 
after damage or deterioration to the growth or quality of 
trees  in  Finland’s  forests  caused  by  invertebrates,  fungi, 
bacteria  or  viruses.  This  scheme  focuses  on  supporting 
the use of biological pesticides and not chemically based 
substitutes that are more severe. 

European Maritime and Fisheries Fund 

Finland’s  investment  package  for  its  maritime,  fisheries 
and  aquaculture  sectors  amounts  to  EUR 140.9 million, 
including EUR 74.4 million of EU funds. 

Finland’s sustainable ﬁshing operational programme aims 
to  promote  environmentally  sustainable, 
resource-
eﬃcient,  innovative,  competitive  and  knowledge-based 
involves  measures  and 
ﬁsheries.  The  programme 
investments  that  drive  proﬁtable  operations,  promote 
demand  for  ﬁsh,  increase  logistical  eﬃciency,  improve 
gear selectivity, approach maritime spatial planning from 
the perspective of ﬁsheries and improve the public image 
of the ﬁsheries sector by promoting dialogue and conﬂict 
management. 

innovation  programmes  for  sustainable 
Multiannual 
ﬁshing and the environmental restoration of ﬁsheries will 
be  launched  in  cooperation  with  stakeholders.  Working 
together, 
scientists  and 
environmental  experts  will  develop  methods  to  help 
ﬁshermen  adjust  to  operating  close  to  a  protected  seal 
population, for example. 

industry,  administrators, 

the  EMFF 

support  will 

sector  and  encourage 

For  aquaculture, 
target 
investments  that  promote  sustainable  growth  and 
the 
renewal  within 
the 
diversiﬁcation  of  production  and  a 
in 
environmental 
impact.  A  multiannual  research  and 
development  programme  will  operate  in  cooperation 
with  stakeholders.  International  cooperation  will  be 
reinforced  in  the  Baltic  Sea  region  and  with  the  Nordic 
countries. 

reduction 

The Connecting Europe Facility (CEF) 

The  CEF  is  a  key  EU  funding  instrument  developed 
investment  towards  European 
specifically  to  direct 

28 

transport,  energy  and  digital  infrastructure  to  address 
identified  missing  links  and  bottlenecks  and  promote 
sustainability. 

By  the  end  of  2017,  Finland  had  signed  agreements  for 
EUR 164 million for projects under the CEF Transport125. 

Horizon 2020 

Finland  has  benefited  from  Horizon  2020  funding  since 
the programme started in 2014. As of January 2019, 584 
participants  have  been  granted  a  maximum  amount  of 
the  Societal 
EUR 233.8  million 
for  projects 
with 
work 
Challenges 
environmental issues126 127.  

programmes 

dealing 

from 

In  addition  to  the  abovementioned  work  programmes, 
climate and biodiversity expenditure is present across the 
entire  Horizon  2020.  In  Finland,  projects  accepted  for 
funding  in  all  Horizon  2020  working  programmes  until 
December  2018  included  EUR  244  million  destined  to 
climate  action  (28.2 %  of  the  total  Horizon  2020 
contribution  to  the  country)  and  EUR  40  million  for 
biodiversity-related  actions  (4.7 %  of  the  Horizon  2020 
contribution to the country)128. 

LIFE programme 

The  LIFE  programme  is  the  EU’s  funding  instrument  for 
the  environment  and  climate  action.  Since  1992,  when 
the LIFE programme was launched, a total of 141 projects 
have  been  co-financed  in  Finland129.  Together,  they 
represent a total investment of EUR 268 million, of which 
EUR 124  million  from  the  EU.  Of  these  projects,  89 
focused  on  environmental  innovation,  51  on  nature 
conservation and 1 on information and communication. 

For  2014-2017,  the  EU  allocated  EUR 10  million 
in 
funding to Finnish projects130. The LIFE EconomisE project 
is  one  of  these  projects.  It  is  working  to  unlock  the 
investment  potential  for  a  resilient  low-carbon  building 
stock, with more than EUR 500 000 in EU funding131. 

125 European Commission, Investments in Finland, 2019, p. 1. 
126 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). A maximum grant amount is the maximum 
grant amount decided by the Commission. It normally corresponds to 
the requested grant, but it may be lower. 
127 i.e. (ii) Food security, sustainable agriculture and forestry, marine 
and maritime and inland water research and the bioeconomy; (iii) 
Secure, clean and efficient energy; (iv) Smart, green and integrated 
transport; and (v) Climate action, environment, resource efficiency and 
raw materials. 
128 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). 
129 European Commission, LIFE in Finland, 2017. 
130 Commission services based on data provided by EASME. 
131 European Commission, LIFE EconomisE. 

                                                                 
Environmental Implementation Review 2019 – Finland 

government 
totalled EUR 2.54 billion137. 

funding 

for  environmental  protection 

As it has been mentioned through the report, one of the 
challenges  for  Finland  is  to  ensure  that  environmental 
financing remains at an adequate level. Existent financial 
gaps 
in  nature  protection  are  delaying  the  correct 
implementation  of  EU  environmental  law  and  policies. 
Therefore,  ensuring  financial  resources  to  reduce  the 
implementation  gap  should  be  considered  as  a  priority 
for the country. 

2019 priority action 

 

Seize the funding possibilities for Natura 2000 under 
the  next  MFF,  including  in  relation  to  preventive 
measures  against  potential  damage  caused  by 
protected species. 

European Investment Bank 

The EIB loans in Finland amounted to over EUR 7.1 billion 
for  2013-2017.  In  2018  alone,  the  EIB  Group132  lent 
Finnish  businesses  and  public  institutions  more  than  1.9 
EUR  billion,  as  shown  in  Figure  22.  Of  this,  EUR 649 
million  (34 %)  were  directly  invested  in  environment-
related projects. 
Figure 22: EIB loans to Finland in 2018133 

European Fund for Strategic Investments 

The European Fund for Strategic Investments (EFSI) is an 
initiative to help overcome the current investment gap in 
the  EU.  By  January  2019,  the  EFSI  had  mobilised  more 
than  EUR 2.0  billion 
in  Finland,  and  the  secondary 
investment  triggered  by  those  funds  is  expected  to  be 
more than EUR 7.9 billion134. 

Funding  for  green  infrastructure  comes  from  the  overall 
framework  for  financing  biodiversity  conservation  in 
includes  dedicated  funding  for  nature 
Finland.  This 
funding  under  different  sectors 
conservation  and 
(agriculture,  forestry,  fisheries  etc.).  As 
in  all  EU 
countries, the funding is a blend of EU sources (e.g. rural 
development  programme  measures  under  the  common 
agricultural policy) and national sources. 

National environmental financing 

Finland 
spent  EUR 499  million  on  environmental 
protection in 2016, the same amount spent in 2015135. Of 
these  payments,  15 %  were  allocated 
for  waste 
management (EU average 49.7 %). EUR 175 million were 
allocated  for  pollution  abatement  (35 %  of  total).  Of 
Finland’s environmental expenditure, 14 % was allocated 
to  protect  biodiversity  and  the 
landscape  (EUR 70 
million)136.  Between  2012  and  2016,  the  general 

132 The EIB Group includes EIB and EFSI investments and loans. 
133 EIB, Finland and the EIB, 2018. 
134 European Investment Bank, EFSI project map. 
135 Eurostat, General Government Expenditure by function, 2018. 
136 No data is available on the funds used for waste water management. 

137 Eurostat, General Government Expenditure by function, 2018. 

29 

 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

5. 

Strengthening environmental governance 

efforts  are  needed  to  make  the  data  accessible  through 
services,  improve  the  conditions  for  data  reuse  and 
prioritise environmental datasets in the implementation. 
This  is  particularly  true  for  those  datasets  identified  as 
high-value  spatial  datasets  for  the  implementation  of 
environmental legislation145. 

Figure 23: Access to spatial data through view and 
download services in Finland (2017)  

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  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  business  that  environmental  information  is  shared 
efficiently  and  effectively138.  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 environment139. It includes the right to bring 
legal challenges (‘legal standing’)140. 

Environmental information 

Finland  has  an  interlinked  approach  for  the  provision  of 
the  Environmental  Information.  Finland’s  Environment 
administration  portal141  provides  all  environmental 
information.  Information  on  water  and  waste  can  be 
found  on 
the 
Environment.142  There  are  some  missing  datasets 
for  habitat,  water,  chemicals  and  waste 
however 
directives.  

the  Ministry  of 

the  portal  of 

Finland’s implementation of the INSPIRE Directive leaves 
room  for  improvement.  The  country’s  performance  was 
reviewed based on its 2016 implementation report143 and 
its most recent monitoring data from 2017144. Finland has 
made 
dataset 
in 
identification  and  documentation  of  data  and  has 
implementation.  Additional 
achieved  good 

good  progress 

coordination, 

levels  of 

138  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  2003/4/EC  and  the  INSPIRE  Directive  2007/2/EC  together 
create a legal foundation for the sharing of environmental information 
between  public  authorities  and  with  the  public.  This  EIR  focuses  on 
INSPIRE. 
139  The  guarantees  are  explained  in  Commission  Notice  on  access  to 
justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen’s Guide. 
140  This EIR  looks at  how  well  Member  States explain access  to  justice 
rights  to  the  public,  and  at  legal  standing  and  other  major  barriers  to 
bringing cases on nature and air pollution. 
141  The  Republic  of  Finland,  Joint  website  of  Finland’s  environmental 
administration.  
142 The Ministry of the Environment, web portal   
143 INSPIRE FI country sheet 2017. 
144 INSPIRE monitoring dashboard 

30 

Public participation 

In  Finland,  public  participation  is  generally  governed  by 
the  Administrative  Procedure  Act  (APA,  434/2003)146, 
which contains provisions on good administration and on 
the  procedure  applicable 
in  administrative  matters. 
Moreover,  the  Environmental  Protection  Act  (527/2014) 
and the Environmental Protection Decree (713/2014) and 
other  sector-specific  environmental  laws  ensure  that 
parties  involved  and  ‘other  persons’  can  submit  their 
statement  with  the  application  documents  during  the 
permit and decision-making procedure. In Finland, there 
is  also  a  well-established  practice  in  public  participation 
in legislative drafting.  

The  guidelines  on  consultation  when  drafting  legislation 
in  Finland  have  been  identified  as  good  practice  in  the 
Commission’s Better Regulation Toolbox147. 

Finland has an action plan on open government, which is 
encouraging  public  participation  across  the  board.  The 

145 List of high value spatial data sets 
146 E-Justice (2016), Access to Justice in Environmental Matters -Finland, 
14.9.2016. 
147 European Commission, the Commission’s Better Regulation Toolbox  

 
 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – Finland 

plan  includes  commitments  and  measures  to  promote 
openness and public participation. 148 
The  2017  Eurobarometer149  shows  that  in  Finland,  an 
overwhelming  majority  of  those  surveyed  (83 %  of 
respondents) strongly agree that an individual can play a 
role 
the  environment,  a  significant 
in  protecting 
improvement from 2014. 

Access to justice 

justice 

Finland  does  not  provide  clear,  user-friendly  online 
information  on  access  to 
in  environmental 
matters.  Finnish  law  appears  to  use  the  geographical 
location  or  mandate  of  an  individual  or  an  NGO  to 
determine whether or not they can bring legal challenges 
or  make  environmental  appeals  in  court,  thus  limiting 
their possibility to do so. For instance, the local branch of 
Friends  of  the  Earth  was  refused  legal  standing  for  an 
appeal  against  a  local  mining  permit  because  Friends  of 
the Earth’s mandate is global, not local. 

2019 priority actions 

 

Improve  access  to  spatial  data  and  services  by 
making  stronger 
linkages  between  the  country 
INSPIRE  portals  ,  identify  and  document  all  spatial 
datasets  required  to  implement  environmental  law, 
and  make  the  data  and  documentation  at  least 
accessible  'as  is'  to  other  public  authorities  and  the 
public  through  the  digital  services  envisaged  in  the 
INSPIRE Directive. 

  Better inform the public about their access to justice 
rights, notably in relation to air pollution and nature. 
Ensure that there is legal standing for individuals and 
environmental NGOs to bring legal  challenges on air 
pollution and nature. 

 

148 Avoin Hallinto  (2016), Open Government partnership: Finland’s self-
assessment report, P. 10,  
149 European Commission, 2017, Special 468 Eurobarometer, ‘Attitudes 
of European citizens towards the environment’. 

31 

Compliance assurance 

to  ensure 

Environmental compliance assurance covers all the work 
that 
undertaken  by  public  authorities 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste150.  It 
includes  support  measures  provided  by  the  authorities, 
such as:  
(i) compliance promotion151;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring152; and  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement153.  
Citizen  science  and  complaints  enable  authorities  to 
liability154 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring 

The  quality  of  online  information  to  farmers  on  how  to 
comply  with  obligations  on  nitrates  and  nature  is  an 
indicator of how actively authorities promote compliance 
in  subject-areas  with  serious 
implementation  gaps. 
Finnish  official  websites  lack  detailed  information  for 
farmers on how to comply with these obligations. 

Major  industrial  installations  present  serious  pollution 
risks.  Public  authorities  are  required  to  have  plans  to 
inspection 
inspect  them  and  must  make 
reports available to the public155. Finnish official websites 
fail to make this information available to the public. 

individual 

Citizen science and complaint handling 

Engaging  the  general  public,  including  through  citizen 
science,  can  deepen  people’s  knowledge  about  the 
environment  and  help  the  authorities  in  their  work. 
Citizen  science  is  used  for  biodiversity  in  Finland156.The 
availability  of  clear  online  information  about  how  to 
make  a  complaint  is  an  indicator  of  how  responsive  the 
authorities  are  to  complaints  from  the  public.  However, 
the  Finnish  authorities  do  not  provide  people  with  clear 

150  The  concept  is  explained  in  detail  in  the  Communication  on  ‘EU 
improve  environmental  compliance  and  governance’ 
actions  to 
COM(2018)10  and  the  related  Commission  Staff  Working  Document, 
SWD(2018)10. 
151 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
152 This EIR focuses on inspections of major industrial installations. 
153This  EIR  focuses  on  the  availability  of  enforcement  data  and  co-
ordination between authorities to tackle environmental crime. 
154  The  Environmental  Liability  Directive  2004/35/EC,  creates  the 
framework. 
155 Article 23, Industrial Emissions Directive 2010/75/EU. 
156  Luomus  (2016),  Seurantauutiset  kaikille  luonnosta  kiinnostuneille, 
4.4.2016. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – Finland 

online  information  about  how  to  file  an  environmental 
complaint. 

Enforcement 

When  monitoring 
identifies  problems,  a  range  of 
responses may be appropriate. The Finnish authorities do 
not  publish 
information  on  how  the  administration 
follows  up  on  reports  of  non-compliance.  Furthermore, 
no  information  is  published  on  responses  to  cross-
compliance breaches on nitrates and nature. Finland has 
produced  a  yearly  report  on  environmental  crime  since 
1998, with detailed statistics on environmental offences.  

is  especially  challenging. 

Tackling  waste,  wildlife  and  other  environmental 
offences 
It  requires  close 
cooperation  between  inspectors,  customs  authorities, 
police  and  prosecutors.  Finland  has  a  national-level 
working group for the coordination of preventative work 
against  Environmental  crime,  as  well  as  regional-level 
working  groups  (17  groups  all  around  the  country).  Co-
operation between authorities is done at these two levels 
and across working groups157. 

Environmental liability 

The  Environmental  Liability  Directive  (ELD)  establishes  a 
framework  based  on  the  ‘polluter  pays’  principle  to 
prevent  and  remedy  environmental  damage.  The  2017 
EIR 
information  on 
environmental  damage  and  on  financial  security  and 
guidance.  The  Commission  is  still  collecting  evidence  on 
progress made. 

focused  on  gathering  better 

2019 priority actions 

  Better inform the public about compliance promotion, 
monitoring  and  enforcement  by  at  least  ensuring  that 
the  following 
is  available  online:  (i) 
guidance  to  Finnish  farmers  on  how  to  comply  with 
obligations on nitrates and nature, (ii) inspection plans 
and reports on industrial inspections, and (iii) guidance 
on how to file environmental complaints  

information 

  Publish  information  on  the  outcome  of  administrative 
enforcement  action  and  the  follow-up  to  detected 
cross-compliance breaches on nitrates and nature; 

  Improve  financial  security  for 

liabilities  and  ELD-
guidance  and  publish  information  on  environmental 
damage. 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

environmental 
Those 
legislation at EU, national, regional and local levels need 
to have the knowledge, tools and capacity to ensure that 
the  legislation  and  the  governance  of  the  enforcement 
process bring about the intended benefits. 

Administrative capacity and quality 

Central, regional and local administrations must have the 
ability  to  carry  out  their  own  tasks  and  work  effectively 
with  each  other,  within  a  system  of  multi-level 
governance. 

In  order  to  ensure  effective  environmental  governance, 
environmental  administrations  have  to  have  staff  with 
the  appropriate  administrative  and  technical  knowledge 
and skills. With the 2017 EIR, the Commission introduced 
the  TAIEX-EIR  PEER2PEER  (P2P)  instrument  to  facilitate 
peer 
from  different 
environmental authorities of Member States. 

learning  between 

experts 

2018. 

There  participants 

An  expert  from  the  Finnish  Ministry  of  the  Environment 
participated in a TAIEX-EIR P2P workshop in Budapest on 
17-18 May 
the 
governments  of  Hungary,  the  Czech  Republic,  Slovakia 
and  Poland  received  advice  and  guidance  on  how  to 
prepare  a  national  circular  economy  action  plan  from 
government  experts  from  Finland,  the  Netherlands  and 
Slovenia  which  have  already  adopted  such  a  plan  or 
roadmap or are more advanced in the process. 

from 

Coordination and integration 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised Environmental Impact Assessment (EIA) Directive 
2014/52/EU into national law provides an opportunity for 
countries  to  streamline  their  regulatory  framework  on 
environmental assessments. 

Finland was late in transposing the Directive but recently 
submitted the complete legislation. 

the  streamlining 

in  environmental  assessments 

The  Commission  encourages 
the 
environmental  assessments  to  reduce  duplication  and 
for 
avoid  overlaps 
projects.  Streamlining  helps  to  reduce  unnecessary 
administrative  burden. 
It  also  accelerates  decision-
making,  without  compromising  the  quality  of  the 
In  2016,  the 
environmental  assessment  procedure. 
Commission  published  guidance158  on  setting  up 

157 Yhteistyöryhmä (2018), Ympäristötorjunnan toimenpideohjelma 
vuosille 2017-2018.  

158 Commission notice — Commission guidance document on 
streamlining environmental assessments conducted under Article 2(3) 
of the Environmental Impact Assessment Directive (Directive 

32 

                                                                 
                                                                 
 
Environmental Implementation Review 2019 – Finland 

and/or 

joint  procedures 

are 
coordinated 
simultaneously  subject  to  assessments  under  the  EIA 
Directive,  the  Habitats  Directive,  the  Water  Framework 
Directive, and the Industrial Emissions Directive. 

that 

Adaptability, 
(eGovernment) 

reform 

dynamics 

and 

innovation 

On digital public services, Finland is ranked best in the EU 
with  a  score  of  78.6/100  based  on  Europe's  Digital 
Progress  Report  2018,  well  above  the  EU28  average 
(57.5/100)159.  

Finland is one of the EU countries with the highest online 
interaction  between  public  authorities  and  citizens.  In 
July  2017,  the  eGovernment  portal  Suomi.fi  was 
revamped, merging the former Suomi.fi portal for citizens 
and  Suomi.fi  Workspace  pages  for  authorities’  services, 
while the activities of EnterpriseFinland.fi were added by 
the  end  of  2017.  It  now  provides  the  possibility  for 
citizens  to  get  to  know  their  own  information  in  the 
authorities’  registers.  Consequently,  Finland  performed 
much  better  than  the  previous  year  for  open  data  at 
90/100 compared to 76/100 the previous year according 
to Europe's Digital Progress Report 2018160. 

Enabling financing and effective use of funds 

The  Finnish  authorities,  at  national  and  regional  level, 
have  a  good  experience  in  the  management  of  EU 
funding and no major problems arise in this respect.  

2019 priority action 

  Finland 

can 
environmental governance. 

further 

improve 

the 

overall 

International agreements 

The  EU  Treaties  require  the  EU  environmental  policy  to 
promote  measures  at  international  level  to  deal  with 
regional or worldwide environmental problems. 

The EU is committed to strengthening environmental law 
and its implementation globally. It therefore continues to 
support  the  Global  Pact  for  the  Environment  process, 
which  was  launched  by  the  United  Nations  General 
Assembly  in  May  2018161.  The  EIR  is  one  of  the  tools  to 
ensure  that  the  Member  States  set  a  good  example  by 

2011/92/EU of the European Parliament and of the Council, as 
amended by Directive 2014/52/EU). 
159 European Commission, Europe's Digital Progress Report (EDPR) 2018 
Country Profile Finland, p. 10. 
160 European Commission, Europe's Digital Progress Report (EDPR) 2018 
Country Profile Finland, p. 10. 
161 UN General Assembly Resolution 72/277 and Organizational session 
of the ad hoc open-ended working group.  

33 

respecting  European  Union  environmental  policies  and 
laws and international agreements.  
 Forests:  EU  Timber  Regulation  (EUTR)162/  Forest  Law 
(FLEGT) 
Enforcement,  Governance 
Regulation163 

Trade 

and 

Between  March  2015  and  February  2017,  Finland 
performed 20 checks on operators that were planned for 
domestic  timber  and  32  checks  for  imported  timber 
instead of the 30 initially planned. In general, the number 
of  checks  remains  low  compared  to  the  estimated 
number of operators placing timber on the EU market for 
the first time in Finland164. Of the 30 notices of remedial 
action that the Finnish authorities imposed on operators 
importing 
to  have  an 
inappropriate due diligence system, only four resulted in 
injunctions. 

timber  who  were 

found 

On cooperation (Article 12, EUTR), the Finnish authorities 
reported  that  they  cooperated  with  EU  and  non-EU 
institutions,  particularly  with  authorities  in  the  United 
States and with non-governmental organisations (NGOs). 
Finland is also a member of the Nordic Baltic cooperation 
network. 

Genetic  resources:  Nagoya  Protocol  on  Access  to 
Genetic Resources and the Fair and Equitable Sharing of 
Benefits Arising (ABS)165  

into  the  EU 

In  accordance  with  the  EU  ABS  Regulation,  which 
legal  order  the  required 
transposes 
compliance measures under the Nagoya Protocol, Finland 
designated competent authorities and enacted sanctions 
for  infringements  of  the  EU  ABS  Regulation.  No  due 
diligence  declaration  has  been  submitted  so  far,  and  no 
penalties  have  been  applied.  Finland  submitted  its  first 
report  to  the  Commission  on  applying  the  EU  ABS 
Regulation (end of 2017). 

International  wildlife 
the  Convention  on 
trade: 
International  Trade  in  Endangered  Species  of  Wild 
Fauna and Flora (CITES)166 

Finland has established relevant national authorities and 
is  regularly  processing  (requests  for)  documents  for 
importing,  (re-)  exporting  and  intra-EU  trade.  This  is 

162 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010 
163 Regulation (EC) No 2173/2005. 
164 On the basis of customs data, it was estimated that 350’000 Finnish 
operators placed domestic timber on the EU market, and 2’000 
imported timber. 
165 Regulation (EU) No 511/2014 of the European Parliament and of the 
Council of 16 April 2014 on compliance measures for users from the 
Nagoya Protocol on Access to Genetic Resources and the Fair and 
Equitable Sharing of Benefits Arising from their Utilisation in the Union 
Text with EEA relevance. 
166  The  Convention  on  International  Trade  in  Endangered  Species  of 
Wild Fauna and Flora (CITES). 

                                                                                                        
                                                                 
Environmental Implementation Review 2019 – Finland 

A key policy document for sustainable development (The 
Finland  We  Want  by  2050  —  Society’s  Commitment  to 
Sustainable  Development)  was  adopted  in  2013.  The 
document  was  updated  in  April  2016  to  be  in  line  with 
the  2030  Agenda  for  Sustainable  Development  (Agenda 
2030). 

The  Prime  Minister’s  Office  is  in  charge  of  coordinating 
the  country’s  national  sustainable  development  policy 
and is responsible for implementing and drawing up the 
national implementation plan for Agenda 2030. 

In  addition  to  the  National  Commission  on  Sustainable 
Development,  Finland  has  a  Sustainable  Development 
Expert  Panel  comprising  eminent  professors 
from 
different  disciplines.  The  Panel  challenges  and  enhances 
the  work  of  the  National  Commission  on  Sustainable 
Development. 

In 2016, Finland was one of the first four EU countries to 
submit  a  Voluntary  National  Review  on  the  SDGs  to  the 
UN. According to Finland’s Review, incorporating Agenda 
2030 into national budget planning is a key precondition 
for  its  successful  implementation  in  the  country.  The 
government  aims  to  identify  short  and  medium-term 
objectives  that  are  tangible  for  inclusion  in  the  budget 
planning  of  Finland’s  various  administrative  branches. 
Each  administrative  branch  should  incorporate  these 
objectives  in  its  budget  proposals,  as  these  proposals 
form  the  basis  for  preparing  the  national  budget.  In  the 
public  sector,  implementation  of  Agenda  2030  will  also 
require  budgeting  for  objectives  across  administrative 
branches169.  The  ministries  reported  (*update)  for  the 
first  time  in  August  2018  how  the  broader  issues  of  the 
SDG  implementation  are  progressing.  The  inclusion  of 
SDG  implementation  in  the  budget  is  planned  for  2019 
170. 

pursuant  to  the  obligations  laid  down  in  the  Basic 
Regulation167,  which 
involve  transposing  the  major 
obligations  of  the  Convention  on  International  Trade  in 
Endangered Species of Wild Fauna and Flora (CITES) into 
EU  law.  Reports  on  seizures  of  illegal  shipments,  in 
particular  those  reported  every  6  months  to  TRAFFIC 
under  its  contract  with  the  Commission,  and  those 
exchanged  through  the  EU-TWIX  platform,  testify  to  the 
activity of the customs authorities. 

To ensure full implementation of the EU’s wildlife action 
plan  (2016)  and  improve  the  rate  of  detection  of  illegal 
activities,  Finland  reported  on  specific  training  courses 
organised  for  enforcement  agencies,  especially  custom 
officers  to  develop  their  knowledge  of  EU  wildlife 
regulations.  Some  of  the  training  courses  have  been 
incorporated  into  the  general  curriculum  on  criminal 
activities, especially in police academies. Finland has also 
been  financially  supporting  programmes  against  wildlife 
through 
trafficking. 
its 
this 
through  a 
development  cooperation  policy,  e.g. 
in  Laos, 
multiannual  project  against 
conducted jointly with the World Bank. 

It  has  been  doing 

logging 

illegal 

Sustainable 
implementation of the UN SDGs 

development 

and 

the 

Sustainable development links environmental, social and 
economic policies in a coherent framework and therefore 
legislation  and 
helps  to 
policies. 

implement  environmental 

strategy 

in  domestic  policies  and 

Finland  has  a  long  tradition  of  promoting  sustainable 
in 
development  both 
international  development  cooperation168.  The  country 
has 
implemented  various  sustainable  development 
programmes  since  the  mid-1990s.  In  2006,  Finland 
adopted  a 
for 
comprehensive  national 
sustainable  development  (Towards  Sustainable  Choices. 
A  Nationally  and  Globally  Sustainable  Finland).  It  was 
prepared  by  the  Finnish  National  Commission  on 
Sustainable  Development.  The  National  Commission  has 
a  broad  membership  that  includes  approximately  90 
organisations  from  civil  society,  industry,  business,  the 
labour  market  and  the  educational  world.  The  National 
Commission  also  has 
the 
government,  parliament,  ministries,  local  and  regional 
organisations, 
the  Evangelical  Lutheran  Church  of 
Finland,  the  indigenous  Sámi  people  and  other  public, 
private  and  third  sector  stakeholders.  The  Prime 
Minister’s Office acts as the Coordination Secretariat. 

representatives 

from 

167 Council Regulation (EC) No 338/97. 
168 European Sustainable Development Network, Single country profile: 
Finland. 

169 Prime Minister’s Office (2017), National report on the 
implementation of the 2030 Agenda for Sustainable Development. 
Finland, 10/2016.  
170 Finnish Government, Kestävän kehityksen toimintaohjelma Agenda 
2030 etenee, 19.12.2017.  

34