COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019 Country Report - THE NETHERLANDS Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2019: A Europe that protects its citizens and enhances their quality of life
Date: 2019-07-31
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Netherlands, 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, 31.7.2019  SWD(2019) 133 final/2  CORRIGENDUM This document corrects document SWD(2019) 133 final of 04.04.2019 Footnote 104 modified The text shall read as follows: COMMISSION STAFF WORKING DOCUMENT The EU Environmental Implementation Review 2019        Country Report - THE NETHERLANDS                 Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 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) 134 final} - {SWD(2019) 135 final} - {SWD(2019) 136 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. 
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1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
©European Union, 2019 

Reproduction is authorised provided the source is acknowledged. 

2 

 
 
Table of Contents 

EXECUTIVE SUMMARY ........................................................................................................................ 4 

PART I: THEMATIC AREAS .................................................................................................................... 5 

1.  TURNING THE EU INTO A CIRCULAR, RESOURCE-EFFICIENT, GREEN AND COMPETITIVE LOW-CARBON 
ECONOMY ........................................................................................................................................... 5 

Measures towards a circular economy ............................................................................................... 5 
Waste management ............................................................................................................................ 9 
Climate change .................................................................................................................................. 10 

2. PROTECTING, CONSERVING AND ENHANCING NATURAL CAPITAL ................................................... 13 

Nature and biodiversity ..................................................................................................................... 13 
Maintaining and restoring ecosystems and their services ................................................................ 14 
Estimating natural capital ................................................................................................................. 15 
Invasive alien species ........................................................................................................................ 16 
Soil protection ................................................................................................................................... 16 
Marine protection ............................................................................................................................. 17 

3. ENSURING CITIZENS’ HEALTH AND QUALITY OF LIFE ....................................................................... 19 

Air quality .......................................................................................................................................... 19 
Industrial emissions ........................................................................................................................... 20 
 ............................................................................................................................................... 21 
Noise 
Water quality and management ....................................................................................................... 22 
Chemicals .......................................................................................................................................... 24 
Making cities more sustainable ......................................................................................................... 26 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ........................................................... 29 

4. GREEN TAXATION, GREEN PUBLIC PROCUREMENT, ENVIRONMENTAL FUNDING AND INVESTMENTS    
 .......................................................................................................................................................... 29 

Green taxation and environmentally harmful subsidies ................................................................... 29 
Green public procurement ................................................................................................................ 30 
Environmental funding and investments .......................................................................................... 31 

5. STRENGTHENING ENVIRONMENTAL GOVERNANCE ........................................................................ 36 

Participation, information and access to justice ............................................................................... 36 
Compliance assurance ....................................................................................................................... 37 
Effectiveness of environmental administrations............................................................................... 39 
International agreements ................................................................................................................. 41 
Sustainable development and the implementation of the UN SDGs ................................................ 42 

3 

 
 
Environmental Implementation Review 2019 – the Netherlands 

Executive summary 

and 
Netherlands 
The 
Implementation Review (EIR) 

the 

Environmental 

In  the  2017  EIR,  the  main  challenges  identified  with 
regard  to  implementation  of  EU  environmental  policy 
and law in the Netherlands were:  

 

 

improving  water  quality,  in  particular  regarding 
nutrient concentrations in surface waters;  
the 
improving 
concentrations  of  nitrogen  dioxide  and  ozone  to 
prevent premature deaths; and  

particular 

quality, 

air 

in 

  optimising the contribution of the Natura 2000 and 
the  national  ecological  networks  to  achieve  good 
conservation 
reduce  habitat 
fragmentation  and  biodiversity  loss,  atmospheric 
nitrogen deposition, desiccation and acidification. 

status,  and 

to 

The Netherlands organised an EIR dialogue in April 2018 
focusing  on  air  and  water  quality,  the  circular  economy 
and green public procurement. The event confirmed the 
authorities’ commitment to tackling the main gaps in the 
implementation  of  EU  environmental  legislation  and  go 
further in some areas, such as tackling water pollution by 
pharmaceutical  products.  The  ‘bilateral  dialogue  on  the 
action  plan  for  nature,  people  and  the  economy’  in 
October 2018 was further proof of this commitment. 

In 2017, the Commission launched the TAIEX-EIR Peer-to-
Peer (EIR P2P), as a new practical tool facilitating peer-to-
peer  learning  between  environmental  authorities.  As  of 
January 2019, the Netherlands had participated in six P2P 
events  on  different  topics,  including  air  pollution  and 
circular economy. 

Progress on meeting challenges since the 2017 EIR 

The  2019  EIR  shows  that  for  water  quality  there  has 
been  some  progress  in  reducing  nutrient  concentration 
and  eutrophication.  Nitrate  pollution  remains  a  major 
concern  despite  the  efforts  made  by  the  Dutch 
government  through  the  national  action  programme  for 
nitrates.  A  derogation  for  nitrogen  from  livestock  has 
been granted on a series of conditions, including limits to 
phosphate  production  and  an  enhanced  enforcement 
strategy 
improper  animal 
registration.  However,  continued  progress  is  needed  to 
achieve full compliance.  

to  address, 

inter  alia, 

For  air  quality,  there  has  been  some  progress  on 
reducing  the  number  of  non-compliant  areas.  However, 
air  quality  is  still  cause  for  concern:  in  2015,  there  were 
1 900 premature deaths attributable to nitrogen dioxide, 
9 800  to  fine  particulate  matter  concentrations,  and  an 
additional  290  to  ozone  concentration.  The  steady 

in  previous  years  has  continued. 
decrease  seen 
Innovative  solutions  to  reduce  traffic  congestion  are 
being  tested  in  a  number  of  cities.  They  are  helping  to 
reduce  the  use  of  older  diesel  cars,  which  will  have  a 
positive impact on air pollutants. The national strategy on 
air  quality  and  the  national  air  quality  cooperation 
programme  will  be  key 
instruments  to  reduce  air 
pollution in the country. 

is 

still 

there 

considerable 

Regarding nature conservation, some progress has been 
made  to  improve  the  status  of  species  and  habitats. 
However, 
for 
fragmentation,  atmospheric 
improvement.  Habitat 
nitrogen  deposition,  desiccation  and  acidification  affect 
the Natura 2000 network,  which  is still  smaller than the 
EU  average.  In  addition,  farmland  bird  populations 
to  experience  significant  decline  despite 
continue 
national protection measures. 

room 

The  Netherlands continues to be efficient  in making  use 
of EU funds and loan opportunities. The country is also a 
model to follow on national green funding, thanks to the 
use of ‘green deals’.  

Examples of good practice 

 

Circular  economy  actions  continue  to  play  an 
important role. The country is an example of public-
private partnership and the best performer in terms 
of  resource  productivity.  Small  businesses  are 
becoming increasingly circular and the recycling rate 
for municipal waste is among the highest  in the EU. 
The  programme 
the 
Netherlands by 2050’ is one of the most far-reaching 
in the EU. 

‘A  circular  economy 

in 

  Green  public  procurement 

already 

exceeds 
Commission recommendations. The Netherlands has 
several  circular  procurement  practices  in  place  and 
the  ‘green  deal’  programme  has  begun  with  a 
number  of  pilots  and  guidance  for  functional 
specifications. 
The  Netherlands  is  making  good  use  of  green  tax 
instruments  to  tackle  climate  and  environmental 
problems.  Several  subsidies  and  exemptions  for 
petroleum  and  natural  gas  have  been  removed  in 
recent  years  and  CO2-based  taxes  are  becoming 
more common. 
Environmental  authorities  are 
jointly  making 
information  on  environment  and  health  available 
through  the  portal  Atlas  Living  Environment  (Atlas 
Leefomgeving) in the form of searchable maps. 

 

 

4 

 
 
 
Environmental Implementation Review 2019 – the Netherlands 

Part I: Thematic areas 

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

competitive low-carbon economy 

Measures towards a circular economy 

greater  EU  investment  in  environmental  protection  (EU-
28: 85 %). 

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. 

The  EU’s  circular  economy  monitoring  framework  tracks 
key  trends  and  patterns  to  understand  how  the  various 
parts  of  the  circular  economy  are  developing  and 
whether sufficient action has been taken. 

Circular  (secondary)  use  of  materials  in  the  Netherlands 
stood at 29 % in 2016, a remarkable share compared with 
the  EU-28  average  of  11.7 %3.  By  contrast, 
the 
Netherlands performed slightly below the EU-28 average 
for  the  number  of  persons  employed  in  the  circular 
economy (at 1.19 % of total employment in 2016, against 
an EU-28 average of 1.73 %)4. 

There is clear support for circular economy initiatives and 
environmental  protection 
and 
government. 

in  both 

society 

Citizens  seem  aware  of  the  problems  of  a 
linear 
economy5.  In  2017,  81 %  of  Dutch  citizens  expressed 
concern  about  the  effects  of  plastic  products  on  the 
environment (EU-28: 87 %), and 83 % about the impact of 
chemicals  (EU-28:  90 %).  Moreover,  88 %  supported 

1 European Commission, 2018 Circular Economy Package. 
2 COM(2018) 029. 
3 European Commission, Circular material use rate. This indicator 
measures the share of material recovered and fed back into the 
economy. 
4 European Commission, Indicators for the Circular Economy Monitoring 
Framework, 2018. 
5 European Commission, Special 486 Eurobarometer ‘Attitudes of 
European citizens towards the environment’, 2017. 

5 

followed 

In  addition,  the  Netherlands  was  one  of  the  first  EU 
countries  to  present  a  circular  economy  programme 
(2014), 
the 
comprehensive  programme  ‘A  circular  economy  in  the 
Netherlands  by  2050’6.  The  country  is  in  many  cases 
leading by example and partnering up to push circularity 
in the EU7. 

September 

2016  by 

in 

the 
The  2017  Coalition  Agreement 
government’s  commitment  to  transition  towards  a 
circular economy. It also promised to identify bottlenecks 
to  sustainable  innovation  in  legislation,  supervision  and 
enforcement, and see whether these can be resolved8. 

reaffirmed 

All national policy efforts related to the circular economy 
are captured in the action plan ‘From waste to resource’ 
(the VANG programme), covered in the 2017 EIR. 

Since  2017,  the  government  has  built  the  circular 
economy  into  its  climate  action  plans.  According  to 
various  studies,  the  2016  circular  economy  programme 
impact  on  the  reduction  of 
could  have  a  decisive 
greenhouse  gas  (GHG)  emissions  by  2050.  Plastics  reuse 
and  recycling  could  account  for  28 %  of  emissions 
reduction, while biomass and food circular actions might 
add up to around 35 %9. 

(CBS), 

New  developments  are  expected 
in  the  way  the 
Netherlands  deals  with  measuring  progress  towards  a 
circular  economy.  In  January  2018  three  government 
agencies called for a  new monitoring system10. Statistics 
Netherlands 
the  Netherlands  Environmental 
Assessment  Agency  (PBL)  and  the  National  Institute  for 
Public  Health  and  the  Environment  (RIVM)  proposed  to 
go  further  than  the  Commission’s  circular  economy 
monitoring  framework,  to  address  whether  all  activities 
that stakeholders need to carry out are on schedule. The 
Dutch  government  will  reply  to  this  with  a  monitoring 

6 Government of the Netherlands, A Circular Economy in the 
Netherlands by 2050, 2016. 
7 Speech by the State Secretary for Infrastructure and Water 
Management Stientje van Veldhoven at the seminar ‘Luxembourg and 
the Netherlands: Together on the way to a circular economy’, 24 May 
2018. 
8 Government of the Netherlands, Coalition Agreement 'Confidence in 
the Future’, 10 October 2017, p. 50. 
9 TNO, Effecten van het Rijksbrede Programma Circulaire Economie en 
de Transitieagenda’s op de emissie van broeikasgassen, pp. 22-24. 
10 ENDS Europe, Dutch agencies call for a circular economy monitoring, 
22 January 2018. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

report on “guidance, progress, environmental and socio-
economic  effects  in  the  Circular  Economy”  that  will  be 
published by the beginning of 2020. 

All in all, the Netherlands can be considered a  model of 
public-private  partnership  to  achieve  a  more  circular 
economy.  Several  projects  have  been  financed  and 
successfully implemented in recent years. 

The  Pension  Fund  for  Civil  Servants  (ABP),  the  largest 
Dutch pension fund, adopted a new policy for sustainable 
investment  in  2015  and  has  continued  its  environment-
friendly approach. In 2017 alone, the ABP cut the level of 
CO2  emissions  in  its  equity  portfolio  by  7  million  tonnes 
(the  annual  emissions  of  2.8  million  cars),  while  its 
investment in renewable energy rose by 25 %11. 
Nitrates and the circular economy12 13 

Current  manure  policy  costs  about  EUR 350  million,  but 
increases  welfare  by  around  EUR 2  billion  when  the 
benefits  for  nature  and  health  are  included  in  the 
calculations14.  Because  the  amount  of  manure  that  is 
produced is more than can applied on the land, farmers, 
unless  they  give  in  to  fraud,  are  forced  to  dispose  the 
surplus  manure  either  via  direct  exports  or  processing. 
Both are costly, implying that intensive livestock farmers 
have  to  pay  to  get  rid  of  manure:  the  marginal  value  of 
manure  as  a  fertiliser  in  the  Netherlands  is  therefore 
negative.  

Newly  developed  manure-processing  technologies,  such 
as  one  developed  by  the  EU-funded  project  BioEcoSIM, 
may  reduce  the  cost  of  the  manure  policy  with  benefits 
for the circular economy. A study has estimated that with 
the  current  policy  and  economic  circumstances,  if  all 
Dutch  pig  manure  went 
like 
BioEcoSIM’s  and  cost  estimates  are  correct,  this  would 
increase  GDP  by  EUR 15  million  and  reduce  the 
environmental  costs  of  greenhouse  gas  emissions  and 
particulate matter formation by about EUR 75 million15. 

through  a  process 

The  LIFE-granted  project  REBUS  aims  to  secure  more 
resource-efficient business models. After a trial phase in 
the  United  Kingdom  and  the  Netherlands,  more  than 
62 000  tonnes  of  materials  have  been  saved.  Scaling  up 
the  benefits  could  result  in  184  million  tonnes  of  direct 

11 Pensioenfonds voor overheid en onderwijs, ABP on course with 
sustainable investments. 
12 Woltjer, G. & Smits, M., 2018. Phosphorus Recycling from Manure, 
CIRCULAR IMPACTS project. 
13 PBL, 2017. Evaluatie Meststoffenwet 2016: Syntheserapport. 
14 Van Grinsven, H.J.M., Tiktak, A. & Rougoor, C.W., 2016. Evaluation of 
the Dutch implementation of the nitrates directive, the water 
framework directive and the national emission ceilings directive. NJAS 
— Wageningen Journal of Life Sciences, 78, pp.69-84.  
15 Van Grinsven, H.J.M., Tiktak, A. & Rougoor, C.W., 2016. Evaluation of 
the Dutch implementation of the nitrates directive, the water 
framework directive and the national emission ceilings directive. NJAS 
— Wageningen Journal of Life Sciences, 78, pp.69-84. 

material  savings  and  172  million  tonnes  of  materials 
diverted (e.g. to reuse and recycling) in the EU16. 

The Dutch system of collection of domestic medicines is 
another good example of how circularity can be applied 
to  almost  every  economic  sector.  The  Royal  Dutch 
Pharmacists  Organisation  (KNMP)  states  that  more  than 
140 tonnes of waste medicine ends up in surface waters. 
KNMP  is  reducing  the  amount  of  leftover  medication 
ending up in the environment through initiatives such as 
medicine use monitoring and incentives for a new waste 
collection  system 
in  pharmacies.  The  number  of 
municipalities making pharmacies pay for waste medicine 
fell from 45 % in 2016 to 10 % in 201817. 

The  Netherlands,  Belgium,  France  and  the  United 
Kingdom participate in the Nereus project, funded by the 
EU  through  its  European  Regional  Development  Fund 
(ERDF)  programme  Interreg  2  Seas.  The  aim  is  to  boost 
the  development  of  the  green  economy  and  the 
transformation  of  wastewater  into  a  valuable  source  of 
water,  resources  (e.g.  cellulose  and  nutrients)  and 
energy.  In  June  2018,  the  first  pilot  location  officially 
opened in Rotterdam to create as much value as possible 
from  domestic  waste  water  after  it  is  collected  and 
processed18. 

The  ‘green  deals’  continue  to  be  one  of  the  most 
innovative  ways  of  overcoming  obstacles  to  green 
developments.  On  7 June 2018,  a  new  green  deal  on 
circular procurement was signed by 50 public and private 
organisations  and  companies,  adding  up  to  EUR 100 
million in purchasing power19. The initiative is open to all 
organisations keen on circular purchasing. 

Besides  these  examples,  the  Netherlands  is  the  best 
performer  in  the  EU  in  terms  of  resource  productivity 
(how efficiently the economy uses material resources to 
produce  wealth)20,  at  EUR 4.2/kg 
(EU: 
EUR 2.04/kg).  Figure  1  shows  a  gradual  increase  since 
2008, with a temporary decline between 2013 and 2015, 
and  a  significant  increase  in  2016.  The  main  reasons  for 
this  good  performance  are  the  slowdown  of  fossil  fuel 
for  non-metallic 
falling  demand 
consumption  and 
minerals due to increasing reuse and recycling rates21. 

in  2017 

16 Wrap UK and Dutch Ministry of Infrastructure and the Environment, 
the REBus Project, December 2017, p. 6. 
17 EIR Dialogues, Summary Country Dialogue Netherlands 12 April 2018. 
18 Nereus Project, First Nereus demo case officially opened in 
Rotterdam. 
19 Green Deal, Circulair inkopen 2.0. 
20 Resource productivity is defined as the ratio between gross domestic 
product and domestic material consumption. 
21 European Environment Agency, More from less — material resource 
efficiency in Europe (Dutch report), 2017; and Government of the 
Netherlands, A Circular Economy in the Netherlands by 2050, 2016. 

6 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

Figure 1: Resource productivity 2010-201722 

Figure 2: Environmental performance of SMEs26 

Furthermore, 
the  Netherlands  employed  132 008 
workers  in  the  environmental  goods  and  services  sector 
in 2015, slightly up from 201223. 

The  Netherlands’  performance  should  be  seen  as  an 
example  for  other  countries  of  the  effect  of  policies  to 
improve resource productivity, although its high  level of 
imported  raw  materials  remains  a 
dependence  on 
concern. 

The  many  positive  developments  and  achievements 
leave,  however,  scope  for  stepping  up  circular  economy 
activities.  The  value  added  of  the  environmental  goods 
and  services  sector  is  increasing,  but  more  slowly  than 
might be expected from a strong service-based economy 
like  the  Netherlands  (to  2.45 %  of  GDP  in  2015,  from 
2.44 % in 2014)24. 

There  are  still  a  number  of  barriers  to  promoting 
innovation in the circular economy. These require greater 
recognition  that  transitioning  to  a  circular  economy 
innovation:  technological, 
needs  different  forms  of 
financial 
(working 
(business  cases),  organisational 
methods)  and  social  (focused  on  cooperation  and 
teamwork)25. 

SMEs and resource efficiency 

regard 

The  Commission’s  annual  SME  performance  review  for 
2018 showed the general situation of small businesses in 
the  Netherlands  with 
to  environmental 
performance  (see  Figure  2).  These  companies  were 
above  the  European  average  in  green  turnover  (green 
products  or  services  accounted  for  more  than  50 %  of 
turnover in 23 % of Dutch SMEs) and in public funding for 
resource efficiency actions. On the other hand, they were 
below  the  EU  average  only  in  public  sector  support  for 
production of green products. 

22 Eurostat, Resource productivity. 
23 Eurostat, Employment in the environmental goods and services 
sector. 
24 CBS, Green Growth 2018 . 
25 European Commission, European Semester Country Report for the 
Netherlands, 2018, p. 51. 

and 

showed 

In  2018,  the  latest  Eurobarometer  on  ‘SMEs,  resource 
green  markets’ 27 
efficiency 
new 
developments  on  some  of  the  main  indicators.  37 %  of 
Dutch  SMEs  are  currently  offering  green  products  and 
services  (up  from  27 %  in  2015).  20 %  of  the  companies 
surveyed  (EU  average  of  14 %)  said  that  green  products 
or services accounted for more than 75 % of their annual 
turnover for the latest available fiscal year. Although only 
35 %  of  Dutch  SMEs  have  employees  working  in  green 
jobs  (25 %  in  2015,  EU-28  average:  40 %),  the  average 
number  of  green  employees  within  these  companies  is 
6.2,  much  higher  than  the  EU  average  of  4.7.  Finally, 
public 
to  be 
acknowledged, as 87 % of ‘green’ SMEs are satisfied with 
the  assistance  provided  by  the  public  sector  (EU-28: 
58 %). 

for  SMEs 

support 

seems 

sector 

investment 

Nonetheless,  SMEs  reduced 
in  resource 
efficiency actions in the period 2015-2017 (51 % said they 
had invested up to 5 % of their annual turnover in 2017, 
against  62 %  in  2015),  although  the  figure  is  still  just 
above  the  EU  average  of  50 %.  That  slight  fall  might 
adversely  affect  the  Netherlands’  performance,  as  the 
country  relies  heavily  on  voluntary  agreements  and 
initiatives  to 
improve  resource  efficiency.  National 
policies  and  other  support  measures  are  not  enough, 

26 European Commission, 2018 SBA fact sheet - Netherlands, p.15 
27 Eurostat, Flash Eurobarometer 456: SMEs, resource efficiency and 
green markets, 2018. 

7 

 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

particularly for improving financing, supporting extended 
producer  responsibility,  encouraging  external  audits  and 
improving company accounting and reporting practices28. 

In any case, in recent years there has been an increasing 
number  of  public-funded  projects  to  increase  resource 
(an  environmental 
efficiency.  The  MIA 
investment 
rebate)  and  VAMIL 
(discretionary  depreciation  of 
environmental investments) are public schemes to grant 
tax  advantages  for  environment-friendly  products  and 
entrepreneurs  and  to  bring 
innovative  products  to 
market more rapidly29. 

The 2017 Coalition Agreement also included proposals to 
resource  efficiency30.  The  new 
improve  national 
Environment and Planning Act and the implementation of 
the  circular  economy  programme  and  the  transition 
agendas  set  out  in  the  Raw  Materials  Agreement  are 
good examples. 

EU  funding  can  also  contribute  to  companies’  resource 
efficiency. Most of the European funds and programmes 
connect  competitiveness,  innovation,  the  environment 
and  climate  in  one  way  or  another.  In  addition,  specific 
instruments  for  resource  efficiency,  such  as  the  Private 
Finance for Energy Efficiency (PF4EE) instrument and the 
European Energy Efficiency Fund, have been launched by 
the Commission, the European Investment Bank (EIB) and 
national investment banks31. 

These  measures  are  crucially  important  because  the 
Dutch economy depends on rare or critical materials and 
resources32.  According  to  the  Eurobarometer,  resource 
efficiency  actions  already  undertaken  have  helped  cut 
production costs in 30 % of the Netherlands’ SMEs (EU-28 
average  41 %).  So  small  businesses  have  yet  to  harness 
the full potential of resource efficiency. 

The  EIR  2017  suggested  action  to  “explore  the  full 
potential  of  resource  efficiency  measures  for  and  by 
SME” remains as priority action 2019, as there is scope to 
give  more  support  to  financing,  Extended  Producer 
Responsibility 
(EPR)  and  accounting  and  reporting 
practices. 

Eco-innovation 

The Netherlands has been a leader in EU innovation since 
at  least  the  1970s.  The  country  ranked  fourth  on  the 

28 Ecologic Institute, IEEP, BIO by Deloitte, 2015. A framework for 
Member States to support business in improving its resource efficiency. 
Study for the European Commission. 
29 Netherlands Enterprise Agency, Environmental subsidies and 
programmes. 
30 Government of the Netherlands, Coalition Agreement ‘Confidence in 
the Future’, 10 October 2017. 
31 European Commission. Improving resource efficiency in SMEs, 
December 2017, pp. 21-31. 
32 CBS, Monitor Duurzaam Nederland 2017. 

overall  European  Innovation  Scoreboard  2018,  and  was 
the  second  fastest  growing  innovator  (with  a  15.9 % 
increase  since  2010)33.  However,  it  ranked  only  14th  on 
the  eco-innovation  scoreboard  for  2017  as  shown  in 
Figure 3. 
Figure 3: 2017 Eco-innovation index (EU=100)34 

Since  2011,  the  Netherlands  has  seen  its  eco-innovation 
performance  decline,  from  112  points  to  a  low  of  88  in 
2017  (see  Figure  4),  mainly  due  to  poor  performance  in 
two  areas:  eco-innovation  activities  and  socioeconomic 
outcomes35. 
Figure 4: Dutch eco-innovation performance36 

The  Netherlands’  low  score  seems  to  contradict  its 
ambitious  sustainability  objectives;  eco-innovation  at 
national  level  may  need  to  be  improved.  At  local  and 
regional level, more progress has been made, particularly 

33 European Commission, European innovation Scoreboard 2018. 
34 European Commission Eco-innovation Observatory, Eco-Innovation 
scoreboard 2017, 2018. 
35 European Commission Eco-Innovation Observatory, EU Eco-
Innovation Index 2017 Brief, 2018. 
36 Authors based on the EU Eco-Innovation Index (see 27). 

8 

                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

on  sustainable  energy,  with  many  local  initiatives  and 
ambitious city projects. 

Other  barriers  to  eco-innovation  are  the  low  take-up  of 
ecolabel  licences  (only  1  100  products  registered  out  of 
71  707  in  the  EU,  compared  to  30 384  in  Spain)37  and 
limited use of eco-management and audit schemes (only 
fewer  EMAS  helpdesk 
Latvia  and  Malta  have 
organisations  and  sites)38. 
In  September  2018,  the 
Netherlands  had  1  100  products  and  83 
licences 
registered  with  the  EU  Ecolabel  scheme  and  only  two 
organisations 
in  EMAS.  Nevertheless,  some  national 
schemes  are  in  place,  such  as  the  Milieukeur,  the 
environmental quality label for products and services39. 

link 

is  an 

important 

On the other hand, the Netherlands has the  potential to 
be  a  frontrunner  and  testing  ground  for  the  circular 
economy for several reasons: with big harbours and good 
infrastructure,  the  country 
in 
international material flows and can therefore also play a 
part  in  the  flow  of  recycled  and  bio-based  materials. 
for 
Second, 
entrepreneurial  spirit  and  knowledge,  and  a  leading 
position  in  design  and  advanced  waste  management 
systems. Other important drivers of the circular economy 
are  opportunities  to  innovate,  attract  new  business, 
improve  the  environment  and  people’s  wellbeing,  and 
reduce dependency on external resources40. 

the  Netherlands  has  a 

reputation 

The  Netherlands  continues  to  do  well 
in  waste 
management  and  green  procurement,  with  the  green 
deal programme helping to launch several pilot projects. 
The  number  of  local  sustainable  energy  corporations 
increased to 392 in 2017. Together, they started 100 new 
collective solar energy projects. 

The ‘Make it Work’ project 

experts 

together 
for 

An  example  of  good  practice  is  the  ‘Make  it  Work’ 
to  produce 
project,  bringing 
recommendations 
keeping  EU  environmental 
legislation  and  implementation  practice  fit  for  purpose. 
Make 
is  on  enabling  eco-
the  circular  economy  under  EU 
innovation 
environmental legislation: specifically, turning waste into 
new secondary raw materials41. 

it  Work’s  current  focus 

for 

All  in  all,  to  overcome  the  eco-innovation  gap,  some  of 
the  main  indicators  in  the  index  need  to  improve.  For 
instance,  only  2 677  organisations  use  the  ISO 14001 
standard42  for  effective  environmental  management 

37 European Commission, Ecolabel Facts and Figures. 
38 European Commission, Eco-Management and Audit Scheme. 
39 Milieukeur, website. 
40 European Commission, Eco-Innovation Observatory, Country profile 
2016-2017: The Netherlands. 
41 EIR Dialogues, Summary Country Dialogue Netherlands 12 April 2018. 
42 International Organisation for Standardisation, ISO 14001:2015.  

9 

systems,  putting  the  Netherlands  in  11th  place  in  the 
EU43.  Employment  in  eco-industries  and  the  circular 
economy accounts  for only 1.17 % of total employment, 
against 1.71 % for the EU-2844. 

2019 priority action 

  Adopt  circular  economy  principles  that  act  as 
incentives  for  resource  efficiency  measures  and 
increased  recycling;  eco-innovation  performance; 
and investments in green products and services. 

Waste management 

Turning waste into a resource is supported by: 
(i) fully implementing EU waste legislation, which 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 
waste45  for  which  EU  law  sets  mandatory  recycling 
targets46. 

Figure  5  shows  that  the  amount  of  municipal  waste 
generated 
fell  slightly  between  2014  and  2017, 
continuing  the  downward  trend  of  previous  years. 
However, 
(at 
513 kg/y/inhabitant against 487 kg/y/inhabitant) and the 
decline has slowed (from 45 kg per capita between 2010 
and 2013 to 13 kg per capita between 2013 and 2017). 

the  EU  average 

is  still  above 

it 

On  the  very  positive  side,  the  recycling  rate  (including 
composting)  for  municipal  waste,  at  54 %  in  2017,  is 
higher  than  the  EU  average  of  46 %,  and  recycling 
remains the main form of treatment of municipal waste, 
while landfilling, at 1 %, is well below the EU average of 
24 %, as a result of landfill taxes and bans. 

Figure  6  shows  that  since  2013  the  Netherlands  has 
complied  with  the  EU  2020  municipal  waste  recycling 
target  of  50 %,  placing  the  country  among  the  best 
performers in the EU. 

43 International Organisation for Standardisation, ISO Survey of 
Certifications, 2016. 
44 Eurostat, Circular Economy Monitoring Framework, 2018. 
45 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. 
46 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. 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

Figure  5:  Municipal  waste  by  treatment 
Netherlands 2010-201747 

in  the 

part  to  ensure  that  by  2025  the  annual  volume  of 
residual  household  waste  is  no  more  than  30 kg  per 
capita (100 kg in 2020). By  2022, the volume of residual 
waste  from  companies,  organisations,  and  governments 
comparable to residual household waste must be halved 
(compared to 2012. In line with these operational goals, 
the  government  also  aims  to  reduce  the  amount  of 
residual  waste  incinerated/landfilled  from  10  million 
tonnes in 2012 to 5 million tonnes in 2022. 

Local and regional authorities are creating new networks 
on  waste-related 
issues,  mainly  to  support  plastic 
recovery  and  recycling.  Some  260  municipalities  within 
the Statiegeld Alliantie are calling for a deposit system for 
plastic  bottles51.  On  10 March 2018,  the  State  Secretary 
for  Infrastructure  and  Water  Management  announced 
that  a  deposit  on  small  plastic  bottles  would  be 
introduced 
industry 
managed to achieve 90 % recycling of throw-away bottles 
by  the  autumn  of  2020.  She  also  urged  the  packaging 
sector to reduce street litter by 70 to 90 %52. 

in  2021,  unless  the  packaging 

Figure 6: Recycling rate of municipal waste 2010-201748 

2019 priority actions 

 

 

including 

Introduce  new  policies, 
economic 
instruments,  to  promote  waste  prevention,  make 
reuse and recycling more economically attractive. 
Shift  reusable  and  recyclable  waste  away  from 
incineration. 

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.  

50 % reduction in the use of primary raw materials (from minerals, 
fossil fuels and metals) by 2030. 
51 Statiegeld Alliantie, Demand for deposit schemes continues to grow. 
52 Government of the Netherlands, Breakthrough in combating plastic 
soup (press release). 

However,  more  effort  will  be  needed  to  comply  with 
recycling  targets  for  the  post-2020  period49.  This  will  in 
particular  require  action  to  reduce  the  incineration  of 
municipal waste (44 % in 2017). 

To boost waste prevention and further increase recycling 
rates,  the  2016  programme  for  a  circular  economy  (A 
circular  economy  in  the  Netherlands  by  2050)50  aims  in 

47 Eurostat, Municipal waste by waste operations. 
48 Eurostat, Recycling rate of municipal waste. 
49 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. 
50 Government of the Netherlands, A Circular Economy in the 
Netherlands by 2050. The programme aims at developing a circular 
economy in the Netherlands by 2050. It sets an (interim) objective of a 

10 

 
 
                                                                 
 
                                                                                                        
Environmental Implementation Review 2019 – the Netherlands 

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  ‘effort  sharing’ 
legislation53.  The  Netherlands  had  lower  emissions  than 
its  annual  targets  in  each  of  the  years  2013-2017.  For 
2020,  the  Netherlands’  national  target  under  the  Effort 
Sharing  Decision 
is  to  reduce  emissions  by  16 % 
compared to 2005. For 2030, the target will be to reduce 
emissions by 36 % compared to 2005 (see Figure 8). 

Figure  7:  Change  in  total  GHG  emissions  1990-2017 
(1990=100 %)54. 

platforms:  built  environment,  industry,  agriculture  and 
land  use,  mobility,  and  electricity.  Each  platform  was 
asked  to  map  out  the  measures  required  for  a  55 % 
emission reduction.  

Figure 8: Targets and emissions under the Effort Sharing 
Decision and Effort Sharing Regulation57 

The national energy and climate plan will be partly based 
on the Energy Agenda55. The Energy Agenda was adopted 
at  the  end  of  2016  and  focuses  on  GHG  emission 
reductions needed to achieve the climate goals agreed in 
Paris in 2015. 

The 
low-carbon  development  strategy  explores  the 
concept  of  a  climate-neutral  economy.  The  new 
government has committed to a more ambitious climate 
policy, which will be laid down in a new Climate Law and 
a national Climate Agreement next to the existing Energy 
Agreement56. The National Climate Agreement, the Dutch 
contribution to "Paris", has one central goal, which  is to 
reduce  GHG  emissions  in  the  Netherlands  by  at  least 
49 % in 2030 compared to 1990. Additionally, the Dutch 
government's  efforts  in  a  European  context  could  result 
in an even more ambitious target towards 55 %.  

To come to a Climate Agreement with organisations and 
companies, conversations are taking place on  five sector 

53 See Regulation (EU) 2018/842. 
54 European Environmental Agency, Annual European Union greenhouse 
gas inventory 1990–2016. Proxy GHG emission estimates for 2017, 
Member States national projections. 
55 Government of the Netherlands, Energy Agenda: Towards a low-
carbon energy supply. 
56 Sociaal-Economische Raad, Agreement on Energy for Sustainable 
Growth, 2013.  

Focus  is  also  necessary  on  transport,  as  this  represents 
almost  a  quarter  of  the  EU’s  GHG  emissions  and  is  the 
main cause of air pollution in cities.  Transport emissions 
fell by 8 % from 2012 to 2015in the Netherlands. 

Figure  9:  Greenhouse  gas  emissions  by  sector  (Mt  CO2-
eq.). Historical data 1990-2016. Projections 2017-203058 

According  to  EU  Law,  and  to  control  emissions  from 
(F-gases),  Member  States  must 
fluorinated  GHGs 

57 European Environmental Agency, Annual European Union greenhouse 
gas inventory 1990–2016. Proxy GHG emission estimates for 2017, 
Member States national projections. 
58 European Environmental Agency, Annual European Union greenhouse 
gas inventory 1990–2016. Proxy GHG emission estimates for 2017, 
Member States national projections. 

11 

 
                                                                 
 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

auctioning  revenues  has  been  reported  as  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.  

introduce  training  and  certification  programmes  and 
rules for penalties, and must notify the Commission these 
measures  by  2017.  The  Netherlands  has  notified  the 
Commission both measures. 

The  accounting  of  GHG  emissions  and  removals  from 
forests and agriculture is governed by the Kyoto Protocol. 
A  preliminary  accounting  exercise  for  the  period  2013-
2016  shows  that  the  Netherlands  had  net  debits  of,  on 
average, 0.7 Mt CO2-eq, which corresponds to a negative 
contribution  of  -0.6%  of  the  EU-28  accounted  sink  of  -
115.7  Mt  CO2-eq.  The  Netherlands  is  one  of  six  EU 
in  this 
Member  States  which  showed  net  debits 
preliminary accounting exercise. 

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.  

The  Netherlands  adopted  its  first  national  adaptation 
strategy in 2007. Adaptation policy has two components: 
the  2016  national  climate  adaptation  strategy  ‘Adapting 
with  ambition’ 59  (December  2016,  following  an  initial 
adaptation  strategy  from  2007)  and  the  2010  Delta 
programme.  The  adaptation  strategy  complements  the 
Delta programme60. It describes how climate change will 
affect 
in  the  Netherlands,  drawing  particular 
attention  to  those  effects  which  are  likely  to  have 
significant  impact  in  the  years  ahead,  such  as  water 
forestry, 
agriculture 
management, 
recreation, infrastructure and energy.  

health, 

and 

life 

Through  its  role  complementing  the  national  climate 
adaptation strategy, the Delta programme involves many 
adaptation measures. The aim is to ensure that flood risk 
management, freshwater supply and spatial planning will 
be climate-proof and water-resilient by 2050, in the face 
of  increasing  weather  extremes.  A  Delta  plan  on  spatial 
adaptation  has  been  published61.  In  line  with  the  2014 
Delta decision on spatial adaptation, it specifically adopts 
a  territorial  approach.  The  action  programme  on 
adaptation  was 
in  March  2018  and  the 
monitoring and evaluation framework is being set up. 

launched 

Total  revenue  from  auctioning  emission  allowances 
under the EU ETS for 2013-2017 was EUR 786 million. The 
Netherlands  does  not  earmark  auctioning  revenue  for 
specific  uses.  An  amount  equalling  100 %  of  the 

59 Government of the Netherlands, National Climate Adaptation 
Strategy, 2016. 
60 Government of the Netherlands, Delta Programme. 
61 Government of the Netherlands, Delta Plan on Spatial Adaptation 
2018. 

12 

                                                                 
 
 
Environmental Implementation Review 2019 – the Netherlands 

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 
full 
biodiversity 
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 

sustainable 

conservation 

Biodiversity strategy 
Various  Dutch  policy  plans62
  together  serve  as  a  revised 
national  biodiversity  strategy  and  action  plan.  Based  on 
the  recommendations  of  the  Taskforce  on  Biodiversity 
and  Natural  Resources,  the  document  ‘Natural  capital 
of 
and 
agenda: 
use 
biodiversity‘63  sets 
implementation 
agenda  to  2020  for  the  Netherlands  and  the  Dutch 
Caribbean64
. 
The  ‘government  vision  2014’65  advocates  a  shift  in 
thinking  about  nature  policy,  from  protecting  nature 
from  society  towards  strengthening  nature  with  society. 
Biodiversity  targets  should  be  reached  by  using  all 
opportunities  for  synergy  between  the  value  of  nature 
and social and economic activities. 

the  biodiversity 

Setting up a coherent network of Natura 2000 sites 

By  early  2018,  13.3 %  of  the  national  land  area  of  the 
Netherlands  was  covered  by  Natura  2000  (EU  average 
18.1 %).  Special  areas  of  protection  (SPAs),  under  the 
Birds  Directive,  covered  11.5 %  (EU  average  12.3 %)  and 
Sites of community importance (SCIs), under the Habitats 
Directive, covered 8 % (EU average 13.8 %)66. 

been  observed  in  the  country  and  still  need  to  be 
addressed,  plus  some  potential  gaps 
in  the  SPA 
network67. 

Farmland  bird  populations  continue  to  experience 
significant  population  declines  despite  protection 
measures. For example, populations of the oystercatcher 
(Haematopus ostralegus), the black-tailed godwit (Limosa 
limosa)  and  the  skylark  (Alauda  arvensis)  have  declined 
by more than 60 % between 1990 and 2015. 

Dutch  overseas  countries  and  territories  benefited  from 
calls under the BEST 2.0 Programme68. 

Progress 
restoring 
in  maintaining  or 
conservation status of species and habitats 

favourable 

Member  States  report  only  every  6  years  on  progress 
made under the two directives, so no new information is 
available on the state of natural habitats and species, or 
on progress made in improving the conservation status of 
species  and  habitats,  since  the  2017  EIR.  However,  it  is 
clear  that  there  are  still  certain  situations  of  non-
compliance  in  relation  with  the  insufficiency  of  the 
network (SPAs and SCIs) and qualitative aspects of some 
management plans in place. 

2019 priority actions 

 

Further  optimise  the  contribution  of  Natura  2000 
and  national  nature  protection  networks 
to 
achieving  good  conservation  status,  in  particular  by 
ensuring sufficient resources for full implementation 
of  the  Natura  2000  management  plans  in  order  to 
maintain/restore species and habitats of community 
interest  to  a  favourable  conservation  status  across 
their natural range. 

  Reduce habitat fragmentation, atmospheric nitrogen 

Designating Natura 2000 sites and setting conservation 
objectives and measures 

 

The latest assessment of the Natura 2000 network shows 
that  the  Netherlands  has  largely  completed  its  Natura 
2000 network on land and on sea. There are a few minor 
gaps,  mainly  concerning  species  that  have  only  recently 

deposition, desiccation and acidification. 
Take  the  necessary  measures  to  halt  the  decline  of 
meadow  and  farmland  birds  and  to  re-establish  a 
sufficient area and diversity of habitats for them. 

62 Ministry of Economic Affairs, The Natural Way Forward: Government 
Vision 2014, 2014. 
63 Ministry of Economic Affairs, Natural Capital Agenda, 2014. 
64 Ministry of Economic Affairs, Nature Policy Plan for the Caribbean 
Netherlands, 2014. 
65 Ministry of Economic Affairs, The Natural Way Forward: Government 
Vision 2014, 2014. 
66 The figures do not add up because some sites are designated as both 
SCIs and SPAs. Special Areas of Conservation (SACs) are SCIs designated 
as such by the Member States. 

67 For each Member State, the Commission assesses whether the 
species and habitat types listed in 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 to December 2013. 
68 BEST, Voluntary Scheme for Biodiversity and Ecosystem Services in 
Territories of European Overseas. 

13 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

Maintaining and restoring ecosystems and 
their services 

than  specific  habitats  or  species,  and  opportunities  for 
increasing the value of nature are considered.  

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 
related  plans  and 
programmes. 

infrastructure 

into 

(GI) 

The EU has provided guidance on the further deployment 
of green and blue infrastructure in the Netherlands69 and 
a  country  page  on  the  Biodiversity  Information  System 
for  Europe  (BISE)70.  This  information  will  also  contribute 
to the final evaluation of the EU  Biodiversity Strategy to 
2020. 

The  Netherlands  has  several  policies  and  strategies 
including  relevant  green  infrastructure  measures.  The 
National  Ecological  Network  (NEN)  71  includes  existing 
protected areas and areas that need to be restored, and 
is intended to be connected to other European countries, 
but the extent of progress is unclear. 

The NEN is complemented by the policy documents ‘The 
Natural Way Forward: Government Vision 2014’72, which 
promotes  ‘nature  combinations’  (combining  nature  with 
agriculture, private estates, recreation, water extraction, 
cities,  business  areas,  waterways,  etc.)  and  ‘Nature 
ambition  for 
latter  envisages 
optimising  ecosystem  services  in  the  major  national 
waters. 

large  waters’73.  The 

GI  has  been  included  in  water  management.  New  water 
management measures focus on natural processes rather 

69 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. 
70 Biodiversity Information System for Europe. 
71 Government of the Netherlands, National Ecological Network (NEN). 
72 Ministry of Economic Affairs, The Natural Way Forward, 2014. 
73 Ministry of Economic Affairs, Natuurambitie Grote Wateren 2050 en 
verder, 2014. 

subsidies  aim 

Since  2016,  groups  of  farmers  have  been  allowed  to 
apply  for  subsidies  in  areas  with  high  potential  to 
increase  natural  value.  These 
to 
complement  the  NEN.  The  NEN  is  protected  by  spatial 
planning schemes in provincial regulations and listed as a 
in  the  national  policy  strategy  for 
national  priority 
infrastructure  and  planning  (Structuurvisie  Infrastructuur 
en  Ruimte)74.  In  that  strategy,  ´building  with  nature´  is 
mentioned as a  way to create nature value within other 
tasks. National and local authorities, businesses and non-
governmental organisations (NGOs) are working together 
to 
infrastructure  (highways, 
into 
railways, waterways) through green deals. These forms of 
infrastructure,  and  ecological  barriers  formed  by  highly 
intensive  agricultural  areas,  are  the  main  challenges  for 
GI. 

incorporate  nature 

Water-related projects and nature restoration 

(on 

restoration 

former  agricultural 

The  Netherlands  excels  at  water-related  projects  and 
nature 
lands). 
Examples  include  projects  such  as  the  Sand  Motor  and 
the  Marker  Wadden75  and  the  transformation  of  80 000 
hectares of agricultural lands, which have been included 
in  the  NEN.  Another  interesting  approach  is  that  of  the 
project Temporary Nature, which enables flora and fauna 
to  emerge  on  wasteland  areas.  To  prevent  developers 
from  having  to  compensate  for  habitats  that  have 
emerged,  when  the  building  project  is  carried  out,  a 
green  deal  with  the  national  government  allows 
developers  to  be  exempted  from  the  Flora  and  Fauna 
Law  —  so  there  is  no  incentive  to  try  to  keep  out 
protected  species  from  temporary  waste  ground.  This 
way,  a  temporary  habitat  can  be  created  or  naturally 
emerge on waste land. 
The  National  Green  Fund  (Nationaal  Groenfonds)76 
finances projects that improve the quality of the natural 
environment.  Green  deals  are  another  way  to  promote 
and  sometimes  finance  sustainable  projects.  Several 
projects also receive co-finance from the EU. 

for 

The  Netherlands  has  developed  a  dynamic  strategic 
for  ecosystem 
framework 
setting  priorities 
level.  The 
restoration  at  sub-national  and  national 
framework  has  four  layers;  (1)  its  prioritised  action 
framework  for  Natura  2000,  (2)  its  national  ecological 
network,  (3)  its  policy  strategy  for  large  waters,  and  (4) 
smaller national projects. It will be regularly updated. 

74 Government of the Netherlands, Summary of the national policy 
strategy for infrastructure and spatial planning.  
75 University of Delft, Marker Wadden: Building wetlands with soft mud. 
76 Government of the Netherlands, Green Deals. 

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Environmental Implementation Review 2019 – the Netherlands 

Estimating natural capital 

The  EU  biodiversity  strategy  calls  on  Member  States  to 
map  and  assess  the  state  of  ecosystems  and  their 
services77 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. 

The  Netherlands  has  implemented  the  Mapping  and 
Assessment  of Ecosystems and their Services (MAES) via 
its  Atlas  of  Natural  Capital78  and  the  development  of  a 
system  of  National  Natural  Capital  Accounts79,  leading 
efforts on ecosystem accounting. 

To enhance the applicability of the data, CBS developed a 
natural  capital  model  based  on  the  national  land  cover 
and ecosystems unit maps. The model consists of a set of 
input maps, a simulation tool and output maps which set 
out  the  relationship  between  the  ecosystems  and  the 
services  they  provide  and  that  is  consistent  with  the 
United  Nations  System  of  Environmental  Economic 
Accounting  (SEEA).  The  applicability  of  the  maps  is  now 
being tested in various pilot studies. 
The  TEEB  project80  has  delivered  a  tool  which  calculates 
the  monetary  value  of  green  areas  in  cities.  Over  20 
municipalities,  several  research 
institutes  and  other 
relevant  parties  agreed  to  cooperate  on  improving  and 
integrating  the  existing  tools  for  better  decision-making 
on natural capital. 

Wageningen  Environmental  Research, 
in  cooperation 
with the PBL,  the RIVM and  the Belgian INBO and VITO, 
has  started  a  project  to  create  a  tool  for  devising 
scenarios  for  natural  capital.  This  instrument  should 
enable  authorities,  assessment  agencies,  companies  and 
other stakeholders to estimate the effects of strategies or 
policies  on  natural  capital  and  ecosystem  services.  The 
project  also  aims  to  provide  a  range  of  practical 
approaches to natural capital for various actors. 

Business, nature organisations and governments have set 
up  an  online  platform,  ‘Naturalcapital.community’81  to 
scale  up  the  application  of  natural  capital  principles  in 
daily business practice. 
The  Natural  Capital  Community82  is  part  of  the  Dutch 
societal  programme  for  natural  capital,  a  national 
programme  in  which  the  employers’  organisation  VNO-

IUCN  Netherlands  and  the 
NCW,  CSR  Netherlands, 
professional  body  for  accountants  NBA83  have  joined 
forces with the government to scale up natural capital. It 
offers business-to-business solutions, insights, events and 
—  most  importantly  —  a  relevant  business  network 
working  on  natural  capital  in  the  Netherlands.  The 
for  Nature  network84  brings  together  20 
Leaders 
multinationals  and  major  Dutch  enterprises  aiming  to 
make  ecosystem  thinking  central  to  business  decision-
making. 

In November 2016 and 2017, the Netherlands co-hosted 
the  first  and  second  WAVES  policy  forums85.  WAVES 
(Wealth  Accounting  and  the  Valuation  of  Ecosystem 
Services)  is  a  World  Bank-led  global  partnership  to 
promote  sustainable  development  by  ensuring  that 
natural  resources  (including  ecosystems  and  ecosystem 
services) are mainstreamed in development planning and 
national  economic  accounts.  The  Netherlands  supports 
this programme with expertise from CBS and PBL. 

At  the  final  Esmeralda  workshop  and  MAES  Working 
Group  meeting  in  Brussels  in  September  2018,  the 
Netherlands  was  shown  to  be  one  of  the 
leading 
countries when it comes to the implementation of MAES 
(Figure  10).  This  assessment  was  produced  by  the 
Esmeralda  project  based  on  27  questions  about 
implementation and is updated every 6 months. 
Figure 10: Implementation of MAES (September 2018)86 

The Commission encourages the Netherlands to continue 
sharing its experience with other Member States. 

Business  and  biodiversity  platforms,  networks  and 
communities of practice are key tools for promoting and 
facilitating  natural  capital  assessments  (NCA)  among 
business  and  financial  service  providers,  for  instance  via 
the  Natural  Capital  Protocol  designed  by  the  Natural 
Capital  Coalition87.  NCAs  help  private  business  to  better 
understand and put a value not only on their impacts, but 

77 Ecosystem services are benefits provided by nature such as food, 
clean water and pollination on which human society depends. 
78 Atlas of Natural Capital, website. 
79 The system will be completed in 2019, and the regular monitoring 
implemented in 2020. 
80 TEEB, The Economics of Ecosystems and Biodiversity. 
81 MVO Nederland, Naturalcapital.community. 
82 MVO Nederland, Naturalcapital.community. 

83 Koninklijke Nederlandse Beroepsorganisatie van Accountants, 
website. 
84 International Union for Conservation of Nature (IUCN) National 
Committee of the Netherlands, Leaders for Nature. 
85 WAVES Partnership, WAVES Hosts the First Policy Forum with the 
Netherlands Government. 
86 Esmeralda project, website. 
87 Natural Capital Protocol, Natural Capital Coalition. 

15 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

also on their dependence on nature, and so contribute to 
EU  biodiversity  strategy.  Business  and  diversity  groups 
have been established at EU level88 and in some, but not 
all, Member States. 

Asian  hornet  has  been  eradicated  and  eradication 
measures  for  raccoon  are  ongoing.  Also,  the  Pallas’ 
squirrel  (Callosciurus  erythraeus)  and  the  Indian  house 
crow (Corvus splendens) have been eradicated. 

As,  according  to  the  data,  the  Muntjac  deer  (Muntiacus 
reevesi)  is  still  in  the  early  invasion  stage,  and  the 
Netherlands is one of the few Member States with a local 
population  of  these  species,  it  is  advised  to  attempt  to 
eradicate them.  

Figure  11:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information89 

Invasive alien species 

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. 

The  report  on  the  baseline  distribution  (Figure  11),  for 
which the Netherlands could only review its country data 
(reviewing  grid-level  data  required  more  time),  shows 
that of the 37 species on the first EU list, 25 have already 
been  observed,  of  which  20  are  established  and  15  are 
aquatic species.  

The  number  of  established  populations  is  the  fourth 
highest in the EU, after that of Germany, France and Italy. 
The  high  registered  number  of  IAS  of  EU  concern, 
particularly  given  the  Netherlands’  smaller  surface  area, 
is  related  not  only  to  its  key  location  as  a  river  delta  at 
important  European  river  systems  and 
the  end  of 
intensive economic and transport activities, but also to its 
considerable  surveillance  efforts.  The  country  is  facing 
great invasion pressure from the raccoon (Procyon lotor), 
moving from Germany. 

into  force  of  the  EU 

Between  the  entry 
list  and 
18 May 2018,  the  Netherlands  submitted  two  early 
detection notifications, as required under Article 16(2) of 
the  IAS  Regulation:  one  for  the  Asian  hornet  (Vespa 
velutina)  and  one  for  the  raccoon  (Procyon  lotor).  The 

The  Netherlands  has  notified  the  Commission  of  its 
competent  authorities  responsible  for  implementing  the 
IAS  Regulation,  as  required  by  Article 24(2)  of  the  IAS 
Regulation. 

It  has 
informed  the  Commission  of  the  national 
provisions on penalties for infringements, as required by 
Article 30(4) of the IAS Regulation, and has therefore met 
its notification obligations.  

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. 

Soil  is  a  finite  and  extremely  fragile  resource  and  it  is 
increasingly degrading in the EU. 
The percentage of artificial land90 in a country (Figure 12) 
can  be  seen  as  a  measure  of  the  relative  pressure  on 

88 The European Business and Biodiversity Campaign aims to promote 
the business case for biodiversity in the EU Member States through 
workshops, seminars and a cross-media communication strategy. 

89 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. 

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Environmental Implementation Review 2019 – the Netherlands 

nature  and  biodiversity,  as  well  as  the  environmental 
pressure  on  people  living  in  urbanised  areas.  A  similar 
measure is population density.  
Figure 12: Proportion of artificial land cover, 201591. 

The Netherlands ranked 2nd highest in the EU  according 
to 2015 Eurostat data, with 12.1 % of artificial land. The 
population density in the country was 498/km2 (Eurostat 
2016), which is the 2nd highest in the EU and more than 
four  times  the  EU  average  of  11892.  This  correlates  with 
challenges on air quality in urban areas, for example. 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  A  recent 
report of the Joint Research Centre (JRC)93 estimated that 
potentially  polluting  activities  have  taken  or  are  still 
taking place in approximately 2.8 million sites in the EU. 
650 000 of these sites have been registered in national or 
regional inventories and 65 500 contaminated sites have 

90 Artificial 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). 
91Eurostat, Land cover and land use.  
92 Eurostat, Population density by NUTS 3 region. 
93 Ana Paya Pérez, Natalia Rodríguez Eugenio, Status of local soil 
contamination in Europe: Revision of the indicator “Progress in the 
management Contaminated Sites in Europe”, 2018. 

already been remediated. The Netherlands has registered 
1 455  sites  where  potentially  polluting  activities  have 
taken or are taking place, and has already remediated or 
applied aftercare measures on 176 sites. 

Soil  organic  matter  also  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.  

Soil  erosion  by  water  is  a  natural  process,  which  can  be 
aggravated by climate change and human activities such 
as  inappropriate  agricultural  practices,  deforestation, 
forest  fires  or  construction  works.  High  levels  of  soil 
erosion  can  reduce  productivity  in  agriculture  and  can 
have negative and transboundary impacts on biodiversity 
and ecosystem service, and on rivers and lakes (increased 
volume  of  sediments,  transport  of  contaminants). 
According  to  the  RUSLE2015  model94,  the  Netherlands 
has an average soil loss rate by water of 0.27 tonnes per 
hectare  per  year  (t ha−a yr−y)  compared  to  a  European 
mean  average  of  2.46  t ha−a yr−y,  which  indicates  soil 
erosion  is  low  on  average.  It  is  important  to  note  that 
these  figures  are  the  output  of  a  model  run  at  EU  level 
and  therefore  should  not  be  considered  as  values 
measured  in-situ  field.  The  actual  soil  loss  rate  can  vary 
strongly  within  the  Member  State  depending  on  local 
conditions. 

in  all,  the  Netherlands 

All 
faces  pressures  as  a 
consequence of its high population density, although the 
situation is improving thanks to soil remediation activities 
and low average levels of erosion. 

Marine protection 

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)95 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. 

The  Convention  for  the  protection  of  the  marine 
environment  of  the  north-east  Atlantic  (the  ‘OSPAR 
Convention’) 
in 
achieving the goals of the Directive. Its marine strategies 

for  the  Netherlands 

important 

is 

94 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, Environmental Science and Policy, 
54, 2015, pp. 438-447. 
95 Directive 2008/56/EC. 

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Environmental Implementation Review 2019 – the Netherlands 

comprise different steps to be taken over six-year cycles. 
Each  Member  State  had  to  set  up  and  report  on  its 
programme  of  measures 
the  Commission  by 
31 March 2016.  The  Commission  assessed  whether  the 
Dutch  measures  were  appropriate  to  reach  good 
environmental status (GES)96.  

to 

Member  States  have  now  started  implementing  the 
the  Marine  Strategy  Framework 
second  cycle  of 
Directive.  As  of  November  2018,  only  the  Netherlands 
and  Belgium  have  submitted  their  reports,  but  more 
Member  States  might  have  done  it  by  the  publication 
date  of  this  report.  The  Netherlands  submitted  updated 
assessments,  determinations  of  GES  and  targets  on  15 
October 2018. 

The  Dutch  programme  of  measures  addresses  most 
relevant  pressures  and  targets  for  most  aspects  of  the 
marine environment. For example, for fish, the measures 
address  mortality  and  age/size  distribution  and  are 
closely  linked  to  the  implementation  of  the  common 
fisheries policy. The Netherlands is also acting to reduce 
discards  and  aiding  recovery  of  depleted  sensitive  fish 
species  stocks (i.e. sharks, rays and skate). This is in line 
with  the  Netherlands’  pressures,  targets  and  GES 
definitions. 

Another  example  is  the  Dutch  measures  aiming  to 
address  key  pressures  for  the  introduction  of  non-
indigenous  species  (NIS):  aquaculture  and  shipping 
(including  ballast  water  and  hull  fouling).  The  measures 
aim  to  prevent  an  increase  in  the  relative  abundance  of 
NIS through improved management of high risk pathways 
and vectors by shipping and aquaculture.  

In  several  cases,  the  Netherlands  is  uncertain  whether 
GES will be achieved by 2020. In some cases, it states that 
GES will be ‘within reach’ but does not clearly say if it will 
be  achieved.  In  other  cases,  it  reports  that  it  does  not 
know  when  GES  will  be  achieved.  Overall,  the  Dutch 
programme  of  measures  is  partially  appropriate  for 
meeting the requirements of the MSFD. 

2019 priority actions 

Set targets for GES where these do not exist. 

 
  Determine  the  timelines  for  achieving  GES,  if  these 

 

have not been reported. 
Provide  more  information  about  marine  protection 
measures  and  establish  more  measures  that  have  a 
direct impact on the relevant pressures and quantify 
the  level  of  pressure  reduction  expected  as  a  result 
of these measures. 

96 COM(2014) 97. 

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Environmental Implementation Review 2019 – the Netherlands 

3. Ensuring citizens’ health and quality of life 

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 
legislation97,  which  establishes  health-based 
quality 
standards  and  objectives  for  a  number  of  air  pollutants. 
However,  according  to  the  European  Court  of  Auditors 
(ECA)98  EU  action  to  protect  human  health  from  air 
pollution has not delivered its expected impact. 

several  air  pollutants  have 

fallen 
Emissions  of 
significantly99.  The  emission  reductions  between  1990-
2014 mentioned in the previous EIR, continued between 
2014-2016  with  emissions  of  nitrogen  oxides  (NOx) 
decreasing  by  5.72 %,  emissions  of  volatile  organic 
compounds  (NMVOCs)  by  7.37 %,  emissions  of  fine 
particulate  matter  (PM2.5)  by  7.67 %  and  of  sulphur 
oxides  (SOx)  by  6.53 %  (see  also  Figure  13  on  the  total 
PM2.5  and  NOx  emissions  per  sector).  Meanwhile, 
emissions  of  ammonia  (NH3)  from  agricultural  practices 
have increased by 1.87 %.  

Despite these emission reductions, additional efforts are 
needed to meet the commitments (compared with 2005 
emission levels) laid down in the new National Emissions 
Ceilings  Directive100  for  2020  to  2029  and  for  any  year 
from 2030. 

At  the  same  time,  air  quality 
in  the  Netherlands 
continues  to  give  a  cause  for  concern.  For  2015,  the 
European  Environment  Agency  (EEA)  estimated  that 
about  9 800  premature  deaths  were  attributable  to  fine 
particulate  matter  concentrations101,  with  an  additional 

97 European Commission, 2016. Air Quality Standards 
98 European Court of Auditors, Special report no 23/2018, Air pollution: 
Our health still insufficiently protected, p.41. 
99 See EIONET Central Data Repository and Air pollutant emissions data 
viewer (NEC Directive). 
100 Directive 2016/2284/EU. 
101 Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) of a wide range of sizes and chemical composition. PM10 (or 
PM2.5) refers to particles with a diameter of 10 (or 2.5) micrometres or 
less. PM is emitted from many human sources, including combustion. 

290 to ozone concentration102 and over 1 900 to nitrogen 
dioxide103 104. 

Figure  13:  PM2.5  and  NOx  emissions  by  sector  in  the 
Netherlands105 

Figure  14:  Air  quality  zones  exceeding  EU  air  quality 
standards in 2017106 

For 2017107, EU air quality standards for nitrogen dioxide 
were exceeded in two air quality zones: Amsterdam  and 
Rotterdam.  There  were  not  exceedances  for  PM2.5  and 
PM10 in the country. See Figure 14 on the number of air 
quality zones exceeding ceilings for NO2, PM2.5, and PM10. 

102 Low-level ozone is produced by photochemical action on pollution. 
103 NOx is emitted during fuel combustion e.g. from industrial facilities 
and the road transport sector. NOx is a group of gases comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
104 EEA, Air Quality in Europe – 2018 Report, p. 64. Please see details in 
this report as regards the underpinning methodology. 
105 2016 NECD data submitted by Member State to the EEA. 
106 EEA, EIONET Central Data Repository. Data reflects the reporting 
situation as of 26 November 2018. 
107 European Environment Agency, Information on the attainment of 
environmental objectives for the Netherlands, 20 September 2017. 

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Environmental Implementation Review 2019 – the Netherlands 

for  Public  Health  and 

During  the  EIR  dialogue  in  The  Hague,  the  National 
Institute 
the  Environment 
presented  the  main  air  quality  trends.  Exceedance  of 
binding  limit  values  of  both  PM10  and  NO2  has  fallen  in 
recent years but they are still a cause for concern. Traffic 
and  agricultural  emissions  are  the  most 
important 
national sources. 

The  coalition  government  has  decided  to  work  towards 
meeting  the  WHO  targets  for  air  pollution  (which  are 
considerably  more  difficult  to  meet  than  the  EU  binding 
limit values). The National Health Council (NHC) has also 
including 
recommended  reducing  certain  emissions, 
those  coming  from  wood  burning  and  other 
local 
sources.  In  its  document  “Health  profit  by  clean  air”108, 
the  NHC  stated  that  further  action  is  needed  in  the 
the 
international 
emissions  from  industry  and power  plants.  International 
policies  are  important  for  reduction  of  the  emissions  of 
particulate  matter  and  especially  ammonia 
from 
agriculture.  Among  the  initiatives  being  taken  in  the 
Netherlands,  the  ‘smart  and  healthy  cities  programme’ 
(2015-2018) is trying to is trying to induce local policies to 
reduce air pollution below legal limit values. 

context,  especially 

focused  on 

The  national  strategy  on  air  quality  is  expected  to  help 
tackle 
these  challenges.  The  national  air  quality 
cooperation  programme  (NSL)  included  EUR 1.5  billion 
and  involved  local  and  regional  authorities.  However, 
following  a  decision  by  a  Dutch  district  court  of 
7 September 2017, the NSL had to be amended so that it 
could  act  as  an  air  quality  plan,  as  required  by 
Article 23(1)  of  Directive  2008/50/EC.  New  measures 
include  actions  on  low-emission  zones,  electric  vehicles, 
mobile  machinery  and  livestock  farming.  The  amended 
plan was updated and supplemented by the Government 
on  28  September  2018  and  sent  to  the  Parliament.  Its 
effectiveness  will  be  monitored  and  assessed  in  the 
future  to  determine  whether  additional  measures  are 
necessary. 

All  in  all,  although  emissions  of  certain  pollutants  have 
decreased,  additional  efforts  are  needed  to  meet  the 
commitments  for  2020  to  2029.  Emissions  of  ammonia 

108 National Health Council, Document 2018/01 ‘Gezondheidswinst 
door schonere lucht’.  

have increased between 2014 and 2016. 

2019 priority actions 

 

Take,  in  the  context  of  the  National  Air  Pollution 
towards 
Control  Programme 
reducing the main emission sources. 

(NAPCP),  actions 

  Accelerate  reductions 

in  nitrogen  oxide 

(NOx) 
emissions and nitrogen dioxide (NO2) concentrations 
inter alia by further reducing transport emissions  — 
in  particular 
in  urban  areas,  proportionate  and 
targeted  restrictions  on  vehicle  access  may  be 
required; or using fiscal incentives. 

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 Directive109 (IED). 

The overview of industrial activities regulated by the IED 
below  is  based  on  the  project  on  Industrial  Emissions 
policy country profiles110. 

In  the  Netherlands,  around  3 500  industrial  installations 
are  required  to  have  a  permit  based  on  the  IED111.  The 
sectors  with  the  most  installations  in  2015  for  activities 
listed  in  the  IED  are  intensive  rearing  of  poultry  or  pigs 
(62 %)  and  hazardous  (13 %)  and  non-hazardous  waste 
management (7 %). 

The  sectors  accounting  for  the  greatest  burden  on  the 
environment in the form of emissions to air are shown in 
Figure 16. 

production, 

activities’,  metal 

‘Other 
chemicals, 
power/refining  and  waste  management  accounted  for 
significant  environmental  burdens 
form  of 
emissions 
‘Other  activities’  and  waste 
to  water. 
management  contributed  significantly  to  non-hazardous 
waste  generation,  while  waste  management,  chemicals 
to 
and  metal  production  contributed  significantly 

in  the 

109 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). 
110 Ricardo Energy and Environment, Industrial emissions country 
profile: the Netherlands, 2018. 
111 This overview of industrial activities regulated by IED is based on the 
project on Industrial Emissions policy Country profiles: Industrial 
emissions policy country profiles. 

20 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

hazardous waste generation.  

Figure  15:  Number  of  IED  installations  by  sector,  the 
Netherlands (2015)112 

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

The  Commission  relies  on  and  welcomes  the  efforts  of 
national  competent  authorities  to  implement  the  legally 
binding  BAT  conclusions  and  associated  BAT  emission 
levels in environmental permits, resulting in considerable 
and continuous reduction of pollution.  

By  way  of  example,  the  implementation  of  the  recently 
adopted  BAT  associated  emission 
levels  for  Large 
Combustion Plants will -on average and depending on the 
situation of individual plants- reduce emissions of sulphur 
dioxide with 25% to 81%, nitrogen oxide with 8%to 56%, 
dust  with  31%  to  78%  and  mercury  with  19%  to  71%  at 
EU level. 

A specific feature of Dutch policy is the close connection 
between  chemicals  legislation  and  industrial  emissions, 
which  is  embedded  in  national  legislation.  Relatively 
strict rules for emissions apply for chemicals that comply 
with  the  criteria  for  Substances  of  Very  High  Concern 
(SVHC),  such  as  the  need  to  minimise  emissions  and  to 
investigate  reduction  options.  There  is  a  national  list  of 
SHVC  (zeer  zorgwekkende  stiffen)  with  approximately 
1 500 substances that fulfil the SVHC criteria.  Recently a 
list  of  ‘potential  SVHC’  has  been  added  to  aid  in  the 
permitting process. 

The  competent  authority  in  the  Netherlands  identified 
the main challenge for the IED sectors as pollution from 
intensive rearing of poultry and pigs. 

2019 priority actions 

  Review of permits to comply with new adopted BAT 

 

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

  Addressing  pollution 

(e.g.  dust) 

from  certain 
activities  and  take  actions  to  improve  IED  and 
EPRTR113  reporting,  specifically  for  intensive  rearing 
of poultry or pigs activities.  

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

The  development  of  Best  Available  Techniques  (BAT) 
Reference  Documents  (BREFs)  and  BAT  Conclusions 
through  the  exchange  of  information  involving  Member 
States, Industrial associations, NGOs and the Commission 
ensures  a  good  collaboration  with  stakeholders  and 
enables a better implementation of IED. 

112 Ricardo Energy and Environment, Industrial emissions country 
profile: the Netherlands, 2018. 

Noise 

The  Environmental  Noise  Directive114  provides  for  a 
common  approach  to  avoiding,  preventing  and  reducing 
the harmful effects of exposure to environmental noise. 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health-related  issues 
in the EU115. 

113 The European Pollutant Release and Transfer Register (EPRTR) is the 
Europe-wide register that provides key environmental data from 
industrial installations in Europe 
114 Directive 2002/49/EC. 
115 WHO/JRC, 2011, Burden of disease from environmental noise, 
Fritschi, L., Brown, A.L., Kim, R., Schwela, D., Kephalopoulos, S. (eds), 

21 

 
 
                                                                 
                                                                 
 
Environmental Implementation Review 2019 – the Netherlands 

Based  on  a  limited  set  of  data116,  environmental  noise 
causes  at  least  around  200  premature  deaths  and  1 400 
hospital  admissions  per  year  in  the  Netherlands,  and 
some  390 000  people  experience  disturbed  sleep.  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 has 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  (WFD)  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) 
in  a  more 
sustainable and resource-efficient way. 

is  managed 

The  existing  EU  water  legislation117  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 
impacts  of  climate  change  are 
into  the 
integrated 
corresponding  planning 
instruments,  e.g.  flood  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. 

Water Framework Directive 

The  Netherlands  has  adopted  and  timely  reported  its 
second  generation  of  River  Basin  Management  Plans 
(RBMPs) under the WFD. The European Commission has 
assessed  the  status  of  Dutch  waters  and  the  main 
developments  since  the  adoption  of  the  first  RBMPs, 
including the progress on the 2017 EIR suggested actions. 

The most significant pressures on Dutch surface affecting 
water  bodies  come  from  diffuse  agricultural  sources 
(78 %  of  surface  water  bodies  affected),  followed  by 

World Health Organisation, Regional Office for Europe, Copenhagen, 
Denmark. 
116 European Environment Agency, Noise Fact Sheets 2017. 
117 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). 

pressures  from  dams,  barriers  and  locks  (61 %).  For 
groundwater bodies the most significant pressure comes 
from  point  sources  (57 %  affected),  followed  by  diffuse 
pollution from agriculture (52 %). 

followed  by  altered  habitats  due 

Nutrient  pollution  was  the  most  significant  impact  on 
surface  water  categories  (65 %  of  surface  water  bodies 
affected), 
to 
morphological  changes  (75 %),  altered  habitats  due  to 
hydrological  changes  (68 %),  chemical  pollution  (50%) 
and organic pollution (48 %). For groundwater bodies the 
most  significant 
impacts  were  nutrient  and  organic 
pollution,  each  with  61 %  of  groundwater  bodies 
affected. 

Overall, there has been a slight increase in the number of 
sites used for operational and/or surveillance monitoring 
of  ecological  status  in  surface  water  bodies  in  the 
country. However, there were significant decreases in the 
number  of  sites  used  for  the  surveillance  monitoring  of 
all four water categories between the two RBMPs in the 
Netherlands. 

Figure 17: Ecological status or potential of surface water 
bodies in the Netherlands118 

There  are  only  two  water  bodies  in  good  or  better 
ecological  status/potential  despite  the  first  RBMPs 
objective  to  achieve  good  ecological  status/potential  by 
2015  for  9-13 %  of  artificial  and  heavily  modified  water 
bodies  and  for  28  %  of  the  natural  water  bodies.  The 
achievement  of the good status objective has now been 
postponed to 2027 or later for most of the water bodies. 
The ecological status/potential is illustrated in figure 17. 

118 EEA, WISE dashboard. 

22 

                                                                                                        
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

Investment  needs  are  related  to  infrastructure  renewal 
and/or  maintenance  and  these  seem  to  have  been 
catered for by the Netherlands. 
Figure 18: Bathing water quality 2014-2017124 

This shows that the Netherlands has a long way to go in 
order to achieve the good status/potential objectives set 
down in the WFD. 

The  majority  of  surface  water  bodies  are  failing  to 
achieve  good  chemical  status  (52 %)  with  39 %  at  good 
status  and  9 %  in  unknown  status.  All  groundwater 
bodies  (100 %)  are  in  good  quantitative  status  and  87 % 
are in good chemical status. 

The  aforementioned  most  significant  pressures  have  to 
be  addressed  using  key  types  of  measures.  The  first 
Programme of  Measures has already been implemented 
and  significant  progress  seems  to  have  been  made  in 
linking  the  measures  to  pressures,  as  well  as  identifying 
analysis gaps and, at least, qualitative information of the 
measures  to  address  them;  and  financial  commitments 
for the implementation of the Programme. However, it is 
not  clear  whether  the  Programme  of  Measures 
is 
sufficient  in  order  to  reach  the  objectives  of  the  WFD, 
since  it  has  been  anticipated  that  for  a  large  number  of 
surface  water  bodies  significant  pressures  will  not  have 
been fully addressed by 2027.  

Drinking Water Directive 

Nitrates Directive 

As  regards  drinking  water,  there  are  no  new  data 
available since the last EIR119. However, it is clear that the 
Netherlands  continues  to  have  very  high  compliance 
rates  for  drinking  water  quality  and  urban  waste  water 
treatment,  so  there  are  no  particular  implementation 
issues. Overall, 100 % of the waste water is collected and 
undergoes  stringent  treatment.  Investment  is  expected 
to be stable120. 

Bathing Water Directive 

Figure  18  shows  that  in  2017,  out  of  the  719  Dutch 
bathing waters, 73.4 % were of excellent quality, 17 % of 
good  quality  and  4.6 %  of  sufficient  quality  (74.8 %, 
16.2 %  and  3.8 %  respectively  in  2016).  In  2017,  20 
bathing  waters  were  of  poor  quality121.  Detailed 
information on Dutch bathing waters is available from a 
national  portal 122  and  via  an  interactive  map  produced 
by the EEA123.  

Urban Waste Water Treatment Directive  

The  Netherlands  demonstrates  excellent 
levels  of 
compliance  with  the  Urban  Waste  Water  Treatment 
Directive. Overall in the Netherlands, 100 % of the waste 
is  collected  and  undergoes  more  stringent 
water 
Investments  are  expected  to  be  stable. 
treatment. 

119 Compliance with the microbiological and chemical parameters of the 
Drinking Water Directive as last reported was very high. 
120 COM (2017) 749 and SWD (2017) 445. 
121 European Environment Agency, European bathing water quality in 
2017, 2018, p. 17. 
122 Dutch national portal for bathing waters, website.  
123 EEA, State of bathing waters. 

(resulting 

from  effluents  of 

Water quality remains of great concern due to pollution 
by  nitrates 
intensive 
farming125).  Moreover, 
livestock-rearing  and  dairy 
eutrophication  is  widespread.  The  Netherlands  has  an 
action programme for the Nitrates Directive covering the 
whole  territory.  It  has  been  granted  a  derogation  for 
nitrogen originating from livestock manure in connection 
with  the  action  programme,  on  the  basis  of  scientific 
evidence  and  on  a  number  of  conditions,  including 
phosphate  production  not  exceeding  the  2002  level 
(172.9 million kg), and better enforcement to ensure that 
the manure policy is correctly implemented. 

livestock 

in  a  sharp 

intensification  of 

farming 
The  significant 
activities  due  to  the  end  of  the  milk  quota  system  has 
resulted 
in  the  cattle  sector, 
increase 
representing an additional challenge to the management 
of  nutrients  in  the  country.  This  has  pushed  phosphate 
levels beyond the above limits between 2015 and end of 
2017,  thus  posing  additional  concerns  about  the  water 
quality  objectives  and  prompting  the  Commission  to 
open an investigation.  

is 

The  Commission 
the 
closely 
implementation  of  both  the  Nitrates  and  the  Water 
Framework Directives will contribute to ensuring that the 
Netherlands meets EU water quality objectives. 

following  how 

124 European Environment Agency, European bathing water quality in 
2017, p. 21, 2018. 
125 The Netherlands is the biggest manure producer, measured by land 
area, in the EU. 

23 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

Floods Directive 

Flood  risks  have  been  part  and  parcel  of  Dutch  society 
for many centuries. With more than 60 % of the territory 
vulnerable to flooding and 75 % of population potentially 
living in those areas, the Netherlands has introduced new 
standards  to  respond  to  the  new  challenges  linked  to 
climate  change, urban  development  and  economic 
growth126. 

The  Delta  programme  and  other  public  initiatives  have 
contributed  to  ensuring  flood  protection  in  the  country 
but  climate  change  is  expected  to  increase  risks.  In  the 
absence of measures, the potential damage is estimated 
at  between  EUR 400  billion  and  EUR 800  billion  by  2040 
and EUR 3 700 billion by 2100, with a sea level rise of 24 
to 60 cm in 2040 and 150 cm in 2100127. 
The  Floods  Directive128  establishes  a  framework  for  the 
assessment and management of flood risks, aiming at the 
reduction  of  the  adverse  consequences  associated  with 
significant  floods.  The  Netherlands  has  timely  reported 
its first Flood Risk Management Plans (FRMPs) under the 
Directive  and  the  European  Commission  conducted  its 
assessment. 

The  Commission’s  assessment  found  that  good  efforts 
and  positive  results  have  been  achieved 
in  setting 
objectives and devising measures focusing on prevention, 
protection  and  preparedness.  The  assessment  also 
showed that, as it was the case for other Member States, 
the  Netherlands’  FRMPs  include  measures  that  require 
clearer prioritisation and linking to the objectives set and 
an  as  complete  as  possible  estimation  of  the  cost  of 
measures.  There  is  also  scope  for  reinforcing  the  aspect 
of  public  participation  and  the  active  involvement  of 
stakeholders in relation to the FRMPs. 

The EIB is supporting flood defence works, specifically for 
the  rehabilitation  and  modernisation  of  the  Afsluitdijk 
dam. By 2022, more than EUR 330 million will have been 
allocated  to  this  project  from  the  European  Fund  for 
Strategic Investments (EFSI)129. 

International  cooperation  between  the  Netherlands, 
Belgium,  France  and  Germany  is  important  to  ensure 
proper  flood  protection  for  international  river  basins 
such  as  the  Scheldt.  The  Hedwige-Prosperpolder  project 
is  a  good  example  of  cooperation  between  Belgium  and 
the  Netherlands  to  leave  the  area  to  nature  and  avoid 

126 OECD, Financing needs in the water sector, Country fiche for the 
Netherlands (not yet published). 
127 RPA, Study on economic and social benefits of environmental 
protection and resource efficiency related to the European Semester. 
Study for the European Commission, Annex 1: Country fiches, 2014. 
128 Directive 2007/60/EC. 
129 European Commission, EUR 330 million EIB support under Juncker 
Plan for Afsluitdijk flood defence works in the Netherlands. 

floods130. This and other initiatives are welcome and can 
help with the transboundary aspect of certain issues. 
2019 priority actions131 

 

 

 

Ensure that steps are taken in order to complete the 
assessment  of  the  effectiveness  of  the  existing 
agricultural  measures  and  identify  which  additional 
measures  are  needed  to  achieve  the  objectives  of 
the  Water  Framework  Directive  and  Nitrates 
Directive. 
Ensure  that,  for  chemical  pollution  from  non-
agricultural sources, the Programmes of Measures is 
based on reliable assessment of the pressures. 
Take  steps  to  reinforce  the  aspect  of  public 
involvement  of 
the  active 
participation  and 
stakeholders 
the  Flood  Risk 
to 
Management Plan. 

relation 

in 

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. 

legislation132  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  2016  European  Chemicals  Agency  (ECHA)  report  on 
the  operation  of  REACH  and  CLP133  showed  that 
enforcement activities are still evolving. In the Forum for 
Exchange  of  Information  on  Enforcement,  coordinated 
projects134  have  shown  that  the  effectiveness  of  the 
enforcement activities can still be improved, in particular 
regarding registration obligations and safety data  sheets 
where a relatively high level of non-compliance has been 
found.  

improving,  there 

Whilst 
further 
improvement  of  national  enforcement  activities  as 

is  also  room  for 

130 European Environment Agency, Green Infrastructure and Flood 
Management, 2017, p. 36. 
131 The full set of recommendations in relation to the Water Framework 
Directive are here. 
132 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. 
133 European Chemicals Agency, Report on the Operation of REACH and 
CLP 2016. 
134 On the basis of the projects REF-1, REF-2 and REF-3, available at 
ECHA website. 

24 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

It 

imported  goods. 

regards  harmonisation  throughout  the  Union,  including 
controls  on 
is  also  clear  that 
enforcement  is  still  weak  in  some  Member  States  in 
particular  with  respect  to  control  of  imports  and  supply 
chain  obligations.  The  architecture  of  enforcement 
capabilities  continues  to  be  complex 
in  most  EU 
countries.  The  enforcement  projects also revealed  some 
differences  among  Member  States  (e.g.  some  tend  to 
systematically  report  higher  compliance  than  the  EU 
average and others lower). 

inspections  of  CLP.  There  is  a  national  helpdesk  to 
provide  fast  and  effective  answers  to  REACH-related 
inquiries. 

The  Netherlands  plays  an  active  role  in  REACH/CLP  by 
participating  in  the  Substances  of  Very  High  Concern 
(SVHC)  roadmap.  This  work  includes  the  submission  of 
types  of 
substance-specific  dossiers 
substance 
regulatory 
evaluation, 
and 
commenting of such dossiers of other Member States.  

for  different 
SVHC, 

action 
harmonised 

classification 

(restriction, 

etc.) 

A  2015  Commission  study  highlighted  already  the 
importance  of  harmonisation  in  the  implementation  of 
REACH  at  Member  State  level,  in  terms  of  market 
surveillance and enforcement, as a critical success factor 
in the operation of a harmonised single market135.  

In March 2018, the Commission published an evaluation 
of  REACH136.  The  evaluation  concluded  that  REACH  is 
delivering on its objectives, but that the progress made is 
slower  than  anticipated.  In  addition,  the  registration 
dossiers are often incomplete. The evaluation underlines 
the need to enhance enforcement by all actors, including 
registrants, downstream users and importers; to ensure a 
level  playing  field,  meet  the  objectives  of  REACH  and 
ensure  consistency  with  the  actions  envisaged  to 
improve  environmental  compliance  and  governance. 
Consistent  reporting  of  Member  State  enforcement 
activities was considered important in that respect. 

The  Netherlands  hosts  more  than  400  top  chemical 
companies across the supply chain, with 19 out of the 25 
in  the  world  maintaining 
top  chemical  companies 
significant  operations 
the 
Investment  Agency,  chemicals 
Netherlands  Foreign 
exports account for 17 % of total Dutch exports, ranking 
fifth in the world in absolute terms. 

there137.  According 

to 

The enforcement of REACH, CLP and Biocides Regulations 
in the Netherlands is based on the cooperation of several 
Inspectorates138. These are the Inspectorate SZW (former 
Labour Inspectorate), The Health Care Inspectorate (IGZ), 
the Human Environment and Transport Inspectorate (ILT) 
and the Netherlands Food and Consumer Product Safety 
Authority (NVWA). The ILT, NVWA and SZW staff a REACH 
and  CLP  Enforcement  Coordination  Point  which 
is 
responsible  for  the  supervision  of  compliance  with 
REACH  and  CLP.  The  Coordination  point  consists  of  a 
REACH  and  CLP  Enforcement  Steering  Group  and  a 
REACH and CLP Enforcement Alliance.  

A system of penalties is in place for infringement of both 
REACH  and  CLP,  as  are  regular  checks  and  routine 

135 European Commission, Monitoring the Impacts of REACH on 
Innovation, Competitiveness and SMEs, 2015.  
136 COM(2018) 116. 
137 Government of the Netherlands, Invest Holland — Chemicals. 
138 ECHA, National inspectorates – Netherlands.  

The  country  is  trying  to  enforce  REACH  substitution  of 
through  bio-based  alternatives.  After 
some  SVHC 
shortlisting  bio-based  alternatives  for  SVHCs  that  could 
be  produced  at  a  short-term,  Wageningen  University  & 
Research  Centre  has  started  to  develop  alternatives  for 
polar  aprotic  solvents139.  Following  this  approach,  the 
government is trying to see new opportunities in REACH, 
inspiring substitution initiatives. 

the  essential 

On  28 March 2018,  the  Ministry  of  Infrastructure  and 
Water  Management  hosted  a  workshop  on  the  national 
safe  chemicals  innovation  agenda  (SCIA),  an  initiative  to 
promote  safe  materials  and  products  that  can  replace 
hazardous chemicals. This research agenda aims to serve 
as  guidance  for  R&D  policies  at  EU  and  Member  State 
level140.  The  SCIA  focuses  on  three  interlinking  items: 
first, 
functionalities  of  widely  used 
chemicals;  second,  hazardous  chemicals  considered 
difficult  to  substitute;  and  third,  the  potential  for  new 
market niches and/or longer-term competitive advantage 
for European businesses141. 
The  circular  economy  plan142  also  recognises  the 
opportunities  for  new 
investment  and  employment 
provided by advanced biofuels, bio-based chemicals and 
materials. 

the  Netherlands 

The  ECHA  has  taken  the  initiative  of  holding  EU-wide 
dialogues  with  all  parties  in  the  production  and  supply 
chain143.  On  5 October 2018, 
in 
cooperation  with  ECHA,  hosted  in  Rotterdam  a  dialogue 
with  the  supply  chain  on  the  topic  of  anti-fouling 
products 
innovative 
alternatives  to  conventional  paints  that  contain  heavy 
metals.  Discussions  dealt  with 
the  health  and 
environmental  implications  and  trade-offs  of  alternative 

to  discuss  how 

to  stimulate 

139 Ministry of Infrastructure and the Environment, Sustainable 
innovation of substances, materials and products, 2017. 
140 Government of the Netherlands, Workshop Towards a Safe 
Chemicals Innovation Agenda From Substitution to Safe-by-design. 
141 Government of the Netherlands, Safe Chemicals Innovation Agenda, 
June 2018, p. 4. 
142 Government of the Netherlands, A Circular Economy in the 
Netherlands by 2050, 14 September 2016. 
143 Government of the Netherlands, Speech by State Secretary for 
Infrastructure and Water Management Stientje van Veldhoven on the 
Safe Chemicals Innovation Agenda, 29 March 2018. 

25 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

anti-fouling/biocidal  applications,  as  well  as  the  current 
marketplace  challenges,  needs,  opportunities  and  next 
steps. 

a  total  ERDF  budget  of  EUR 372  million  for  2014-2020. 
The  Netherlands  obtained  funding  in  the  first  two  calls 
for projects in Rotterdam and Utrecht152. 

is 

involved 

in  REACH-related 
The  Netherlands 
committees and different  EU chemical networks such as 
HBM4EU  (Human  Biomonitory  for  the  EU)  and  R4R 
(European  chemical  regions  for  resource  efficiency), 
which  brings  together  research  institutes,  industry  and 
regions in five countries144. 

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 
sustainable 
urban  public 
buildings,  energy  efficiency  and  urban  biodiversity 
conservation. 

transport  and  mobility, 

Europe  can  be  seen  as  a  union  of  cities  and  towns. 
Around  75 %  of  the  EU  population  live  in  urban  areas145 
and  the  figure  is  projected  to  rise  to  just  over  80%  by 
2050146.  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 Award147, the Green 
Leaf Award148 and the Green City Tool149. 

Financing greener cities 

The  Netherlands  has  assigned  EUR 45  million,  or  9 %  of 
its allocation under the European Regional Development 
Fund (ERDF), and EUR 25 million, or 5 % of its allocation 
under  the  European  Social  Fund  (ESF),  to  sustainable 
urban development150. 

The  Netherlands  participates  in  the  European  Urban 
Development  Network  (UDN)151,  which  includes  more 
than  500  cities  across 
for 
implementing  integrated  actions  based  on  sustainable 
urban  development  strategies  financed  by  ERDF  in  the 
2014-2020 period. 

responsible 

the  EU 

Participation in EU urban initiatives and networks 

Dutch  municipalities  are  generally 
in  EU 
initiatives  on  environment  protection  and  climate 
change. 

involved 

Nijmegen  became  the  first  Dutch  city  to  win  the 
European  Green  Capital  Award  in  2018,  thanks  to  its 
cycling  infrastructure,  traffic  management,  clean  public 
to  waste 
transport 
management153. In addition, Horst aan de Maas has won 
the  2019  European  Green  Leaf  Award154.  The  city  was 
commended 
its  enthusiasm  and  well-planned 
inclusive urban strategy155. 

approach 

excellent 

and 

for 

to 

support 

initiative 

A  total  of  10  Dutch  municipalities  are  involved  in  the 
URBACT 
sustainable  urban 
development, through 24 different thematic networks156. 
Six  of  these  networks  are  currently  led  by  Dutch  cities: 
Eindhoven coordinates  CHANGE! for the social design of 
public  services;  Delft  manages  EUniverCities  for  the 
exchange  of  good  practice  among  knowledge  cities; 
Rotterdam,  with  My  Generation  and  My  Generation  at 
Work,  is  working  towards  greater  employability  and 
employment of young people, and with ResilientEurope is 
trying  to  foster  urban  sustainability;  and  Utrecht  is 
local 
leading  CityLogo  to  develop  new  styles  of 
governance. 

Within the UDN initiatives, the ERDF is supporting urban 
innovative  actions  (UIA)  as  a  way  of  testing  new  and 
unproven solutions to address urban challenges. UIA has 

144 European Commission. Improving resource efficiency in SMEs, 
December 2017, p. 43. 
145 European Commission, Urban Europe, 2016. 
146 European Commission, Eurostat, Urban Europe, 2016, p.9. 
147 European Commission, European Green Capital. 
148 European Commission, European Green Leaf Award.  
149 European Commission, European Green City Tool.  
150 Government of the Netherlands, Partnership Agreement 2014-2020, 
2014, p. 79. 
151 European Commission, The Urban Development Network . 

Several  Horizon  2020  network  projects  have  also 
contributed  to  the  sustainability  of  Dutch  cities.  CIVITAS 
includes 
the 
Netherlands  in  a  common  effort  to  achieve  cleaner  and 
better  transport  in  cities157.  Amsterdam  is  part  of  the 

seven  municipalities 

representing 

152 European Commission, Urban Innovative Actions . 
153 European Commission and City of Nijmegen, European green capital 
2018, 2017, p. 15. 
154 European Commission, Finalists for the 2020 European Green Capital 
and 2019 European Green Leaf Award. 
155 European Commission, Winners European Green Leaf 2019. 
156 URBACT, Associated Networks by country. 
157 European Commission, Horizon 2020 Civitas Project. 

26 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

ClairCity  project,  a  citizen-led  initiative  to  reduce  air 
pollution in cities158. FosterReg, intended to boost public 
capacity  to  plan,  finance  and  manage  integrated  urban 
regeneration  for  sustainable  energy  uptake,  also  has 
Dutch cities as participants159. 

Over  70 %  of  Dutch  municipalities  have  climate  policies 
and action plans160. 24 are involved with the EU Covenant 
of Mayors  with coordination  from Rijkswaterstaat. As of 
May  2018,  Delft,  Midden-Delfland  and  Nijmegen  had 
already implemented their action plans and their results 
were  being  monitored.  Another  16  cities  have  at  least 
presented their climate action plan and commitments to 
be met by 2020 or 2030161. 

These  urban 
initiatives  and  networks  should  be 
welcomed and encouraged, as they contribute to a better 
urban  environment.  In  2017,  15.2 %  of  city  residents 
considered  their  residential  area  to  be  affected  by 
pollution  or  other  environmental  problems,  down  from 
16.5 %  in  2016  and  17.5 %  in  2015.  These  figures  are 
lower than the EU 28 levels (20 % in 2017, 18.9 % in 2016 
and  19.2 %  in  2015),  but  much  better  than  those  of  the 
neighbouring countries (22.7 % for Belgium and 35 % for 
Germany in 2017)162. 

Nature and cities 

More  than  35 %  of  the  Natura  2000  network  in  the 
Netherlands is to be found within functional urban areas 
(FUAs)163,  which  is  well  above  the  EU  average  of  15 % 
(see Figure 19). 

The  national  ecological  network  is  the  main  instrument 
for maintaining Natura 2000 areas. Provincial authorities 
are  responsible  for  this  network,  but  budget  and 
resource cuts at national level have limited the network’s 
operations. 

Currently,  the  Netherlands  is  reviewing  laws  on  the 
environment and planning to simplify them and combine 
them  in  a  single  Environment  and  Planning  Act164.  The 
Act  will  replace  15  laws,  including  the  Water  Act,  the 
Crisis  &  Recovery  Act  and  the  Spatial  Planning  Act.  One 
main consequence is that municipalities will not have to 
draft  several  land-use  plans:  instead,  there  will  be  one 
environmental plan for the whole municipality. 

Although having one environmental plan will improve the 
current  situation  (over  100  municipalities  already  had 

plans  in  place),  the  government  should  take  care  that 
simplifying  them  does  not  limit  them,  to  ensure  that 
Natura  2000  areas  are  correctly  preserved.  The  new 
Environment  and  Planning  Act  specifies  the  duty  to 
implement  management  plans  for  Natura  2000  sites  by 
provincial governments.  

Figure  19:  Proportion  of  Natura  2000  network 
Functional Urban Areas (FUA)165 

in 

levels 

Several  ‘nature-city’  projects  are  currently  in  progress. 
The  Amsterdam  Dune  project  seeks  to  restore  and 
improve  the  Kennemerland  Zuid  Natura  2000  area166. 
Other projects involve multiple areas, like the action plan 
to  reduce  nitrogen 
in  Natura  2000  areas 
generally167.  In  the  ‘green  deal  for  temporary  nature’, 
parties  teamed  up  to  promote  temporary  nature  areas. 
Private  parties  such  as  port  and  excavation  companies, 
the  central  government  and  nature  conservation 
organisations  worked  together  to  remove  obstacles  in 
legislation,  allowing  protected  bird  and  plant  species  to 
stay in semi-urban areas168. 

Urban sprawl 

The  Netherlands  had  the  highest  weighted  urban 
proliferation  rate,  at  6.61  UPU/m2  169  in  2009  compared 
to a European average (EU-28+4) of 1.64 UPU/m2, having 
increased by 3.31 % from 2006 to 2009170. 

Traffic congestion and urban mobility 

Many  subjects  addressed  in  this  report  are  to  some 
extent  related  to  traffic  volumes  and  congestion, 
especially air quality and noise. 

The total number of road vehicles has increased, to 11.2 
million  in  2018171.  More  than  2  million  of  these  are 

158 European Commission, Horizon 2020 Claircity Project. 
159 European Commission, Horizon 2020 FosterReg Project. 
160 Covenant of Mayors for Climate and Energy, Netherlands country 
coordinators. 
161 Covenant of Mayors for Climate and Energy, Signatories. 
162 European Commission, Pollution, grime or other environmental 
problems by degree of urbanisation, 2018. 
163 European Commission, Definition of Functional Urban Areas. 
164 Government of the Netherlands, Revision of environment planning 
laws . 

165 European Commission, The 7th Report on Economic, Social and 
Territorial Cohesion, 2017, p. 121. 
166 European Commission, LIFE Project Amsterdam Dune. 
167 Government of the Netherlands, Programma Aanpak Stikstof (PAS). 
168 Government of the Netherlands, Green Deal Temporary Nature, 
2015. 
169 Urban Permeation Units measure the size of the built-up area as well 
as its degree of dispersion throughout the region. 
170 EEA, Urban Sprawl in Europe, Annex I, 2014, pp.4-5. 
171 Statistics Netherlands (CBS), Motor Vehicles. 

27 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

commercial vehicles172; the number of vehicles per 1 000 
habitants rose from 636.1 in 2014 to 656.4 in 2018. 

This  increase  has  resulted  in  more  hours  spent  annually 
in road congestion, up from 30.3 in 2014 to 31.5 in 2016. 
The  Netherlands  has  the  ninth  highest  figures  in  the 
EU173. 

Traffic  intensity  and  congestion  varies  greatly  between 
regions  and  infrastructure  types.  The  highest  traffic 
intensity  is  found  in  the  Utrecht  region,  mainly  because 
of the national trunk roads there such as the A1, A2, A12, 
A27 and A28174; and on the A13 between Rotterdam and 
The Hague.  Traffic intensity is rising,  with an increase of 
8 % in 2012-2017175. 

By  contrast,  Dutch  cities  generally  have  low  levels  of 
traffic  congestion.  Haarlem  is  the  only  Dutch  city  with 
congestion levels between 25 % and 50 %, while 14 other 
cities  have  levels  of  between  15 %  and  25 %176.  In 
comparison  with  other  EU  cities,  Haarlem  is  the  82nd 
most  congested city (out  of  215 cities on the list), while 
The  Hague  is  the  121st,  Amsterdam  the  138th  and 
Rotterdam the 178th. 

Regarding  urban  mobility,  around  50 %  of  Dutch 
employees  commute  to  work  from  other  areas177.  In 
such  as  Nieuwegein  and 
certain  municipalities, 
than  70 %  of  employees 
Haarlemmermeer,  more 
commute  from  other  areas178.  Use  of  public  transport, 
especially buses and trams, fell between 2000 and 2005 
due to the arrival of new carriers as a result of tendering 
in  urban  and  regional  transport179.  Nonetheless,  recent 
years  have  seen  a  gradual  increase  in  the  use  of  public 

transport, and alternative means of transport: from 2005 
to  2016,  bicycles  gained  ground  on  cars  and  public 
transport  in  terms  of  their  share  of  commuting  trips  in 
metropolitan areas (bicycle use has grown by nearly 12 % 
since  2005).  All  in  all,  cars  remain  dominant  for  longer-
distance  trips  to  and  from  major  cities,  while  trains 
attract a high proportion of commuters180. 

In  2016,  cars  accounted  for  46 %  of  trips,  while  bicycles 
(including e-bikes) had risen to 28 %, and public transport 
(bus,  metro,  tram  and  train)  accounted 
for  4 %. 
Pedestrian  trips  accounted  for  18 %  of  the  total181.  The 
modal split for inland passenger transport182 was 88 % for 
cars (EU-28 83.4 %) 2 % for buses and trolley buses (EU-
28 9.1 %) and 10 % for trains (EU-28 7.6 %)183. So cars are 
still the favoured mode of transport for longer distances, 
with the Netherlands having the third highest proportion 
of  passenger  transport  by  car  in  the  EU,  after  Portugal 
and Lithuania. 

Among  the  main  challenges  observed  in  this  report 
(water,  air,  nature  and  biodiversity),  it  is  especially  air 
quality  —  to  an  extent  related  to  traffic  congestion  — 
that  requires  priority  at  local  level.  Innovative  traffic 
management solutions are being developed and tested in 
a number of cities. For instance, the Amsterdam Institute 
for Advanced Metropolitan Solutions is developing a fleet 
of  autonomous  boats  that  could  be  used  to  remove 
floating  waste  from  the  canals184.  In  Rotterdam,  many 
local  measures  have  been  taken  in  recent  years  to  help 
the 
reduce 
185. 
concentrations  of  pollutants  such  as  soot  and  NO2
DiTTlab,  a  research 
lab  founded  by  the  Technical 
University  of  Delft  and  business  consultants  CGI 
Nederland, is developing an urban mobility lab to analyse 
multi-modal  traffic  flows  and  an  integrated  mobility 
management  architecture  programme  to 
implement 
congestion avoidance186. 

the  use  of  older  diesel  cars  and 

The  2017  EIR  stated  that  consistency  between  national 
and municipal policies should be improved, and excessive 
bureaucracy reduced. The situation is improving with the 
gradual  implementation  of  sustainable  urban  mobility 
plans and the new Environment Act, which is foreseen to 
enter into force on 1 January 2021187, 188. 

172 Vehicle exclusively or primarily designed for the commercial 
transport of goods and passengers, for special purposes or to haul semi-
trailers. This includes vans, lorries, road tractors, special purpose 
vehicles, buses, trailers and semi-trailers. 
173 European Commission, Hours spent in road congestion annually. 
174 Statistics Netherlands (CBS), Trends in the Netherlands 2017. 
175 Statistics Netherlands (CBS), Traffic Intensity 2017, 21 February 2018. 
176 TOMTOM, TOMTOM Traffic Index. 
177 Statistics Netherlands (CBS), More than half of employees commute 
to work, 10 June 2013. 
178 The number of incoming commuters in Haarlemmermeer is high 
largely because it hosts Amsterdam Schiphol Airport . 
179 European Metropolitan Transport Authorities and Government of 
the Netherlands, Public Transport in the Netherlands, 2010, p. 15. 

180 Government of the Netherlands, Mobility report 2017, 23 October 
2017, p. 16. 
181 Statistics Netherlands (CBS), Transport and Mobility 2016 . 
182 The relation between mode of transport and kilometres travelled 
(excluding bicycles and other alternative methods). 
183 Eurostat, Passenger transport Statistics by modal split. 
184 Amsterdam Institute for Advanced Metropolitan Solutions, Roboat 
Project. 
185 EIR Dialogues, Summary Country Dialogue Netherlands 12 April 
2018. 
186 Dutch Mobility Innovations, DiTTlab. 
187 ELTIS Urban Mobility Observatory, Netherlands country page. 
188 Government of the Netherlands, De Omgevingswet. 

28 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

Part II: Enabling framework: implementation tools 

4. Green taxation, green public procurement, environmental 

funding and investments 

in the  sector would be charged an additional levy based 
on  the  price  difference  between  the  EU  allowances  and 
the price floor. In order to better reflect CO2 emissions, a 
rebalancing of the energy tax for consumers will see gas 
costs increase by EUR 0.03 per cubic metre, while tax on 
electricity  will  decrease  by  EUR 0.0072  per  kilowatt 
hour192. 

Figure  20:  Environmental  tax  revenues  as  %  of  GDP 
(2017)193 

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. 

The  Netherlands’  environmental  tax  revenues  remain 
higher than the EU average, accounting for 3.33 % of GDP 
in 2017 (the EU-28 average was 2.4 % of GDP) as shown 
in  Figure  20,  and  energy  taxes  accounted  for  1.86 %  of 
GDP  (EU  average  of  1.84 %)189.  In  the  same  year, 
environmental  tax  revenues  were  8.49 %  of  total 
revenues  from  taxes  and  social-security  contributions 
(considerably higher than the EU28 average of 5.97 %). 

The  structure  of  taxation  shows  the  proportion  of 
revenues from labour tax in total tax revenues was higher 
than the EU average, with 52 % in 2016, while the implicit 
tax  burden190  on  labour  was  32.9 %191.  Consumption 
taxes  remained  relatively 
low  (29.7 %  of  total  tax 
revenue,  20th  in  EU-28),  pointing  at  a  potential  for 
shifting  taxes  from 
in 
particular  to  taxation  of  environmental  pollution  and  to 
use of natural resources.  

labour  to  consumption  and 

Semester 

Commission’s 

in  the 
The  Commission  has  repeatedly  highlighted 
annual 
(the 
European 
assessment  of  Member  States)  the  potential  to  modify 
the taxation system in the Netherlands. In the European 
Semester country report for 2018, it was mentioned that 
there  are  ongoing  initiatives  aiming  to  offset  reductions 
in income tax by increasing taxes in the fields of energy, 
environment  and  consumption.  The  government  also 
aims  to  introduce  a  minimum  price  for  CO2  generated 
from  electricity  —a  carbon  price  floor—  starting  at 
in  2020  and  rising  to  EUR 43  by  2030  to 
EUR 18 
supplement the price signal from the EU ETS. Companies 

189 Eurostat, Environmental tax revenues, 2019. 
190 Understood as the cost of an activity that is not collected by the 
government but may be the result of government policies on labour. 
191 European Commission, Taxation Trends Report, 2018. 

29 

There  are  other  cases  showing  sound  fiscal  measures 
being  implemented  in  the  area  of  environment.  A  good 
example is the free plastic waste disposal in the ports of 
Rotterdam  and  Amsterdam194.  Also,  taxes  and  fees  paid 

192 European Commission, European Semester Country Report 2018, p. 
52. 
193 Eurostat, Environmental tax revenues, 2019. 
194 Institute for European Environmental Policy, Case Studies on 
Environmental Fiscal Reform, Plastic waste free disposal in the 
Netherlands. 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

to  regional  water  authorities  have  contributed  to 
innovation in the wastewater treatment sector195. 

grams per kilometre, below the EU average of 118 grams 
in 2016203. 

Fossil  fuel  subsidies  decreased  from  2008-2018  and 
currently  only  an  indirect  subsidy  to  fossil  fuels  remains 
active  (ETS  compensation  to  improve  energy  efficiency, 
which  incentivises  the  use  of  electricity  and,  as  81 %  of 
electricity  comes  from  fossil  fuels,  benefits  fossil  fuels). 
Some tax exemptions are still in place for the use of fossil 
fuels  in  horticulture  and  by  non-profit  and  religious 
institutions.  These  exemptions  added  up  to  EUR 144 
million 
in  2016,  and  the  budgetary  transfers  and 
subsidies  amounted  to  over  EUR 51  million.  However, 
most  of  the  subsidies  and  exemptions 
for  using 
petroleum and natural gas have been taken away196. 

Some  progress  has  been  made  on  reducing  the  ‘diesel 
differential’  (difference  in  the  price  of  diesel  versus 
petrol)  since  2005.  In  2016  there  was  still  a  59 %  gap 
between petrol and diesel tax rates, while in 2005 it was 
75 %197.  Excise  tax  rates  levied  on  petrol  and  diesel  in 
2016 slightly increased in comparison with those in 2015 
(EUR 0.77 per litre for petrol and EUR 0.48 for diesel)198. 

Tax  treatment  for  company  cars  is  not  a  cause  for 
concern  in  the  Netherlands199.  These  vehicles  are  taxed 
based  on  CO2  emissions  (if  private  use  exceeds  500 km 
per  year).  No  relevant  fiscal  measures  have  been 
introduced regarding this type of car in 2018200. 

CO2-based  motor  vehicle  taxes  are  in  place  in  the 
country.  The  registration  tax  (Belasting  Personenauto’s 
Motorrijwielen or BPM) is calculated based on emissions. 
A  diesel  surcharge 
is  applied  to  vehicles  with  CO2 
emissions  of  more  than  63 g/km.  The  rates  of  road  tax 
(ACT) also take into account CO2 emissions201. 

Incentives to encourage the purchase of cars with lower 
CO2  emissions  were  common  in  2016,  linked  to  annual 
circulation  taxes,  road  tolls  and  congestion  or  low-
emission  zone  charges;  but  they  are  also  linked  to  the 
acquisition  of  cleaner  vehicles.  In  addition,  there  are 
incentives  connected  to  the  preferential  use  of  public 
infrastructure202.  New  vehicles  purchased 
the 
Netherlands  are  among  the  most  environmentally 
friendly  in  the  EU,  with  average  CO2  emissions  of  105.9 

in 

195 Institute for European Environmental Policy, Case Studies on 
Environmental Fiscal Reform, Fees and taxes of regional water bodies in 
the Netherlands. 
196 OECD, Inventory of Support Measures for Fossil Fuels, 2018. 
197 European Environment Agency 2017, Environmental taxation and EU 
environmental policies, p. 26. 
198 European Commission, Taxes in Europe Database, 2018. 
199 European Commission, Taxation of commercial cars in Belgium, 
2017, p. 3. 
200 FleetEurope, Major changes to company car taxation in Europe. 
201 ACEA, CO2 based motor vehicle taxes in Europe. 
202 European Environmental Agency, Appropriate taxes and incentives 
do affect purchases of new cars, 18 May 2018 . 

The use of alternative fuels in new passenger cars sold in 
the  Netherlands  has  considerably  increased  over  recent 
years.  In  2016  the  proportion  of  new  passenger  cars 
using  alternative  fuels  was  approximately  five  times 
higher  than  in  2012204.  Most  of  these  vehicles  are 
electric.  The  Netherlands  is  among  the  Member  States 
incentivising the use of electric vehicles to improve local 
air  quality  by  applying  lower  excise  duties  for  electricity 
supplied to charging stations205. 

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 
and  can  help  support  sustainable  innovative  businesses. 
The Commission has proposed EU GPP criteria206. 

The  Netherlands  is  one  of  the  front-runners  in  the  EU 
with  regard  to  GPP.  It  was  already  a  priority  before  the 
EU Directives on GPP were implemented. 

in  policies 

The  country  has  in  place  several  circular  procurement 
practices 
the  circular 
economy207,  and  the  Dutch  green  deal  programme  has 
initiated  a  number  of  pilots  and  provided  guidance  for 
functional specifications. 

for  developing 

The  Netherlands  has  set  an  ambitious  government  level 
target  on  GPP  and  it  applies  it  not  only  to  the  central 

203 European Environment Agency, Average CO2 emissions from new 
passenger cars sold in EU-28 Member States plus Norway, Iceland and 
Switzerland in 2016. 
204 European Commission, Transport in the European Union Current 
Trends and Issues, 2018, p. 100. 
205 European Commission, European Semester Country Report 2018, p. 
52. 
206 In the Communication ‘Public procurement 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. 
207 European Parliament, Study on Green Public Procurement and the 
EU Action Plan for the Circular Economy, 2017, p. 50. 

30 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

government,  but  also  at  regional  and  local  levels;  this 
target  aims  at  reducing  over  one  million  tonne  of  CO2 
emissions per year by 2021. 

In  the  Netherlands  there  are  qualitative  but  no  national 
quantitative  targets  in  its  five-year  action  plan.  GPP  is 
seen as an instrument that contributes to realising policy 
objectives  with  sustainability  as  an  integral  part  of  the 
procurement process. 

The  country  currently  offers  a  ‘Circular  Procurement 
Academy’208. Public procurers can only participate if they 
are  tendering  for  an  innovative  solution  and  if  they  are 
willing  to  meet  regularly  with  other  participants.  During 
these meetings, problems, questions and experiences are 
discussed.  The  Netherlands  also  supports 
learning 
networks  and  pilot  projects,  and 
is  working  on 
establishing  monitoring  systems  to  make  the  effects  of 
GPP visible. 

A new green deal on circular procurement was signed by 
50  public  and  private  organisations  and  companies, 
adding up to EUR 100 million in purchasing power209. As 
mentioned  within  the  circular  economy  section,  the 
initiative  is  open  to  all  organisations  that  want  to 
purchase in an environmentally  friendly way, supporting 
the circular economy. Circular procurement is also part of 
the  green  deal  “sustainable  health  for  a  sustainable 
future”,  signed  by  132  parties  aiming,  among  other 
objectives,  at  reducing  of  GHG  emissions  and  resource 
use. 

Local initiatives are also ongoing on this field. Almost 160 
municipalities,  provinces  and  water  boards  have  signed 
the  national  sustainable  public  procurement  manifesto. 
This has helped to increase awareness and understanding 
of,  and  commitment  to  GPP.  A  good  example  is  the 
municipality  of  Goeree  Overflakkee,  which  created  a 
sustainability  programme  presented  during  the  last  EIR 
Dialogue with the Netherlands210. Another example is the 
city of Haarlem, which coordinates the partnership of the 
EU Urban Agenda  on procurement, in which  the circular 
economy is an important theme. 

The  Commission  would  welcome  a  continuation  of  the 
sharing of good practice on circular  procurement  by the 
Netherlands with other countries. 

208 Dutch Public Procurement Expertise Centre, Supporting Circular 
Procurement: experiences from the Netherlands, 2016. 
209 Green Deals Netherlands, Circulair inkopen 2.0. 
210 EIR Dialogues, Summary Country Dialogue Netherlands 12 April 
2018. 

31 

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, 

Achieving  sustainability  involves  mobilising  public  and 
private  financing  sources211.  Use  of  the  ESIFs212 
is 
essential  if  countries  are  to  achieve  their  environmental 
goals  and  integrate  these  into  other  policy  areas.  Other 
instruments such as Horizon 2020, the LIFE programme213 
and the European Fund for Strategic Investments (EFSI)214 
may also support the implementation and spread of good 
practices. 

European Structural and Investment Funds 2014-2020 

Through  seven  national  and  regional  programmes,  the 
Netherlands has been allocated EUR 1.95 billion from the 
ESIF  over  the  period  2014-2020.  With  a  minimum 
national  contribution  of  EUR 1.85  billion,  a  total  budget 
of  EUR 3.57  billion  is  to  be  invested  in  the  country  over 
this  period215.  From  this,  around  EUR 667  million  has 
been  allocated  from  EU  sources  to  environmental 
protection  and  resource  efficiency,  the 
low-carbon 
economy  and  other  environment-related  programmes; 
and  EUR 361  million  has  been  allocated  from  national 
sources through co-financing216. 

The  Netherlands  Enterprise  Agency  (Rijksdienst  voor 
Ondernemende  Nederland  (RVO))  publishes  information 
about available funds for environmental investment at its 
website.  For  2018,  it  had  reserved  in  total  EUR  139 
million  to  be  divided  over  9  themes, 
including: 
agriculture,  biobased  economy,  biodiversity,  circular 
economy,  sustainable  building,  sustainable  transport, 
Green Deals and mobile installations. 

Cohesion policy 

The Netherlands receives over EUR 1 400 million in total 
cohesion  policy  funding  for  the  2014-2020  period, 
including  EUR 389  million 
territorial 
cooperation  and  EUR 510  million  from  the  ESF217.  There 

for  European 

211 See, for example, Action plan on financing sustainable growth 
(COM(2018) 97).  
212 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’. 
213 European Commission, LIFE programme. 
214 European Investment Bank, European Fund for Strategic Investments 
215 European Commission, European Structural and Investment Funds 
(Country factsheet the Netherlands), 2017. 
216 Commission services, using DG Regio data. 
217 European Commission, Cohesion Policy and the Netherlands, 2014. 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

are  four  ERDF  operational  programmes  (OPs)  and  one 
ESF OP218. There are no direct allocations for investments 
in environmental infrastructure in the Netherlands219, 220. 

Nevertheless,  the  European  funds  present  a  strong 
foundation  for  achieving  sustainability221.  One  of  the 
European  Commission’s  investment  priorities  over  the 
2014-2020  period  is  ‘the  promotion  of  a  low-carbon 
resource-efficient  economy  enhancing  energy  efficiency 
and  the  increased  use  of  renewable  energy  sources’222. 
Boosting 
to 
investments  will 
transitioning towards a low-carbon economy. 

contribute 

these 

On  estimating  environmental  expenditure,  innovation 
and  low-carbon  economy  play  a  clear  role.  The  ERDF 
allocation  from  EU  sources  for  indirect  environmental 
investments is EUR 148 million223. In addition, around 9 % 
of  the  ERDF  budget  is  being  used  for  sustainable  urban 
development, concentrated in one of the OPs (West). 

The  last  years,  the  ERDF  supported  projects  such  as  a 
Bioprocess  Pilot  Facility,  to  experiment  and  learn  how 
sustainable  production  processes  can  be  scaled  up;  and 
the Amsterdam Smart City Project, to help create a more 
sustainable,  energy-efficient  city, 
reducing  energy 
consumption by 20 %. 

Current data suggest that the EU funds allocated for the 
Netherlands in the 2007-2013 period were fully spent224.  

Rural development 

The  Netherlands  faces  some  environmental  pressures  in 
rural  areas,  mainly  on  water  quality  and  Natura  2000 
conservation status. 

The  Dutch  Development  Programme  (RDP)  outlines  the 
country’s  priorities  when  it  comes  to  using  EUR 1 630 
million in funds available for the seven-year period 2014-
2020.  This  funding  includes  EUR 765  million  from  the 
EAFRD,  EUR 449  million  of  national  co-funding  and 
EUR 413 million of additional national funding top-ups225, 

218 European Commission, OP North, OP West, OP East, OP South. 
219 Direct environmental investments under CF and ERDF include 
investments in waste, water, air, biodiversity, land rehabilitation, 
climate mitigation and adaptation and risk prevention. 
220 COWI-MILIEU, Study on the integration of environmental concerns in 
the Cohesion Policy funds (ERDF, ESF, CF), 2017, p. 35. 
221 ‘The objectives of the ESI Funds shall be pursued in line with the 
principle of sustainable development and with the Union’s promotion 
of the aim of preserving, protecting and improving the quality of the 
environment, as set out in Article 11 and Article 191(1) TFEU, taking 
into account the polluter pays principle’ Article 8, Regulation (EU) No 
1303/2013. 
222 European Commission, Summary of the Partnership agreement for 
the Netherlands, 2014, p. 2. 
223 Commission services, using DG Regio data. 
224 European Commission, Cohesion Policy — Supporting Growth and 
jobs in the Netherlands (2007-2013), 2015; and European Commission, 
SF 2007-2013 Funds Absorption Rate, 2018. 
225 European Commission, Factsheet on 2014-2020 Rural Development 
Programme for the Netherlands, 2017, p. 1. 

226. 

The  RDP  has  a  solid  environmental  approach,  aiming  to 
have 6 % of agricultural land under contract to stimulate 
biodiversity and improve water and soil management. In 
fact,  56.4 %  of  the  RDP’s  funds  will  be  used  to  attain 
these  objectives  and  for  other  environmental  priorities 
included  under  the  ecosystems  management  section  of 
the RPD227. 

In  total,  EUR 443  million  from  EU  sources  has  been 
allocated 
for  the  environment  within  the  EAFRD, 
including  EUR 248  million  for  agri-environment-climate, 
Natura  2000,  Water  Framework  Directive  and  forest 
services and conservation. The remaining EUR 195 million 
has  been 
indirect  environmental 
for 
investments,  including  organic  farming  and  investments 
in  forest  area  development  and  maintenance,  among 
others228. 

allocated 

comprised 

agri-environment  measures 

The 
can 
potentially  play  a  very  strong  role  in  reversing  the 
biodiversity  decline  in  the  country  in  some  targeted 
areas.  However,  as  stated  in  the  2017  EIR,  the  positive 
effects  are  limited  due  to  the  absence  of  an  ambitious 
baseline and ambitious greening. 

One  of  the  EAFRD-RDP  projects  supports  traditional 
biomass heating for cut-flower production229. This is part 
of  a  strategy  to  ensure  the  economic  survival  and 
flower  plantations, 
environmental  sustainability  of 
replacing the use of natural gas. 

it 

that 

If the Netherlands is to achieve its environmental goals, it 
is  essential 
the  environmental 
improves 
sector.  Primary 
the  agricultural 
sustainability  of 
agriculture  and  horticulture  account  for  15 %  of  GHG 
emissions  (EU-28 12 %),  while the population  of birds in 
farming  areas  has  fallen  over  the  past  30  years  by 
70 %230. 

On integrating environmental concerns into the common 
agricultural policy (CAP), the  two key areas are: (i) using 
the  EAFRD  to  pay  for  environmental  land  management 
and other environmental measures; and (ii) ensuring the 
first  pillar  of  the  CAP  is  implemented  effectively  with 
regard to cross-compliance and first pillar ‘greening’. The 
Netherlands has a ceiling for Direct Payments of EUR 3.62 
billion  for  the  period  2015-2020,  30 %  of  which  is  being 
the 
allocated 

to  greening  practices 

that  benefit 

226 The European Network for Rural Development, 2014-2020 Rural 
Development Programme: Key facts & figures (The Netherlands), 2016. 
227 European Commission, Factsheet on 2014-2020 Rural Development 
Programme for the Netherlands, 2017, p. 3. 
228 Commission services, using DG Regio data. 
229 European Commission, European Structural and Investment Funds 
(Country factsheet the Netherlands), 2017. 
230 SWD(2017) 406. 

32 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

environment231. 

Figure 21: ESIF 2014-2020 – EU allocation by theme, the 
Netherlands (EUR billion)232 

In 2018, the Netherlands transferred EUR 60 million from 
the first pillar of the CAP, allocated to agri-environmental 
commitments, 
and 
cooperation in the form of pilot projects. 

non-productive 

investments 

The  latest  financial  data  available  (on  the  2007-2013 
period)  show 
rural 
that 
development  funds 
in  the  Netherlands  was  99.7 %, 
similar to the EU average (97.3 %)233. 

the  absorption 

rate  of 

European Maritime and Fisheries Fund (EMFF) 

The  Netherlands  receives  around  EUR 128  million  in  co-
financing  for  fisheries  and  the  maritime  sector,  with  an 
EU  contribution  of  EUR 101  million234.  Several  projects 
benefiting  the  environment  have  been  financed  under 
priorities one (sustainable fisheries) and two (sustainable 
aquaculture)  of  the  OP235.  The  environmental  funds 
allocated  from  EU  sources  represent  more  than  EUR 75 
million for the period 2014-2020236. 

Examples  of  success  stories  that  show  the  green  side  of 
the EMFF are: the  Master Plan for Sustainable  Fisheries, 

231 Regulation (EU) No 1307/2013, p. 656. 
232 European Commission, European Structural and Investment Funds 
Data By Country. 
233 COM (2017) 554 and European Parliament, Agriculture and the EU’s 
Common Agricultural Policy in the Netherlands, 2016, p. 21. 
234 European Commission, European Maritime and Fisheries Fund in the 
Netherlands, 2015. 
235 Ministry of Economic Affairs and Climate Policy of the Netherlands, 
Operationeel Programma EFMZV van Nederland 2014-2020, 2014, p. 
95. 
236 European Commission, European Maritime and Fisheries Fund in the 
Netherlands, 2015, p. 2. 

33 

aiming to replace old fishing gear with more sustainable 
alternatives; and the Pulsed fish-stunning at  sea project, 
to  improve  animal  welfare  through  the  development  of 
onboard fish-stunning devices. 

The Connecting Europe Facility (CEF) 

The  CEF  is  a  key  EU  funding  instrument  developed 
specifically  to  direct 
investment  towards  European 
transport,  energy  and  digital  infrastructure  to  address 
identified  missing  links  and  bottlenecks  and  promote 
sustainability. 

By  the  end  of  2017,  the  Netherlands  had  signed 
agreements  for  EUR 357  million  for  projects  under  the 
CEF237. 

EUR 150  million  to  finance  green  shipping  has  been 
granted  using  the  CEF  and  EFSI  instruments  with  the 
support  of  the  EIB238.  The  project  is  open  for  both  the 
retrofitting  of  the  existing  fleet,  and  projects  that 
envisage  the  construction  of  new  vessels  with  a  green 
innovation aspect. 

Horizon 2020 

The  Netherlands  has  benefited  from  Horizon  2020 
funding  since  the  programme  started  in  2014.  As  of 
January  2019,  1 777  participants  have  been  granted  a 
maximum  amount  of  EUR 681  million  for  projects  from 
the  Societal  Challenges  work  programmes  dealing  with 
environmental issues239 240.  

In  addition  to  the  abovementioned  work  programmes, 
climate and biodiversity expenditure is present across the 
entire  Horizon  2020. 
In  the  Netherlands,  projects 
in  all  Horizon  2020  working 
accepted  for  funding 
programmes  until  December  2018  included  EUR  694 
million  destined  to  climate  action  (23 %  of  the  total 
Horizon  2020  contribution  to  the  country)  and  EUR  115 
million  for  biodiversity-related  actions  (3.8 %  of  the 
Horizon 2020 contribution to the country)241. 

Several  successful  projects  are  taking  place 
in  the 
Netherlands.  The  Alliance  for  Sustainable  Cities242  is 

237 European Commission, European Semester Country Report for the 
Netherlands, 2018, p. 13. 
238 European Investment Bank, Investment Plan for Europe: EUR 150 
million to finance green shipping. 
239 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. 
240 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. 
241 European Commission own calculations based on CORDA (COmmon 
Research DAta Warehouse). 
242 European Commission, Together for sustainable cities: an 
international research alliance. 

 
                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

trying  to  develop  comprehensive  approaches  for  the 
management  of  food,  water  and  energy,  which  are 
usually  considered  in  isolation.  Another  international 
project  (TRANSRISK)  is  aiming  to  help  guide  the  global 
transition  from  high-carbon  economies  to  low-carbon 
economies by providing policymakers with the tools and 
information they need to implement effective, evidence-
based climate strategies243. 

LIFE programme 

Since  1992,  when  the  LIFE  programme  was  launched,  a 
total  of  198  projects  have  been  co-financed  in  the 
Netherlands244.  Altogether,  they  represent  a  total 
investment of EUR 585 million, of which EUR 167 million 
has  been  provided  by  the  EU245.  For  the  period  2014-
2017, EUR 37 million were allocated to Dutch projects by 
the EU246. 

Nevertheless,  other  projects  are  indirectly  connected  to 
environmental  protection.  This  is  the  case,  for  example, 
with  signed  loans  to  support  dairy  farmers’  investments 
in  biogas  installations,  or  signed  loans  to  acquire  new 
equipment  to  ensure  that  all  the  electric  trains  in  the 
Netherlands  continue  running  on  green  electricity 
supplied by sustainable power generation252. 

The  EIB  has  also  provided  loans  to  projects  that  fight 
climate  change  in  the  Netherlands.  An  example  is  the 
financing agreement with the Ons Middelbaar Onderwijs 
association to carry out the sustainable refurbishment or 
new construction of a number of schools in the province 
of North Brabant, improving their energy efficiency253. 
Figure 22: EIB loans to the Netherlands in 2018254 

of 

and 

feasibility 

economic 

Two  Dutch  projects  were  included  in  the  Best  LIFE 
Projects  2016-2017247.  The  first  was  QUARTERBACK  for 
LIFE  Project248,  included  in  LIFE  Nature  and  Biodiversity, 
which aimed to reduce the environmental impact of the 
production  of  crude  glycerine.  It  demonstrated  the 
technical 
turning 
oleochemical-based glycerine into biogas to be used on-
site  to  replace  natural  gas,  generating  approximately 
10 %  of  the  energy  required  and  saving  a  substantial 
amount  of  water  and  energy.  The  second  was  the 
Healthy  Heath  Project249, 
LIFE 
Environment  and  Resource  Efficiency.  It  restored  the 
in 
natural  water  balance 
the 
Dwingelderveld  National  Park,  transforming 
former 
agricultural enclaves in Noordenveld back into heathland 
habitats. 

in  over  285 ha 

included  under 

European Investment Bank 

Over the period 2013-2017, EIB loans to the Netherlands 
amounted to nearly EUR 10.4 billion250. The EIB Group251 
loaned  Dutch  businesses  and  public  institutions  more 
than EUR 2.32 billion in 2018, as shown in Figure 21, from 
which  around  EUR 245  million  (10.5 %)  were  directly 
invested in environment-related projects. 

243 European Commission, Guiding the low-carbon transition with 
evidence-based policy tools. 
244 European Commission, LIFE in The Netherlands, 2017. 
245 European Commission, LIFE by country: The Netherlands. 
246 Commission services based on data provided by EASME.  
247 European Commission, Best LIFE-Environment Projects 2016-2017. 
248 European Commission, QUARTERBACK for LIFE — Crude glycerine 
water used on-site as a feedstock in an anaerobic digestion reactor to 
produce the renewable fuel biogas. 
249 European Commission, ‘Healthy Heath’ — Propagation and 
development of dry, moist and wet heath in the Dwingelderveld SPA 
and SCI. 
250 European Investment Bank, Delivering impact in finance in the 
Netherlands, 2017. 
251 The EIB Group includes EIB and EFSI investments and loans. 

34 

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. As of January 2019, the EFSI had mobilised more 
in  the  Netherlands,  and  the 
than  EUR 2.2  billion 
secondary 
is 
expected to be more than EUR 10 billion255, 256. 

investment  triggered  by  those  funds 

Notably,  EFSI  investments  in  the  environmental  sector 
have  been  used  to  boost  actions  on  the  circular 
economy,  renewable  energy  and  energy  efficiency. 
EUR 165 million has been granted for projects that focus 
on  energy  efficiency,  transport,  the  environment  and 
resource efficiency in the Netherlands257. 

An example of an ongoing project is the Green Metropole 
Fund.  Its  goal  is  to  accelerate  the  transition  towards  a 
circular  and  low-carbon  economy  in  the  metropolitan 
area of Amsterdam. EIB funds of EUR 40 million will try to 
leverage  the  investment  capacity  towards  SMEs  and 

252 European Investment Bank, Projects to be financed, 2018. 
253 European Investment Bank, EIB finances OMO association’s 
sustainable buildings. 
254 European Investment Bank, The European Investment Bank in the 
Netherlands, 2017. 
255 European Investment Bank, The EIB in the Netherlands, what we do. 
256 European Investment Bank, EFSI project map. 
257 As of June 2018. Commission services, using DG Regio data. 

                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

upon  a  national  agreement  on  energy,  all  major  Dutch 
banks  have  been  cooperating  to  remove  obstacles  to 
financing  investments  in  renewable  energy  and  energy 
efficiency264.  This  effort  has  been  complemented  by  the 
Sustainable  Finance  Platform,  a  cooperative  venture 
including  several  Dutch  financial  organisations265  to 
promote  and  encourage  discussion  on  sustainable 
finance in the financial sector266. 

One  of  the  challenges  for  the  Netherlands  is  to  ensure 
that  environmental  financing  remains  at  an  adequate 
level to tackle some of the main challenges affecting the 
country. Existent financial gaps in nature and biodiversity 
protection  are  delaying  the  full  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 

 

Ensure  that  the  rural  development  programme  and 
greening measures boost biodiversity and contribute 
to  achieving  favourable  conservation  status  for 
habitats and species. 

small  projects.  Another  good  example  is  the  Limburgs 
Energie  Fonds,  that  aim  to 
improve  SMEs’  energy 
efficiency and develop new waste treatment facilities and 
sustainable  transport  in  the  province  of  Limburg  (EIB 
participation amounts up to EUR 30 million). 

Other  projects  are  still  being  prepared  or  have  been 
recently  approved.  A  six-year  project  to  secure  the 
and 
sustainable  management  of  water 
distribution in South Holland was approved in December 
2017.  Compliance  with  the  EU  Water  Framework  and 
Drinking  Water  Directives258  will  be  verified  during  the 
appraisal. 

supply 

National environmental financing 

allocated 

The Netherlands spent EUR 9.57 billion on environmental 
protection in 2016, a decrease of 8 % from 2015259. Some 
36 %  of  these  payments  was  allocated  to  waste 
management activities (the average in the EU is 49.7 %). 
EUR 3.34  billion  was 
to  wastewater 
management  (35 %  of  total)  and  EUR 1.82  billion  to 
reducing  pollution  (19 %  of  total).  Some  7.3 %  of 
the 
environmental  expenditure  was  allocated 
protection  of  biodiversity  and 
(EUR 705 
landscape 
million).  Between  2012  and  2016, 
the  general 
government funding for environmental protection added 
up  to  EUR 50  billion,  the  fifth  highest  total  in  absolute 
terms in the EU260. 

to 

Since 1985, several programmes have been developed to 
finance projects connected to environmental protection. 
Possibly the most significant is the Green Funds Scheme, 
a  tax  incentive  scheme  launched  in  1995  to  encourage 
individual  investors  to  put  money  into  projects  that 
benefit nature and the environment. By December 2016, 
185 deals had been concluded, with 1 225 participants261. 

The  Dutch  National  Fund  for  Green  Investments  is 
another instrument that provides services in the fields of 
financing,  public 
financial 
management  to  make  the  Netherlands  greener.  The 
Fund’s contribution to climate targets helped to prevent 
136 131 tonnes of CO2 from being released and helped to 
restore 345 hectares of natural environment262. 

support, 

advice 

and 

Provinces  also  cooperate  and  finance  some  projects. 
Among  other  instruments,  there  are  subsidies  available 
for  agricultural  collectives  for  wildlife  and  landscape 
management263. 

Since  2013,  when  more  than  40  organisations  agreed 

258 Directive 2000/60/EC  and Directive 98/83/EC. 
259 Eurostat, General Government Expenditure by function, 2018. 
260 Eurostat, General Government Expenditure by function, 2018. 
261 Government of the Netherlands, Green Deals Overview, 2016. 
262 Nationaal Groendfonds, A green environment is worth investing in. 
263 Biodiversity Information System for Europe, Green Infrastructure in 
the Netherlands. 

264 United Nations Environment Programme and Sustainable Finance 
Lab, Design of a Sustainable Financial System (Netherlands Input to the 
UNEP Inquiry), 2016, p. 4. 
265 De Nederlandsche Bank, the Dutch Banking Association, the Dutch 
Association of Insurers, the Federation of the Dutch Pension Funds, the 
Dutch Fund and Asset Management Association, the Netherlands 
Authority for the Financial Markets, the Ministry of Finance, the 
Ministry of Infrastructure and the Environment, and the Sustainable 
Finance Lab. 
266 De Nederlandsche Bank, Sustainable Finance Platform. 

35 

                                                                 
 
 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

5. Strengthening environmental governance 

Participation, information 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  effectively267.  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 environment268. It includes the right to bring 
legal challenges (‘legal standing’)269. 

Environmental information  

for 
The  Netherlands  has  a  centralised  approach 
dissemination of environmental data. The  main portal is 
the  ‘Compendium  voor  de  Leefomgeving’  (CLO)270.  The 
portal  presents  indicators  for  about  30  environmental 
topics, covering the environmental information demand. 
On  each  indicator  page,  links  provide  access  to  further 
information  and  data  downloads.  However, 
the 
references  to  the  EU  environmental  provisions  are 
difficult  to  find.  Reference  to  the  INSPIRE  Directive  is 
missing  for  half  of  the  domains.  Most  sectorial  sites  are 
entirely separate from the main environmental portal.  

In addition, public authorities are making environmental 
in  the  form  of 
information  available  to  the  public 
searchable  maps  through  the  Atlas  Living  Environment 
(Atlas  Leefomgeving)271  portal.  This  Atlas  aims  to 
translate  complex  information  to  the  local  level.  New 
datasets are being added on a regular basis. 

The Netherlands' performance on the implementation of 
the INSPIRE Directive is good. The performance has been 

267 The Aarhus Convention, the Access to Environmental Information 
Directive, 2003/4/EC and the INSPIRE Directive, 2007/2 together create 
a legal foundation for the sharing of environmental information 
between public authorities and with the public. This EIR focuses on 
INSPIRE. 
268 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. 
269 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. 
270 Government of the Netherlands, Environmental Data Compendium.  
271 The portal is available in both Dutch and English. 

reviewed  based  on  the  2016  implementation  report272 
and  the  most  recent  monitoring  data  from  2017273. 
However,  additional  efforts  are  needed  to  prioritise 
environmental  datasets,  in  particular  those  identified  as 
high-value  spatial  data  sets  for  the  implementation  of 
environmental legislation274. 

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

Public participation 

is 

invested 

Participation  is  considered  one  of  the  pillars  of  Dutch 
environmental  policy.  Much  effort 
in 
interactive  processes  of  policy  development  and  multi-
stakeholder  approaches.  The  ministry  of  Infrastructure 
and  Water  Management  has  a  division  for  participation 
(Directie  Participatie)275,  which  advises  policy  makers  on 
participation processes. It published a code defining what 
societal  participation  entails 
its  minimum 
requirements  (Code  Maatschappelijke  Participatie)276.  In 
addition,  the  government  publishes  a  central  list  of  the 
proposals under consultation277.  

and 

in 

the 

field  of  environment, 

the  Environmental 
In 
Management Act (Wet Milieubeheer)278 provides rules for 
the  participation  in  national,  provincial  and  municipal 
planning  procedures 
(Plans  and 
programs);  and  in  EIA  and  SEA  (Strategic  Environmental 
Assessments) procedures in its Chapter 7. Some sectoral 
provisions  also  exist.  In  some  cases,  procedures  are 
subject  to  a  formal  consultation  of  the  public,  which  is 
regulated  by  Section  3.4  of  the  General  Administrative 
Law  Act  (Algemene  Wet  Bestuursrecht)279.  In  addition, 

its  Chapter  4 

272 European Commission, INSPIRE Netherlands - country sheet for 
2017. 
273 European Commission, INSPIRE monitoring dashboard. 
274 European Commission, List of high value spatial data sets.  
275 Overheid, Organisatie- en mandaatbesluit Infrastructuur en 
Waterstaat.  
276 Overheid, Code Maatschappelijke Participatie. 
277 Overheid, Internetconsultatie.  
278 Overheid, Environmental management Act.  
279 Overheid, Algemene wet bestuursrecht. 

36 

 
 
                                                                 
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

every  Dutch  ministry  is  obliged  to  organise  an  internet 
consultation for each legislative proposal since 2013. 

The  Eurobarometer  figures  from  2017  show  that  in  the 
Netherlands,  there  is  a  very  strong  agreement  (97%  of 
respondents)  that  an 
in 
protecting the environment.  

individual  can  play  a  role 

Access to justice 

Significant  progress  is  needed  to  inform  the  general 
public about possibilities to appeal decisions taken by the 
authorities; i.e., which effective remedies are available to 
individuals  and  environmental  associations  on  access  to 
justice  in  environmental  matters  under  Dutch  and  EU 
law280.  The  official  website  of  the  Government  does  not 
provide  easy  access  to  information  and  statistics  on 
environmental  case  law  but  refers  in  this  respect  to  the 
European Case Law Identifier (ECLI) and general case law 
websites281. 

The  main  rule  is  that  only  those  whose  interests  are 
directly affected by a decision are allowed to start a legal 
case (General Administrative Law Act, Article 1:2(1)). This 
standing  requirement  has  been 
further  developed 
through  case  law  in  the  sense  that  an  interested  party 
must  have  an  interest  that  is  direct,  own,  personal, 
objective  and  actual282.  A  similar  arrangement 
is 
applicable to environmental NGOs. In principle, they are 
only  allowed  to  challenge  issues  that  are  expressly 
mentioned in their statutes as well as evidenced by their 
actual  activities  (General  Administrative  Law  Act,  Article 
1:2(1)). Dutch law does not distinguish between national 
or  foreign  individuals  or  NGOs.  The  interpretation  of 
these  provisions,  however,  is  ultimately  in  the  hands  of 
the court. 

Furthermore, citizens and environmental NGOs can start 
legal  procedures  based  on  civil  law.  Two  important 
developments need to be noted with respect to access to 
justice in practice. Firstly, actual access to justice may be 
diminished  due  to  the  fact  that  most  installations  and 
activities  have  been  brought  under  a  system  of  generic 
rules,  instead  of  individual  permits.  This  could  reduce 
options  for  appeal  against  the  granting  of  permits  and 
permitting  rules.  However,  under  the  generic  rules 
claimants  can  still  challenge  that  rules  are  not  complied 

280 It is to be noted that there is a legal obligation to mention the 
possibility for an appeal to decisions made by public authorities. 
However, this does not apply to general administrative acts. In 
particular for these acts, it is important that information is easily 
available and user- friendly. 
281 E.g. Rechtspraak and Raad van State. 
282 Backes C., The implementation of Article 9.3 of the Aarhus 
Convention on access to justice in the Netherlands, 2013; and Darpö, J. 
Effective Justice. Synthesis report of the study on the Implementation of 
Articles 9.3 and 9.4 of the Aarhus Convention in the Member States of 
the European Union, 2013, p. 11. 

with  and  ask  the  authorities  to  intervene.  Secondly, 
Dutch NGOs increasingly seem to opt  for civil instead of 
administrative procedures. 
The  loser  pays  principle  mainly  applies  in  civil  cases283. 
However, its application is at the discretion of the judge. 
Each party has to pay for its own legal assistance, experts 
and  other  costs.  However,  legal  assistance  by  a  solicitor 
or barrister (advocaat) is mandatory only when cases are 
lodged  before  a  civil  court  including  in  case  of  appeal. 
Applicants  before  administrative  courts  do  not  need  to 
be  represented  by  a  solicitor  or  barrister.  The  costs  of 
legal assistance and expert advice in a civil lawsuit can be 
considerable.  However,  if  the  administrative  court  asks 
the Administrative Courts Advisory Foundation (Stichting 
Advisering  Bestuursrechtspraak  (STAB))  for  advice,  this 
expert  witness  will  provide  his  or  her  opinion  without 
charge. 

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. 

Compliance assurance  

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste284.  It 
includes  support  measures  provided  by  the  authorities, 
such as:  
(i) compliance promotion285;  
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring286; and  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement287.  
Citizen  science  and  complaints  enable  authorities  to 
liability288 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

283 In administrative procedures citizens are rarely asked to pay for the 
costs of the authorities linked to the appeal (Art. 875 AWB). 
284The concept is explained in detail in COM(2018)10 and SWD(2018)10. 
285 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
286 This EIR focuses on inspections of major industrial installations. 
287This EIR focuses on the availability of enforcement data and co-
ordination between authorities to tackle environmental crime. 

37 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

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.  

citizens are invited by the RIVM to measure air quality293, 
Wageningen  University  is  doing  an  appeal  on  citizens  to 
collect  data  on  nature294,  and  the  city  of  Amsterdam 
encourages  citizens  to  use  the  app 
Improve  your 
Neighbourhood  (app  Verbeter  de  Buurt)  to  inform  the 
municipal services about local issues295. 

The Dutch government is increasingly developing specific 
approaches  and  tools  to  help  economic  operators 
understand  how  to  deal  with  environmental  rules  and 
regulations.  For  example,  with  regard  to  nitrates, 
national and regional public authorities jointly developed 
a  specific  Programme  Approach  Nitrates  (Programma 
Aanpak Stikstof (PAS)) in 2015. This approach is meant to 
give  guidance  to  public  authorities,  entrepreneurs,  and 
nature organisations how to reduce the nitrogen load as 
well  as 
(agricultural) 
businesses at the same time.  

to  create  opportunities 

for 

In respect to Natura 2000 sites, the ministry of Economic 
Affairs developed a detailed route planner for those who 
would  like  to  develop  an  activity  in  a  nature  protection 
area289.  The  PAS 
legal  scrutiny 
following  preliminary 
(C-293+294/17  of  7 
November 2018) of the Court of Justice of the EU.  

is  currently  under 

rulings 

Major  industrial  installations  present  serious  pollution 
risks.  Public  authorities  are  required  to  have  plans  to 
inspect  them  and  to  make  individual  inspection  reports 
available  to  the  public290.  Publicly  available  information 
about such plans and reports seems to be missing in the 
Netherlands  but  it  is  available  upon  request.  However, 
information 
inspections  of 
installations  that  fall  under  the  Seveso  Directive291, 
including short summaries of inspection results.  

is  published 

about 

The  Human  Environment  and  Transport  Inspectorate 
(Inspectie  voor  Leefomgeving  en  Transport  (ILT))292  is 
increasingly  using  new  technologies 
inspection 
purposes.  In  2017,  it  set  up  an  ID  Lab  for  experiments 
with new sources of data as well as analysis techniques. 
Examples  of  such  projects  are  text  mining  in  relation  to 
Schiphol Airport and the use of Geographical information 
system  to  visualize  data  related  to  the  European  Waste 
Shipment Regulation in an interactive map.  

for 

Citizen science and complaint handling  

Engagement of citizens, including through citizen science, 
can deepen knowledge about the environment and help 
the  authorities  in  their  work.  The  added  value  of  citizen 
science  is  recognised  in  the  Netherlands.  For  example, 

288 The Environmental Liability Directive, 2004/35, creates the 
framework. 
289 Dutch route planner in nature protection areas, website.  
290 Article 23, Directive 2010/75/EU. 
291 Directive 2012/18/EU. 
292 Dutch Human Environment and Transport Inspectorate, website.  

in 

active 

institutions 

The availability of clear online information about how to 
make  a  complaint  is  an  indicator  of  how  responsive 
authorities  are  to  complaints  from  the  public.  In  the 
Netherlands,  many 
the 
environmental  field  have  put 
in  place  complaints 
the  Regional  Environmental 
mechanisms,  such  as 
Services  as  well  as  the  environmental  departments  of 
provinces  and  municipalities. 
In  order  to  provide 
guidance,  the  Foundation  Environmental  Complaints 
(Stichting  Milieuklachten)296  operates  a  website  which 
provides  assistance  in  the  identification  of  the  proper 
public 
institution  where  a  complaint  should  be 
submitted.  

Enforcement 

When  monitoring 
identifies  problems,  a  range  of 
responses may be appropriate. The activity reports of the 
ILT297,  as  well  as  of  the  ODNL298,  do  not  provide 
information about identified instances of non-compliance 
and follow-up measures taken but members of the public 
can  request  that  this  information  is  made  available  to 
them.  The  Regional  Environmental  Service  DCMR 
publishes  on  its  website  enforcement  sanctions299.  CBS 
does  not 
statistics  on 
environmental  crimes300.  In  the  general  crime  statistics, 
in  the  category 
environmental  crimes  are 
‘other’.  Information  on  responses  to  cross-compliance 

separate 

included 

compile 

any 

293 Ministry of Infrastructure and Water Manegement, Citizen Science.  
294 Breman, B., van Vliet, A., Vullings, W., Citizen science voor natuur in 
Nederland, Van onschatbare waarde en onderschat belang, report 
2806, Wageningen University & Research, 2017.  
295 Improve your Neighbourhood app, website.  
296 Stichting Milieuklachten, website.  
297 Dutch Human Environment and Transport Inspectorate, website.  
298 Omgevingsdienst, website.  
299 See Overzicht opgelegde handhavingsbeschikkingen. 
300 CBS, Open data portal.  

38 

                                                                                                        
 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

breaches  on  nitrates  and  nature  does  not  seem  to  be 
publicly available.  

Tackling  waste,  wildlife  and  other  environmental  crimes 
is  especially  challenging  and  requires  close  co-operation 
and  co-ordination  arrangements  between  inspectors, 
customs  authorities,  police  and  prosecutors.  The  lead 
authority  for  enforcement  of  the  Waste  Shipment 
Regulation  is  the  ILT301.  It  cooperates  with  customs, 
police  and  the  public  prosecutor’s  office.  Following 
previous  concerns  about  the  high  number  of  criminal 
investigations  that  did  not  lead  to  court  cases  and 
convictions302,  in  2017  the  Court  of  Audit  produced  an 
information  note303  about  the  follow-up  given  to  its 
report,  referring  to 
improved  cooperation  between 
public  authorities  through  the  digital  service  Inspection 
View  (Inspectieview)304,  evaluation  of  risk  profiles,  and 
more targeted control and enforcement. 

The  lead  authority  for  enforcement  of  wildlife  trade 
regulations  is  located  at  the  Netherlands  Food  and 
(Nederlandse 
Consumer  Product  Safety  Authority 
Voedsel-  en  Warenautoriteit  (NVWA))  of  the  ministry  of 
Agriculture,  Food  Quality  and  Nature305.  Staff  from  the 
NVWA periodically gets together with officers from other 
enforcement  agencies,  such  as  customs,  national  police, 
and  the  public  prosecutor’s  office.  The  frequency  of 
meetings amounts to 6 times per year306. In recent years, 
several  criminal  investigations  have  led  to  court  cases 
and  convictions.  A  major  case  concerned  a  bird  trader 
who received a sentence of 15 months in prison because 
of  large-scale  trading  and  membership  in  a  criminal 
organization which was confirmed in appeal307.  

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  focused  on  better  information  on  environmental 
damage, financial security and guidance. The Commission 
is still collecting evidence on the progress made. 

2019 priority actions 

  Better 

inform 

the  public  about 

compliance 
promotion, monitoring and enforcement by, at least, 
providing online information on inspection plans and 
inspections, 
industrial  and  other 
reports  on 

301 Dutch Human Environment and Transport Inspectorate, website.  
302 Algemene Rekenkamer, Handhaving Europese regels voor 
afvaltransport, The Hague, 2012, 54 p. 
303 Court of Auditors of the Netherlands, Opvolging aanbevelingen 
Handhaving Europese regels voor afvaltransport.  
304 Digital service inspection view, website.  
305 Nederlandse Voedsel- en Warenautoriteit, website.  
306 CITES, Netherlands Biennial Report 2013-2014, p. 14 
307 Rechtspraak, website. See reference ECLI:NL:GHARL: 2017: 336  

publishing information on outcomes of enforcement 
action  and  of  the  follow-up  to  detected  cross-
compliance breaches on nitrates and nature. 
Ensure  more 
dealing with environmental crime work together. 
Improve  financial  security  for  liabilities  and  ELD-
guidance  and  publish  information  on  environmental 
damage. 

information  on  how  professionals 

 

 

Effectiveness of environmental 
administrations 

in 

involved 

implementing 

Those 
environmental 
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 

As  mentioned  in  the  2017  EIR,  the  Netherlands  has  an 
adequate  administrative  capacity  to  fulfil  environmental 
obligations.  There  is  a  longstanding  tradition  to  involve 
all 
and 
relevant 
implementation. 

in  policy-making 

stakeholders 

Although  the  quality  of  public  administration  in  the 
Netherlands  is  generally  considered  as  high,  not  more 
than 57 % of citizens expressed confidence or satisfaction 
in  the 
in  public 
institutions  across  public  services 
Netherlands, according to a recent OECD study308. 

Coordination and integration 

As  mentioned  in  the  2017  EIR  Report,  the  transposition 
of the revised EIA Directive309 provides an opportunity to 
streamline  the  regulatory  framework  on  environmental 
the 
assessments.  The  Netherlands  has  completed 
transposition  of  the  EIA  Directive  by  the  deadline  (May 
2017).  

to 

in  order 

The  Commission  encourages  the  streamlining  of  the 
reduce 
environmental  assessments 
duplication  and  avoid  overlaps.  Streamlining  helps 
reducing  unnecessary  administrative  burden  and 
accelerates  decision-making,  without  compromising  the 
quality  of  the  environmental  assessment  procedure310. 
The  Netherlands  has 
streamlining  of 
environmental  assessments  of  the  EIA  and  Habitats 
Directives.  Where  an  assessment  is  required  also  under 

introduced 

308 OECD, Government at a Glance 2017, Netherlands fact sheet, p. 4.  
309 Directive 2014/52/EU. 
310 The Commission issued a guidance document in 2016 regarding the 
setting up of coordinated and/or joint procedures that are 
simultaneously subject to assessments under the EIA Directive, Habitats 
Directive, Water Framework Directive, and the Industrial Emissions 
Directive, OJ C 273, 27.7.2016, p. 1. 

39 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

the  Water  Framework  Directive,  the  procedures  are 
coordinated. 

Adaptability, 
(eGovernment) 

reform 

dynamics 

and 

innovation 

In  the  Netherlands,  EIAs  and  SEAs  are  mandatory  for 
plans  and  projects  that  are  listed  in  a  ministerial  decree 
(Besluit  milieueffectrapportage311). 
EIA/SEA 
procedures  are  coordinated  with  other  permitting  and 
assessment requirements as outlined in Chapter 7 of the 
Environmental Management Act (Wet Milieubeheer)312. 

The 

environment-friendly 

The  EIA  and  SEA  reports  are  usually  written  by 
consultancy bureaus at the request of private and public 
initiators  of  plans  and  projects313.  According  to  Dutch 
law,  the  preparation  of  EIAs  and  SEAs  should  include  a 
description of alternatives and their impacts, including a 
most 
public 
participation,  and  a  mandatory  quality  review  by  an 
independent  advisory commission. The role of the latter 
for 
is 
de 
Environmental  Assessment 
milieueffectrapportage 
advises 
competent  authorities  on  the  quality  of  environmental 
information  in  EIAs  and  SEAs  in  order  to  stimulate  its 
effective use in decision-making procedures.  

the  Netherlands  Commission 
voor 

(NCEA))314  which 

fulfilled  by 

alternative, 

(Commissie 

In  the  case  of  both  voluntary  and  mandatory  advisory 
reports, the competent authority may request the NCEA 
to  take  into  account  submissions  by  the  public  in  its 
advice.  The  non-binding  advice  by  the  NCEA  includes 
considerations on whether the EIA is of sufficient quality 
to  serve  as  a  basis  for  decision-making,  whether 
alternatives are adequately examined, and whether gaps 
in knowledge exist requiring supplementary research. 

the 

Framework 

Assessment 

The  Dutch  government  has  developed  an  Integrated 
Impact 
(Integraal 
Afwegingskader Beleid en Regelgeving) which is meant as 
a  tool  to  be  used  by  civil  servants  in  formulating  sound 
framework 
legislation.  The  assessment 
policy  and 
requires 
environmental 
consequences. The framework distinguishes the stages of 
problem  analysis, 
impact 
assessment. A booklet explaining its approach is available 
in  both  Dutch  and  English,  and  there  is  an  available 
website  providing  information  about  regulatory  impact 
assessments, 
to 
professionals315. 

intervention  choices,  and 

consideration 

specifically 

addressed 

but 

of 

311 Decree environmental impact assessment (Besluit 
milieueffectrapportage (Staatsblad 1994, 540, as amended). 
312 Portal Overheid.nl (providing full texts of laws and regulations), 
Environmental Management Act, Chapter 7.  
313 Hoevenaars, G., Assessing the assessment. A quality review of 
EIAs/SEAs: a Dutch perspective, Environmental Law Network 
International, 2013, 1/2 , 30-37,  
314 Netherlands Commission for Environmental Assessment, website.  
315 Government of the Netherlands, Integrated Impact Assessment 
Framework, information about regulatory impact assessment. 

Dutch  public  authorities  are  increasingly  adopting  and 
interact  with  public  or 
using  electronic  services  to 
regulated  entities  online.  For  Digital  Public  Services,  the 
Netherlands  has  a  score  of  0.77/1  based  on  Europe's 
Digital Progress Report 2017, this is higher than the EU28 
average  (0.55/1)316. 
In  the  DESI  Report  2018,  the 
Netherlands had a score of 71 out of 100 on digital public 
services, higher than the EU average of 58317. 

construction 

conservation, 

(Omgevingswet)318 

A  major  overhaul  of  the  environmental  legislation  is 
currently  being  prepared.  The  envisaged  Environment 
and  Planning  Act 
is  meant  to 
modernise, harmonise and simplify current rules in areas 
such  as  land  use  planning,  environmental  protection, 
buildings, 
nature 
protection  of  cultural  heritage,  water  management, 
urban  and  rural  redevelopment,  development  of  major 
public and private works and mining and earth removal. 
It will integrate these rules into one legal framework. The 
new  act  has  been  adopted  by  Parliament  and  officially 
published319.  The  ministry 
is  currently  elaborating 
associated implementation regulations. The new act and 
associated regulations are expected to enter into force in 
2021. 

of 

With  the  new  Environment  and  Planning  Act  and  its 
associated regulations, the government aims to: 

 

Improve the transparency, predictability, and ease of 
use of environmental law; 

  Achieve  a  coherent  approach  towards  the  physical 
and 

in  policy,  decision-making 

environment 
regulations; 

  Achieve more administrative discretion by means of 

 

an active and flexible approach;  
Improve  and  speed  up  the  decision-making  with 
regard to projects in the physical environment.  

2) 

An 

strategy, 

instruments 

in  the  new  act  are:  1)  An 
The  key 
environmental 
environmental 
programme,  3)  Central  government  regulations,  4) 
Regulations  from  decentralised  authorities, 
including 
provinces,  regional  water  authorities  and  municipalities, 
5)  An  environmental  permit,  and  6)  A  project  decision. 
The  latter  is  designed  as  a  generic  arrangement  for 
decision-making  in  relation  to  projects  with  a  public 
interest according to the ‘faster-and-better’ approach. 

316 European Commission, Europe's Digital Progress Report (EDPR) 2017 
Country Profile Netherlands, 2017, p. 9,  
317 European Commission, Digital Economy and Society Index Report 
2018, Digital Public Services. 
318 Government of the Netherlands, Environment and Planning Act.  
319 Official publication of Environment and Planning Act in Staatsblad 
2016, 26 april 2016. 

40 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

However,  relevant  information  about  Dutch  activities  in 
the environmental field is scattered over  many different 
websites.  A  central  navigation  system  that  helps  to  find 
your way in the ‘jungle of information’ does not exist. An 
initiative  of 
attempt  to 
environmental  authorities  to  making  information  on 
environment  and  health  available  through  the  portal 
Atlas  Living  Environment  (Atlas  Leefomgeving)320  in  the 
form of searchable maps. 

improve  this 

is  the 

joint 

The  new  Environment  and  Planning  Act  reflects  the 
ambition  to  work  towards  a  digital  portal  for  citizens, 
businesses and NGO’s that gives access to environmental 
data  relevant  to  a  specific  geographical  location  as  well 
as  to  the  rules  applicable  to  that  location.  The  website 
Infomil  of  Rijkswaterstaat  also  offers  a  platform  for 
environmental  information  related  to  the  actions  of  the 
government321.  

Enabling financing and effective use of funds 

The  Dutch  authorities  have  a  long  experience  in  the 
management of EU funding and no major problems arise 
in this respect.  

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  2018322.  The  EIR  is  one  of  the  tools  to 
ensure  that  the  Member  States  set  a  good  example  by 
respecting  European  Union  environmental  policies  and 
laws and international agreements.  

The Netherlands is one of the best performers in the EU 
in  signing  and  ratifying 
international  environmental 
agreements.  
Forests:  EU  Timber  Regulation  (EUTR)323/  Forest  Law 
Enforcement,  Governance 
(FLEGT) 
Regulation324 

Trade 

and 

Under  the  EUTR,  which  prohibits  the  placing  of  illegally 
harvested  timber  on  the  EU  market,  the  relevant 
authorities  in  EU  Member  States  must  conduct  regular 

checks on operators and traders, and apply penalties for 
non-compliance. 

the 

Between  March  2015  and  February  2017, 
the 
Netherlands  did  not  plan  or  carry  out  any  checks  on 
market  operators  dealing  with  domestic 
timber, 
domestic  production325. 
highlighting 
limited 
However,  74  out  of  100  checks  on  operators  importing 
timber planned for this same period were conducted. So 
far,  about  30 %  of  checked  operators  were  found  in 
breach  of  their  due  diligence  obligation  and  have  been 
sent  notices  of  remedial  action.  The  Netherlands  issued 
one administrative measure to prevent further placing on 
the market of products without proper due diligence. The 
measure was upheld in a court case. 

collaborating  with 

On  cooperation  (Article 12  EUTR),  the  Netherlands 
government 
reported 
institutions  in  the  country,  and  with  competent  EU 
authorities,  mainly  through  FLEGT/EUTR  Expert  Group 
meetings,  the  Ad  Hoc  Expert  Group  on  FLEGT,  the  TREE 
meetings and during bilateral visits. 

other 

Genetic  resources:  Nagoya  Protocol  on  Access  to 
Genetic Resources and the Fair and Equitable Sharing of 
Benefits Arising (ABS)326  

Under  the  EU  ABS  Regulation,  which  transposes  the 
required  compliance  measures  under 
the  Nagoya 
Protocol  into  the  EU  legal  order,  the  Netherlands  has 
designated competent authorities and enacted sanctions 
for infringements of the Regulation. They have also put in 
place  a  risk-based  plan  for  checks  and  have  conducted 
checks  (on-site  visits  and  inspections).  No  due  diligence 
declaration  was  submitted  so  far  and  no  penalties  have 
been  applied.  At  the  end  of  2017,  the  Netherlands 
submitted  their  first  report  to  the  Commission  on 
implementing the EU ABS Regulation. 

the  Convention  on 
trade: 
International  wildlife 
International  Trade  in  Endangered  Species  of  Wild 
Fauna and Flora (CITES)327 
Under  the  obligation  laid  down  in  the  Regulation328  to 
transpose the major obligations stemming from the CITES 
into  EU  law,  the  Netherlands  has  established  relevant 
national  authorities  and  is  processing  (requests  for) 
import,  (re-)  export  and  intra-EU  trade  documents  on  a 
regular basis. 

Reports  on  seizures  of  illegal  shipments,  in  particular 
those  reported  every  6  months  to  the  wildlife  trade 

320 The portal is available in both Dutch and English. 
321 Ministry of Infrastructure and Water Management, Kenniscentrum 
InfoMil.  
322 UN General Assembly Resolution 72/277 and Organisational session 
of the ad hoc open-ended working group.  
323 Regulation (EU) No 995/2010. 
324 Regulation (EC) No 2173/2005. 

325 Based on customs’ data, it is estimated that 100 Dutch operators 
placed domestic timber on the EU market for the first time and 4 900 
imported timber. 
326 Regulation (EU) No 511/2014. 
327 European Commission, The Convention on International Trade in 
Endangered Species of Wild Fauna and Flora (CITES). 
328 Council Regulation (EC) No 338/97. 

41 

                                                                 
                                                                 
Environmental Implementation Review 2019 – the Netherlands 

monitoring  network  TRAFFIC329  under  its  contract  with 
DG  Environment,  and  those  exchanged  through  the  EU-
TWIX  platform330,  testify  to  the  activity  of  customs 
authorities. 

To  ensure  the  EU  wildlife  action  plan  (2016)  is  fully 
implemented,  a  national  CITES  Day  is  organised  every 
year in the Netherlands. This day provides an opportunity 
for  everyone  involved  in  CITES  and  combating  wildlife 
trafficking, including prosecutors, to gather, get to know 
each other and exchange best practices. 

Sustainable 
implementation of the UN SDGs 

development 

and 

the 

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

implement  environmental 

a 

comprehensive 

Although  the  Netherlands  has  been  a  frontrunner  as 
regards  strategic  environmental  planning,  it  has  not  yet 
adopted 
sustainable 
development plan. A draft of such a plan was turned into 
an action plan, which was adopted in 2003. Following an 
international  peer  review,  the  government  revised  its 
policy  in  2008  in  a  programme  known  as  the  ‘cabinet-
wide approach to sustainable development’ (KADO). 

national 

is  no  separate  coordination  mechanism  for 
There 
Sustainable Development between the national and sub-
national levels. In sectoral policies, there is coordination 
between the political levels, e.g. in environmental policy, 
transport  policy, spatial planning, water management  or 
climate  change.  Coordination  at  the  national  level  is 
addressed  by  the  regular  coordination  mechanisms  that 
support the Council of Ministers, such as the Council for 
Infrastructure and Environment.  

At  the  policymaking  level  the  Ministry  of  Foreign  Affairs 
leads the Task Force on Sustainable Development (TFDO 
—  task  force  duurzame  ontwikkeling)331.  In  2018,  the 
the  Ministry  of 
Ministry  of  Foreign  Affairs  and 
Infrastructure  and  Water  Management  signed  the  “Blue 
Deal”,  which  aims  to  give  20  million  people  around  the 
world access to clean, sufficient and safe water332. 

A  dedicated  website  brings  together  information  on  the 
implementation of the SDGs in the Netherlands333. This is 
a joint initiative involving the Ministry of Foreign Affairs, 
stakeholders  from  civil  society  and  business,  and  the 

329TRAFFIC, website.  
330 EUTWIX, website. 
331 European Sustainable Development Network, Single Country Profile: 
Netherlands. 
332 Dutch Water Authorities, Blue Deal 2018-2030. 
333 Government of the Netherlands, SDGS. 

association of municipalities. 

The CBS put in place a ‘Monitor Sustainable Netherlands’ 
(Monitor  Duurzaam  Nederland) in  2016334  and  the 
government  reports  annually  on  the  progress  made  on 
the SDGs to Parliament. Since 2018, the SDG monitoring 
is  integrated  under  the  wider  Quality  of  Life  Monitor 
(Monitor Brede Welvaart)335. 

The  economic,  environmental  and  societal  Planning 
Agencies  annually  publish  an  outlook  on  relevant  topics 
related to the SDGs. The 2018 edition has been dedicated 
to the Circular Economy Consumer Behaviour and Policy 
Options336. Five major stakeholder groups –business, civil 
society,  knowledge  institutions,  local  governments  and 
youth- are also involved in this report. 

The Netherlands  submitted a  Voluntary National  Review 
on the implementation of the SDGs to the UN in 2017337. 

Sustainability and media attention 

NGO’s involved in promoting sustainability are drawing a 
lot  of  media  attention.  Examples  are  Urgenda338 
promoting  drastic  climate  action  and  the  Plastic  Soup 
Foundation339  calling  for  action  to  combat  plastics 
pollution. Every year, the newspaper Trouw compiles the 
Sustainable 100340, a list of people who achieved most in 
terms  of  creating  a  more  sustainable  society.  A  more 
recent  initiative  is  a  top  100  of  young  people  taking 
action  for  increased  sustainability341.  Furthermore,  local 
energy cooperatives342 set up by citizens are flourishing. 

334 Government of the Netherlands, Monitor Duurzaam Nederland. 
335 Statistics Netherlands, Monitor Brede Welvaart. 
336 CPB, PBL and SCP, Verkenning Brede Welvaart 2018: Circulaire 
economie, gedrag en beleid. 
337 UN, Sustainable Development Knowledge Platform; and Report on 
the Implementation of the Sustainable Goals. 
338 Urgenda foundation, website.  
339 Plastic Soup Foundation, website.  
340 Newspaper Trouw, Sustainable 100.  
341 Sustainable motion, De 100 duurzaamste jonge koplopers van 
Nederland.  
342 Association of Dutch energy cooperatives HIER opgewekt, website.  

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