COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - FINLAND Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Finland, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 8.9.2022  SWD(2022) 277 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022      Country Report - FINLAND             Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 278 final}  
 
 
Finland | 1 

This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
Comments are welcome, please send them to: ENV-EIR@ec.europa.eu 

More information on the European Union is available at http://europa.eu. 

Photographs:  

For reproduction or use of these photos, permission must be sought directly from the copyright holder. 

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Finland | 2 

Table of contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................................. 9 
Nature protection and restoration ....................................................................................................................... 9 
Marine ecosystems............................................................................................................................................. 15 
Ecosystem assessment and accounting ............................................................................................................. 16 
3. ZERO POLLUTION ..................................................................................................................................................... 18 
Clean air ............................................................................................................................................................. 18 
Industrial emissions ............................................................................................................................................ 19 
Major industrial accidents prevention – SEVESO ............................................................................................... 22 
Noise .................................................................................................................................................................. 23 
Water quality and management ........................................................................................................................ 23 
Chemicals ........................................................................................................................................................... 27 
4. CLIMATE ACTION ..................................................................................................................................................... 30 
Key national climate policies and strategies ...................................................................................................... 30 
Effort sharing target ........................................................................................................................................... 31 
Key sectoral developments ................................................................................................................................. 31 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 32 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 34 

5. FINANCING ............................................................................................................................................................. 34 
Environmental investment needs in the European Union .................................................................................. 34 
EU environmental funding  2014-2020 .............................................................................................................. 35 
EU environmental funding  2021-2027 .............................................................................................................. 37 
National environmental financing ..................................................................................................................... 38 
Green budget tools ............................................................................................................................................. 40 
Overall financing compared to the needs .......................................................................................................... 41 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 43 
Information, public participation and access to justice...................................................................................... 43 
Compliance assurance ........................................................................................................................................ 44 
Effectiveness of environmental administrations ................................................................................................ 46 
TAIEX EIR peer to peer ........................................................................................................................................ 47 

Environmental Implementation Review 2022 – Finland 

 
 
 
Finland | 3 

Executive summary

In  previous  Environmental 
Implementation  Reviews 
(EIRs),  the  main  challenges  identified  for  Finland  for  the 
implementation of EU environmental policy and law were 
to: 

 

 

 

complete  the  Natura  2000  site  designation 
integrate  biodiversity 
process  and  better 
concerns into other policies; 
address  air  and/or  water  pollution  linked  to 
emissions from installations in one or more of the 
following  sectors:  power,  intensive  rearing  of 
poultry and pigs, waste treatment activities, and 
iron and steel plants; and 
improve  the  monitoring  and  assessment  of  all 
relevant quality elements in all water categories 
in  accordance  with  the  Water  Framework 
Directive,  and  ensure  that  water  pollution  from 
agriculture,  among  other  sectors,  is  effectively 
addressed  under  the  Nitrates  and/or  Water 
Framework Directives. 

to  offset 

Despite Finland’s comprehensive biodiversity strategy for 
2014-2020,  the  loss  in  biodiversity  continues  and  it  is 
currently  unclear  whether  the  measures  set  out  in  the 
strategy  are  sufficient 
the  agricultural 
intensification  and  resulting  eutrophication  occurring  in 
the  wider  countryside.  The  conservation  status  of  many 
grassland habitats and many of their associated species is 
still unfavourable. Forestry is the most reported pressure 
on Natura 2000 sites. In April 2020, the EU Court of Justice1 
condemned Finland for failing to fulfil its legal obligations 
under  EU  law  on  the  conservation  of  wild  birds,  and  for 
recurrently  granting  authorisations  for  spring  hunting  of 
male common eiders in the province of Åland since 2011. 
Another case is ongoing on the summer hunting of male 
common eiders in mainland Finland. 

for 

On  water  quality,  some  progress  has  been  made  on 
forestry, 
reducing  pollution  and  on  measures 
watercourses, 
rehabilitation 
managing 
of 
hydromorphological 
protecting 
and 
pressures 
groundwater.  However,  more  effective  measures  are 
needed  to  reduce  chemical  and  nutrient  pollution  on 
surface  water.  For  example,  Finland  is  advised  to  better 
integrate water objectives into other policy areas such as 
agriculture, transport and energy. Finland also falls short 
on  the  full  implementation  of  the  Marine  Strategy 
Framework Directive, where further efforts are needed if 
it is to achieve good environmental status by 2020. 

In 2019, Finland benefited from an exchange of experts on 
public procurement under the TAIEX EIR peer-to-peer (EIR 
P2P) mutual learning programme launched in 2017. 

EU financing continues to provide substantial support for 
environmental  objectives.  From  the  European  Structural 
and Investment Funds (ESIFs), Finland received EUR 146.1 
million  to  cover  direct  environmental  investments  in 
2014-2020. So far, Finland has spent EUR 21.7 million on 
biodiversity  and  nature;  EUR 6.1  million  on  climate 
mitigation  and  adaptation,  and  risk  management;  and 
EUR 300 000  on  waste  management.  With  other  EU 
funding  and  European  Investment  Bank  (EIB)  ￼loans, 
total  EU  financing  reached  around  EUR 679  million  in 
2014-2020. 

Finland  is  due  to  receive  over  EUR 2.1  billion  from  its 
recovery  and  resilience  plan  (RRP)  (2021-2026)  and 
EUR 1.49 billion from the cohesion policy (ERDF and ESF) 
(2021-2027).  Investment  priorities  in  Finland  are  clearly 
shifting towards climate, energy and transport policies set 
out in the national RRP. 

Emissions  of  numerous  air  pollutants  have  decreased 
significantly in Finland since 2014, continuing the previous 
downward trend. Nevertheless, air pollution is responsible 
for about 1 500 premature deaths a year in Finland, and 
emissions in certain urban hotspots may exceed maximum 
limits. The latest inventory data submitted by Finland, but 
not yet reviewed by the Commission, indicate that Finland 
is 
reduction 
commitments for all pollutants in 2020. 

compliance  with 

the  emission 

in 

level  of 

financing 

Through  these  sources,  it  is  important  to  maintain  and 
increase  the 
for  environmental 
investments (around 0.42% of GDP in 2014-2020) to cover 
the investment needs in 2021-2027 (over 0.96% of GDP, 
indicating  a  financing  gap  of  0.54%  of  GDP  assuming 
financing levels remain unchanged). 

1 CURIA - Documents (europa.eu) 

Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
 
 
 
 
 
 
Finland | 4 

Part I: Thematic Areas 

1. Circular Economy and waste management  

Measures towards a circular economy 

Figure 1 – Circular material use rate (%), 2010-20202 

The new Circular Economy Action Plan adopted in March 
2020 is one of the main building blocks of the European 
Green Deal. The EU’s transition to a circular economy will 
reduce  pressure  on  natural  resources  and  will  create 
sustainable  growth  and  jobs.  It  is  also  a  prerequisite  to 
achieve the EU’s 2050 climate neutrality target and to halt 
biodiversity  loss.  The  Action  Plan  announces  initiatives 
along the entire life cycle of products, aiming to reduce the 
EU's consumption footprint and to double the EU's circular 
material  use  rate  by  2030.  It  targets  how  products  are 
designed,  promotes 
circular  economy  processes, 
encourages sustainable consumption, and aims to ensure 
that waste is prevented and the resources used are kept 
in the EU economy for as long as possible.  

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s circularity, as it includes all the materials that 
are  fed  back  into  our  economy.  Large  differences  in  the 
circularity  rate  exist  between  countries.  To  help  achieve 
the goal in the EU circular economy action plan of doubling 
the  EU’s  circular  material  use  rate  by  2030,  ambitious 
measures  targeting  the  whole  product  life  cycle  are 
needed at Member State level. Such measures range from 
sustainable  product  design  that  makes  it  possible  to 
increase  the  durability,  reparability,  upgradability  and 
recyclability  of  products,  to  other  measures,  like:  (i) 
‘remanufacturing’; (ii) increasing circularity in production 
processes; (iii) recycling; (iv) boosting eco-innovation; and 
(v) increasing the uptake of green public procurement 

 In 2020, the circular (secondary) use of material in Finland 
was 6.2 %. This percentage compared to the EU average 
of 12.8% shows that there was very limited progress over 
the last few years.  

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw material markets. As shown in 
Figure  2,  with  EUR  1.29  generated  per  kg  of  material 
consumed in 2020, resource productivity in Finland is well 
below the EU average of EUR 2.09 per kg. 

2 Eurostat, Circular Economy Monitoring Framework.  

Environmental Implementation Review 2022 – Finland 

 
                                                                 
 
 
 
Finland  5 

a  step  towards  achieving  the  government’s  carbon 
neutrality target by 2035. 

The  vision  will  be  guided  by  the  following  steps  and 
objectives:  the  consumption  of  non-renewable  natural 
resources  will  decrease,  and  the  sustainable  use  of 
renewable  natural  resources  may  increase  to  the  extent 
that  the  total  consumption  of  primary  raw  materials  in 
Finland  in  2035  will  not  exceed  that  of  2015.  The 
productivity of resources will double by 2035 from what it 
was in 2015 and the circular material use rate will double 
by 2035. 

Finland  does  not  have  a  sectoral  strategy  on  plastics; 
however, the Plastics Roadmap for Finland, published in 
September  2018 
is  the  first  step  towards  a  new, 
sustainable  plastics  economy.  Of  the  more  than  100 
proposals made, the roadmap now presents a set of key 
actions to find solutions to challenges caused by plastics. 

Similarly,  Finland  has  not  adopted  sectoral  strategies  on 
the  textiles  and  construction  sectors;  however,  the 
resolution  on  promoting  a  circular  economy  has  the 
potential to impact these two sectors. 

Eco-innovation 

A  successful  transition  to  a  circular  economy  requires 
social and technological innovation. This is because the full 
potential  of  the  circular  economy  can  only  be  reached 
when  it  is  implemented  across  all  value  chains.  Eco-
innovation is an important enabling factor for the circular 
economy.  New  approaches  to  product  design  and  new 
business  models  can  help 
to  produce  circularity 
innovations, creating new business opportunities. 

ranked  2nd  on 

Finland 
the  2021  Eco-Innovation 
Scoreboard, with a total score of 157,  classifying it as an 
'eco-innovation leader'. In three out of five components of 
the  2021  Eco-Innovation  Index  Finland  performs  above 
the  EU  average,  namely  on  eco-innovation  inputs,  eco-
innovation outputs and socioeconomic outputs. 

Figure 2: Resource productivity 2010-20203 

Circular economy strategies 

The Commission encourages Member States to adopt and 
implement  national/regional circular economy strategies 
covering the whole life cycle of products. This is because 
such  strategies  are  one  of  the  most  effective  ways  to 
progress  towards  a  more  circular  economy.  Since  the 
launch of the online Circular Economy Platform in 20174, 
national,  regional  or  local  authorities  have  used  the 
platform to share their strategies and roadmaps. 

In 2019, The Finnish government updated its roadmap on 
the circular economy, introducing 30 new actions, and in 
April 2021 it went on to adopt the resolution on promoting 
a  circular  economy.  The  government  has  prepared  a 
strategic programme to promote a circular economy and 
to  transform  the  economy  based  on  circular  economy 
principles  by  2035.  This  will  set  a  national  framework 
programme and concrete targets for the consumption of 
non-renewable  natural  resources,  resource  productivity 
and  circular  material  use  rate,  all  complemented  by  the 
promotion  of  voluntary  sectoral  agreements  between 
municipalities, business and other stakeholders as well as 
by  creating  a  sustainable  circular  economy  market 
through 
and 
digitalisation. The transition to a circular economy is also 

instruments 

legislation, 

economic 

3Eurostat, Resource productivity. 

4 Circular Economy Stakeholder Platform. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
  
Figure 3 – Eco-innovation performance 2010-20195 

Green public procurement (GPP) 

Public  procurement  accounts  for  a  large  proportion  of 
authorities’ 
consumption,  with  public 
European 
purchasing  power  representing  around  14%  of  EU  GDP. 
Public  procurement  can  help  drive  the  demand  for 
sustainable  products 
reparability  and 
recyclability standards. To date, reporting to monitor the 
uptake of green public procurement (GPP) is voluntary. 

that  meet 

The first public procurement  strategy in Finland was put 
forward  in  2020,  with  27  objectives,  such  as  innovative, 
social, ecological and financial objectives. 

The  main  approaches  of  the  strategy  are:  (i)  developing 
legislative  proposals  to  account  for  the  environmental 
impact of procurement; (ii) encouraging environmentally-
responsible procurement and voluntary commitments to 
advance  sustainable  development  principles  in  public 
procurement;  (iii)  updating  guides  on  the  responsible 
procurement  of  foodstuff  (in  line  with  the  farm  to  fork 
strategy);  and  (iv) 
low  carbon  public 
launching  a 
procurement  development  programme  with  pioneer 
organisations.  The  strategy  does  not  establish  product-
specific rules, but it has developed criteria for example on 

Finland  6 

food  and  catering  as  well  as  on  green  deals6  To  ensure 
successful  implementation  and  the  achievement  of  the 
strategy's  objectives,  public  procurement  units  will  be 
supported by members of the KEINO Competence Centre 
for Sustainable and Innovative Public Procurement. 

EU ecolabel and the eco management and auditing 
scheme (EMAS) 

The number of EU ecolabel products and EMAS-licensed7 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and  national 
stakeholders  in  that  country  are  actively  engaged  in  the 
transition  to  a  circular  economy.  It  also  shows  how 
committed  public  authorities  are 
supporting 
instruments designed to promote the circular economy.  

to 

As of September 2021, Finland had 1 744 products out of 
83 590 and 14 licences out of 2 057 registered in the EU 
ecolabel  scheme,  showing  a  significant  take-up  of 
products  but  a  low  take-up  of  licences8.  Since  the  last 
report in 2019, there have been 869 fewer products and 4 
fewer licences registered under the EU ecolabel. However, 
in Finland there are around 10 000 Swan-labelled products 
(out of 40 000) and 150 licences out of 2500 in the Nordic 
countries. Moreover, 4 organisations spread over 18 sites 
in Finland are currently registered in EMAS9. 

As Finland’s circular material use rate is far below the EU 
average, a priority action is proposed. 

2022 priority actions 

 

Introduce  measures  to  increase  the  circular 
material use rate. 

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;  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and phasing out the landfilling of recyclable or recoverable 
waste. 

This  section  focuses  on  the  management  of  municipal 
waste10 for which EU law sets mandatory recycling targets. 

5 European Commission - Directorate-General for Environment (DG ENV), 
Eco-innovation Observatory, Eco-innovation index. 
6 https://ym.fi/green-deal-sopimukset 
7  EMAS  is  the  European  Commission’s  eco-management  and  audit 
scheme, a programme to encourage organisations to behave in a more 
environmentally sustainable way. 

8 European Commission, Ecolabel Facts and Figures. 
9 As of May 2018. European Commission, Eco-Management and Audit 
Scheme. 
10 Municipal waste consists of (a) mixed waste and separately collected 
waste  from  households,  including  paper  and  cardboard,  glass,  metals, 

 Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
 
Preventing products and materials from becoming waste 
for as long as possible is the most efficient way to improve 
resource  efficiency  and  to  reduce  the  environmental 
impact of waste. Waste prevention and reuse are the most 
preferred  options,  and  are  therefore  at  the  top  of  the 
waste  hierarchy.  The  amount  of  municipal  waste 
generated  is  a  good  indicator  of  the  effectiveness  of 
waste-prevention measures. 

After  a  downward  trend,  municipal  waste  generation  in 
Finland  has  started  to  increase  in  recent  years  reaching 
566 kg/year/inhabitant  in  2019  in  contrast  with  the  EU 
average  (502 kg/year/inhabitant),  as  shown  in  Figure  4. 
This indicates that Finland’s generation of municipal waste 
is not yet decoupled from its economic growth. 

Figure 4: Municipal waste by treatment in Finland, 2010-
202011 

Finland  has  made  considerable  progress  in  curbing  its 
landfill rate over recent years due to a significant increase 
in  the  incineration  rate.  The  recycling  rate  for  municipal 
waste  in  2019  was  43.4%  (29.3%  of  which  was  material 
recycled,  while  14.1%  was  composted  or  anaerobically 
digested), slightly below the EU average of 47.7% for the 
same year. 

Figure 5 shows that Finland needs to continue investing in 
recycling to meet the EU's recycling targets for 2020 and 
2025. 

Finland  7 

Figure 5: Recycling rate of municipal waste, 2010-2020912 

The Commission’s early warning report13 listed Finland as 
one of the countries at risk of missing the EU 2020 target 
of recycling 50% of municipal waste. The report listed key 
priority measures which Finland should take to close the 
implementation  gap.  The  Commission 
is  currently 
the 
finalising 
recommendations  set  out  in  the  2018  early  warning 
reports and an analysis of progress towards achieving the 
2025 waste recycling targets. This report will be presented 
at the end of 2022.  

its  analysis  of  progress  made  on 

Implementation of the 2018 waste legislative package14 

By 5 July 2020, Member States had to bring their national 
laws  in  line  with  modifications  included  in  the  revised 
Waste Framework Directive, the Packaging and Packaging 
Waste Directive and the Landfill Directive. Finland recently 
notified  the  Commission  about  national  transposition 
measures,  and  the  Commission  is  now  carrying  out  a 
conformity assessment. 

Waste  management  plans  and  waste  prevention 
programmes are instrumental for a sound implementation 
of  the  EU  waste  legislation.  They  set  out  key  provisions 
and investments to ensure compliance with existing and 
new legal requirements (e.g. waste prevention, separate 
collection  for  a  number  of  specific  waste  streams, 
recycling  and 
targets).  Revised  plans  and 
programmes were due on 5 July 2020. 

landfill 

In March 2022, Finland adopted a revised national waste 
management plan15 that runs until 2027. This plan applies 

plastics,  bio-waste,  wood,  textiles,  packaging,  waste  electrical  and 
electronic  equipment,  waste  batteries  and  accumulators,  and  bulky 
waste, 
including  mattresses  and  furniture;  (b)  mixed  waste  and 
separately  collected  waste  from  other  sources,  where  such  waste  is 
similar in nature and composition to waste from households. (Directive 
2008/98/EC, Art. 3 2b). 
11 Eurostat, Municipal waste by waste operation, april 2022. 
12 Eurostat, Recycling rate of municipal rate, april  2022. 
13European  Commission,  Report  on  the  implementation  of  waste 
legislation, including the early warning report for Member States at risk 

of missing the 2020 preparation for re-use/recycling target on municipal 
waste. 
14  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.e, SWD(2018)422 accompanying COM(2018)656 
15https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/163978/Y
M_2022_13.pdf?sequence=1&isAllowed=y 

 Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
 
Finland  8 

2022 priority actions 

 

 

 

Introduce  progressive  and  effective  economic 
instruments  to  curb  the  rate  of  landfilling  of 
waste  streams  other  than  municipal  waste. 
Channel  those  revenues  towards  measures  to 
improve  waste  management  in  line  with  the 
waste hierarchy. 
Introduce  new  policies  in  line  with  the  waste 
hierarchy,  i.e.  promote  prevention,  and  make 
product 
recycling  more 
economically attractive. 
the  adopted  national  waste 
that 
Ensure 
management plan covers the whole territory, the 
Åland Islands islands.  

reuse  and  waste 

to the mainland only and does not cover the Åland islands, 
which  is  regarded  as  a  major  shortcoming  in  legal 
compliance. The Commission will carry out a compliance 
check  to  ensure  that  the  plan  aligns  with  EU  waste 
legislation. 

In the  2019 EIR, Finland receive priority actions to apply 
economic instruments to waste management; to promote 
prevention, make reuse and recycling more economically 
attractive;  to 
improve  the  functioning  of  extended 
producer  responsibility;  to  shift  reusable  and  recyclable 
waste away from incineration; to set mandatory recycling 
targets for municipalities and shift responsibilities back to 
the  municipalities,  with  measures 
in  case  of  non-
compliance;  and  to 
introduce  mandatory  minimum 
service standards on separate collection. 

Given  the  limited  progress  and  in  light  of  the  upcoming 
early  warning  report  for  2022,  similar  priority  actions  as 
the ones set out in the 2019 EIR are proposed below. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
Finland  9 

2. Biodiversity and natural capital 

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and sets out new targets and governance mechanisms to 
achieve  healthy  and  resilient  ecosystems.  In  particular, 
the strategy sets out ambitious targets to:  

(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;  

(ii) strictly protect at least a third of the EU’s protected 
areas, including all remaining EU primary and old-growth 
forests; and  

(iii) effectively manage all protected areas, defining clear 
conservation  objectives  and  measures,  and  monitoring 
them appropriately.  

The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore degraded ecosystems across the EU by 2030, and 
manage them sustainably, addressing the key drivers of 
biodiversity loss. 

The EU’s Habitats and Birds Directives are key legislative 
tools  to  deliver  on  the  targets  in  the  EU’s  biodiversity 
strategy for 2030, and are the cornerstone of European 
legislation aimed at conserving the EU’s wildlife16. 

To  follow  up  on 
its  national  action  plan  for  the 
conservation  and  sustainable  use  of  biodiversity  for 
2013-2020,  Finland  plans  to  adopt  its  new  national 
biodiversity strategy to 2030 and a related action plan in 
early 202217. 

Nature protection and restoration  

Natura  200018,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
in  the  Birds  and  Habitats 
achieve  the  objectives 

16 These should be reinforced by the Nature Restoration Law, 
according to the new EU biodiversity strategy. 
17 National Biodiversity Policy - Ministry of the Environment (ym.fi). 
18  Natura  2000  comprises  sites  of  Community  importance  (SCIs) 
designated under  the  Habitats Directive  as  well  as  special  protection 
areas  (SPAs)  classified under  the  Birds  Directive.  Coverage  figures do 
not add up as some SCIs and SPAs overlap. Special areas of conservation 
(SACs) are SCIs designated by Member States. 
19 Sites of Community importance (SCIs) are designated under to the 
Habitats  Directive  whereas  Special  Protection  Areas  (SPAs)  are 
designated under to the Birds Directive; figures of coverage do not add 
up  since  some  SCIs  and  SPAs  overlap.  Special  Areas  of  Conservation 
(SACs) are SCIs designated by the Member States. 

Directives.  These  objectives  are:  (i)  to  ensure  the  long-
term  protection,  conservation  and  survival  of  Europe’s 
most valuable and threatened species and habitats; and 
(ii)  to  maintain  or  restore  the  favourable  conservation 
status  of  these  species  and  habitats.  Key  milestones 
towards meeting the objectives of the Birds and Habitats 
Directives  are:  (i)  the  setting  up  of  a  coherent  Natura 
2000 network; (ii) the designation of sites of Community 
importance  (SCIs)  as  SACs19;  and  (iii)  the  setting  of 
conservation  objectives  and  measures  for  the  Natura 
2000 sites. 

Setting up a coherent network of Natura 2000 sites 

Finland  hosts  68  habitat  types20  and  128  species21 
covered by the Habitats Directive. The country also hosts 
populations of 81 bird taxa listed in Annex I to the Birds 
Directive22. 

By 202123, 12.6% of the territory of Finland was covered 
by  Natura  2000  (EU  average  18.5%),  with  special 
protection  areas  (SPAs)  classified  under  the  Birds 
Directive  covering  7.3%  (EU  average  12.8%)  and  SCIs 
under the Habitats Directive covering 12.5% (EU average 
14.2%) of the Finnish territory. 

Considering  both  Natura  2000  and  other  nationally-
designated  protected  areas,  Finland  legally  protects 
13.2% of its terrestrial areas (EU-27 average 26.4%) and 
11% of its marine areas (EU-27 average 10.7%)24. 

20 EEA, Article 17 dashboard, Annex I total, 2019 
21  Number  of  habitats  and  species  per  Member  State  — 
European Environment Agency (europa.eu) 

22  EEA, Article  12  dashboard,  Annex  I,  2020. This counting  only  takes 
into account birds taxa for which information was requested. 
23 Workbook: Barometer (europa.eu) 
24 
 European  Environment  Agency,  Protected  Areas,  terrestrial 
protected  area  percentage  (2021)  and  marine  protected  area 
percentage (2019), March 2022. 

Environmental Implementation Review 2022 – Finland 

 
 
                                                                 
 
 
 
 
 
 
Figure 6: Marine & terrestrial protected area coverage, 
202125  

Designating special areas of conservation (SACs) and 
setting conservation objectives and measures 

Finland  10 

In  the  2019  EIR,  Finland  received  priority  actions  to 
complete the Natura 2000 network, especially for marine 
sites. Finland took decisive steps in this respect, however 
it  still  needs  to  speed  up  the  necessary  conservation 
measures, as they are yet to be defined for some sites, 
including the Åland Islands. 

Progress in maintaining or restoring favourable 
conservation status of species and habitats 

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
favourable 
the 
towards  maintaining  or  restoring 
conservation status of species and habitats. 

According  to  Finland's  report  for  2013-2018  on  the 
conservation  status  of  habitats  and  species  required 
under  Article 17  of  the  Habitats  Directive,  31.87%  of 
habitats  were  assessed  as  being  in  good  conservation 
status in 2018, slightly lower than the 33.70% reported in 
the  previous  reporting  period  (2007-2012).  As  for 
protected  species,  45.28%  were  assessed  as  being  in 
good conservation status in 2018, marginally lower than 
the 46.00% reported  in 2007-2012.  Only 11.76% of the 
forest habitats of Community interest in Finland show a 
favourable conservation status27. Regarding birds , 26% 
of the breeding species showed short-term increasing or 
stable population trends. Together with Austria, Finland 
has  the  highest  trend  in  reported  increasing  wintering 
populations in the short term (50%). 

Between  the  same  reporting  periods,  the  share  of 
habitats  in  bad  conservation  status  increased  from 
26.09%  to  31.87%  and  the  share  of  assessments  for 
species  in  bad  conservation  status  also  increased  from 
11.33%  to  13.21%.  The  main  pressures  identified  for 
habitats are forestry, mixed source pollution, agriculture, 
and development and construction. Unknown pressures 
including pressures from outside Finland also rank high 
for habitats, and are the main pressure for species, which 
are  also  strongly  affected  by  forestry  and  natural 
processes. 

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202126  

25  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 

26  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 
27State of Nature Report. EEA 2021. 

Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
 
 
 
 
                                                                 
 
Figure  8:  Assessments  on  conservation  status  for 
habitats  for  2007-2012  and  2013-2018  reporting 
periods28  

Figure  9:  Assessments  on  conservation  status  for 
species 
for  2007-2012  and  2013-2018  reporting 
periods29 

Finland  needs  to  ensure  that  species  and  habitats  of 
Community  interest  are  maintained  at  or  restored  to 
favourable  conservation  status  across  their  natural 
range.  Finland  has  ambitious  nature  protection  and 
restoration programmes, namely the METSO programme 
for financing forest biodiversity measures and the HELMI 
programme focusing mainly on mires, wetlands, coastal 
habitats and semi-natural grasslands. The SOTKA project 
is  also  important  to  improve  the  status  of  waterfowl. 
Considering the increasing numbers of negative trends in 
the  conservation  status  of  habitats  and  species,  it  is 

Finland  11 

important that Finland pursues such actions with similar 
ambition over the years. 

In  April  2020,  the  EU  Court  of  Justice30  condemned 
its  obligations  under 
Finland  for  failing  to  fulfil 
Article 7(4) and Article 9(1)(c) of Directive  2009/147/EC 
on  the  conservation  of  wild  birds  and  for  recurrently 
granting  authorisations  for  spring  hunting  of  male 
common  eiders  in  the  province  of  Åland  since  2011.  
Another case is ongoing on the summer hunting of male 
common eiders in mainland Finland. 

In its judgment of October 2019, following a question for 
a preliminary ruling from Finland, the EU Court of Justice 
set  out  the  strict  conditions  under  which  a  derogation 
from the prohibition on the deliberate killing of a species 
protected under the Habitats Directive, such as wolves, 
may be granted in the context of hunting for population-
management purposes. Finland is promoting coexistence 
through  various  strands  of  action  and  has  to  fully  take 
account of this ruling in its legal framework. 

In  the  2019  EIR,  Finland  received  priority  actions  to 
better integrate biodiversity concerns into other policies 
and promote better communication between actors; and 
to develop a strategy with the forest sector in order to 
ensure the forestry sector better integrates biodiversity 
goals, including outside Natura 2000. Limited progress is 
noted on these actions. 

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable agriculture.  
The biodiversity and farm to fork strategies have set four 
important targets for 2030:  
- a 50% reduction in the overall use of – and risk from – 
chemical pesticides; 
-  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
-  a  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  a  20%  reduction  in  the  use  of 
fertilisers);  
- bring back at least 10% of agricultural area under high-
diversity  landscape  features  and  increase  areas  under 

28.  European Environment Agency, Conservation status and trends of 
habitats and species, December 2021. Please note when comparing the 
figures shown for 2007-2012 and 2013-2018 these may also be affected 
by changes of methods or due to better data availability. 

29 idem 
30 CURIA - Documents (europa.eu) 

Environmental Implementation Review 2022 – Finland 

 
 
 
 
                                                                 
 
Finland  12 

(i) preventing further soil degradation;  
(ii) making sustainable soil management the new normal;  
(iii) taking action for ecosystem restoration. 

One factor in the degradation of soil ecosystems is the 
area of soil that is sealed or artificialised33. The net land 
taken  (land  ‘taken’  means 
is  sealed  or 
artificialised)  per  year  in  2012-2018  can  be  seen  as  a 
measure  of  one  significant  pressure  on  nature  and 
biodiversity  –  land  use  change.  At  the  same  time,  land 
use  change  constitutes  an  environmental  pressure  on 
people living in urbanised areas. 

land  that 

Despite a reduction in the last decade (land take was over 
1 000  km2/year  in  the  EU-28  between  2000  and  2006), 
land take in the EU-28 still amounted to 539km2/year in 
2012-201834.  The  concept  of  ‘net  land  take’  combines 
land  take  with  the  return  of  land  to  non-artificial  land 
categories  (re-cultivation).  While  some  land  was  re-
cultivated in the EU-28 in 2000-2018, 11 times more land 
was taken than returned. 

Finland ranks well below35 the EU average with net land 
take of 11.5 m²/Km² (EU-27 average: 83.8 m2/km2). 

In  2018,  Finland  updated 
land 
degradation  according  to  the  next  PRAIS3  reporting 
platform36  with  actions 
intended  to  combat  the 
degradation identified. 

its  reporting  on 

organic farming to at least 25%. 

Finland,  with  estimated  13.93%  of  area  under  organic 
farming,  is  above  the  EU  average  of  9.07%  (2020  data, 
Eurostat), making it a key contributor to the 2030 target 
of having 25% of the EU’s agricultural land under organic 
farming. 

Figure  10:  Share  of  total  utilised  agricultural  area 
occupied by organic farming per Member State, 202031  

According  to  the  Commission's  recommendations  for 
Finland’s  common  agricultural  policy  (CAP)  strategic 
plan32,  Finland  should  step  up  efforts  on  ammonia 
emissions,  biodiversity  and  water  quality.  In  particular, 
Finland  is  at  high  risk  of  not  reaching  its  ammonia 
emission  reduction  commitments  for  2020-2029.  The 
Farmland Bird Index shows a decrease in farmland birds, 
and bird species associated with agricultural habitats are 
also  decreasing.  Further  investments  are  needed  to 
protect  wetlands,  peatlands  and  grassland,  and  for 
manure  management  (particularly  to  reduce  ammonia 
emissions). 

Soil ecosystem 

soil 

new 

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
adopted 
on 
The 
EU 
17 November 2021,  stresses  the 
importance  of  soil 
protection,  of  sustainable  soil  management  and  of 
restoring  degraded  soils  to  achieve  the  Green  Deal 
objectives as well as land-degradation neutrality by 2030.  
This entails:  

strategy, 

31  
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en (Eurostat, Area under organic farming, February 2022). 
32 EUR-Lex - 52020SC0376 - EN - EUR-Lex (europa.eu) 
33 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). 
34 Land take  in Europe — European Environment Agency (europa.eu) 
Fig 6. 
35 Land take in Europe – European Environment Agency (europa.eu) 
Fig 6. 
36 All Reports | Prais3 (unccd.int). 

Environmental Implementation Review 2022 – Finland 

 
 
                                                                 
Figure  11:  Land  take  and  re-cultivation 
(m2/km2), 2012-201837 

in  EU27 

is vital if the EU is to achieve climate neutrality by 2050 

Finland  13 

Out  of  the  27%  of  EU  forest  area  protected  under  the 
Habitats Directive, less than 15% of assessments show a 
favorable conservation status39. The share of forest area 
in  the  EU  in  a  bad  conservation  status  increased  from 
27% in 2015 to 31%.  

Forests  cover  79.6%  of  Finland's  territory40  and  more 
than  75%  of  the  assessments  reveal  a  bad  to  poor 
status41.  203 000 ha  in  Finland  is  covered  by  primary 
forests42. 

Figure  12:    Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)43 

Sustainable Development Goal (SDG) target 15.3 states: 
‘By 2030, combat desertification, restore degraded land 
and  soil,  including  land  affected  by  desertification, 
land 
drought  and  floods,  and  strive  to  achieve  a 
degradation-neutral world.’ 

In 2015, a breakthrough agreement was reached under 
the  United  Nations 
Combat 
Desertification (UNCCD)38 to endorse the vision of  land 
degradation 
the 
implementation  of  the  Convention  to  the  SDGs  in 
general, and target 15.3 in particular. 

Convention 

neutrality 

(LDN) 

and 

link 

to 

To date, Finland has not yet committed to set LDN targets 
under the UNCCD agreement. 

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
part  of  the  ‘Fit  for  55’  package.  The  strategy  promotes 
the many services that forests provide. Its key objective 
is to ensure healthy, diverse and resilient EU forests that 
contribute significantly to the strengthened biodiversity 
and climate ambitions.  
Forests are important carbon sinks and conserving them 

37 European Environment Agency, Land take in Europe, December 2021. 
38 The LDN Target Setting Programme | UNCCD. 
39 EEA, State of Nature in the EU 
40 EEA, Forest information system for Europe. 
41 COM SWD (2021) 652 
42 JCR, Mapping and assessment of primary and old-growth forests in 
Europe, p. 13. 

The  European  Union  Timber  Regulation 
(EUTR)44 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested  timber.  In  accordance  with  the  EUTR,  EU 
Member  States’  competent  authorities  must  conduct 
regular  checks  on  operators  and  traders,  and  apply 
penalties  for  non-compliance.  With  the  amendment  of 
Article 20 of the EUTR, reporting every 2 years has been 
changed  to  annual  reporting,  and  covers  the  calendar 
year as of 2019. 

Between  March  2017  and  February  201945,  Finland 
carried  out  60  checks  on  operators  importing  timber-
based  products.  It  is  estimated  that  Finland  had  2 000 
operators placing imported timber-based products onto 
the  internal  market  over  the  reporting  period.  In  total, 
there are approximately 350 000 domestic operators in 
Finland,  of  which  about  100 000  actively  place  timber 
onto  the  market  every  year.  A  proposal  for  the 

43  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
44 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
45 COM/2020/629 final 

Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
 
Regulation on the making available on the EU market and 
export  of  products  associated  with  deforestation  and 
forest  degradation 
(Deforestation  Regulation)  was 
adopted on 17 November 2021 following a request from 
the  Council  in  2019  to  table  a  legislative  proposal  to 
address  the  problem  and  a  European  Parliament 
resolution  recommending  the  Commission  to  come 
forward with an EU legal framework to halt and reverse 
EU-driven  global  deforestation.  This  Regulation  will 
repeal and replace the EU Timber Regulation, as the new 
Deforestation  Regulation  will  essentially  integrate  and 
improve  the  existing  system  to  control  the  legality  of 
timber.  

Invasive alien species (IAS) 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside changes in land and sea use, overexploitation, 
climate change and pollution).  
Besides  inflicting  major  damage  on  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 
and wildlife.  
The  implementation  of  the  EU  Invasive  Alien  Species 
legislation  must  be 
Regulation  and  other  relevant 
stepped up.  
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  invasive  alien  species  and  decrease  the 
number of ‘red list’ species they threaten by 50%. 

The core of Regulation (EU) 1143/2014 on IAS (‘the IAS 
Regulation’46) is the list of IAS of Union concern.  

The total number of IAS of Union concern is currently 66, 
of which: 30 are animal species; 36 are plant species; 41 
are  primarily  terrestrial  species;  23  are  primarily 
freshwater species; 1 is a brackish-water species; and 1 is 
a marine species. 

According  to  a  2021  report47 on  the  implementation  of 
the  IAS  Regulation,  progress  was  being  made  towards 
certain  objectives,  such  as  creating  a  coherent 
framework for addressing IAS at EU level and increasing 
awareness of the problem of invasive alien species. The 
report  also  identified  some  challenges  and  areas  for 
improvement.  However,  given  that 
implementation 
deadlines  for  the  IAS  Regulation  were  staggered  from 
July  2016  to  July  2019,  it  is  still  too  early  to  draw 
conclusions on several aspects of implementation. 

Finland  14 

A 2021 report48 on the baseline distribution shows that 
of the 66 species on the EU list, 13 have been observed 
in  the  environment  in  Finland.  The  spread  can  be 
checked in Figure 13. 

Figure  13:  Number  of  invasive  alien  species  of  EU 
concern, based on available georeferenced information 
for Finland, 2021 

2022 priority actions  

 

 

 

 

Pursue  and  step  up  efforts  to  finalise  site 
specific  conservation  objectives  and  measures 
for  all  Natura  2000  sites  and  to  protect  or 
restore  species  and  habitats  of  Community 
interest  to  a  favourable  conservation  status 
across their natural range. 
Fully  integrate  biodiversity  concerns  into  the 
implementation  of  other  policies, 
including 
outside the Natura 2000 network, in particular 
in the forestry sector. 
Ensure  the  regulatory  framework  applying  in 
Finland to the taking of protected species is fully 
in  line  with  the  requirements  of  the  Nature 
Directives. 
Pursue  and  scale  up  efforts  to  ensure  that 
forestry practices take full account of the need 
to protect and restore the  conservation  status 
of forest habitats and species. 

46 Regulation (EU) No 1143/2014 of the European Parliament and of the 
Council of 22 October 2014 on the prevention and management of the 
introduction and spread of invasive alien species. 
 47  Report  from  the  Commission to  the  European  Parliament  and the 
Council  on  the  review  of  the  application  of  Regulation  (EU) 
No 1143/2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 

48  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D’  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines, 
the  European  Union, 
EUR 30 689  EN,  Publications  Office  of 
Luxembourg,  2021, 
ISBN  978-92-76-37420-6,  doi:10.2760/11150, 
JRC123170. 

Environmental Implementation Review 2022 – Finland 

 
                                                                 
 
 
Finland  15 

Figure 14: Level of adequacy of GES determination by 
Finland (BAL region) with criteria set under the 
Commission GES Decision – Article 9 (2018 reporting 
exercise)51 

 

 

implementing 

the 
Step  up  action  on 
recommendations  set  out  in  Finland’s  CAP 
strategic  plan,  especially  on  improving  rural 
areas. 
Step  up  the  implementation  action  of  the  EU 
Invasive Alien Species Regulation. 

Marine ecosystems 

The  EU  Biodiversity  Strategy 
for  2030  aims  to 
substantially  reduce  the  negative  impacts  on  sensitive 
species  and  habitats  in  marine  ecosystems  and  to 
achieve good environmental status as well as eliminate 
or 
incidental  catches  of  protected, 
endangered, threatened and sensitive species to a level 
that allows species recovery and conservation[1]. 

reduce 

the 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member States must draw up marine strategies for their 
marine  waters,  and  cooperate  with  Member  States 
sharing  the  same  marine  region  or  sub-region.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

requires  Member 

The  MSFD  also 
States  by 
15 October 2018 to draw up a set of GES characteristics 
for each descriptor (Article 9), and to provide an initial 
assessment  of  their  marine  waters  (Article  8).  The 
Commission  then  assesses  whether  this  constitutes  an 
appropriate framework to meet the requirements of the 
Directive. 

assessed 

Finland’s 

Commission 

 The 
2018 
determinations  of  GES  for  each  of  the  MSFD’s  11 
descriptors49 and determined their level of adequacy  in 
relation to the Commission’s GES Decision50. A good or 
very 
the  national 
indicates 
determinations  of  GES  are  well  aligned  with 
requirements of the Commission GES Decision, providing 
qualitative  and  quantitative  national  environmental 
objectives to be achieved for their marine waters. 

score 

good 

that 

Finland  has  one  marine  sub-region,  BAL-Baltic  Sea.    In 
this marine sub-region, 8 of of 11 determinations of GES 
were  assessed  as  good  or  very  good.  The  national 
determination of GES by Finland is coherent for 8 out of 
11 descriptors. 

The  MSFD  also  requires  that  Member  States  make  an 
assessment of the current environmental status of their 
marine waters in relation to the determination of GES. A 
good or very good score indicates that a Member State 
has good capabilities to assess their marine environment 
in  accordance  with  the  requirements  set  out  in  the 
Commission GES Decision. 

[1]  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
49 Annex I of Directive 2008/56/EC. 
50  Commission  Decision  (EU)  2017/848  laying  down  criteria  and 
methodological  standards  on  good  environmental  status  of  marine 

waters  and  specifications  and  standardised  methods  for  monitoring 
and assessment, and repealing Decision 2010/477/EU. 
51  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States, January 2022. Please note that only 
two sub-sections of descriptor D1 are displayed (D1-M Mammals and 
D1-B Birds). For the analysis, these two sub-sections were considered 
as a whole after averaging them. 

Environmental Implementation Review 2022 – Finland 

 
                                                                 
 
Figure 15: Level of adequacy of initial assessment of 
Finland’s marine environment (BAL region) with 
criteria set under the Commission GES Decision – 
Article 8 (2018 reporting exercise)52 

Finland  16 

to 

the  Commission's 
Member  States.  According 
assessment, Member States need to step up their efforts 
to determine the good environmental status and the use 
of the criteria and methodological standards according to 
the Commission GES Decision. The above considerations 
form the basis for the 2022 priority actions. 

2022 priority actions 

 

 

the 

Communication55 

Implement the recommendations made by the 
Commission  in  the  staff  working  document54 
accompanying 
on 
recommendations  per  Member  States  and 
region on the 2018 updated reports for Articles 
8, 9 and 10 of the MSFD. 
Continue  to  ensure  regional  cooperation  with 
Denmark,  Estonia,  Germany,  Latvia,  Lithuania, 
Poland and Sweden in the Baltic Sea  region to 
address predominant the main pressures. 

Ecosystem assessment and accounting  

The  EU  biodiversity  strategy  for  2030  calls  on  Member 
States to better integrate biodiversity considerations into 
public and business decision making at all levels and to 
develop  natural  capital  accounting.  The  EU  needs  a 
better-performing biodiversity-observation network and 
more  consistent 
the  condition  of 
reporting  on 
ecosystems.  

Ecosystem assessment is an analysis of the pressures and 
the  condition  of  terrestrial,  fresh  water  and  marine 
ecosystems  and  their  services.  It  uses  spatially-explicit 
data  and comparable methodology based on European 
data  about  the  functions  of  ecosystem  assets  and  the 
ecosystem services they produce, relative to the baseline 
year 2010. 

Ecosystem  accounting  is  built  on  five  core  accounts 
(ecosystem  extent,  ecosystem  condition,  physical 
ecosystem  services,  monetary  ecosystem  services  and 
monetary  ecosystem  asset).  These  accounts  are 
compiled  using  indicators  of  ecosystem  assets  and  the 
ecosystem services they produce. 

Finland has actively participated in the Esmeralda project 
the  previous  ecosystem  service 
which  continues 
assessment  works  such  as  TEEB  for  Finland  study 
(Towards  Sustainable  and  Genuinely  Green  Economy  - 
The value and social significance of ecosystem services in 
Finland),  and  development  of  the  Finnish  Ecosystem 
framework  that 
Services 

Indicators  –  a  national 

In  this  marine  sub-region,  BAL-Baltic  Sea,  7  descriptors 
out  of  11  were  scored  as  good  or  very  good.  Finland’s 
assessment  of its marine environment  is coherent  with 
requirements set under the Commission GES Decision for 
7 out of 11 descriptors. 

the  MSFD53,  while 

As  highlighted  in  the  Commission’s  report  on  the 
implementation  of 
regional 
cooperation  has  improved  since  the  adoption  of  the 
MSFD, more cooperation is needed to attain full regional 
coherence  of  the  marine  strategies,  as  required  by  the 
Directive. 

for 

the 

timelines 

achieving 

In  the  2019  EIR    Finland  received  priority  actions  to 
determine 
good 
environmental  status  when  these  have  not  been 
reported  and  to  ensure  regional  cooperation  with 
Denmark,  Estonia,  Germany,  Latvia,  Lithuania,  Poland 
and  Sweden  in  the  Baltic  Sea  region  to  address  the 
predominant pressures. Finland made some progress on 
the above actions. However, the levels measured above 
call for further actions to achieve GES in the descriptors 
ranked as poor in Figure 15 above. 

Furthermore, in March 2022, the European Commission 
published a  Communication  with recommendations for 

52  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by the Member States, January 2022. Please note that only 
two sub-sections of descriptor D1 are displayed (D1-M Mammals and 
D1-B Birds). For the analysis, these two sub-sections were considered 
as a whole after averaging them. 

53 COM(2020)259 
54 
SWD(2022)1392. 
55 
 COM(2022)550. 

Environmental Implementation Review 2022 – Finland 

 
 
 
  
                                                                 
integrates  CICES  classification  and  Cascade  model.  This 
internet  portal  aims  at  synthesising  the  knowledge  on 
the  status  of  biodiversity,  ecosystem  services,  and  for 
instance, to serve as the national webpage of the Nagoya 
Protocol  on  genetic  resources  and  the  Cartagena 
Protocol on biosafety. 

MAES-related  developments  in  Finland  fall  under  four 
categories:  (i)  networking  and  information  sharing;  (ii) 
supporting  land  use  planning;  (iii)  integrated  natural 
capital  accounting;  and  (iv)  preparing  for  ecosystem 
condition  assessment.  Finland  has  provided  updated 
information  and  progress  has  been  recorded  since 
January 2016 (Figure 16). This assessment is based on 27 
implementation questions and updated every 6 months. 

Figure 16: ESMERALDA MAES Barometer (January 2016 
- March 2021)56 

Progress  on  ecosystem  accounting  implementation  is 
assessed  at  national  scale  based  on  13  questions  (see 
Figure 17). 

Figure 17: Ecosystem accounting Barometer, 
September 202157 

Finland  17 

bottom  up  process.  The  Eurostat  initiative  to  update 
Regulation (EU) 691/2011 and the SEEA-EA are expected 
to  increase  demand  for  natural  ecosystem  accounting 
from  the  policy  side  in  Finland.  Finland  has  developed 
multiple  frameworks  and  has  done  multiple  academic 
exercises in natural capital accounting but there are no 
official accounts published so far. 

in  Finland.  Moreover, 

The lack of a mandate is possibly the main barrier to the 
implementation  of  ecosystem 
development  and 
accounts 
finding  common 
language  between  natural  scientists,  economists  and 
statisticians  takes  time.  Data-based  quantification  of 
fresh  water  assets  is  currently  not  possible  as  data  are 
fully  or  partly  missing.  The  marine  condition  account 
needs 
to 
contradictory  or  non-feasible  guidelines.  For  instance, 
the  concepts  of  'green  water  footprint'  or  'soil  water 
consumption' are found to be very theoretical and hard 
to apply in the Finish national context. 

refining.  Some  problems  are 

linked 

2022 priority actions 

  Develop  harmonised, 

IUCN  GET-compliant 

hierarchical ecosystem classification. 

  Decide whether to provide ecosystem accounts, 
which  would  ensure:  (i)  human  resources  for 
Statistics Finland, SYKE and Luke to incorporate 
the  SEEA-EA  in  their  daily  activities;  (ii)  the 
automatisation of the workflow; and (iii) closer 
collaboration with expert networks.  

Currently  there  is  no  official  mandate  for  ecosystem 
accounting in Finland. Methodological development for 
piloting  ecosystem  and  water  accounting  has  been  a 

56 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem assessment: summary for policymakers, page 80, May 2021. 
57  MAIA  Portal,  Mapping  and  assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Experimental  Ecosystem 
Accounting (SEEA-EEA) as the methodological basis for the ecosystem 

accounting. The SEEA EA is an integrated and comprehensive statistical 
framework  that  is  based  on  five  core  accounts:  ecosystem  extent, 
condition, services and monetary ecosystem asset. 

Environmental Implementation Review 2022 – Finland 

 
 
 
 
                                                                 
 
Finland  18 

3. Zero pollution

Clean air 

Figure  18:  Emission  trends  of  main  pollutants/  GDP  in 
Finland, 2005-201964 

its 

 EU clean-air policies and legislation need to significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  
Air  pollution  and 
impacts  on  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 
clean-air  legislation  and  defining  strategic  targets  and 
actions for 2030 and beyond.  
The 2030 zero-pollution action-plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the  EU  ecosystems  threatened  by  air  pollution  by  25%, 
compared to 2005.  

The EU has developed a comprehensive suite of clean air 
legislation, which sets health-based air quality standards58 
and  emissions-reduction  commitments59  by  Member 
State for a number of air pollutants. 

Air quality in Finland is generally good, with a exceptions. 
The  latest  available  annual  estimates  (for  2019)  by  the 
European  Environment  Agency60  point  to  about  1  500 
premature  deaths  (or  15  900  years  of  life  lost  (YLL)) 
attributable  to  fine  particulate  matter  concentrations61, 
and 90 (1 000 YLL) to ozone concentrations62 63. 

The  emissions  of  several  air  pollutants  have  decreased 
significantly  in  Finland  over  the  last  years,  while  GDP 
growth  continued  (see  graph).  According  to  the  latest 
projections  as  submitted  under  Article 10(2)  of  the 
National  Emission  Reduction  Commitments  Directive 
(NECD),  Finland  projects  to  reach  emission  reduction 
commitments  for  all  air  pollutants  covered  by  the 
Directive 
from  2030  onwards. 
According  to  the  latest  inventory  data  submitted  by 
Finland, which is still to be reviewed by the Commission, 
Finland  is  in  compliance  with  the  emission  reduction 
commitments for all pollutants in 2020. 

for  2020-2029  and 

Finland  submitted 
programme (NAPCP) on 29 March 2019. 

its  national  air  pollution  control 

Figure 19: PM2.5 and NOx emissions by sector in Finland 
(2019)65 

58European Commission, 2016. Air Quality Standards. 
59European Commission, Reduction of National Emissions. 
60 European Environment Agency, Air Quality in Europe –2021 
Rapport. Please see details in this report as regards the underpinning 
methodology, p.106 
61 Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10 (PM2.5) refers to particles with a diameter of 10 (2.5) 

micrometres or less. PM is emitted from many human sources, 
including combustion. 
62 Low-level ozone is produced by photochemical action on pollution. 
63 Please note that these figures refer to the impacts of individual 
pollutants, and to avoid double-counting cannot be added up to 
derive a sum. 
64 European Environment Agency. 
65 European Environment Agency. 

Environmental Implementation Review 2022 – Finland 

 
 
                                                                 
  
 
Finland  19 

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;  

(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 Directive67 (IED). The Commission 
tabled a proposal  in April  202268. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular-economy policies  

The overview of industrial activities regulated by the IED 
set out below is based on data reported to the EU Registry 
(2018)69. 

industrial 

In  Finland,  around  1 250 
installations  are 
required  to  have  a  permit  based  on  the  IED.  This 
represents  an  increase  of  almost  600  installations  since 
2015,  mainly  combustion  plants  but  also  installations  in 
the  waste  management  sector  The  distribution  of 
installations is shown in the figure below. 

The industrial sectors in Finland with most IED installations 
in  2018  were  the  energy  sector  (25%),  followed  by  the 
waste  management  sector, 
landfills  (24%), 
intensive  rearing  of  poultry  and  pigs  (20%)  and  the 
production and processing of metals (10%). 

including 

Air quality in Finland is generally good with exceptions. For 
the  year  2020,  no  exceedances  above  the  limit  values 
established by the  Ambient  Air Quality Directive (AAQD) 
were  registered.  However,  for  one  air  quality  zone  the 
target  values  on  ozone  concentration  have  not  been 
met66. 

In the 2019 EIR, Finland was advised to take, as part of its 
NAPCP,  actions  towards  reducing  the  main  emission 
sources  and  to  meet  all  air  quality  standards.  Some 
progress has been achieved, with the exception of ozone 
concentration. 

2022 priority actions  

 

 

Take, in the context of the National Air Pollution 
Control  Programme  (NAPCP),  actions  towards 
reducing  emissions  from  the  main  sources 
mentioned above.  
Ensure  full  compliance  with  EU  air  quality 
standards  and  maintain  downward  emissions 
trends  for  air  pollutants,  to  reduce  adverse  air 
pollution  impacts  on  health  and  the  economy 
with a view to reaching WHO guideline values in 
the future.  

66 European Environment Agency, Eionet Central Data Repository. 
67  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 
industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 

68  European  Commission,  proposal  for  a  revision  of  the  Industrial 
Emissions Directive, 4 April 2022. The revision of the IED is performed in 
parallel to the revision of Regulation (EC) No 166/2006 on the European 
Pollutant Release and Transfer Register (E-PRTR). 
69 European Environment Agency, European Industrial Emissions Portal. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
 
                                                                 
Figure  20:  Number  of  IED  industrial  installations  per 
sector in Finland, 201870 

Figure 21: Emissions to air from IED sectors and rest of 
national total air emissions in Finland, 201871 

Finland  20 

The industrial sectors identified as contributing the largest 
burden to the environment for emissions to air were the 
energy  sector  for  sulfur  oxides  (SOx),  nitrogen  oxides 
(NOx),  arsenic  (As),  copper  (Cu),  mercury  (Hg),  zinc  (Zn) 
and dioxins; the production and processing of metals (in 
particular iron and steel) for chromium (Cr) and nickel (Ni); 
intensive rearing of poultry or pigs for ammonia (NH3) and 
particulate matter (PM2.5). The breakdown is shown in the 
following graph. 

The  environmental  burdens  for  industrial  emissions  to 
water  mainly  result  from  the  food  and  drink  sector  for 
total  phosphorous  and  total  organic  carbon  (TOC),  from 
the production of pulp and paper for total nitrogen as well 
as for heavy metals (together with metal production and 
processing sector for the latter). The breakdown, based on 
E-PRTR data, is presented in the figure below.  

70  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

71  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
                                                                 
 
 
 
 
Figure  22:  Relative  releases  to  water  from  industry  in 
Finland, 201872 

Figure 23: Number of inspections in IED installations in 
Finland in 2018 73 

Finland  21 

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers the 
public and NGOs to ensure that permits are appropriately 
granted  and  that  the  conditions  of  these  permits  are 
complied  with.  As  part  of  environmental  inspection, 
competent  authorities  undertake  site  visits  at 
IED 
installations  to  take  samples  and  to  gather  necessary 
information.  According  to  Article  23(4)  of  the  IED,  site 
visits must be carried out between once a year and once 
every  3  years,  depending  on  the  environmental  risks 
posed by the installations. In 2018, Finland carried out 825 
IED  site  visits,  mostly  to  the  waste  management  sector, 
including  landfills  (34%),  followed  by  the  energy  sector 
(25%), the production and processing of metals (12%) and 
the chemical sector (10%). 

The  development  of  best-available-technique 
(BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED74. Since the last 
EIR report, the Commission adopted BAT conclusions  for 
Belgium for: (i) waste incineration; (ii) the food, drink and 
milk  industries;  and  (iii)  surface  treatment  using  organic 
solvents  including  the  preservation  of  wood  and  wood-
products with chemicals. 

The  Commission  relies  on  the  efforts  of  national 
competent  authorities  to  implement  the  legally  binding 
BAT  conclusions  and  associated  BAT  emission  levels  in 
environmental permits. This should result in considerable 
and continuous reductions in pollution.  

to 

conclusions, 

to  address  challenges 

In  the  2019  EIR,  the  Commission  suggested  as    priority 
actions  to  review  permits  to  comply  with  new  adopted 
BAT 
strengthen  monitoring  and 
enforcement to ensure compliance with BAT conclusions 
and 
the 
recentdopted BAT conclusions for large combustion plants 
for  existing  boilers  using  biomass  and  peat  by  August 
2021.  These  actions  have  been  followed  up  by  the 
Commission  through  the  reporting  by  Finland  to  the  EU 
Registry. No non-compliant permits have been reported in 
2018. 

to  comply  with 

72 European Environment Agency, E-PRTR, European Industrial Emissions 
Portal. The heavy metals are presented both as a weighted sum of eco 
toxicity and human toxicity factors to illustrate both the ecological and 
human impact (based on USEtox) (data retrieved on 3 November 2021). 

73  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 
74 European Commission BAT reference documents. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
 
                                                                 
 
 
 
 
 
Major industrial accidents prevention – 
SEVESO 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals; 
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment; 
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents. 
The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso-III Directive)75. 

The below overview of industrial plants regulated by the 
Seveso-III Directive (‘Seveso establishments’) is based on 
data  reported  to  the  eSPIRS  database  (2018)76  and  the 
Finland  report  on  the  implementation  of  the  Seveso-III 
Directive for the period 2015-201877. 

In Finland, among the 325 Seveso establishments, 187 are 
categorised as lower-tier establishments (LTEs) and 138 as 
upper-tier establishments (UTEs) – based on the quantity 
of hazardous substances likely to be present. The UTE are 
subject to more stringent requirements. The evolution of 
the  number  of  Seveso  establishments  is  presented  in 
Figure 1. 

Figure 24: Number of Seveso establishments in Finland, 
2011, 2014 and 201878 

Finland  22 

essential to enable the proper preparation and effective 
implementation  of  the  necessary  actions  to  protect  the 
environment and the population in the event of a major 
industrial accident. 

Figure 25: Situation regarding EEPs in Finland, 201879 

The information to the public referred to in Annex V to the 
Seveso-III  Directive  –  especially  about  how  the  public 
concerned will be warned in case of a major accident; the 
appropriate  behaviour  in  the  event  of  a  major  accident; 
and  the  date  of  the  last  site  visit  –  are  permanently 
available  for  100%  of  the  Seveso  establishments  in 
Finland. 

The  share  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available to the public over the last years are presented in 
Figure 3. 

Figure 26: Share of UTEs for which information on safety 
measures and requisite behaviours were actively made 
available to the public in Finland, 2011, 2014 and 201880 

According to Finland, an external emergency plan (EEP) is 
required for 138 UTEs. In 2018, 138 UTEs had an EEP and 
138 of these EEPs had been tested over the last 3 years. 
The  summary  is  shown  in  Figure  2.  Drawing  up  EEPs  is 

75  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances. 
76 European Commission, Seveso Plants Information Retrieval System. 
77 As provided for by Article 21(2) of the Seveso-III Directive 
78 European Commission, Assessment and summary of Member States’ 
Implementing  Decision  2014/896/EU 
implementation  reports  for 

(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 
79 Idem. 
80 Idem. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
                                                                 
 
 
 
 
Finland  23 

In Finland, based on a limited set of data82, environmental 
noise is estimated to cause at least around 50 premature 
deaths  and  200  cases  of  ischaemic  heart  disease  every 
year83.  Moreover,  some  23 000  people  suffer  from 
disturbed  sleep.  In  Finland,  the  overall  noise  exposure 
decreased  by  27%  between  2012  and  2017  based  on 
reported data. 

On the basis of the latest full set of information that has 
been  analysed,  noise  mapping  of  agglomerations,  roads 
and railways is complete . 

Water quality and management 

A letter of formal notice was issued to Finland in July 2020 
for  not  having  correctly  transposed  the  Directive’s 
requirements on: (i) the establishment’s safety report; (ii) 
granting non-governmental organisations the right to get 
information  on  the  establishments  in  question  and  the 
dangerous  substances  used;  and  (iii)  the  information 
underpinning  the 
in  the  establishments. 
Finland has notified the national transposition measures 
that  should  remedy  the  breaches 
identified.  The 
Commission is currently assessing the Finnish notification. 

inspections 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status of water bodies as defined by the Water Framework 
Directive  will  ensure  that  EU  citizens  benefit  from  good 
quality and safe drinking and bathing water. It will further 
ensure that the nutrient cycle (nitrogen and phosphorus) 
is  managed  in  a  more  sustainable  and  resource-efficient 
way 

Noise 

Water Framework Directive 

 The  Environmental  Noise  Directive  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping and planning.  A key target under the 2030 zero 
pollution  action  plan    is  to  reduce  by  30%    the  share  of 
people chronically disturbed by transport noise compared 
to 2017.  

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental-health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress81. 

81 WHO 2018, Environmental Noise Guidelines for the European Region. 
82 For further information: European Environment Agency, Noise Fact 
Sheets 2021. 
83 These figures are an estimation by the European Environmental 
Agency based on: (i) the data reported by Member States on noise 
exposure covered by Directive 2002/49/EC; (ii) ETC/ATNI, 2021, Noise 
indicators under the Environmental Noise Directive 2021: Methodology 
for estimating missing data, ETC/ATNI Report No 2021/06, European 
Topic Centre on Air Pollution, Transport, Noise and Industrial 
Pollution; (iii) the methodology for health impact 
calculations, ETC/ACM, 2018, Implications of environmental noise on 
health and wellbeing in Europe, Eionet Report ETC/ACM No 2018/10, 
European Topic Centre on Air Pollution and Climate Change Mitigation. 
84 The Water Framework Directive (2000/60/EC). 

The Water Framework Directive (WFD)84 and other water-
related legislation85 set the framework for sustainable and 
integrated water management, which aims at a high level 
of  protection  of  water  resources,  prevention  of  further 
deterioration and restoration to good status. 

By  March  2022,  Member  States  had  to  report  the  third 
generation  of  river  basin  management  plans  (RBMPs) 
under  the  WFD.  Finland  has  recently  done  so.  The 
Commission will assess the reported status and progress, 
checking what measures have been taken in response to 
identified  when  the  second  RBMPs86  were 
findings 
assessed.  

85  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban Waste Water Treatment Directive (91/271/EEC), the new Drinking 
Water  Directive  (2020/2184/EC),  the  Nitrates  Directive  (91/676/EEC), 
the  Marine  Strategy  Framework  Directive  (2008/56/EC),  the  Industrial 
Emissions Directive (2010/75/EU) and the new Regulation on minimum 
requirements for water reuse (2020/741). 
86  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
 
                                                                 
In  December  2021,  the  Commission  published  the  sixth 
implementation report, which assesses implementation of 
the WFD and the Floods Directive87. This report includes 
an interim assessment of progress on: (i) implementation 
of the programmes of measures; and (ii) the new priority 
substances.  

Figure  27.  Proportion  of  surface  water  bodies  (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District90 

Finland  24 

report 

for  Finland88  shows 

The  assessment 
that 
programmed measures are included in the 2nd RBMP. New 
regulations  have  been  adopted  in  all  the  River  Basin 
Districts  (RBDs).  Measures  to  help  reach  the  WFD 
objectives have been planned, and their implementation 
has  started  without  delay.  Finland  reports  that  good 
progress  in  reducing  pollution  from  point  sources  has 
been  achieved  in  urban  and  industry  sectors.  There  has 
been progress on the actions associated with forestry and 
aquaculture. More measures are needed in the treatment 
of  rural  waste  water  and  agriculture  and  partly  in 
aquaculture. There is a delay in implementing agriculture 
measures  due  to  insufficient  resources.  Measures  to 
achieve  reductions  in  diffuse  source  pollution  due  to 
agriculture  are  mainly  based  on  voluntary  agreements 
with farmers. Most of the farms (>90%) are committed to 
the CAP's environmental payments.  

The  second  set  of  RBMP  reports  and  data  published  in 
202089  reveal  that  in  Finland  73.2%  of  all  surface  water 
bodies  (i.e.  rivers,  lakes,  transitional,  coastal,  territorial) 
have good ecological status (with 1.4% unknown) and only 
49.5% have good chemical status. For groundwaters, 2.5% 
failed  to  achieve  good  chemical  status  and  98.3%  are  in 
good quantitative status. 

The  figure  below  illustrates  the  proportion  of  surface 
water bodies in Finland and other European countries that 
failed to achieve good ecological status. 

The  following  figure  shows  the  proportion  of  surface 
water bodies in Finland and other European countries that 
failed  to  achieve  good  chemical  status.  For  Finland,  the 
percentage is 50.5%, if one includes water bodies failing 
to  substances  behaving  as  ubiquitous  PBTs 
due 
(persistent,  bio-accumulative,  toxic  chemicals).  Without 
uPBTs,  1%  of  surface  water  bodies  fail  to  achieve  good 
chemical status. 

87 See the 6th WFD and FD implementation report FD. 
88 KH0921556ENN.en.pdf 
89 WISE Freshwater (europa.eu) 

90 European Environment Agency, 2021. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
 
 
Figure 28. Proportionof 
achieving good chemical status91 

surface  water  bodies  not 

Figure 29. Water abstraction per sector in Finland93 

Finland  25 

Under  the  IED  framework,  it  should  be  stressed  that 
Finland showed a  significant  decrease in the last  decade 
(59.3%) in industrial releases of heavy metals like Cd, Hg, 
Ni, Pb and in total organic carbon -TOC (63%) to water92. 

total  amount  of  water  abstracted  annually 
The 
(corresponding  to  the  2019  baseline)  in  Finland  from 
surface  and  groundwater  sources  is  2 456.60  hm3  (EEA, 
2022). The percentage for water abstraction per sector is 
1.26%  for  agriculture,  17.08%  for  public  water  supply, 
17.75%  for  electricity,  63.37%  for  manufacturing  and 
0.53%  for  mining  and  quarrying,  as  illustrated  in  the 
following  figure.  Finland  uses  a  register to  control  water 
abstractions.  Abstractions  less  than  100 m3/day  do  not 
require  permits  in  Finland,  and  are  not  registered.  In 
addition, all abstractions of water intended for domestic 
supply  require  permits,  namely  water  abstraction  over 
250 m3/day, and over 100 m3/day needs to be registered. 
Any abstraction that could cause deterioration or have a 
negative impact on nature always requires a permit. 

In  Finland,  the  water  exploitation  index  plus  (WEI+)94 is 
0.61%  (for  2017),  which  is  far  below  the  20%  generally 
considered as an indication of water scarcity. 

The  bar  below  presents  the  WEI+  in  Finland  and  other 
European countries. Finland is ranked 22nd (from high to 
low score) in the EU in terms of WEI+. 

Figure  30.  Water  exploitation  index  plus  (WEI+)  inside 
EU, 201795 

Floods Directive 

As mentioned above, in December 2021 the Commission 
published the 6th implementation report on the Directive. 
It includes a  review and update of the preliminary flood 
risk assessments during the second cycle (2016-2021). 

91 European Environment Agency, December 2019.  
92 European Environment Agency, June 2021. 
93  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
94 The Water Exploitation Index plus (WEI+) is a measure of total fresh 
water use as a percentage of the renewable fresh water resources 

(groundwater and surface water) at a given time and place. It quantifies 
how much water is abstracted and how much water is returned after 
use to the environment. 
95 European Environment Agency, Water exploitation Index Plus, 2022. 

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Finland  26 

Figure  31:  Bathing  water  quality  in  Europe  in  the  2020 
season100 

Figure 32: Bathing water quality 2017-2020101 

the  Swedish  and  Norwegian  authorities 

According  to  the  assessment  report96,  it  is  considered 
good practice to consider long-term developments such as 
population  and  economic  growth  when  assessing  future 
flood  risk.  A  concise  report  on  the  effects  of  climate 
change  has  also  been  published.  Information  exchange 
with 
in 
international  units  of  management  (UoMs)  has  been 
systematic in all planning phases. The report also suggests 
that  Finland  has  developed  a  clear  methodology  for 
defining  past  floods  with  significant  adverse  impacts, 
including a mechanism for collecting detailed information 
on  the  impact  of  flooding.  However,  no  clear  criteria 
appear to be in place for determining the future flood risk 
in  areas  of  potential  significant  flood  risk  (APSFRs), 
particularly as a result of long-term developments.  

Finland has reported the second generation of Flood Risk 
Management  Plans  (FRMPs)  under  the  Floods  Directive. 
The European Commission will assess progress since the 
adoption  of  the  first  Flood  Risk  Management  Plans  and 
publish a new report, as done in 2019. 

Drinking Water Directive 

On the Drinking Water Directive97, no new assessment of 
the  quality  of  drinking  water  is  available  since  the  2019 
EIR. The quality of drinking water in Finland has not been 
indicated as an area of concern. 

recast  Directive98  entered 

force  on 
The 
12 January 2021,  and  Member  States  have  until 
12 January 2023  to  transpose  it  into  their  national  legal 
system. Finland will have to comply with these reviewed 
quality standards. 

into 

Bathing Water Directive 

On the Bathing Water Directive,  Figure 31  shows that  in 
2020,  269  Finnish  bathing  waters,  (88.8%)  were  of 
excellent  quality99,  20  (6.6%)  were  of  good  quality,  5 
(1.7%)  were  of  sufficient  quality,  4  (1.3%)  were  of  poor 
quality and 5 (1.7%) were not classified. 

Nitrates Directive 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive102,  for  2016-2019103,  warns  that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 

96 European Commission, Directorate-General for Environment, 
Assessment of Second Cycle Preliminary Flood Risk Assessments and 
Identification of Areas of Potential Significant Flood Risk under the 
Floods Directive: Member State: Finland, 2022. 
97 OJ L 330, 5.12.1998, p. 32-54. 
98 OJ L 435, 23.12.2020, pp. 1-62. 

99 European Environment Agency, 2021. State of bathing water – 
European Environment Agency (europa.eu), p. 17. 
100 European Environment Agency, Bathing Water Quality in 2020, 2022. 
101  European  Environment  Agency,  European  Bathing  Water  Quality  in 
2017, 2018, 2019, 2020. 
102 Implementation of the Nitrates Directive in the EU. 
103 Last implementation report 2016-2019. 

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health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication.  Where  national  authorities  and  farmers 
have cleaned up  waters, it has had a  positive impact on 
drinking  water  supply  and  biodiversity,  and  on  sectors 
such  as  fisheries  and  tourism  that  depend  on  them. 
Nevertheless, excessive fertilisation remains a problem in 
many parts of the EU 

Finland  is  one  of  the  countries  facing  the  greatest 
challenges in tackling nutrient pollution from agriculture 
while  Finland’s  surplus  of  nitrogen  and  phosphorus  are 
close to the EU averages. 

According to the Commission’s report, Finland stands out 
for  its  high  number  of  waters  that  are  eutrophic.  Also, 
Finland records bad water quality across its territory and 
faces a systemic problem in managing nutrient losses from 
agriculture. 

Urban Waste Water Treatment Directive  

Overall,  97%  of  urban  wastewater  in  Finland  is  treated 
according to the requirements of the Urban Waste Water 
Treatment  Directive  (UWWTD).  This  is  above  the  EU 
average  of  76%.  According  to  the  UWWTD,  Finland  is 
required to provide in urban areas: 

 
 

 

collection of 5.6 million p.e. of waste water; 
biological  treatment  to 5.5 million  p.e.  of  waste 
water; 
biological  treatment  with phosphorus  removal 
to 5.0 million p.e. of waste water. 

Figure 33: Proportion of urban waste water that  meets 
all  requirements  of  the  UWWTD  (collection,  biological 
treatment,  biological  treatment  with  nitrogen  and/or 
phosphorus  removal)  in  compliant  urban  areas  of  the 
UWWTD (‘compliance rate’), 2018104 

Finland  27 

The use of EU funding has been fundamental in improving 
the compliance and implementation of the UWWTD over 
the years. 

In  the  2019  EIR,  Finland  received  priority  actions  to 
improve the monitoring of water bodies; to take measures 
to  address  diffuse  pollution  from  agriculture,  mainly 
phosphates; and to take steps to ensure that the flood risk 
management  plans  are  coordinated  with  the  national 
climate change adaptation strategy. Only limited progress 
has been noted in this area. 

2022 priority actions 

  Assess new physical modifications to water in line with 
Article 4(7)  of  the  WFD. 
In  these  assessments, 
alternative  options  and  appropriate  mitigation 
measures must be considered. 

  Continue  efforts  to  further  reduce  nitrates  pollution 
from  agriculture 
in  groundwater.  Reinforce  the 
national  action  programme  to  tackle  eutrophication 
issues  for  both  inland  and  marine  waters  where  the 
agricultural pressure is significant. 
Improve  coordination  of  measures  to 
policies on water, marine and nature. 

implement 

 

  Complete implementation of the Urban Waste Water 
Treatment Directive for all agglomerations, by building 
up the necessary infrastructure.  

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  -  'Towards  a  Toxic-Free  Environment'105 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU's zero-pollution 
ambition – a key commitment of the European Green Deal 

The  EU’s  chemicals  legislation1106 provides  a  baseline 
protection for human health and the environment. It also 
for  businesses 
ensures  stability  and  predictability 
operating within the internal market. 

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of Chemicals 
(‘the  REACH  Regulation’)  and 
the  Regulation  on 
Classification, Labelling and Packaging (‘CLP Regulation’). 
In December 2020, the Commission assessed the Member 

104 European Commission, WISE Freshwater, 2021. 
105 COM(2020) 667 final. 
106REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 

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Finland  28 

compliance and the possibility of adverse public 
reaction. 

As  a  rule,  all  infringements  of  REACH  are  classed  as 
‘serious’  or  ‘very  serious’  environmental  administrative 
offences.  If  the  infringement  is  sufficiently  ‘serious’,  the 
competent  authority  may  decide  to 
impose  further 
penalties  in  addition  to  a  fine.  That  authority  may 
also, where  necessary, order  the  provisional  seizure  of 
assets and documents.  

In Finland, 7 staff-years are allocated for both REACH and 
CLP  (and  other  chemicals  regulations  and  market 
in  Customs 
surveillance),  as  well  as  6-7  staff-years 
authorities for REACH controls110. There were nearly 7 000 
REACH  controls  in  2019  alone,  and  more  than  33 000  in 
the  entire  reporting  period.  Most  REACH  controls  are 
proactive  (inspections)  rather  than  reactive/non-  controls 
(i.e. investigations in response to complaints, accidents and 
referrals).  The  high  percentage  of  non-compliance  cases 
out  of  the  total  number  of  controls  should  be 
underlined111￼. 

to 

the 

States’  reports  on  the  implementation  and  enforcement 
of these Regulations107, in line with Article 117(1) of the 
REACH Regulation and Article 46(2) of the CLP Regulation. 
According 
latest  available  data,  national 
enforcement structures have not changed much in recent 
years. However, it is apparent from this report that there 
are  still  many  disparities  in  the  implementation  of  the 
REACH and CLP Regulations, and notably in the area of law 
enforcement.  Recorded  compliance  levels  in  Member 
States seem to be quite stable over time, but with a slight 
worsening  trend,  which  is  likely  due  to:  (i)  enforcement 
authorities  being  more  effective 
in  detecting  non-
compliant  products/companies;  and  (ii)  more  non-
compliant products being put on the EU market. 

In August 2021, the Commission published a  measurable 
assessment  of  the  enforcement108  of  the  two  main  EU 
Regulations  on  chemicals  using  a  set  of  indicators  on 
different aspects of enforcement. 

Responsibility  for  checking  compliance  with  REACH  in 
Finland lies with the following authorities: 

 

Finnish  Safety  and  Chemicals  Agency  (Tukes), 
with CLP as well, 

  Occupational  health  and 

safety  authority 

(Regional State Administrative Agencies) 
Centre  for  Economic  Development,  Transport 
and the Environment (ELY) 
The Finnish Customs 
The Finnish Defence Forces 
Finnish Medicines Agency 

 

 
 
 

Finland has drawn up and fully implemented enforcement 
strategies for both REACH and CLP109. They include: 

  Risk-based prioritisation taking into account the 
effect of non-compliance and the probability that 
non-compliance will occur.  

  Risk  to  human  health  and  the  environment 
depends on the probability of exposure, the scale 
of exposure and the level of danger presented by 
the  chemical.  The  probability 
that  non-
compliance will occur depends on, for example, 
the  level  of  awareness  and  knowledge  of  the 
regulations  among  businesses  and  other 
operators, combined with their ambition to be in 
compliance,  and  the  economic  implications  of 
complying, the probability of being found in non-

107 European Commission, Final  report  on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu). 
108 European Commission, REACH and CLP enforcement: EU level 
enforcement indicators 
109 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76. 

110 European Commission, Final report_REACH-CLP MS 
reporting_2020.pdf (europa.eu), p. 75. 
111 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 87-
88. 

 Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
Figure 34: Percentage  of non-compliance cases out of the 
total number of REACH and CLP controls during 2019 per 
Member State and compared to the EU average112 

Finland  29 

2022 priority actions 

administrative 

Upgrade 
the 
implementation  and  enforcement  of  the  REACH  and 
CLP Regulations. 

capacities 

for 

112 European Commission, Final Report, on the operation of REACH and 
CLP, pp.87-88, 2022. 

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Malta  30 

4. Climate action 

legislation 

In line with the Paris Agreement and as part of the 
European  Green  Deal,  the  European  Climate  Law 
sets the EU target of reaching climate neutrality by 
2050 and reducing greenhouse gas (GHG) emissions 
by  55%  by  2030  compared  to  1990.  The  law  also 
limits  the  contribution  that  carbon  removals  can 
make towards emission reductions in 2030 to ensure 
a sufficient mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
Nationally  Determined  Contribution  (NDC)  to  the 
UNFCCC in December 2020.  
The EU is working across all sectors and policies to 
cut  GHG  emissions  and  make  the  transition  to  a 
climate-neutral and sustainable economy, as well as 
the  unavoidable  consequences  of 
addressing 
climate change.  
incentivises  emissions 
EU  climate 
reductions 
industry, 
from  power  generation, 
transport, the maritime sector and fluorinated gases 
(F-gases) used in products.  
For road transport, EU legislation requires the GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared to 2010113 and sets binding GHG emission 
standards for different vehicle categories114.  
Under the F-gas Regulation, the EU’s F-gas emissions 
will  be  cut  by  two  thirds  by  2030  compared  with 
2014 levels. 
From  2021,  emissions  and  removals  of  GHGs  from 
LULUCF  have  been  included  in  the  EU  emission-
reduction efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States 
are required to report on their national adaptation 
policies115,  as  the  EU  Climate  Law  recognises 
adaptation  as  a  key  component  of  the  long-term 
global response to climate change. Member States 
will be required to adopt national strategies, and the 
EU will regularly assess progress as part of its overall 
governance  on  climate  action.  The  updated  EU 
adaptation  strategy,  published  in  February  2021, 
sets out  how the EU can adapt  to the unavoidable 
impacts  of  climate  change  and  become  climate 
resilient by 2050. 

Key national climate policies and 
strategies  

including  the 

Finland submitted its integrated national energy and 
climate plan (NECP) for 2021-2030. The work builds 
long-term  energy  and  climate  plans  and 
on 
roadmaps, 
long-term  strategy  to 
reduce  greenhouse  gas  emissions  (2020).  The 
government’s objective is to reach carbon neutrality 
by  2035  and  become  carbon  negative  shortly 
thereafter.  The  government  has  approved  the 
proposal  for  the  new  Climate  Change  Act116  to 
ensure  that  Finland’s  carbon  neutrality  target  for 
2035  and  other 
international  and  EU  climate 
objectives  will  be  met.  In  addition  to  the  carbon 
neutrality  target,  the  Act  sets  emission  reduction 
targets for 2030, 2040 and 2050. The Act lays down 
provisions  on  climate  policy  plans,  and  the  reform 
will  extend  the  scope  of  the  Act  to  the  land  use 
sector. A target to strengthen carbon sinks will also 
be included in the Act. 

In  its  recovery  and  resilience  plan  (RRP),  Finland 
allocates 50% of the plans to climate objectives and 
outlines crucial reforms and investments to further 
the  low  carbon  transition,  including  clean  energy 
production  and 
in 
Chapter 5). 

infrastructure  (more  details 

Finland was the first EU country to adopt a national 
climate  change  adaptation  strategy  in  2005,  which 
was  updated  by  the  national  adaptation  plan 
2022117.  A  midterm  evaluation  of  the  national 
adaptation plan (2014) was published in April 2019. 
The  evaluation  was  coordinated  by  the  Finnish 
Environment Institute (SYKE) and Natural Resources 
Institute  Finland  (Luke)  and 
included  a  broad 
stakeholder  engagement  process.  The  national 
adaptation plan 2030 is currently under preparation. 
Aside from its national adaptation strategy and plan, 
Finland has developed sectoral adaptation plans. 

Between 1990 and 2020, greenhouse gas emissions 
in Finland decreased by 32%. Finland’s greenhouse 
gas emission intensity is below the EU average, but 

113  The Fuel  Quality  Directive (Directive 98/70/EC)  sets  strict 
quality requirements for fuels used in road transport in the EU to 
protect  human  health  and  the  environment,  and  to  make  road 
travel across the EU safer. 
114 Directive 98/70/EC. 
115 Article 29 of Regulation (EU) 2018/1999. 

116 
https://www.eduskunta.fi/FI/vaski/KasittelytiedotValtiopaivaasi
a/Sivut/HE_27+2022.aspx 
117MMM-_193086-v1-
Finland_s_National_climate_Change_Adaptation_Plan_2022.pdf 

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Finland  31 

emissions  per  capita  remain  well  above  the  EU 
average. 

Figure  35:  Total  greenhouse  gas  emissions  (incl. 
international aviation) in Finland, 1990-2020 (index 
1990 = 100 %).  

Figure  37:  Emissions,  annual  emission  allocations 
(AEAs)  and  accumulated  surplus/  deficit  of  AEAs 
under the Effort Sharing Decision in Finland, 2013-
2020  

Effort sharing target  

For  emissions  not  covered  by  the  EU's  emissions 
trading scheme (ETS), Member States have binding 
national 
Sharing 
legislation118.  For  2020,  Finland’s  national  target 
under  the  EU  legislation  is  to  reduce  non-ETS 
emissions by 16% compared to 2005.  

targets  under 

the  Effort 

its  NECP,  Finland 

Under 
intends  to  achieve 
reductions similar to its current Effort Sharing target 
for 2030. 

Figure 36: Emissions and targets under the Effort 
Sharing Decision/ Effort Sharing Regulation in 
Finland, 2020 and 2030 as percentage change from 
2005. 

Key sectoral developments 

In road transport, the GHG intensity of vehicle fuels 
in Finland decreased by 7.7%, meaning that Finland 
achieved  the  current  EU-wide  reduction  obligation 
of 6% by 2020. There are several types of action that 
Member States can take in this regard, for example: 
(i)  further  expanding  the  use  of  electricity  in  road 
transport;  (ii)  supporting  the  use  of  biofuels,  and 
advanced biofuels in particular; (iii) incentivising the 
development and deployment of renewable fuels of 
non-biological  origin;  and  (iv)  reducing  upstream 
emissions before refining processes. 

In 2019, road transport in Finland accounted for 19% 
of  total  greenhouse  gas  emissions.  Emissions  have 
decreased by 11% compared to 2005. The target set 
in  the  government  programme  for  the  transport 
sector is to halve its emissions from 2005 levels by 
2030. To this end, the government adopted in May 
2021  a  resolution  on  a  roadmap  for  fossil-free 
transport,  which  is  intended  to  provide  a  basis  for 
achieving the target. 

from 

agriculture  have 

Emissions 
remained 
unchanged  over  the  last  few  years.  The  current 
measures  included  in  the  medium-term  climate 
change policy plan (2021) are expected to lead to a 
slight downward trend in agricultural emissions. 

Emissions from buildings, mainly from heating, have 
decreased  in  recent  years  due  to  the  reduced  oil 
heating  and  the  improved  energy  efficiency  of 
buildings. Finland has an action plan for phasing out 
fossil fuel oil in heating  and a  grant  programme to 
phase out oil use in residential properties. 

118 Regulation (EU) 2018/842 

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Figure 38: Greenhouse gas emissions by sector in 
Finland119 – historical emissions 1990-2020, 
projections 2021-2030120 

Finland  32 

In  the  Land  Use,  Land  Use  Change  and  Forestry 
(LULUCF) sector, Finland projects a small increase of 
net removals in the land use and forestry sector by 
2030. Reported quantities under the Kyoto Protocol 
for the LULUCF sector in Finland show net removals 
of, on average, -34.6 Mt CO2-eq for the period 2013 
to  2019.  In  this  regard,  Finland  contributes  with 
10.0% to the annual average sink of -344.9 Mt CO2-
eq  of  the  EU-27.  Accounting  for  the  same  period 
depicts  net  debits  of,  on  average,  0.5  Mt  CO2-eq, 
which represents -0.4% of the EU-27 accounted sink 
of -115.0 Mt CO2-eq. Reported net removals show a 
decreasing trend from 2013 to 2018 and an increase 
for  2019.  Accounted  net  debits  show  a  decreasing 
trend. Finland is one of six EU Member States with 
average net debits and one of 14 EU Member States 
that  show  net  debits  for  at  least  one  year  in  this 
preliminary accounting exercise. 

Figure 39: Reported and accounted emissions and 
removals from LULUCF in Finland  121 

Use of revenues from the auctioning of EU 
ETS allowances 

Total  revenues  from  the  auctioning  of  emission 
allowances  under  the  EU  ETS  between  2012  and 
2021 amounted to over EUR 1.5 billion. All of these 
auctioning revenues have been used for climate and 
energy  purposes.  In  Finland,  revenues  are  not 
earmarked.  National  spending  on  climate  and 
energy  amounts  to  more  than  100%  of  auctioning 
revenues.  Only  a  part  of  the  actual  spending  has 
been  reported,  but  up  to  100%  of  revenues  went 
towards specific projects in some years, even though 
this  funding  cannot  be  directly 
linked  to  the 
auctioning revenues 

2022 priority actions 

 

 
 

 

 

Increase  efforts  to  reduce  both  final  and 
primary energy consumption by 2030. The 
renovation  of  buildings  will  also  lead  to 
further green job creation in the country. 
Improve energy  networks. 
Enhance the electrification of transport by 
increasing charging points. 
Take-up  renewable  energy  and  renewable 
energy 
technologies,  especially  wind 
energy. 
Ensure the sustainability of biomass. 

119  The  sectors  in  the  figure  correspond  to  the  following  IPCC 
in 
sectors:  Energy  supply:  1A1,  1B  and  1C.  Energy  use 
manufacturing industries: 1A2. Industrial processes and product 
use:  2.  Transport:  1A3.  Other  energy  use:  1A4,  1A5  and  6. 
Agriculture: 3. Waste: 5. International aviation: 1.D.1.a. 

120  European  Environmental  Agency,  Total  GHG  trends  and 
projections. 
121   The  differences  between  reported  and  accounted  emissions 
from  LULUCF  under  the  Kyoto  Protocol  are  described  in  the 
‘explanatory note on LULUCF – accounted and reported quantities 
under the Kyoto Protocol’.   

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Finland  33 

Environmental Implementation Review 2022 – Finland 

 
 
Finland  34 

Part II: Enabling Framework: Implementation Tools 

5. Financing 

Environmental investment needs in the 
European Union 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps.  
Post-2020,  environmental  implementation  will  also  be 
supported by the EU’s  COVID-19 Recovery  Fund (via  the 
RRF) and the ‘do no significant harm’ principle which runs 
across the EU budget. The renewed commitments made 
at  COP26  (Glasgow,  October-November  2021)  and  the 
Biodiversity  Convention  (April-May  2022)122  will  also  be 
reflected in the EU budget. 

Overall environmental investment gaps (EU27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed and what is forecast to be invested if no additional 
action  is  taken)  for  climate,  energy  and  transport  were 
estimated in 2021 at EUR 390 billion a year (EU-27)123, with 
a  further  EUR 130 billion  to  deliver  the  EU’s  core 
environmental objectives124. The costs of climate change 
adaptation  can  also  be  significant,  and  are  estimated  to 
reach  a  total  of  EUR 35-62  billion  (narrower  scope)  or 
EUR 158-518  billion  (wider  scope)  per  year125.  Those 
investment  needs  reflect  the  implementation  objectives 
to  2020  and  to  2030  (except  for  climate  change 
adaptation, the costs of which are expected to last over a 
longer time horizon). 

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  the  following  table.126 
Almost 40% of the environmental investment needs relate 
to dealing with pollution, accounting for nearly two-thirds 
of the total gap if combined with water management. The 
is 
investment  gap 

in  circular  economy  and  waste 

estimated  to  be  between  EUR 
  13-28  billion  p.a., 
depending  on  levels  of  circularity  implemented.  The 
annual  biodiversity  financing  gap  is  estimated  at  around 
EUR  20 billion.  

Table 1: Estimated breakdown of the EU’s environmental 
investment gaps, by environmental objective, 2021-2030 
(per year)127 

Estimated investment gap (EU-27, 
p.a.)   

Environmental 
objective 

Pollution  prevention 
& control 

Water management & 
industries 

Circular  economy  & 
waste 

 EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems128 

R & D & I and other 

Total 

& 

 21.5 

 6.2 

 110.1 

Environmental investment needs in Finland  

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

In 
its  recovery  and  resilience  plan  (RRP)  Finland's 
investment priorities are clearly shifting towards support 
for the transformation of the energy system, reducing the 
climate and environmental impacts of building stock, and 
industrial  reforms  and  investments  for  the  green  and 
digital  transition.  EUR 2.1  billion  will  be  spent  under  the 
Recovery and Resilience Fund to support these priorities 
and 
investments. 
Nevertheless, major investment efforts are still needed in 

additional 

leverage 

private 

122  The  Convention  on  Biological  Diversity  (cbd.int);  Post-2020  Global 
Biodiversity Framework | IUCN. 
123  SWD(2021)621,  accompanying  proposal  COM(2021) 557  to  amend 
the REDII Directive (EU) 2018/2001. 
124 SWD(2020) 98 final/2. 
125 SWD(2018)292 
126  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  DG  ENV  ”Study  supporting  EU  green  investment  needs 
internal  analysis 
analysis” 
”Environmental  Investment  needs  and  financing  in  the  EU’s  green 
transition“,  July 2020. 
127 European Commission, DG Environment, ”Study supporting EU green 
investment needs analysis” (ongoing, 2021-202 3) and DG Environment 

(ongoing,  2021-2023)  and  DG  ENV 

internal analysis  ”Environmental Investment  needs  and 
financing in the EU’s green transition“,  July 2020.  
128  To  meet  the  needs  of  the  2030  Biodiversity  Strategy 
(Natura 2000, green infrastructure), at least EUR 20 billion a 
year  should  be  unlocked  for  nature  (COM/2020/380  final) 
while  to  fully  cover  the  strategy  (including  restoration)  EUR 
30-35 billion may be needed, indicating a gap of  EUR 10-20 
billion a year compared to current baseline expenditure. 

Environmental Implementation Review 2022 – Finland 

 
                                                                 
 
 
the following fields to support the implementation of EU 
environmental legislation. 

Pollution prevention & control 

The  EU’s  first  Clean  Air  Outlook129  under  the  clean  air 
programme estimated that the total air pollution control 
costs  for  Finland  to  reach  the  NECD  emission  reduction 
requirements (ERRs)130 by 2030 amount to a total need of 
EUR 1 107 million per year, including EUR 792 million for 
capital  investment  (assuming  the  achievement  the  2030 
climate and energy targets. 

The  second  Clean  Air  Outlook  suggests131  that  the 
EU would  largely  achieve  the  reductions  of  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NEC  Directive  for  2030  if:  (i)  all  relevant  legislation 
adopted  up  to  2018  is  implemented  (including  all  air 
pollution  legislation  and  the  2030  climate  and  energy 
targets  set 
in  2018);  and  (ii)  Member  States  also 
implemented  the  measures  announced  in  their  national 
air pollution control programmes. The only exception is for 
ammonia (NH3) for 15 Member States, including Finland. 

Water management  

According  to  the  OECD  study  'Financing  a  Water  Secure 
Future'  (2022),  Finland's  compliance  with  the  Drinking 
Water  Directive  and  the  Urban  Wastewater  Treatment 
Directive is high; the financing gap to rehabilitate, renew 
and  replace  the  water  supply  system  (WSS)  is  widening; 
and  the  current  price  levels  demonstrate  the  ability  to 
recover  costs  of  WSS  services.  Healthy  fiscal  conditions 
would  make  it  possible  recourse  to  public  spending, 
should  need  be.  EU  funding  has  provided  a  significant 
share  of  public  funding  over  the  past  decade132.  It  is 
estimated  that  Finland  will  need  to  invest  an  additional 
cumulative EUR 1 309 million by 2030 for drinking water 
and sanitation133 (beyond the baseline investment), over 
90% of which relates to wastewater. Moreover, the recent 
6th  Water  Framework  Directive  and  Floods  Directive 
Implementation  Report134  and  the  financial  -  economic 
study135  accompanying  it,  are  also  a  relevant  source  of 
information in this domain. 

Finland  35 

Waste & circular economy 

According to a Commission study136 to meet the recycling 
targets for municipal waste and packaging waste, Finland 
still needs to invest an additional EUR 289 million (around 
EUR 41.3  million  per  year)  between  2021  and  2027 
(beyond the baseline investment) on collection, recycling 
reprocessors, biowaste treatment, waste sorting facilities 
and digitalising waste registries. 

This does not include the investment necessary across the 
economy  to  unlock  a  higher  uptake  of  circularity,  waste 
prevention and to tackle other key waste streams such as 
plastics, textiles and furniture. 

Biodiversity & ecosystems 

The  recently-submitted  priority  action  framework  (PAF) 
for Finland shows that nature protection costs (including 
Natura 2000) in 2021-2027 amount to EUR 6.03 billion in 
total  -  or  around  EUR 862.4  million  per  year137.  Of  this, 
annual one-off costs amount to EUR 99 million. 

the 
This  excludes  additional  costs 
biodiversity  strategy  to  2030,  including  on  increased 
protection and restoration. 

implement 

to 

EU environmental funding  2014-2020 

The multiannual financial framework (MFF) for 2014-2020 
allocated  almost  EUR  960  billion  (in  commitments,  2011 
prices)138  for  the  EU  to  spend  over  this  period.  The 
commitment 
in  this  2014-2020  MFF  to  the  green 
transition included a 20% climate spending target. It also 
included  funding  opportunities  for  the  environment,  in 
particular under the European Structural and Investment 
(ESI)  Funds139.  The  2014-2020  MFF  budget  was 
subsequently  topped  up  with  over  EUR 50 billion  (in 
current  prices)  from  the  REACT-EU  programme  for 
cohesion policy action against COVID-19140.  

Finland  received  EUR 4.9  billion  from  the  ESI  Funds  in 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 

129 International Institute for Applied Systems Analysis (IIASA), Progress 
towards the achievement of the EU’s air quality and emissions objectives, 
2018. 
130 Covering the reductions of and the emission ceilings for 5 atmospheric 
pollutants,  SOx,  NOx,  PM2.5,  NH3  and VOC  by  2030,  compared to  2005. 
Source:  Progress  towards  the  achievement  of  the  EU’s  air  quality  and 
emissions objectives, IIASA 2018. (page 29). Requirements are based on 
Directive (EU) 2016/2284. 
131 COM(2021) 3 Final and Report Annex. 
132 OECD, Financing Water Supply, Sanitation and Flood Protection: 
Challenges and Options, 2020 6893cdac-en.pdf (oecd-ilibrary.org). 
133 OECD, Financing a Water Secure Future, 2022. 
134 WFD and FD Implementation Reports – DG Environment – European 
Commission. 

135  European  Commission,  Directorate-General 
for  Environment, 
Economic data related to the implementation of the WFD and the FD and 
the financing of measures, Final report. Publications Office, 2021. 

136European Commision, Study on investment needs in the waste sector 
and on the financing of municipal waste management in Member 
States, 2019. 
137See PAF_Priorities. 
138 Council Regulation (EU, Euratom) No 1311/2013. 
139  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI), the European Agricultural Fund for Rural Development (EAFRD) and 
the European Maritime and Fisheries Fund (EMFF).   
140 Regulation (EU) 2020/2221. 

 Environmental Implementation Review 2022 – Finland 

 
                                                                 
EUR 64.6  million,  with  a  further  EUR 81.5  million  in 
indirect  environmental  investment,  bringing  the  total  to 
EUR 146.1  million.  Figure  41  gives  an  overview  of 
(planned) individual ESI Funds earmarked for Finland (EU 
amounts, without national amounts). 

Figure  40:  ESI  Funds  allocated  to  Finland,  including 
environmental investments, 2014-2020141 

Finland  36 

Direct environmental investments 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 
Indirect environmental investments 
Business development 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

19.4 
19.4 
8.7 
7.4 
1.4 

39.2 
39.0 
39.0 

0.2 
0.2 

146.1 
64.6 
81.5 

Funding for the environment from the ESI Funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States  such  as  the  LIFE 
programme,  Horizon  2020,  or  loans  from  the  EIB.  This 
adds  up  to  an  estimated  total  of  EUR 679  million  of  EU 
environmental financing for Finland in 2014-2020. 

is  entirely  dedicated 

The  LIFE  programme144 
to 
environmental  and  climate  objectives. 
finances 
demonstration  and  best  practice  actions  for  green 
solutions to be deployed. In 2014-2020, Finland received 
EU  support  for  12  LIFE  projects  (for  nature  and 
environment)  for  an  amount  of  EUR 65.5  million  (out  of 
1 028 EU-27 LIFE projects with a total EU contribution of 
EUR 1.74 billion)145. 

It 

In  2014-2020,  Horizon  2020  allocated  about  EUR 75.4 
million  to  Finland  for  the  environment  (in  particular,  for 
climate  action  and  circular  economy),  which  is  5%  of  its 
total allocation146. Finland also received EUR 150.0 million 
in  direct  environmental 
further 
EUR 82.0 million for the environment from multi-purpose 
projects that included environmental objectives. 

funding,  with  a 

This  brings  Finland's  total  amount  for  the  environment 
from the European Fund for Strategic Investments (EFSI) 
to EUR 232.0 million out of its total allocation of EUR 1.23 

Table  2: Direct  and indirect environmental investments 
under the ESI Funds in Finland, 2014-2020142 

Instrument 

Under Cohesion policy (ERDF) 
Direct environmental investments 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 
other energy143 
business development, R&I 

Under EAFRD/rural development 

Allocations  
for the environment  
(EUR million) 

78.8 
6.2 
6.2 
72.6 
2.8 
22.9 
0.8 
46.1 

28.1 

Policy 

Funds 

(COWI, 

2017), Regulation 

141  European  Commission,  DG  Environment  -  Data  analysis,  DG 
Environment  analysis  based  on  ESI Funds Open  Data  Portal 
(cohesiondata.ec.europa.eu), Integration  of  environmental  concerns  in 
Cohesion 
(EU)  No 
1303/2013,Regulation  (EU)  2021/1060 and Implementing  Regulation 
(EU) No 215/2014. Cut-off date for data: December 2021. Environmental 
investments  here  are  captured  via  the  combined  use of  intervention 
fields 
No 
under 
1303/2013 and Regulation (EU) 2021/1060  allowing for a more precise 
identification and valuation of relevant environmental investments. N.B. 
Indirect  environmental  investments  are  valued  using  the  Annex  I 
(EU)  2021/1060 (as 
environmental  coefficients  of  the Regulation 
opposed to full value).   
142 European Commission, DG Environment - Data analysis. The values of 
environmental investments identified here in the specific environmental 

the Regulation 

coefficients 

(EU) 

and 

the 

may 

from 

differ 

tracking 

areas 
values 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity due  to 
two factors: the set of environmental coefficients used and the range of 
funds assessed. DG Environment’s analysis here covered the full range of 
ESI Funds. See also previous footnote. 
143  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention field 
53  and  54  respectively  (with  40%  environmental  coefficients)  of 
REGULATION (EU) 2021/1060, Annex I. 
144 European Commission, LIFE Programme. 
145 LIFE Country overview Finland 2021 (europa.eu). 
146 Horizon 2020 Environment and resources data hub (easme-web.eu). 

 Environmental Implementation Review 2022 – Finland 

 
 
 
                                                                 
 
 
billion147.  EIB  support  for  the  environmental  sector 
amounted to EUR 361.5 million, in particular for water and 
sewerage,  with  some  limited  funding  for  waste,  out  of 
Finland's  overall  EIB  support  for  this  period  (EUR 10.38 
billion)148.  The  country  ranks  11th  in  the  EU  in  terms  of 
total EIB lending. 

In 2020, the EIB provided EUR 24.2 billion in funding across 
Europe to fight climate change, 37% of its total financing. 
It  also  provided  EUR 1.8 billion  (3%  of  its  financing)  for 
broader environmental lending149. 

EU environmental funding  2021-2027 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investments (public and private) to 
be made across the EU by 2030. The 2021-2027 MFF and 
the NextGenerationEU spending programme will mobilise 
EUR 2.018  trillion  (in  current  prices)  to  support  the 
recovery from COVID-19 and the EU’s long-term priorities, 
including  environmental  protection150.  Following  the  EU 
Green  Deal’s151  pledge  to 
‘do  no  harm’  and  the 
Interinstitutional  Agreement  on  the  2021-2027  MFF152, 
30% of the EU budget  in 2021-2027 will support  climate 
efforts,  while  biodiversity  will  receive  7.5%  of  the  EU 
budget  as  of  2024  and  10%  as  of  2026.  To  reach  these 
targets, more financial resources will need to be allocated 
to biodiversity, specifically under the 2021-2027 cohesion 
policy and the 2023-2027 CAP.  

that 

finance 

several  programs 

147 European Investment Bank, Approved and signed EFSI financing, 
2015-2020. https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
148 European Investment Bank, EIB loans in EU countries in 2014-2020. 
Source: EIB Open Data Portal: EIB Open Data. 
149  The  EIB  Group  jointly  works  with  the  European  Commission  in 
environmental 
implementing 
implementation: InvestEU, the successor of EFSI, Pillar II and III of the Just 
Transition  Mechanism.  The  EIB  Group  stands  as  a  key  implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budgetary capacity of the mandate. 
150European  Commission,  2021-2027 
NextGenerationEU. 
151 COM/2019/640 final. 
152 Interinstitutional Agreement, OJ L 433I. 
153  EU  taxonomy  for  sustainable  activities  |  European  Commission 
(europa.eu). 
154 EU Green Bond Standard - 2021/0191 (COD). 
155 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
156 COM(2021) 82 final. 

long-term  EU  budget  & 

Finland  37 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)153. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds  (by  developing  the  EU  Green  Bond 
Standard)154.  Reinforced  by  the  renewed  sustainable 
finance  will 
finance  strategy 
increase 
the 
flows 
environment. The new strategy on adaptation to climate 
change156 can help to close the insurance-protection gap, 
which  currently  leaves  many  risks  from  climate-related 
events uninsured157. The EIB will align 50% of its lending 
for  climate  and  environment  projects  by  2025158,  with  a 
EUR 250 billion contribution to the Green Deal investment 
plan by 2027.  

(2020)155,  sustainable 

climate  and 

investment 

to 

Table  3:  Key  EU  funds  allocated  to  Finland  (current 
prices), 2021-2027 

Instrument 

Country funding allocation 
(million EUR) 

Cohesion policy 

Total: 1 655.1159 

ERDF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

EAFRD/rural 
development  

under  CAP  Strategic 
Plans 2023-2027162 

European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

887.8  

604.6  

162.7160 

465.7161 

772.8163 

71.8164 

157  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 
EIOPA (the Association for European Insurance and Occupational Pension 
Authorities)  dashboard  on 
insurance  protection  gap  for  natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
158 EIB Climate Bank Roadmap 2021-2025, November 2020. 
159 European Commission, 2021-2027 - EU allocations available for 
programming | Data | European Structural and Investment Funds 
(europa.eu) 
160 Interreg initial allocations per MS including ETC transnational and 
ETC cross-border cooperation.  
161 European Commission, 2021-2027 - EU allocations available for 
programming | Data | European Structural and Investment Funds 
(europa.eu) 
162 European Commission, CAP strategic plans.  
163 Regulation (EU) 2021/2115, Annex XI.  
164 Regulation (EU) 2021/1139, Annex V. 

 Environmental Implementation Review 2022 – Finland 

 
                                                                 
 
 
and 
Recovery 
Resilience Facility (RRF)  

2021 – 2026165  

2 085.3166 (grants) 

In Finland, the programming for the majority of EU funds 
(cohesion policy funds, EAFRD and EMFAF) is ongoing. 

EUR 2.1 billion 

supported  by 

Finland's RRP consists of 39 investments and 18 reforms 
in 
that  will  be 
grants.  50.3% of the plan will support climate objectives 
(see Figure 42). This exceeds the RRF’s overall 37% climate 
target and puts Finland among the top Member States as 
regards the climate commitment. For the green transition, 
the RRP reflects Finland's climate pledge by transforming 
the energy system (EUR 318.7 million); providing support 
transition 
to 
industry 
and 
(EUR 326 million); 
environmental 
stock 
(EUR 110 million);  providing  low  carbon  solutions  for 
communities  and 
(EUR 40 million);  and 
supporting environmental sustainability and nature-based 
solutions (EUR 30 million)167. 

for  a  green  and  digital 

reducing 
of 

climate 
building 

transport 

the 
the 

impacts 

Figure 41: Climate expenditure in RRP, 2021-2026168 

165 The actual reforms and investments under the RRF have to be 
implemented until 31 December 2026.   
166 Council Implementing Decision, FIN 523. 
167 European Commission, Finland’s recovery and resilience plan. 
168 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
169 European Commission, Multiannual financial framework 2021-2027 
(in commitments) - Current prices. 
170 The CEF (Transport) includes also EUR 11.3 billion transferred from the 
Cohesion Fund. 30% of the transferred amount will be made available, 
on a competitive  basis,  to  all  Member  States eligible  for  the  Cohesion 
Fund.  The  remaining  70%  will  respect  the  national  envelopes  until 
31 December 2023. Any unspent amount, by that date, under national 
envelopes will support all Cohesion Fund’s Member States. 
171 Regulation (EU) 2021/1153. 
172 The InvestEU Fund is expected to mobilise over EUR 372 billion of 
investment through an EU budget guarantee of EUR 26.2 billion to back 

Finland  38 

Under NextGenerationEU, the Commission will issue up to 
EUR 250 billion in EU green bonds (one third of the NGEU) 
until 2026 that will comply with the general spirit of the do 
no significant harm principle, but will not be subject to the 
current delegated acts on EU Taxonomy and will not fully 
align with the proposed EU green bond standard. 

In  addition  to  the  EU  funds  earmarked  specifically  for 
funding 
in  2021-2027,  various  other  EU 
Finland 
programmes are open to all Member States. These include 
the  LIFE  programme  (EUR 5.4 billion),  Horizon  Europe 
(EUR 95.5 billion)169,  the  Connecting  Europe  Facility170 
(EUR 33.7 billion)171  and  InvestEU172.  These  instruments 
will also support the green transition, including research 
and  innovation  activities  for  environmental  protection 
(Horizon  Europe)173,  clean  transport  and  energy  (the 
Connecting 
sustainable 
infrastructure (InvestEU)175.,  

Facility)174 

Europe 

and 

National environmental financing 

Total expenditure on environmental protection (including 
all relevant current and capital expenditure)176 in the EU-
27 was EUR 272.6 billion in 2020, representing 2% of EU-
27 GDP. This percentage has remained quite stable over 
time. While absolute expenditure is concentrated in a few 
countries,  as  a  share  of  GDP,    most  countries  spend 
between 1-2%, including Finland (1.6%). 

Of  this  spending,  the  EU-27’s  capital  expenditure  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR 56.3 billion in 2018, falling to EUR 54.5 billion in 2020, 
representing  around  0.4%  of  EU-27  GDP.  Most  Member 
States  invested  0.2-0.5%  of  their  GDP  in  environmental 
protection. Finland dedicated 0.3% of GDP. In 2014-2020, 
this amounted to around EUR 376 billion of environmental 
investment in the EU-27, of which EUR 4.6 billion was for 
Finland. 

Total  national  environmental  protection  expenditure 
(including all relevant current and capital expenditure )177 

level, 

including  final  consumption, 

the investment of financial partners such as the European Investment 
Bank (EIB) Group and others. 
173 European Commission, Horizon Europe. 
174 European Commission, Connecting Europe Facility. 
175 European Union, InvestEU. 
176  At  economy 
intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes  EU  funds,  while  may  include  some  international  expenditure 
beyond  domestic.  Data  source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy. 
177      At  economy  level,  including  final  consumption,  intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes EU funds, while may include so me international expenditure 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
 
                                                                 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2% of the common GDP being quite stable over time.   

Figure 42: Direct and indirect environmental protection 
investments in the EU-27 (EUR million and % of GDP), 
2018178 

Figure  43:  EU-27  Member  States'  environmental 
protection  investments  (Capex)  by  institutional  sectors 
(Total economy = 100%), 2018179 

Finland  39 

sector, 

institutional 

specialist  producers 

By 
(of 
environmental protection  services, e.g. waste and  water 
companies)  and  industry  (businesses)  provide  the  main 
share of Finland’s environmental protection investments 
(49% and 48%, respectively), with only 3% left to general 
governments. At EU level ( EU average), 37% comes from 
governments,  33%  from  specialist  producers  and  30% 
from industry (business). 

beyond  domestic.  Data  source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy.  
178 Eurostat, Environmental Protection Expenditure Account, 2021.  
179 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
180Data  reporting  differs  for  the  three  institutional  sectors,  leading  to 
aggregation  difficulties.  Specialist  companies  provide  comprehensive 
data across all environmental areas (CEPA 1-9), while this is less the case 
for  general  government  and  industry  that  often  report  (the  non-
obligatory) data in merged categories only (with difficulty to split) or not 
at all. 

A breakdown of investment by environmental topic is only 
available  at  institutional  sector  level  (rather  than  at 
economy  level),  due  to  different  reporting  patterns180. 
Based  on  data  reported  by  Finland,  48%  of  the  general 
investments 
government’s  environmental  protection 
served  biodiversity,  while  the  other  half  concerned  R&D 
and  non-classified  items.  In  the  case  of  the  country’s 
specialist  producers,  55%  of  the  respective  investments 
went  towards  wastewater  and  42%  towards  waste 
management. The business sector mainly  focused on air 
pollution (33%), wastewater (27%), water and soil (23%), 
and waste management (13%).  

In  2020,  the  total  annual  issuance  of  green  bonds181 
(including  some  non-EU  countries)  was  USD  156  billion 
(EUR 137 billion), up from USD 117 billion (EUR 105 billion) 
in 2019182. Looking only at EU-27 Member States, green-
bond issuance in 2020 was EUR 124 billion. To this, Finland 
contributed by issuing green bonds worth EUR 2.12 billion. 
83%  of  the  green  bonds  issued  by  European  countries 
served energy, buildings or transport objectives between 

181  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  The  majority  of  green  bonds 
issued are green ‘use of proceeds’ or asset-linked bonds. The very first 
green  bond  was  issued  in  2007  with  the  AAA-rated  issuance  from 
multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 
182 
Taxonomy 
https://www.climatebonds.net/standard/taxonomy.  USD 
converted via Eurostat’s annual average EUR/USD exchange rates. 

Climate 

Bonds 

value 

- 
is 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
 
                                                                 
 
 
2014-2020, 8% water and waste, with further 6% land use 
– with links to ecosystem conservation & restoration183.  

Figure 45: Environmental taxes in the EU-27, 2020186 

Figure 44: Annual EU green bond issuance in 2020 (EUR 
billion)184 

Finland  40 

Green budget tools 

Green taxation and tax reform 

Finland’s  revenue  from  environmental  taxes  is  slightly 
above  the  EU  average  (2.75%  of  GDP  in  2020  compared 
with  the  EU-27  average  of  2.24  %).  At  1.92%  of  GDP, 
energy  taxes  accounted  for  the  largest  proportion  of 
environmental  taxes  (EU  average:  1.74  %),  followed  by 
transport  taxes  (0.81%  of  GDP  compared  with  an  EU 
average of 0.42%), and taxes on pollution and resources 
(0.02% of GDP compared with 0.08%). In the same year, 
environmental tax accounted for 6.52% of total revenues 
from taxes and social security contributions (above the EU 
average of 5.57 %)185. 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society,  and  promote  a  just 
transition. Tax reforms can contribute to this by sending 
the right price signals and incentives to economic actors. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil fuel subsidies, and a shift in 
the  tax  burden  from  labour  to  pollution.  It  achieves  this 
while 
social 
taking 
considerations187. The Green Deal promotes the ‘polluter-
pays'  principle188,  which  stipulates  that  polluters  should 
bear the cost of measures to prevent, control and remedy 
pollution. The polluter-pays principle is facilitated by the 
European  Commission’s  Technical  Support  Instrument 
(TSI) project on greening taxes. Finland applies economic 
instruments such as packaging tax and peat burning taxes 
(the latter however at a low rate)189. 

simultaneously 

account  of 

Environmentally-harmful subsidies 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms190.  

Fossil  fuel  subsidies  are  costly  for  public  budgets  and 
undermine  Green  Deal  objectives.  They  also  often 
deincentivise green investments and do not contribute to 
levelling the playing field. Fossil fuel subsidies have varied 
by around EUR 55 billion in the EU since 2015. They rose 
by 4% between 2015 and 2019, although some countries, 

183 Interactive Data Platform at www.climatebonds.net. Climate Bonds 
Taxonomy is similar to the EU Taxonomy. 
184 Climate Bonds Initiative, 2022. 
185 Eurostat, Environmental taxes (env_eta). 
186  Eurostat, Environmental taxes accounts (env_eta). 
187 COM (2019/640 final), p. 17. 
188 Enshrined in Article 191(2) of the Treaty on the Functioning of the 
European Union: ‘Union policy on the environment (…) shall be based 

on the precautionary principle and on the principles that preventive 
action should be taken, that environmental damage should as a priority 
be rectified at source and that the polluter should pay’. 
189 European Commission, Green taxation and other economic 
instruments, 2021.  
190 European Commission, Study on assessing th environmental fiscal 
reform potential for the EU-28, 2016. 

 Environmental Implementation Review 2022 – Finland 

 
 
                                                                 
 
Finland  41 

budgetary  policies.  This  is  aimed  at  improving  policy 
coherence  and  supporting  green  policies  (including 
climate and environmental objectives)194. 

The Commission has also drawn up climate-proofing and 
sustainability-proofing guidance as tools to assess project 
eligibility and a project’s compliance with environmental 
legislation  and  criteria195.  The  Commission  developed  a 
green budgeting reference  framework196 and launched a 
Technical  Support  Instrument  (TSI)  project  on  green 
budgeting  in  2021  to  help  Member  States  develop 
national  green  budgeting  frameworks  to  improve  policy 
coherence and the green transition.  

Finland  does  not  participate  in  the  Commission’s  green 
budgeting  project  started  in  2021.  However,  it  benefits 
from a DNSH-themed TSI project to support its significant 
green  transition  efforts.  Finland  has  also  carried  out 
sustainable development budgeting since 2018, and since 
2019  has  estimated  the  amount  of  appropriations 
dedicated  to  actions  that  support  the  government’s 
carbon neutrality goal. 

Overall financing compared to the needs 

The EU's overall financing for environmental investments 
is estimated to have been 0.6-0.7% of GDP in 2014-2020, 
comprising  both  major  EU  funds  and  national  financing. 
This  ranged  from  0.3%  (Ireland)  to  1.91%  (Bulgaria), 
depending  on  the  level  of  environmental  challenges  in 
different  Member  States.  In  2021-2027,  it  is  estimated 
that the EU's environmental investment needs will range 
between  0.9  and  1.5%  of  the  projected  GDP  (in  2027-
2030), suggesting a potential environmental financing gap 
of  0.6-0.8%  of  GDP,  with  baseline  financing 
levels 
assumed197. 

Figure 47: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU27 (% of 
GDP)198 

such  as  Latvia,  Lithuania  Sweden,  Greece  or  Ireland, 
managed to decrease subsidies for fossil fuels.  

At  EU  level,  subsidies  on  petroleum  products,  in  sectors 
such as transport and agriculture, continued to increase in 
2015-2019,  whereas  subsidies  on  coal  and 
lignite 
decreased, largely owing to the diminishing role of solid 
fuels in electricity generation. As a share of GDP, fossil fuel 
subsidies ranged from 1.2% in Hungary to less than 0.1% 
in Malta in 2019 (EU average: 0.4%). In Finland, total fossil 
fuel  subsidies  amounted  to  EUR 0.7  billion  in  2019, 
representing 0.28% of GDP (below the EU average). 

In 2020, the EU-27’s total fossil fuel subsidies decreased to 
EUR 52 billion (due to falling consumption trends amid the 
COVID-19-related  restrictions).  Without  Member  State 
actions, these subsidies are likely to rebound as economic 
activity picks up from 2020191. 

Figure 46: Trends in fossil fuel subsidies in Finland192 

% GDP 

Coal 
Natural gas 
Petroleum 
Electricity 

2013 
0,08 
0,04 
0,27 
0,06 

2014  2015  2016  2017  2018  2019 
0,12 
0,08 
0,03 
0,04 
0,37 
0,45 
0,03 
0,05 

0,11 
0,03 
0,42 
0,05 

0,13 
0,03 
0,39 
0,05 

0,11 
0,03 
0,40 
0,05 

0,09 
0,02 
0,42 
0,05 

2020 
0,11 
0,03 
0,36 
0,05 

Green budgeting practices  

‘Green  budgeting’  encompasses  various  climate  and 
environmental tagging and tracking practices in budgets. 
Some  EU  Member  States  already  use  certain  green 
budgeting practices193. Green budgeting helps identify and 
track green expenditure and green revenues to increase 
implications  of 
transparency  on  the  environmental 

191 State of the Energy Union report, COM(2021) 950 and Annex 
192 OECD Fossil Fuel Subsidy Tracker. 
193 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. 
194  European  Commission,  European  Commission  Green  Budgeting 
Reference  Framework.  European  Commission,  Green  Budgeting  in  the 
EU Key insights from the 2021 Commission survey. 
195 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 

196 European Commission, Green Budgeting Reference Framework, based 
on the review of the OECD Paris Collaborative on the Green Budgeting 
initiative, 2017. 
197DG Environment data analysis. EU financing sources covered: ESI Funds 
(ERDF, CF, ESF, YEI, EAFRD, EMFF), Horizon 2020, LIFE, EFSI (EU amount), 
EIB  loans.  National  financing:  total  national  environmental  protection 
capital  expenditure  (investments).  Sources:  ESI  Funds  Open  Data 
(cohesiondata.ec.europa.eu, European Commission, Eurostat. 
198 Eurostat, ESI Funds Open Data, 2021. 

 Environmental Implementation Review 2022 – Finland 

 
 
                                                                 
 
 
 
Finland  42 

financing sources to environmental priorities. 

2022 priority actions 

In  the  2019  EIR,  Finland  had  no  priority  actions  for 
environmental  financing  and  the  high  share  of  private 
financing  can  provide  useful  examples  to  other  EU 
Member States. However, there is room for improvement 
in the coming years. 

  Draw  up  an  environmental  financing  strategy  to 
maximise  opportunities  for  closing  environmental 
implementation  gaps,  bringing  together  all  relevant 
administrative levels. 
Ensure  an 
level  of  financing  for  the 
increased 
environment  to  cover  the  investment  needs  for  all 
environmental objectives and to close the investment 
gaps. 

 

investments 

investment  needs 

Finland’s  environmental  financing  for 
is 
estimated  to  have  been  0.42%  of  GDP  in  2014-2020, 
mostly  relying  on  national  financing  sources  (90%). 
Environmental 
in  2021-2027  are 
expected  to  be  over  0.96%  of  Finland’s  GDP  (partial 
coverage, 
including  needs  with  country  breakdown 
available), suggesting an environmental financing gap of at 
least  0.54%  of  GDP,  likely  to  be  higher  when  also 
accounting for needs currently identified at EU level only 
(e.g.  water  protection,  circularity,  biodiversity  strategy 
etc.). This gap is to be addressed by mobilising additional 

 Environmental Implementation Review 2022 – Finland 

 
 
 
 
  
 
 
 
 
 
Finland  43 

6. Environmental governance  

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention: 
(i) access to information; 
(ii) public participation in decision-making; 
(iii) access to justice in environmental matters. 

It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively199.  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  environment200.  It  includes  the  right  to  bring  legal 
challenges (‘legal standing’)201. 

Environmental information 

This  section  focuses  on  Finland’s  implementation  of  the 
INSPIRE  Directive.  The 
INSPIRE  Directive  aims  at 
establishing  a  European  spatial  data  infrastructure  for 
information  between 
sharing   environmental  spatial 
public  authorities  across  Europe,  assisting   in  policy-
making across boundaries and facilitating public access to 
this  information.  Geographic  information  is  needed  for 
good  governance  at  all  levels  and  should  be  readily  and 
transparently available.  

Finland’s  performance  has  been  reviewed  based  on  the 
country’s  2021  country  fiche202.  Progress  on  data 
identification  and  documentation  has  been  slow,  and 
implementation  levels  need  improvement.  More  efforts 
are needed to: 

  make the data more widely accessible, and 
 
datasets 

in 
prioritise 
implementation,  especially  those  identified  as 
high-value  spatial  datasets  for  implementing 
environmental legislation203. 

environmental 

the 

This 

(Directive 2003/4/EC) and 

199  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive 
INSPIRE 
Directive, (Directive 2007/2/EC) together  create  a  legal  foundation  for 
the sharing of environmental information between public authorities and 
with 
focuses  on implementation  of 
the  public. 
the INSPIRE Directive. 
200  The  guarantees  are  explained  in  Commission  Notice  on  access  to 
justice  in  environmental  matters,  OJ L  275,  18.8.2017  and  a  related 
citizen’s guide. 
201 This EIR report focuses on measures taken by the Member State to 
guarantee access to justice, legal standing and to overcome other major 
barriers to bringing cases on nature and air pollution. 

EIR 

Table  4:  Country  dashboard  on  the  implementation  of 
the INSPIRE Directive, 2016-2020204 

2016 

2020 

Legend 

Effective  coordination  and  data 
sharing 

Ensure  effective 
coordination  

■ 

Data 

without obstacle   ■ 

sharing 

■ 

■ 

INSPIRE performance indicators 

i.  Conformity  of 
metadata  

ii.  Conformity  of 
spatial 
data 
sets205 

iii. Accessibility of 
spatial  data  sets 
through view and 
download 
services 

■ 

■ 

■ 

■  

■   ■  

iv.  Conformity  of 
network services  ■ 

■ 

■  Implementation  of  this 
provision  is  well  advanced 
completed. 
(nearly) 
or 
Outstanding 
are 
issues 
minor and can be addressed 
easily. Percentage: >89% 

■  Implementation  of  this 
provision  has  started  and 
made  some  or  substantial 
progress but is still not close 
complete.  
be 
to 
Percentage: 31–89% 

■  Implementation  of  this 
falling 
is 
provision 
significantly behind. Serious 
efforts  are  necessary  to 
close  implementation  gap. 
Percentage: <31% 

Public Participation 

Finland is committed to facilitating public participation in 
the environmental impact assessment (EIA) and strategic 
environmental assessment (SEA) procedures. The regional 
ELY centres are the competent EIA authorities. There is a 
central data source for all open and closed EIA procedures 

202 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/FI. 
203 European Commission, List of high value spatial data sets. 
204 INSPIRE knowledge base, 2021. 
205 The deadlines for implementation of the spatial data interoperability 
were  in  2016  still  in  the  future:  23/11/2017  for  Annex  I  data  and 
21/10/2020 for Annex II and III data. It must be also considered that this 
conformity indicator will in many cases never reach 100% conformity as 
majority  of  the  countries  provide  as-is-data  sets  in  addition  to  the 
INSPIRE harmonised data sets. 

Environmental Implementation Review 2022 – Finland 

 
                                                                 
 
 
  
  
  
 
Finland  44 

in Finland206207.￼. To facilitate participation, a video and a 
leaflet explaining what EIA is and how to participate in it 
has  been  produced  for  the  public208209.A  service  design 
working group for the EIA authorities (ELY centres) looked 
improving  the  public  participation 
at  options 
process￼, although it is unclear when and how these will 
be put into practice. 

for 

Not enough data are available to assess the level of public 
participation in decision-making processes related to the 
EIA or SEA Directives. Individual EIA projects may receive 
a large amount of feedback from the public participation 
process, but no data are available on the general level of 
participation. 

information on access to the courts. The websites of the 
four Regional State Administrative Agencies competent in 
environmental and water permit matters include registers 
on pending permit matters and permit decisions. There is 
Information  Service 
also  a 
available on environmental and water permit matters210. 
Further information on specific environmental procedures 
and access to justice may be provided on the websites of 
municipalities, for example. 

joint  web-based  Permit 

In the 2019 EIR Finland received priority actions on access 
to justice, in particular, to provide broader legal standing 
to the public and to better inform them about their rights. 
Progress on both aspects has been limited. 

Access to justice  

2022 priority actions 

can 

generally  participate 

With a few exceptions, there are no specific provisions on 
legal  standing  during  the  administrative  procedure,  i.e. 
NGOs 
through  public 
consultation  in  decision-making  procedures  that  include 
public  consultation.  To  challenge  plans,  in  general,  the 
provisions of Administrative Judicial Procedure Act (AJPA) 
on legal standing and access to justice apply to plans and 
programmes  adopted  by  the  state  authorities  and  the 
provisions  of  the  Local  Government  Act  on  municipal 
appeal apply to plans and programmes at the local level of 
administration. However, in most cases the right to appeal 
for environmental plans is to be determined by the special 
provisions on access to justice in different environmental 
Acts. Under these special provisions, access to justice also 
covers the standing of NGOs. In light of the national case 
law, access to national courts in environmental matters is 
guaranteed. There is also a system of regular supervision 
of  regulatory 
largely 
legally-binding  acts  but 
inaccessible to members of the public and NGOs, who can 
only  flag  cases  to  bodies  or  officials  that  are  entitled  to 
initiate an extraordinary supervision procedure. 

is 

it 

 

in 

for 

  Make  spatial  data  more  widely  accessible  and 
the 
prioritise  environmental  datasets 
implementation  of 
INSPIRE  Directive, 
the 
especially  those  identified  as  high-value  spatial 
datasets 
implementing  environmental 
legislation.  
Improve access to courts by the public concerned  
for  administrative  or 
regulatory  planning 
decisions on water, nature and air quality. 
  Better  inform  the  public  using  the  relevant 
Commission  eJustice  fact  sheets211  about  their 
access to justice rights. 
Consider  further  improvements  to  the  tools 
available  for  public  participation  in  the  light  of 
the 
group’s 
recommendations. 

working 

service 

design 

 

  Monitor  levels  of  public  participation  to  assess 
whether Finland’s ambitions for improved public 
engagement are being met. 

Compliance assurance  

Comprehensive  information  on  access  to  justice  is  not 
available  for  environmental  matters  specifically.  General 
information  about  administrative  (and  general)  court 
proceedings  is  available  on  the  website  of  the  Finnish 
justice  system.  Information  about  the 
is 
available in the FINLEX database. The general website of 
the  environmental  administration  provides  information 
including 
on  different  environmental  procedures, 

legislation 

Environmental compliance assurance covers all the work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, and manage waste212. It includes support 
measures provided by the authorities such as: 
(i) compliance promotion213;  
(ii) inspections and other checks that they carry out, i.e. 

206 https://www.ymparisto.fi/yva-hankkeet?n5=1 
207 https://www.suomi.fi/palvelut/ymparistovaikutusten-
arviointimenettely-elinkeino-liikenne-ja-ymparistokeskus/99980420-
f076-4636-a752-d16ae39e5e16 
208https://www.ymparisto.fi/fi-
FI/Asiointi_luvat_ja_ymparistovaikutusten_arviointi/Ymparistovaikutust
en_arviointi 
209 https://www.ely-keskus.fi/documents/10191/40025628/YVA-
kuulemisen_palvelumuotoilu.pdf/b3b909a0-6449-4be8-bb22-
d5036f4c53e1 

210 ylupa.avi.fi 

211 https://e-
justice.europa.eu/content_access_to_justice_in_environmental_matter
s-300-en.do 
212 The concept is explained in detail in the Communication on ‘EU actions 
to  improve  environmental  compliance  and governance’  COM(2018) 10 
and the related Commission Staff Working Document, SWD(2018)10. 
213 This EIR focuses on the help given to farmers to comply with nature 
legislation and nitrates legislation. 

 Environmental Implementation Review 2022 – Finland 

 
                                                                 
compliance monitoring214;  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement215.  
Citizen science and complaints enable authorities to focus 
their efforts better. Environmental liability216 ensures that 
the polluter pays to remedy any damage.  

Compliance promotion and monitoring 

Finland  has  taken  steps  to 
improve  the  practical 
information  available  to  forest  owners,  particularly  on 
habitats for the flying squirrel217. Additional measures to 
promote  the  implementation  of  the  Birds  and  Habitats 
Directives  have  been  introduced  since  the  2019  EIR, 
mainly  focusing  on  the  forestry  sector.  Measures  and 
information  for  the  agricultural  sector  are  currently 
lacking.There is also a website jointly managed by several 
public  authorities 
information  on 
that  provides 
coexistence  with  large  carnivores,  including  material 
relevant  to  farmers  and  foresters218.  However,  there  do 
not  appear  to  be  similar  tools  targeted  at  farmers  in 
relation to the Nitrates Directive; information available to 
farmers  is  largely  confined  to  details  on  the  cross-
compliance  requirements  for  CAP  payments,  and  while 
research has been carried out into farm-level actions, this 
does not seem to have been translated yet into accessible 
online information219. 

The planning of Industrial Emissions Directive inspections 
is  the  responsibility  of  the  regional  environmental 
authorities,  the  Centres  for  Economic  Development, 
Transport  and  the  Environment  (ELY  centres).  Each 
regional centre prepares a separate inspection plan for its 
own 
special 
characteristics  of  the  area,  supervision  needs,  and  the 
resources  and  objectives  for 
inspections.  Inspection 
reports are not automatically published online; in principle 
they can be requested by members of the public. The ELYs 

area,  describing 

geographical 

the 

214This EIR focuses on inspections of major industrial installations. 
215  This  EIR  focuses  on  the  availability  of  enforcement  data  and 
coordination between authorities to tackle environmental crime. 
216  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
217See e.g. https://tapio.fi/oppaat-ja-tyovalineet/liito-oravan-
huomioon-ottaminen-metsankayton-yhteydessa-neuvontamateriaali/ 
218 See www.suurpedot.fi 
219 See for example the development of a calculator tool for the use of 
fertilisers 
(https://mmm.fi/documents/1410837/0/Typpitaselaskuri_Loppuraportt
i.pdf/60a54676-e53b-6491-fbbd-
3ccb3483e749/Typpitaselaskuri_Loppuraportti.pdf?t=1622007989988), 
and research aimed at improving water management: 
https://www.syke.fi/fi-
FI/Tutkimus__kehittaminen/Tutkimus_ja_kehittamishankkeet/Hankkee
t/KiertoVesi_hanke 
220 Available at: https://www.ymparisto.fi/fi-
FI/Asiointi_luvat_ja_ymparistovaikutusten_arviointi/Luvat_ilmoitukset_
ja_rekisterointi/Ymparistolupa/Valvonta?f=VarsinaisSuomen_ELYkeskus 

Finland  45 

inspections220.  By  contrast, 
publish  annual  data  on 
inspections  of  waste 
incineration  plants  must  be 
published: the list of installations in the geographical area 
of each ELY centre and a report on the activities of each 
installation221 is available online.  

Complaint handling and citizen science 

Some  general  information  is  available  online  on  how  to 
submit a  complaint  to authorities,  which  is however not 
tailored  to  environmental  issues222.  Some  municipalities 
also  provide  specific  information  on  how  to  complain 
about  environmental  issues  specifically223.  Generally,  a 
complaint  on  the  Finnish  administrative  system 
is 
addressed to the supervisory authority legally responsible 
for supervising an activity. This is either an ELY centre or a 
municipal  authority,  depending  on the  matter224.  Where 
the complainant is not a party to any open proceedings or 
permitting  procedure,  they  would  need  to  identify  the 
right  contacts  at  regional 
level  for  submitting  the 
complaint or submit their observations/complaints via the 
general service email or registry. There are no statistics or 
information available on the numbers of complaints or on 
the  ways  the  complaints  are  usually  initiated  with  the 
authorities. 

While, as noted above, the use of information provided by 
citizens in the form of complaints or infringement reports 
is  not  systematic,  there  are  a  number  of  citizen  science 
initiatives in Finland. These include the Finnish Biodiversity 
Information  Facility225,  which  is  an  open  access  data 
repository  for  researchers,  government,  and  the  public, 
allowing users to search and download information, and 
to record and share their own observations. The database 
combines officially gathered data with data submitted by 
citizens  and  NGOs.  The  environmental  services  website 
Ymparisto.fi also includes information on how to submit 
citizen observations with a few links on how to submit the 
information226. 

221 These can be accessed at https://www.ymparisto.fi/fi-
FI/Asiointi_luvat_ja_ymparistovaikutusten_arviointi/Luvat_ilmoitukset_
ja_rekisterointi/Ymparistolupa/Valvonta/Jatteenpoltto_ja_rinnakkaispo
lttolaitoks(32775) 
222General information on how to submit a complaint is available on on 
the  police  website  ((https://poliisi.fi/en/environmental-and-animal-
offences).  
223 
for 
https://www.hel.fi/helsinki/fi/kaupunki-ja-
hallinto/hallinto/palvelut/palvelukuvaus?id=2761 

Helsinky’s 

example 

website: 

See 

224Information  on  how  to  report  alleged  environmental  offences  is 
available  on  a  dedicated  section  of  the  Finnish  Police  website 
((https://poliisi.fi/en/environmental-and-animal-offences￼) .  
225 https://laji.fi 
226 https://www.ymparisto.fi/fi-
FI/Asiointi_luvat_ja_ymparistovaikutusten_arviointi/Kansalaishavainnot 

 Environmental Implementation Review 2022 – Finland 

 
                                                                 
Enforcement 

Environmental crimes are monitored by the government’s 
Finnish 
Environmental  Crime  Monitoring  Group 
(Ympäristörikosten  seurantaryhmä),  which  publishes  an 
annual  report227.  The  total  number  of  offences  affecting 
the  environment  has  increased  in  2021  as  compared  to 
2020, and the number of environmental offences, natural 
resource  offences  and  health  and  safety  offences  has 
reached a record high. The reports provide summary data, 
not details of individual cases or penalties imposed. 

An  updated  national  strategy  to  combat  environmental 
crime was published in 2020228, covering the period 2020-
2026. It aims to facilitate cooperation between authorities 
working  on  environmental  crime  prevention,  including 
sharing  of  best  practices;  to  coordinate  budgetary  and 
other supervision; to develop joint training materials; and 
to further develop statistical information. The strategy is 
monitored  by  a 
joint  executive  board  of  relevant 
stakeholders at governmental and regional level. Biennial 
programmes  will  help  to  implement  the  strategy;  the 
programme for 2021-2022 can be accessed online229. 

Environmental Liability Directive 

The  Statistical  Centre  of  Finland  publishes  data  and 
statistics on the investments and private expenses caused 
by environmental damages, as part of regular reports on 
the costs of environmental protection. This data does not 
cover  the  number  of  reported  ELD  cases  or  incidents  of 
damage230.  The  Finnish  Environmental  Institute  SYKE 
publishes  reports  on  environmental  damage.  The  most 
recent was published in 2019231, and resumes a series of 
regular reports interrupted in 2005. It notes that since the 
last  ELD reporting period in  2013, there  have been  one 
new  certain  ELD  case  (the  decision  is  final)    and  two 
potential ELD cases (one is under appeal and one is under 
consideration  by  the  competent  authority).  The  list  of 
certain ELD cases and ELD cases under an appeal, with the 
relevant hyperlinks are  available on the web page of the 
Ministry of Environment232, under the national register for 
ELD cases. .  The national register for ELD cases. Since the 
information is on the web page, it is easily  available to the 
insurance 
public.  Private 

insurance  companies  offer 

227 https://valtioneuvosto.fi/-/25235045/ymparistorikollisuus-nostaa-
paataan 
228 https://ym.fi/-/ymparistorikosten-torjuntastrategia-korostaa-
viranomaisten-yhteistyota-ja-koulutusta 
229  https://julkaisut.valtioneuvosto.fi/handle/10024/162667  (Can  our 
translator 
the  Finnish 
the  hyperlink 
publication with hyperlink to the shorter Swedish version 
leave  the  hyperlink  to  the  Finnish 
or  should  we 
publication instead? JD: Yes no problem 

replace 

to 

Finland  46 

products  aimed  at  covering  liability  for  environmental 
damage.  There  are  many  issuers  for  these  insurance 
instruments.  However,  the  environmental 
insurance 
market 
for  stand-alone  environmental 
insurance policies is not well developed. Demand by small 
to medium sized businesses for environmental insurance 
is low but steadily growing. Demand by large businesses is 
also steadily growing233. 

in  Finland 

In the 2019 IER  Finland received priority actions to better 
inform 
the  public  about  compliance  promotion, 
monitoring and enforcement by at least ensuring that the 
following  information  is  available  online:  (i)  guidance  to 
Finnish  farmers  on  how  to  comply  with  obligations  on 
nitrates  and  nature,  (ii)  inspection  plans  and  reports  on 
industrial  inspections,  and  (iii)  guidance  on  how  to  file 
environmental  complaints.  It  was  also  recommended  to 
publish  information  on  the  outcome  of  administrative 
enforcement action and the follow-up to detected cross-
compliance breaches on nitrates and nature; and finally to 
improve financial security for liabilities and ELD guidance 
and publish information on environmental damage.  

Limited progress is noted and Finland still falls short on its 
compliance assurance obligations. 

2022 priority actions 

  Better 

and 

inform  the  public  about  compliance 
promotion,  monitoring 
enforcement. 
Provide clear and well-signposted information for 
citizens  on  how 
report  environmental 
complaints or infringements. 
Take  forward  the  commitments  set  out  in  the 
national  strategy  on  environmental  crime, 
including on developing better statistics. 

to 

 

Effectiveness of environmental 
administrations  

Those involved in implementing 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. 

230 https://www.stat.fi/til/ympsm/2019/ympsm_2019_2021-10-
28_tie_001_fi.html 
231 

https://helda.helsinki.fi/bitstream/handle/10138/327983/SYKEra_8_20
21_Ymparistovahingot-Suomessa-2013-
2019.pdf?sequence=4&isAllowed=y 
232 https://ym.fi/ymparistovahinkojen-ehkaiseminen 
233 
https://ec.europa.eu/environment/legal/liability/pdf/Annex-
I_Finland.pdf MS Finland country report. Annex to the Report: Improving 
financial security in the context of the Environmental Liability Directive 
No 07.0203/2018/789239/SER/ENV.E.4 May 2020. 

 Environmental Implementation Review 2022 – Finland 

 
                                                                 
 
Administrative capacity and quality 

administration, the financial sector and access to 
finance. 

Finland  47 

Reforms  through  the  Commission’s  Technical 
Support Instrument (TSI)  

The Commission supports environmental implementation 
and  the  green  transition,  not  only  through  the  EU 
financing  programmes,  but  also  granting  technical 
assistance such as the TSI. 

in  Finland, 

The  Commission’s  TSI  supported  several  environment-
including  a  project  on 
related  projects 
sustainable finance ecosystems under the 2020 TSI  and a 
project on the emerging forest pest risks under the 2021 
TSI. Under the 2022 TSI, a request has been validated on 
the  Do  no  significant  harm  (DNSH)  guidelines  to 
implement the green transition in Finland. 

TAIEX EIR peer to peer 

The TAIEX EIR peer-to-peer tool236 as launched in 2017 by 
the  Commission  to 
learning 
between environmental authorities.  

facilitate  peer-to-peer 

In  2019,  Finland  benefited  from  an  expert  mission  on 
circular  procurement  training. It also participated in two 
workshops  on  advancing  cities’  sustainability  targets 
strategically  through  public  procurement  and  on  EU 
Timber Regulation Nordic Baltic Competent Authorities. In 
2022, Finland participated in two multi country workshop 
on zero pollution and ammonia reducing technology and 
measures. 

Environmental policy developments in Finland are mainly 
driven by EU directives and regulations, and the relevant 
EU rules are generally transposed in time. At present, the 
number  of  complaints  and 
the 
environmental  field  can  be  considered  below  the  EU 
average. 

infringements 

in 

Overall,  during  the  last  decade  an  improvement  in  the 
implementation of EU environmental law  can be observed 
across sectors. For instance, progress has been made on 
the  implementation  of  environmental  assessments.  A 
recent  package  of  legislation  aimed  at  speeding-up  the 
licencing of the 'projects of national interest' raised some 
doubts  but  no  serious  problems  were  identified  when  it 
entered into force. 

Coordination and integration  

Environmental 

Impact  Assessment 

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
(EIA) 
revised 
Directive234  provides  an  opportunity  to  streamline  the 
regulatory  framework  on  environmental  assessments. 
Despite  a  delay  in  full  transposition  in  relation  to  the 
deadline (May 2017), Finland has transposed the revised 
Directive.  The  quality  of  the  transposition  is  currently 
undergoinga conformity check by the Commission. 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments  to  reduce  duplication  and 
avoid  overlaps  in  environmental  assessments  applicable 
to  projects.  Moreover,  streamlining  helps  to  reduce 
unnecessary  administrative  burden  and  accelerates 
is 
decision-making, 
done  without 
compromising 
the  environmental 
assessment  procedure235.  Finland  started  streamlining 
environmental  assessments  under  the  EIA  and  Habitats 
Directives  even  before  the  revision  of  the  EIA  Directive. 
Coordinated procedures have been put in place for the EIA 
Directive, the Water Framework Directive and the IED.  

provided 
it 
the  quality  of 

A  notable  good  practice  is  the  Single  Environmental 
Permitting  Platform  developed  to  operationalise  the 
Single Environmental Permitting Regime, which simplifies, 
harmonises and articulates many environmental permits. 

2022 priority actions 

 

Continue  to  build  adminstrative  capacity  to 
support  the  green  transition,  particularly  in  the 
areas of circular economy, governance and public 

234 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment. 
235 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.  
236  TAIEX  -  Environmental  Implementation  Review  -  PEER  2  PEER  - 
Environment - European Commission (europa.eu) 

 Environmental Implementation Review 2022 – Finland