COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - SLOVENIA 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, Slovenia, 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) 273 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022       Country Report - SLOVENIA               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) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Slovenia  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. 

 
 
 
 
 
 
 
 
 
 
 
Slovenia  2 

Table of Content 

EXECUTIVE SUMMARY ........................................................................................................................................... 0 

PART I: THEMATIC AREAS ...................................................................................................................................... 1 

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 1 
Measures towards a circular economy ................................................................................................................ 1 
Waste management ............................................................................................................................................. 3 
2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................................. 6 
Nature protection and restoration ....................................................................................................................... 6 
Marine ecosystems............................................................................................................................................. 12 
Ecosystem assessment and accounting ............................................................................................................. 13 
3. ZERO POLLUTION ..................................................................................................................................................... 15 
Clean air ............................................................................................................................................................. 15 
Industrial emissions ............................................................................................................................................ 16 
Major industrial accidents prevention – SEVESO ............................................................................................... 19 
Noise .................................................................................................................................................................. 20 
Water quality and management ........................................................................................................................ 20 
Chemicals ........................................................................................................................................................... 24 
4. CLIMATE ACTION ..................................................................................................................................................... 26 
Key national climate policies and strategies ...................................................................................................... 26 
Effort sharing target ........................................................................................................................................... 26 
Key sectoral developments ................................................................................................................................. 27 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 28 

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

5. FINANCING ............................................................................................................................................................. 29 
Environmental investment needs in the European Union .................................................................................. 29 
EU environmental funding 2014-2020 ............................................................................................................... 31 
EU environmental funding 2021-2027 ............................................................................................................... 32 
National expenditure on environmental protection ........................................................................................... 34 
Green budget tools ............................................................................................................................................. 36 
Overall financing compared to the needs .......................................................................................................... 38 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 40 
Information, public participation and access to justice...................................................................................... 40 
Compliance assurance ........................................................................................................................................ 41 
Effectiveness of environmental administrations ................................................................................................ 43 
Reforms through the Commission’s Technical Support Instrument (TSI) ........................................................... 44 
TAIEX EIR peer to peer ........................................................................................................................................ 44 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
Slovenia  0 

Executive summary 

In  previous  environmental 
implementation  reviews 
(EIRs),  the  Commission  identified  the  following  main 
challenges 
implementation  of  EU 
environmental policy and law: 

for  Slovenia’s 

  putting 

in  place  all  conservation  measures  and 

 

enforcing their implementation in Natura 2000 sites; 
integrating  nature-conservation  measures  into  other 
sectors,  by  getting  the  support  of  some  sectoral 
stakeholders, particularly in the agriculture sector;  
  reducing  particulate  matter  emissions  by  reducing 
traffic  congestion  and  the  burning  of  fossil  fuels,  as 
well as supporting efficient and clean district heating; 
improving 
and 
treatment  through  appropriate  investments  to  meet 
the country’s accession obligations (which expired at 
the end of 2015);  

urban  wastewater 

collection 

 

On  the  Natura  2000  network,  all  sites  of  community 
importance  have  been  designated  as  special  areas  of 
conservation.  As  a  result,  the  Natura  2000  network  on 
land can be considered complete. However, there is still a 
gap  in  the  classification  of  marine  special  protection 
infringement 
is  the  subject  of  an  EU 
areas  which 
procedure. 
conservation 
site-specific 
In  addition, 
objectives of sufficient quality have yet to be established 
for  all  Natura  2000  sites.  There  are  also  delays  in 
implementing  the  necessary  conservation  measures  for 
many sites. All conservation measures for all Natura 2000 
sites  need  to  be  strengthened  and  fully  implemented, 
using  also  the  prioritised  action  framework.  In  terms  of 
EU funding, there are practically no funds for biodiversity 
in  the  national  recovery  and  resilience  plan  to  cover 
several needs. Therefore, the shortfall needs to be made 
up from other EU funds (in  particular, from those under 
the common agricultural policy and cohesion policy) and 
national sources. 

On integrating nature conservation measures into other 
sectors, there has been no progress. This has contributed 
to  the  deterioration  of  the  conservation  status  of 
habitats  and  species.  On  the  impact  of  agricultural 
practices  on  grassland  habitats  and  associate  species 
(inside  and  outside  Natura  2000  sites),  the  Commission 
started an infringement procedure. Adapting agricultural 
practices  within  the  sites  where  the  conservation  status 
of habitats and/or species is declining due to agricultural 

is  a  priority.  The 

activities 
integration  of  nature-
conservation  measures  into  other  sectors  still  remains  a 
concern.  

On air quality there has been progress. The emissions of 
key air pollutants have decreased significantly in Slovenia 
in  recent  years,  while  GDP  growth  continued.  Slovenia 
expects to reach its emission-reduction commitments for 
all  air  pollutants  covered  by  the  National  Emission 
Reduction  Commitments  Directive  for  the  period  2020-
2029,  and  for  most  pollutants  from  2030  onwards. 
However,  the  projections  do  not  demonstrate  that  they 
meet  the  emission-reduction  commitments  for  PM2.5  for 
2030 onwards. In terms of EU funding, almost a quarter of 
the  national  recovery  and  resilience  plan  is  allocated  to 
sustainable  energy  and  transport  which  is  expected  to 
benefit air quality, including PM2.5. 

Despite  some  progress  made  in  recent  years  in  the 
wastewater  sector,  Slovenia  has  yet  to  fully  achieve 
compliance  with  the  Urban  Waste  Water  Treatment 
Directive.  Slovenia  is  under  infringement  procedure  as 
some  agglomeratons  with  a  population  of  over  10.000 
are not compliant with the requirements of the UWWTD. 
The  procedure  may  result 
in  fines.  The  situation 
regarding  smaller  agglomerations  (above  2 000  people.) 
is  also  unsatisfactory.  Developing  and  modernising  the 
necessary infrastructure for all agglomerations, as set out 
under  the  Urban  Waste  Water  Treatment  Directive,  has 
yet to be completed. 

Slovenia’s environmental financing for investments came 
to  1.76%  of  GDP  (EU  average:  0.7%)  in  2014-2020,  over 
80%  of  which  originated  from  domestic  sources.  On  the 
other  hand,  the  country’s  environmental-investment 
needs  for  2021-2027  are  estimated  to  be  at  least  2.06% 
of GDP, indicating an additional financing need (or gap) 
of  0.3%  of  GDP  for  environmental 
implementation 
compared to the 2014-2020 period financing baseline. 

On  environmental  harmful  subsidies,  Slovenia  allocated 
more than the EU average numbers of these subsidies for 
fossil  fuels,  which 
  than  the 
subsidies  allocated  to  renewable  energy.  This  does  not 
encourage greener investments. 

is  significantly  higher 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
Slovenia  1 

Part I: Thematic Areas 

1. Circular Economy and waste management 

Figure 1: Circular material use rate (%), 2010-20201 

Measures towards a circular economy 

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 
reparability, 
upgradability  and  recyclability  of  products,  to  other 
(ii) increasing 
measures, 
circularity 
(iii) recycling; 
(iv) boosting eco-innovation and (v) increasing the uptake 
of green public procurement. 

like: 
(i) remanufacturing; 
in  production  processes; 

the  durability, 

increase 

to 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
impacts  on  the  environment  and  reduce 
negative 
dependency on volatile raw  material  markets. As  shown 
in  Figure  2,  Slovenia  generated  EUR  1.54  per  kg  of 
material  consumed 
resource 
in  2020.  This  puts 
in  Slovenia  considerably  below  the  EU 
productivity 
average of EUR 2.09 per kg. 

Figure 2: Resource productivity, 2010-20202 

The rate of Slovenia’s circular (secondary) use of material 
rose from 8.5% in 2016 to 12.3% in 2020, coming close to 
the  EU  average  of  12.8%,  and  showing  a  strong  and 
positive dynamic. 

1 Eurostat, Circular Economy Monitoring Framework.. 
2 Eurostat, Resource productivity. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
 
 
                                                                 
Circular economy strategies  

Eco-innovation 

Slovenia  2 

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  at 
Member  State  level.  Since  the  launch  of  the  online  
in  20173, 
Circular  Economy  Stakeholder  Platform 
national,  regional  or  local  authorities  have  used  the 
platform to share their strategies and roadmaps. 

the 

sectors,  gives 

recommendations 

‘Roadmap  towards  the  Circular 
In  May  2018,  the 
Economy in Slovenia’ was published. It sets out the path 
for  Slovenia  to  become  a  front  runner  for  the  circular 
economy  in  the  region.  The  roadmap  identifies  four 
priority 
the 
government  and  identifies  best  practice.  In  November 
2012, 
an 
Slovenian  Government 
Implementation  plan  for  an  European 
Institute  of 
Innovation  &  Technology  (EIT)  Climate-KIC-led  project 
called ‘A Deep Demonstration of a Circular, Regenerative 
and  Low-Carbon  Economy  in  Slovenia’.  The  initiative  is 
one  of  eight  deep  demonstrations4  launched  by  EIT 
Climate-KIC, which together offer a test bed environment 
for the ambitious, 1.5-degree-consistent systems. 

adopted 

to 

(i) 

forestry; 

Slovenia’s plan centres on driving circularity in five main 
areas: 
environment; 
(iii) manufacturing;  (iv)  food;  and  (v)  mobility.  It  focuses 
on the three pillars of: (i) smart and circular communities, 
(ii)  circular  green  development  and  (iv) circular  policy 
design and science. 

built 

(ii) 

Slovenia  does  not  have  in  place  a  sectoral  strategy  for 
plastics,  textiles  or  construction.  However,  the  proposal 
on  ‘Deep  Demonstration  of  a  Circular,  Regenerative  and 
Low-Carbon  Economy  in  Slovenia’  includes  initiatives 
targeting these sectors. 

In addition, as part of the national recovery and resilience 
plan,  Slovenia  will  establish  a  strategic  and 
legal 
framework for the transition to a circular economy. It will 
responsibility, 
also  work  on  extending  producer 
promoting  the  integration  of  recycled  material  into  new 
products, integrating the principle of circular economy in 
the green public procurement system, and establishing a 
one-stop shop to support businesses. 

3  Circular Economy Stakeholder Platform 
4  Deep  demonstrations  are  large-scale  projects  through  which 
EIT  Climate-KIC  offers 
innovation  as  a 
service’ model  to  Europe’s  most  ambitious  challenge  owners  – 
industries  and 
i.e. 
community  leaders,  and  funders  who  have  the  means  and 
mandate to tackle climate change challenges. 

the  mayors,  government  ministries, 

 ‘systems 

its 

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 
to  produce  circularity 
business  models  can  help 
innovations, creating new business opportunities. 

In  2021,  Slovenia  ranked  13th  on  the  2021  Eco-
Innovation Index, with a total score of 113, resulting in an 
average  eco-innovation  performance.  In  one  out  of  five 
components (eco-innovation inputs), Slovenia performed 
above  the  EU  average.  However,  its  performance  is 
below  the  average  for  eco-innovation  activities,  eco-
innovation  outputs,  resource-efficiency  outcomes  and 
socio-economic outfits. 

Figure 3: Eco-innovation performance, 2010-20195 

Green public procurement (GPP) 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  around  14%  of  EU  GDP. 
Although GPP is a voluntary instrument, it has a key role 
to  play  in  the  EU's  efforts  to  become  a  more  resource-
efficient  and  sustainable  economy.  The  European 
Commission  is  helping  to  increase  the  use  of  GPP  or 

5  European  Commission  -  Directorate-General  for  Environment  (DG 
ENV), Eco-innovation Observatory, Eco-innovation index. 

 Environmental Implementation Review 2022 – Slovenia 

 
 
                                                                 
 
 
 
                                                                 
green  purchasing.  Thus,  EU  GPP  criteria  are  set  up  for 
many sectors6. 

Waste management 

Slovenia  3 

Turning waste into a resource is supported by:  
(i)  fully 
legislation,  which 
implementing  EU  waste 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets, etc.;  
(ii) reducing waste generation and waste generation per 
capita in absolute terms;  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
and  phasing  out  landfilling  of  recyclable  or  recoverable 
waste. 
This  section  focuses  on  the  management  of  municipal 
waste10,  for  which  EU  law  sets  mandatory  recycling 
targets. 

resource  efficiency  and 

Preventing products and materials from becoming waste 
for  as  long  as  possible  is  the  most  efficient  way  to 
improve 
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. 

reduce 

to 

After  a  downward  trend,  municipal-waste  generation  in 
Slovenia has started to increase again in recent  years. It 
came  to  487 kg/year/inhabitant  in  2020  (compared  to 
449 kg/year/inhabitant in 2015), although it remains  just 
below  the  EU  average  (505  kg/year/inhabitant)11  –  see 
Figure 4. 

A Green Public Procurement Regulation has been in force 
since 2012, renewed in 2018 and 2021. In January 2020, 
minor  changes  in  some  articles  were  introduced.  The 
regulation  is  mandatory  for  22  groups  of  products  and 
services. According to the data from the annual statistical 
reports  on  the  award  of  public  contracting  authorities, 
the GPP system is gradually expanding. 

Since  2019,  the  GPP  team  at  the  Ministry  of  the 
Environment  and  Spatial  Planning  has  been  offering 
substantive  promotion  and  support.  The  team  has  built 
its capacity and human resources mainly through LIFE IP 
project ‘Care 4 Climate’. 

EU ecolabel and the eco-management and audit 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 
supporting 
committed  public  authorities  are 
instruments designed to promote the circular economy. 

to 

As of September 2021, Slovenia had 110 products out of 
83 590, and 35 licences out of 2 057 registered in the EU 
ecolabel  scheme.  This  shows  a  low  take-up  of  the 
products  and  licences8.  Moreover,  16  sites  belonging  to 
10  organizations  in  Slovenia  are  currently  registered  in 
EMAS9. Since the last report in 2019, there have been 38 
new  registrations  of  EU  ecolabel  products  and  5  licence 
registrations,  as  well  as  5  new  organisations  registered 
with EMAS in Slovenia. 

In  2019,  one  of  the  priority  actions  recommended  for 
Slovenia  was  to  continue  efforts  to  get  all  economic 
sectors  to  accelerate  their  uptake  of  the  circular 
economy.  In  view  of  Slovenia’s  good  progress  and  its 
commitment, this action has not been recommended this 
time. 

6  In  the  Communication  ‘Public  procurement  for  a  better 
environment’ (COM (2008) 400) the Commission recommended 
the creation of a process for setting common GPP criteria. The 
EU GPP criteria are regularly published and updated. 
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, 
plastics,  biowaste,  wood,  textiles,  packaging,  waste  electrical  and 
electronic  equipment,  waste  batteries  and  accumulators,  and  bulky 
waste,  including  mattresses  and  furniture;  and  (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 treatment. 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
                                                                 
 
                                                                 
Figure 4: Municipal waste by treatment in Slovenia, 
2010-202012 

Figure 5: Recycling rate of municipal waste, 2010-202015 

Slovenia  4 

Figure  4  also  shows  municipal  waste  by  treatment  type, 
in  kg  per  capita.  The  situation  varies  by  region,  but 
managing  waste  efficiently  still  remains  a  challenge  for 
Slovenia. 

Slovenia  has  made  slow  but  steady  progress  over  the 
its  recycling  rate  and 
past  decade  on  stepping  up 
diverting  municipal  waste  from  landfilling.  The  recycling 
rate for municipal waste in 2020 was 59.3%. This is well 
above  the  EU-27  average  of  47.8%  (2020)13.  This  puts 
Slovenia among eight Member States (Germany, Austria, 
the  Netherlands,  Belgium,  Denmark.  Luxembourg  and 
Italy14), which achieved recycling rates of 50% or higher. 

There  is  still  a  problem  with  several  illegal  landfills  that 
have  yet  to  be  closed.  Two  infringement  cases  remain 
open,  one  concerning  the  site  of  Bukovžlak  close  to 
Cinkarna  Celje,  and  the 
landfill  of  Suhadole  (last 
remaining ones of the group of illegal landfills). Slovenia 
may  be  facing  fines  due  to  the  abovementioned 
infringements.  

Figure  5  shows  that  Slovenia  has  already  reached  the 
EU’s  2025  recycling  target  (55%)  and  is  on  the  way  to 
meeting the EU 2030 recycling target (60%). 

12  Eurostat, Municipal waste by waste operation, april 2022. 
13 Eurostat, Recycling rate of municipal waste. 
14 Eurostat 2020 data, with an exception of AT and IT data (2019). 

The  Commission's  Early  Warning  report16  did  not  list 
Slovenia as one of the countries at risk of missing the EU 
2020  target  of  recycling  50%  of  municipal  waste  –  it  is 
among  best  performing  Member  States  in  this  respect. 
The  Commission  is  currently  finalising  its  analysis  of  the 
progress  made  on  the  recommendations  from  the  2018 
Early  Warning  Reports  and  its  analysis  of  the  progress 
made  towards  achieving  the  2025  waste  recycling 
targets. This report will be presented at the end of 2022 
and will assess the progress made to date. 

Implementation of the 2018 waste legislative package 

By 5 July 2020 EU Member States were required to bring 
their national laws into line with changes included in the 
revised  Waste  Framework  Directive,  the  Packaging  and 
Packaging  Waste  Directive  and  the  Landfill  Directive17. 
Slovenia has notified the transposition of the Landfill and 
the  Packaging  and  Packaging  Waste  directives  to  the 
Commission. A conformity assessment is now ongoing. 

plans 

Waste-management 
and  waste-prevention 
programmes are instrumental for the full implementation 
of  the  EU  waste  legislation.  They  set  out  key  provisions 
and investments to ensure compliance with existing and 
new  legal  requirements  (e.g.  on  waste  prevention;  on 
separate  collection  for  a  number  of  specific  waste 

15 Eurostat, Recycling rate of municipal rate, april 2022. 
16  European  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, SWD(2018)422 accompanying COM(2018)656. 
17  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. 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
                                                                 
 
 
                                                                 
streams;  on  recycling  targets;  and  on  landfill  targets). 
Slovenia  was  due  to  submit  revised  waste-management 
plans and waste-prevention programmes by 5 July 2020. 

The  drafting  of  the  operational  programme  for  waste 
management  and  prevention  is  in  the  final  stage.  It  will 
provide the basis for the drawing up of an environmental 
report.  The  programme  also 
includes  activities  for 
preventing  food  waste.  An  analysis  of  how  effective  the 
management  of  municipal  and  other  waste  was  in  2018 
and  of  possible  developments  over  the  next  20  years  is 
being  carried  out.  The  Slovenian  government  had  been 
expected  to  adopt  the  programme  in  the  first  quarter 
of 2022. 

The  2019  EIR  for  Slovenia  contained  several  priority 
actions in the waste sector, including the need to:  

i. 

ii. 

introduce  new  instruments  to  promote  waste 
prevention,  make  reuse  and  recycling  more 
economically  attractive  and  shift  reusable  and 
recyclable waste away from incineration;  
improve  and  extend  separate  collection  of 
waste, including for biowaste;  

Slovenia  5 

iii. 

iv. 

v. 
vi. 

targets 

recycling 

for 
set  mandatory 
municipalities  with  measures  in  case  of  non-
compliance (e.g. fines); 
improve  the  functioning  of  extended  producer 
responsibility systems;  
improve data on waste management;  
close  and 
rehabilitate 
landfills. 

the  non-compliant 

2022 priority actions 

 

new 
to 

policies, 
further 

including 
implement 

Introduce 
economic 
the  waste 
instruments, 
hierarchy,  i.e.  promote  prevention,  and  make  reuse 
and  recycling  more  economically  attractive;  and/or 
implement the policies which are already in place. 
  Ensure  a  waste-management  plan  in  line  with  the 

revised Waste Framework Directive is in place. 

  Close  and  rehabilitate,  as  quickly  as  possible,  the 
landfills  to  avoid  charges  from 

illegal 

remaining 
infringement procedures. 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
Slovenia  6 

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;  

(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.. 

importance  (SCIs)  as  special  areas  of  conservation 
(SACs)20, and the setting of conservation objectives and 
measures for the Natura 2000 sites. 

Setting up a coherent network of Natura 2000 sites 

Slovenia  hosts  60  habitat  type21s  and  202  species22 
covered  by  the  Habitats  Directive.  The  country  also 
hosts  populations  of  76  bird  taxa  listed  in  the  Birds 
Directive Annex I23. 

importance 

By 2021, 37.9% of the national land area of Slovenia was 
covered  by  Natura  2000  (EU  coverage  18.5%),  with 
special  protection  areas  (SPAs)  classified  under  Birds 
Directive covering 25% (EU coverage 12.8%) and sites of 
community 
(SCIs)  under  the  Habitats 
Directive  covering  32.7%  (EU  coverage  14.2%)  of  the 
Slovenian territory. Whilst the Natura 2000 network on 
land can be considered complete, there is still a  gap in 
the classification of marine SPAs for the Mediterranean 
Shag 
in  Slovenian  marine  waters,  for  which  the 
Commission began an infringement procedure in 2020. 

The  EU  Habitats  and  the  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 
wildlife18.  

into  account  both  Natura  2000  and  other 
Taking 
nationally  designated  protected  areas,  Slovenia  legally 
protects  40.5%  of  its  terrestrial  areas  (EU-27  coverage 
26.4%)  and  5.2%  of  its  marine  areas  (EU-27  coverage 
10.7%)24. 

At  present,  Slovenia  does  not  have  a  national  strategy 
for  biodiversity  and  nature 
the 
commitments  and  actions  of  the  EU  biodiversity 
strategy. 

reflects 

that 

Nature protection and restoration  

Natura  200019,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  objectives 
in  the  Birds  and  Habitats 
Directives.  These  objectives  are  to  ensure  the  long- 
term  protection,  conservation  and  survival  of  Europe's 
most valuable and threatened species and habitats and 
the ecosystems they underpin.  Key milestones towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are:  (i) the  setting  up  of  a  coherent  Natura 
2000 network; (ii) the designation of sites of community 

18 These should be strengthened by the Nature Restoration Law, a key 
deliverable of the EU biodiversity strategy for 2030. 
19  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;  figures  of  coverage 
do  not  add  up  to  100%  due  to  some  SCIs  and  SPAs  overlapping.  A 
special area of conservation (SAC) is an SCI designated by the Member 
States. 

20 SCIs are designated under the Habitats Directive whereas SPAs are 
designated under the Birds Directive; figures of coverage do not add 
up  to  100%  due  to  some  SCIs  and  SPAs  overlapping.  SACs  are  SCIs 
designated by the Member States. 
21 EEA, Article 17 dashboard, Annex I total, 2019. 
22  EEA,  Article  17  dashboard,  Annex  II  +  Annex  IV  excluding  those  in 
Annex  II  +  Annex  V  excluding  those  in  Annex  II,  2019.  This  counting 
only takes into account species and habitats for which assessment of 
conservation status was requested. 
23  EEA, Article  12  dashboard,  Annex  I,  2020. This counting  only  takes 
into account birds taxa for which information was requested. 
24  European  Environment  Agency,  Protected  Areas,  terrestrial 
protected  area  percentage  (2021)  and  marine  protected  area 
percentage (2019), March 2022. 

Environmental Implementation Review 2022 – Slovenia 

 
                                                                 
 
                                                                 
Figure 6: Marine & terrestrial protected area coverage, 
202125 

conservation  objectives  and  measures  has  expired  for 
all but a few sites in Slovenia. 

Slovenia  7 

Although  all  SCIs  have  been  designated  as  SACs, 
Slovenia  has  yet  to  establish  site-specific  conservation 
objectives of sufficient quality for all of them. 

Furthemore,  the 
implementation  of  the  necessary 
conservation  measures  has  been  delayed  for  many 
sites.  Slovenia  is  currently  addressing  some  of  these 
shortcomings  within  the  ‘LIFE  Integrated  Project  for 
Enhanced Management of Natura 2000 in Slovenia’. 

Therefore, Slovenia still has to provide for the necessary 
conservation  objectives  and  measures 
the 
designated sites. 

for 

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 
towards  maintaining  or  restoring 
favourable 
the 
conservation status of species and habitats. 

According  to  the  report  submitted  by  Slovenia  on  the 
conservation  status  of  habitats  and  species  covered  by 
Article 17 of the Habitats Directive for 2013-201827, the 
share of assessments for habitats in good conservation 
status  in  2018  is  10%  less  than  the  42.7%  reported 
under  the  previous  reporting  period  (2007-2012).  On 
protected species, the share of assessments for habitats  
in good conservation status in 2018 was 29.22%, slightly 
more  than  the  28.96%  reported  under  the  previous 
reporting  period  (2007-2012).  On  birds,  82%  of  the 
breeding species showed short-term increases or stable 
population  trends  (for  key  wintering  species  this  figure 
was 40%). 

At  the  same  time,  the  share  of  habitats 
in  bad 
conservation status in 2018 increased to 61.8% and the 
share  of  assessments  for  species  in  bad  conservation 
status also increased to 53%. 

The  habitat  groups  that  have  been  faring  particularly 
badly  are  forests,  bogs,  mires  and  fens,  grasslands  and 
freshwater habitats. On species, groups that have been 
faring  particularly  badly  are mammals,  amphibians  and 
arthropods, while notably there are still knowledge gaps 
on the conservation status of species. 

from  agriculture,  urban 
The  main  pressures  are 
development,  changes  in  water  regime,  forestry  and 
other extraction of resources. 

27 EEA, Conservation status and trends of habitats and species, 2019. 

Figure  7:  Natura  2000  terrestrial  protected  area 
coverage, 202126 

Designating SACs and setting conservation objectives 
and measures 

The  6-year  deadline  set  by  the  Habitats  Directive  to 
designate an SCI as an SAC and to establish appropriate 

25  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
26  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
                                                                 
                                                                 
On  the  impact  of  agriculture  on  grassland  habitats  and 
associated  species,  in  particular  birds  and  butterflies, 
the  Commission  begun  an 
infringement  procedure 
against  Slovenia  in  2019  for  its  failure  to  address 
inside  and  outside 
damaging  agricultural  practices 
Natura 2000 sites. 

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 

Slovenia  8 

the  habitats  and  species 

restoration 
implementation  of  conservation  and 
measures  on 
in  bad 
conservation  status  and/or  declining  trends,  such  as 
(i) grasslands  and  associated  species  by  addressing 
agricultural pressures, (ii) forests and associated species 
by  addressing  forestry  practices  and  (iii) freshwater 
habitats  and  associated  species  by  addressing  changes 
in the water system. 

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 
organic farming to at least 25%. 

Slovenia has an estimated 10.76% of area under organic 
farming,  marginally  above  the  EU  average  of  9.07% 
(2020)30. 

significant  progress 

To  make 
restoring  and 
maintaining favourable conservation status of protected 
its 
habitats  and  species,  Slovenia  should 

focus 

in 

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. 

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

30 Eurostat, Area under organic farming. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
 
                                                                 
 
 
 
 
 
 
 
 
 
 
 
                                                                 
Slovenia  9 

land degradation neutrality by 2030.  
This entails:  
(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 artificialised34. 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 

land  take 

Despite  a  reduction  in  the  last  decade  (land  take  was 
over  1 000  km2/year  in  the  EU-28  between  2000  and 
2006), 
in  the  EU-28  still  amounted  to 
539km2/year between 2012-201835. The concept of ‘net 
land take’ combines land take with the return of land to 
land  categories  (re-cultivation).  While 
non-artificial 
some land was re-cultivated in the EU-28 in 2000-2018, 
11 times more land was taken than returned. 

Slovenia  ranks  below  the  EU  average  with  a  net  land 
take of 49.8 m2/km2 (EU-27 average: 83.8 m2/Km2) 36. 

In  2018,  according  to  the  Performance  Review  and 
Implementation  System  (PRAIS3)  reporting  platform, 
Slovenia  updated  its  reporting  on  land  degradation37 
with  actions 
intended  to  combat  the  degradation 
identified. However, Slovenia has not yet committed to 
setting  land  degradation  neutrality  targets  under  the 
UN Convention to Combat Desertification (UNCCD)38. 

semi-subsistence 

Agricultural land covers 36% of Slovenia’s territory. The 
agricultural  sector  consists  of  a  significant  share  of 
small-sized, 
small-scale 
commercial  farms,  due  to  the  country’s  geological  and 
other  natural 
agriculture 
generates one of the lowest incomes from agriculture in 
the EU.  

conditions. 

Slovenia’s 

and 

terms  of  environmental 

In 
impacts,  Slovenia’s 
agriculture  has  been  identified  as  one  of  the  main 
pressures on water bodies which is, among other things, 
linked  to  the  management  of  nutrients  (nitrogen, 
phosphorous,  potassium,  etc.)  and  livestock  manure. 
According to the Slovenian prioritised action framework 
(PAF)32,  the  sector  also  affects  biodiversity  because  of 
the 
systems 
(i) 
systems), 
(fertilisation, 
(ii) conversion  into  arable  land,  (iii) abandonment  of 
inappropriate 
traditional  management  systems,  (iv) 
techniques  or  timing 
(v) 
inorganic 
inappropriate  application  of  natural  or 
fertilisers as well as (vi) drainage of land33.  

agricultural 
intensification  of  mowing 

for  mowing  grasslands, 

intensification  of 

Soil ecosystems  

Soil  is  a  finite  and  extremely  fragile  resource.  It  is 
increasingly degrading in the EU. 
The  new  EU  soil  strategy,  adopted  on  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 

31https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/defaul
t/table?lang=en (Eurostat, Area uner organic farming, February 2022). 
32  Ministry  of  the  Environment  and  Spatial  Planning,  The  Slovenian 
Prioritised Action Framework (PAF), 2019.  
33 European Commission, CAP strategic plans recommendations, SWD 
2020(394)  –Slovenia  and  Ministry  of  the  Environment  and  Spatial 
Planning, The Slovenian Prioritised Action Framework (PAF), 2019. 

34 Artificial  land cover  is defined as the total of roofed built-up areas 
(e.g  buildings  and  greenhouses),  artificial  non-built-up  areas  (e.g. 
sealed  area  features,  such  as  yards,  farmyards,  cemeteries,  and  car 
parking  areas,  and  linear  features,  e.g.  streets,  roads,  railways, 
runways, bridges) and other artificial areas (e.g. bridges and viaducts, 
mobile  homes,  solar  panels,  power  plants,  electrical  substations, 
pipelines, water sewage plants, and open dump sites). 
35 Land take  in Europe — European Environment Agency (europa.eu) 
figure 6. 
36 EEA, Land take in Europe.  
37 UNCCD, Prais3, Slovenia Report, 2018. 
38  UNCCD, The LDN Target Setting Programme. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
                                                                                                      
 
                                                                 
Figure 11: Land take and re-cultivation in EU27 
(m2/km2), 2012-201839 

Slovenia  10 

is  to  ensure  healthy,  diverse  and  resilient  EU  forests 
that  contribute  significantly 
the  strengthened 
to 
biodiversity and climate ambitions.  
Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 

Of  the  27%  of  EU  forest  area  protected  under  the  EU 
nature  directives, 
less  than  15%  has  a  favorable 
conservation  status.  Assessments  reveal  that  bad 
conservation  status  increased  from  27%  to  31%  in  the 
EU41 in 2018 compared to 2015. More than 75% of the 
assessments 
to  poor 
conservation status. 

in  Slovenia  show  a  bad 

In  Slovenia,  forests  cover  58.61%  of  its  territory42  and 
more than 75% of the assessments reveal a bad to poor 
status43. A total of 34 000 ha in Slovenia are covered by 
primary forests44. 

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

information 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  and  the  environment.  The  last 
from  EU  Member  States40 
available 
estimated that potentially polluting activities have taken 
place  or  are  still  taking  place  on  approximately  2.8 
million  sites  in  the  EU.  At  EU  level,  650 000  of  these 
sites  have  been  registered  in  national  or  regional 
inventories.  A  total  of  65 500  contaminated  sites 
already have been remediated. 

Slovenia  had  registered  181  sites  where  potentially 
polluting  activities  had  taken  place  or  are  still  taking 
place, and had already remediated or applied aftercare 
measures on 83 sites. 

45 

Soil  organic  matter  plays  an  important  role  in  the 
carbon cycle and in climate change. Soils are the second 
largest carbon sink in the world after the oceans. 

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 

39  European  Environment  Agency,  Land  take  in  Europe,  December 
2021. 
40  Ana  Paya  Perez,  Natalia  Rodriguez  Eugenio  (2018),  Status  of  local 
soil contamination in Europe: Revision of the indicator ‘Progress in the 
management Contaminated Sites in Europe’. 

The European Union Timber Regulation (EUTR)46, which 
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 

41 COM/2020/635 final 
42 EEA, Forest information system for Europe 
43 COM SWD (2021) 652 
44 JCR, Mapping and assessment of primary and old-growth forests in 
Europe, p. 13. 
45  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
46 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
                                                                 
 
 
                                                                 
Slovenia  11 

changed  to  annual  reporting,  and  covers  the  calendar 
year as of 2019. 

In  the  period  from  March  2017  to  February  201947, 
Slovenia  carried  out  611  checks  on  domestic  timber 
operators.  It  also  carried  out  29  checks  on  operators 
importing timber. It is estimated that Slovenia had 2 124 
operators  placing  imported  timber  types  onto  the 
internal market over the reporting period. 

The  new  Deforestation  Regulation48  will  repeal  and 
replace  the  EUTR,  as  it  will  essentially  integrate  and 
improve  the  existing  system  to  check  the  legality  of 
timber. 

some challenges and areas for improvement. Given that 
the  deadlines  for  implementing  the  various  obligations 
of  the  IAS  Regulation  applied  gradually  between  July 
2016 and July 2019, it is premature to draw conclusions 
on  several  aspects  of  the  implementation  of  the  IAS 
Regulation. 

A 2021 report51 on the baseline distribution (see Figure 
13) shows that from the 66 species on the Union list, 21 
have been observed in the environment in Slovenia.  

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

Invasive alien species (IAS) 

in 

and 

land 

changes 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside 
use, 
sea 
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  IAS  and  decrease  the  number  of  'red  list' 
species they threaten by 50%. 

The core of Regulation (EU) 1143/2014 on IAS (‘the IAS 
Regulation’49) 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 report50 on the review of  how  the 
IAS Regulation has been applied, the implementation of 
the  IAS  Regulation  is  already  starting  to  deliver  on  its 
objectives such as a coherent framework for addressing 
IAS at EU level and increased awareness of the problem 
of  IAS.  At  the  same  time,  the  above  report  identified 

47 COM/2020/629 final. 
48 A proposal for the Regulation on the making available on the Union 
market as well as export from the Union of certain commodities and 
products associated with deforestation and forest degradation. 
49  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. 
50  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 
October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 

An  infringement  case  is  ongoing  against  Slovenia  as  it 
failed to establish and implement a single action plan or 
a set of action plans fulfilling the requirements specified 
in Article 13 of the IAS Regulation by 13 July 2019 and to 
notify it/them to the Commission. 

2022 priority actions 

 

 

Improve the quality of conservation objectives and 
measures in all sites. 
Fully  implement  all  conservation  measures  in  all 
Natura  2000  sites,  paying  special  attention  to 
adapting  agricultural  practices  within  the  sites 
where  conservation  status  of  habitats  and/or 
species  are  experiencing  a  decline  due 
to 
agricultural activities. 

51  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,  EUR 
30689  EN,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, ISBN 978-92-76-37420-6, doi:10.2760/11150, JRC123170. 

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Slovenia  12 

 

 

 

 

land  degradation  neutrality 

Integrate  the  Commission’s  recommendations52  in 
the  Slovenian  CAP  strategic  plan  of  relevance  to 
environment  and  climate  action,  including  related 
EU objectives53.  
Commit  to  setting 
targets under the UNCCD. 
Take  measures  to  address  the  bad  and  poor 
conservation status of forest habitats to ensure the 
number  of  habitats  with  a  favourable  status 
increases.  
Establish  and  implement  a  single  action  plan  or  a 
set  of  action  plans  under  Article  13  of  the  IAS 
Regulation. 

Marine ecosystems 

descriptors55 and determined their level of adequacy in 
relation  to  the  Commission  GES  Decision56.  A  good  or 
very  good  score 
in  the  Commission  assessment 
indicates  that  the  national  determinations  of  GES  are 
well  aligned  with  the  requirements  of  the  Commission 
GES  Decision,  and  provide  qualitative  and  quantitative 
national  environmental  objectives  to  be  achieved  for 
their marine waters. 

Figure 14: Level of adequacy of GES determination by 
Slovenia (MAD region) with criteria set under the 
Commission GES Decision – article 9 (2018 reporting 
exercise)57 

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

reduce 

the 

The  Marine  Strategy  Framework  Directive  (MSFD)54 
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 6-year cycles. 

(Article  9),  and  to  provide  an 

The  MSFD  also  requires  Member  States  by  15  October 
2018  to  draw  up  a  set  of  GES  characteristics  for  each 
descriptor 
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. 

Commission 

2018 
assessed 
The 
determinations  of  GES  for  each  of  the  MSFD’s  11 

Slovenia’s 

52 European Commission, CAP strategic plans recommendations, SWD 
2020(394) – Slovenia. 
53  More  specifically,  recommendations  on:  (i) improving  biodiversity 
status;  (ii)  fostering  sustainable  forest  management;  (iii) encouraging 
farming  practices  aimed  at 
improving  nutrient  management; 
(iv) sustaining  current  trend  in  organic  production;  (v) increasing 
resilience  to  climate  change;  (vi)  mitigating  the  recent  trend  of 
increased GHG emissions from agriculture; and (vii) strengthening the 
efforts to reduce ammonia and methane emissions in line with the EU 
methane strategy. 
[1]  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
54 Marine Strategy Framework Directive 2008/56/EC 

Slovenia 
has 
Mediterranean: Adriatic Sea. 

one  marine 

sub-region,  MAD 

In this marine sub-region, 6 out of 11 determinations of 
GES  were  assessed  as  good  or  very  good.  The  national 
determination of GES by Slovenia is consistent for 6 out 
of 11 descriptors. 

The  MSFD  also  requires  Member  States  to  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  the  Member 
its  marine 
State  has  good  capabilities  to  assess 

55 Annex I of Directive 2008/56/EC. 
56  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. 
57  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 – Slovenia 

 
                                                                 
 
 
 
                                                                 
environment  in  accordance  with  the  requirements  set 
out in the Commission GES Decision. 

Figure 15: Level of adequacy of national assessment of 
Slovenia’s marine environment (MAD region) with 
criteria set under the Commission GES Decision – 
article 8 (2018 reporting exercise)58 

 

Slovenia  13 

It  should 

score;  and 

recommendations per Member State and region on 
the 2018 updated reports for Articles 8, 9 and 10 of 
the  MSFD. 
improve  national  GES 
determinations  for  five  descriptors  with  a  very 
should  carry  out 
poor/poor 
assessments  of  the  marine  environment  for  five 
descriptors with a very poor/poor score. 
Implement  the  Commission’s  recommendations 
regarding the preparation of the marine strategies, 
encompasing: 
(ii) the 
determination  of  good  environmental  status  and 
(iii) the establishment of environmental targets.   

assessment, 

(i) their 

it 

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  reporting  on  the  condition  of 
ecosystems. 

(iv) 

(ii)  biomass  production 

Within  the  AlpES  project  (Ecosystem  Services  in  the 
Alps,  2018),  eight  ecosystem  services  have  been 
mapped for the whole of Slovenia: (i) surface water for 
drinking; 
from  grassland, 
(iii) fuelwood; 
filtration  of  surface  water  by 
ecosystem  types;  (v) protection  against  avalanches, 
mudslides and rockfalls; (vi) CO2 sequestration by forest 
and  bogs;  (vii) outdoor  reacreation  activities;  and 
(viii) symbolic  alpine  plants  and  animals,  landscapes. 
The mapping is publicly available at the AlpES project’s 
website61.  

To  assess  progress 
in  ecosystem  mapping  and 
assessment, the Commission sends out a questionnaire 
twice  a  year  containing  27  implementation  questions. 
Slovenia  has  provided  updated 
information  and 
progress has been recorded  since  January 2016 (Figure 
16). This assessment is updated every 6 months. 

Seven descriptors out of 11 were scored as good or very 
good.  Slovenia’s  assessment  of  its  marine  environment 
is  aligned  with  the  requirements  set  out  under  the 
Commission GES Decision for 7 out of 11 descriptors. 

In  the  EIR  2019,  the  Commission  recommended  that 
Slovenia  should promptly report  on the updates to the 
different steps to comply with the MSFD. 

The 

States. 

Commission 

Furthermore, in March 2022, the European Commission 
published a  Communication  with recommendations for 
assessment 
Member 
highlighted  that  Member  States  need  to  step  up  their 
efforts to determine 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 

 

 

Ensure  regional  cooperation  with  Member  States 
sharing  the  same  marine  (sub)region  to  address 
major pressures. 
Implement  the  recommendations  made  by  the 
in  the  staff  working  document59 
Commission 
on 
accompanying 

Communication60 

the 

58 Idem. 
59  SWD(2022)1392. 
60  COM(2022)550.  

61 AlpES project’s mapping. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
                                                                 
                                                                 
Figure 16: ESMERALDA MAES Barometer, January 2016 
- March 202162 

Slovenia  14 

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

Figure 17: Ecosystem accounting Barometer, 
September 202163 

2022 priority action 

 

Slovenia  should  continue  to  support  the  mapping 
and  assessment  of  ecosystems  and  their  services, 
and  the  development  of  ecosystem  accounting.  It 
should  do  this  through  appropriate  indicators  for 
integrating  ecosystem  extent,  condition  and 
services  (including  some  monetary  values)  into 
national accounts. Slovenia should also continue to 
support  the  development  of  national  business  and 
biodiversity  platforms, 
including  natural-capital 
accounting  systems  to  monitor  and  value  the 
impact of business on biodiversity. 

62 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem  assessment:  summary  for  policymakers,  page  80,  May 
2021. 
63  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 an comprehensive statistical 
framework  that  is  based  on  five  core  accounts:  ecosystem  extent, 
condition, services and monetary ecosystem asset. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
                                                                 
 
 
Slovenia  15 

3. Zero Pollution 

below  the  EU  average  of  762  per  100 000  inhabitants. 
Similarly,  the  number  of  YLL  due  to  pollution  from  NO2 
dropped from 29 per 100 000 inhabitants in 2018 to 19 in 
2019 (EU-27 average is 99). 

The  emissions  of  key  air  pollutants  have  decreased 
significantly in Slovenia in recent years, while GDP growth 
has  continued  (see  Figure  18).  According  to  the  latest 
projections  as  submitted  under  Article  10(2)  of  the 
National  Emission  Reduction  Commitments  Directive 
(NECD)71, Slovenia projects that it will reach its emissions-
reduction  commitments  for  all  air  pollutants  covered  by 
the  Directive  for  the  period  2020-2029  and  for  most 
pollutants from 2030 onwards. However, the projections 
do  not  demonstrate  how  the  emissions-reduction 
commitments  for  PM2.5.  from  2030  onwards  will  be 
reached. The latest inventory data submitted by Slovenia, 
prior to review by the Commission, indicate that Slovenia 
complied with the emissions-reduction commitments for 
all pollutants in 2020. 

Slovenia  submitted 
programme on 10 October 2019. 

its  national  air-pollution  control 

Figure 18: Emission trends of main pollutants/ GDP in 
Slovenia, 2005-201972 

Clean air 

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%. 

The  EU  has  developed  a  comprehensive  suite  of  air- 
quality  legislation,  which  sets  health-based  air-quality 
standards64  and  emissions-reduction  commitments65  by 
Member State for a number of air pollutants. 

attributable 

Air  quality  in  Slovenia  still  continues  to  give  cause  for 
concern.  However,  the  trend  seems  to  be  more  positive 
compared with previous data. The latest available annual 
estimates  (for  2019)  by  the  European  Environment 
Agency66  point  to  Slovenia  suffering  about  1 400 
premature  deaths  each  year  (or  15 500  years  of  life  lost 
(YLL)) 
particulate  matter 
concentrations67;  90  premature  deaths  each  year  (1 000 
YLL)  attributable  to  excessive  ozone  concentrations68; 
and  40  premature  deaths  (400  YLL)  attributable  to 
excessive nitrogen dioxide concentrations69 70. Compared 
with the EU-27 average, Slovenia is doing worse for fine 
particulate  matter  and  ozone,  but  better  for  nitrogen 
dioxide concentrations. 

fine 

to 

The  number  of  YLL  due  to  air  pollution  from  PM2.5 
decreased  from  1 016  in  2018  to  744  in  2019,  which  is 

64 European Commission, 2016. Air Quality Standards. 
65European Commission, Reduction of National Emissions. 
66  European  Environment  Agency,  Air  Quality  in  Europe  –2021  Report. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106. 
67  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
refers  to  particles  with  a  diameter  of  10  micrometres  or  less.  PM2.5 
refers  to  particles  with  a  diameter  of  2.5  micrometres  or  less.  PM  is 
emitted from many human sources, including combustion. 
68 Low-level ozone is produced by photochemical action on pollution. 
69  NOx  is  emitted  during  fuel  combustion e.g. from  industrial  facilities 
and  the  road  transport  sector.  NOx  is  a  group  of  gases  comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
70  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. 

71 Directive 2016/2284/EU  
72 European Environment Agency. 

Environmental Implementation Review 2022 – Slovenia 

 
                                                                 
 
 
                                                                 
Figure 19: PM2.5 and NOx emissions by sector in 
Slovenia, 201973 

case  against  Slovenia  concerning  daily  exceedances  of 
PM10 values has been ongoing since 2012. 

Slovenia  16 

Slovenia  received  several  priority  actions  from  the 
Commission  in  the  2019  EIR  as  regards  clean  air.  More 
specifically, the Commission recommended that Slovenia: 
(i) take  action  to  reduce  the  main  emission  sources, 
its  national  air-pollution  control  programme 
under 
in  particulate 
(NAPCP);  (ii)  accelerate  the  reduction 
matter  emissions  and  concentrations;  (iii) upgrade  and 
improve 
the  air-quality  monitoring  network;  and 
(iv) ensure  the  timely  reporting  of  adequate  data. 
Slovenia has been taking some action in this respect, e.g. 
planning  for  clean-energy  and  transport  investments 
under  the  national  recovery  and  resilience  plans,  and 
upgrading  the  monitoring  network,  e.g.  with  funding  of 
approximately  EUR  39  million  under  the  2014-2020 
cohesion  policy  (this  was  used  for  a  monitoring  project: 
‘Sinica  -  Upgrading  the  Air-Pollution  Monitoring  System, 
Identifying Causes of Excessive Burden, and Analysing the 
Effects of Improvement Measures’). 

2022 priority actions 

  Take,  in  the  context  of  the  NAPCP,  action  towards 
reducing emissions from the main sources mentioned 
above. 

  Ensure  full  compliance  with  EU  air-quality  standards 
and maintain downward trends in emissions from air 
pollutants.  This  will  help  the  country  reduce  adverse 
air-pollution impacts on health and the economy and 
abide by WHO guideline values in the future. 

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 Directive75 (IED). The Commission 

In 2020, no exceedances above the EU limit values set by 
the  Ambient  Air  Quality  Directive  were  registered. 
However,  for  several  air-quality  zones,  the  target  values 
for ozone concentration have not been met74. 

Persistent  breaches  of  air-quality  requirements,  which 
have  severe  negative  effects  on  health  and  the 
environment,  are  being  followed  up  by  the  European 
Commission through infringement procedures (mainly for 
PM10  and  NO2  exceedances)  covering  all  Member  States 
concerned,  including  Slovenia  for  exceedances  of  PM10 
limit  values.  The  aim  is  for  appropriate  measures  to  be  
put  in  place  to  swiftly  bring  all  air-quality  zones  into 
compliance  with  the  EU  requirements.  An  infringement 

73 Idem. 
74 European Environment Agency, Eionet Central Data Repository. 

75  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 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
 
 
                                                                 
 
 
                                                                 
 
Slovenia  17 

Figure 20: Number of IED industrial installations per 
sector in Slovenia, 201878 

tabled a proposal  in April  202276. 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  IED 
below  is  based  on  data  reported  to  the  EU  Registry 
(2018)77. 

In  Slovenia,  around  260 
installations  are 
required  to  have  a  permit  based  on  the  IED.  The 
distribution  of  installations  is  shown  in  the  Figure  20 
below. 

industrial 

The  industrial  sectors  in  Slovenia  with  the  most  IED 
installations  in  2018  were:  (i)  metals  production  (24%), 
(ii) waste  management  (17%),  (iii)  chemicals  production 
(15%),  and  (iv) intensive  rearing  of  poultry  and  pigs 
(14%). 

industrial  sectors 

identified  as  contributing  the 
The 
largest  burden  to  the  environment  for  emissions  to  air 
were: 

 

 

the iron and steel production for cadmium (Cd), 
mercury (Hg), nickel (Ni), lead (Pb), zinc (Zn) and 
dioxins; 

the  power  generation 
(As), 
chromium  (Cr),  Copper  (Cu),  nitrogen  oxides 
(NOx) and sulphur oxides (SOx); 

for  arsenic 

  manure management for ammonia (NH3); 

 

coating  applications  for  non-methane  volatile 
organic compounds (NMVOCs); and 

  mineral activities for particule matter (PM2.5). 

industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
76  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). 
77  https://industry.eea.europa.eu/ 

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

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
                                                                                                        
 
 
 
                                                                 
Figure 21: Emissions to air from IED sectors and rest of 
national total air emissions in Slovenia, 201879 

Slovenia  18 

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 
that  permits  are 
to  ensure 
public  and  NGOs, 
appropriately  granted  and  that  the  conditions  of  these 
permits  are  complied  with.  As  part  of  environmental 
inspection, competent authorities undertake site visits to 
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,  Slovenia  undertook 
130 site visits. The largest number of visits were at plants 
for  the  production  of  metals  (31%  of  visits),  chemicals 
production (15% of visits), and waste management (15% 
of visits). 

Figure 23: Number of inspections in IED installations in 
Slovenia in 201881 

The  environmental  burdens  for  industrial  emissions  to 
water  mainly  result  from:  (i)  the  production  of  pulp, 
paper  and  wood  for  heavy  metals  and  (ii) total  organic 
carbon.  The  breakdown,  based  on  E-PRTR  data, 
is 
presented in Figure 22.  

Figure 22: Relative releases to water from industry in 
Slovenia, 201880 

The  development  of  best-available  technique  (BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED82. Since the last 
EIR report, the Commission adopted BAT conclusions for 
Slovenia 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. 

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

79  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 
80European 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). 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
 
 
 
                                                                 
 
 
 
 
                                                                 
Slovenia  19 

Figure 24: Number of Seveso establishments in Slovenia 
(2011, 2014 and 2018)86  

Many  Seveso  establishments  are  required  to  draw  up 
external  emergency  plans 
(EEPs).  These  EEPs  are 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  actions  to  protect  the 
environment  and  the  population  should  a  major 
industrial accident occur at them. According to Slovenia, 
an EEP is required for 24 UTEs. In 2018,  24 UTEs had an 
EEP, and 23 of these EEPs had been tested over the last 3 
years.  The  summary  of  EEPS  in  Slovenia  is  shown  in 
Figure  25.  The  establishment  of  EEPs  is  essential  to 
enable  establishments 
to  properly  prepare  and 
implement  effectively the actions needed to protect the 
environment  and  the  population  should  a  major 
industrial accident ever happen. 

Figure 25: Situation regarding EEP in Slovenia(2018)87 

In  2019,  Slovenia  received  priority  actions  to  (i) review 
permits  to  comply  with  newly  adopted  BAT  conclusions; 
and (ii) to strengthen control and enforcement to ensure 
compliance  with  BAT  conclusions.  These  actions  have 
been  followed  up  by  the  Commission  through  the 
reporting by Slovenia to the EU Registry. The Commission 
is  currently  verifying  with  Slovenia 
reported 
information  about 
for  each 
installation in the scope of the IED. 

the 
the  permits  granted 

There  is  an  ongoing  infringement  case  against  Slovenia 
concerning  the  transposition  of  the  requirements  of  IED 
Directive into its legislation. 

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)83. 

The below overview of industrial plants regulated by the 
Seveso-III Directive (‘Seveso establishments’) is based on 
data  reported  to  the  eSPIRS  database  (2018)84  and  the 
Slovenia  report  on  the  implementation  of  the  Seveso-III 
Directive for the period 2015-201885. 

In  Slovenia,  of  the  60  Seveso  establishments,  36  are 
categorised as lower-tier establishments (LTEs) and 24 as 
upper-tier  establishments  (UTEs),  based  on  the  quantity 
of hazardous substances likely to be present in them. The 
UTEs  are  subject  to  more  stringent  requirements.  The 
change  in  the  number  of  Seveso  establishments 
is 
presented in Figure 24. 

The  following  types  of  information  are  permenantly 
available  for  80%  of  the  Seveso  establishments 
in 
Slovenia:  (i)  information  to  the  public  referred  to  in 

83  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances. 
84 European Environment Agency, European Industrial Emissions Portal. 
85 As provided for by Article 21(2) of the Seveso-III Directive. 

86 European Commission, Assessment and summary of Member States’ 
implementation  reports  for 
Implementing  Decision  2014/896/EU 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 
87 Idem. 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
                                                                 
 
 
 
 
                                                                 
Annex V of the Seveso-III Directive especially about  how 
the  public  concerned  will  be  warned  if  there  is  a  major 
accident; (ii) information about appropriate behaviour in 
the  event  of  a  major  accident;  and  (iii) information 
containing the date of the last site visit. This provision on 
knowledge  is  an  important  provision  of  the  Seveso-III 
Directive, as knowledge of this information by the public 
may  reduce  the  consequences  of  a  major  industrial 
accident. 

The  share  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available  to  the  public  in  recent  years  are  presented  in 
Figure 26. 

Figure 26: Share of UTE for which information on safety 
measures and requisite behaviours was actively made 
available to the public in Slovenia (2011, 2014 and 
2018)88 

Slovenia  has  had  some  issues  with  the  transposition  of 
the Seveso-III Directive. 

2022 priority action 

 

Slovenia should strengthen control and enforcement 
to  ensure  compliance  with  Seveso-III  Directive 
provisions, especially on information to the public. 

Noise 

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.  Its  main 
instruments  in  this  respect  are  noise  mapping  and 
planning.  A  key  target  under  the  2030  zero  pollution 
action  plan  is  to  reduce  by  30%  the  share  of  people 
disturbed by transport noise. 

Excessive  noise  from  aircrafts,  railways  and  roads  is  one 
of  the  main  causes  of  environmental-health‐related 
issues  in  the  EU.  It  can  cause  ischaemic  heart  disease, 

88 Idem. 

Slovenia  20 

interrupted  sleep,  cognitive 

impairment  and 

stroke, 
stress89. 

limited  set  of  data90, 
In  Slovenia,  based  on  a 
environmental  noise  is  estimated  to  cause  at  least  30 
premature  deaths  and  130  cases  of  ischaemic  heart 
disease  annually91.  Moreover,  some  15 000  people  in 
Slovenia  suffer  from  disturbed  sleep.  In  Slovenia,  the 
proportion  of  people  exposed  to  noise  reduced  by  9% 
between 2012 and 2017. On the basis of the latest full set 
of 
of 
agglomerations, roads and railways is complete. 

noise  mapping 

information 

analysed, 

Water quality and management 

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

Water Framework Directive 

is 

(WFD)92 

the 
The  Water  Framework  Directive 
cornerstone of the EU water policy in the 21st century93. 
The  WFD  and  other  water-related  legislation94  set  the 
framework 
integrated  water 
sustainable  and 
management, which aims at a high level of protection of 
water resources, prevention of further deterioration, and 
restoration to good status. 

for 

under 

89 WHO 2018, Environmental Noise Guidelines for the European Region 
90  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
91  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 
Environmental Noise Directive 
the 
2021: Methodology  for  estimating  missing  data, ETC/ATNI  Report  No 
2021/06, European Topic Centre on  Air Pollution, Transport, Noise and 
Industrial  Pollution;  and (iii) the methodology 
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.  
92 The Water Framework Directive (2000/60/EC). 
93 The EU Water Policy. 
94  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 
(2010/75/EU),  and  the  new 
Regulation on minimum requirements for water reuse (2020/741). 

Industrial  Emissions  Directive 

for  health 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
                                                                 
                                                                 
Slovenia  21 

By  March  2022,  Member  States  were  meant  to  have 
reported  on  the  third  round  of  river  basin  management 
plans  (RBMPs).  Under  the  WFD,  Member  States  must 
draw  up  management  plans  for  all  river  basins  on  their 
territory. The Commission will assess the reported status 
of river basins and progress made in these river basins. It 
will check how the findings identified in its assessment of 
the  second  round  of  RBMPs95  have  been  addressed. 
Slovenia has yet to report on the third round of RBMPs. 

Figure  27  below  illustrates  the proportion  of  surface 
water  bodies  in  Slovenia  and  other  European  countries 
that failed to achieve good ecological status. 

Figure 27. Proportion of surface water bodies (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District100 

The  Commission  published  in  December  2021  the  6th 
Implementation  Report,  which  assesses  implementation 
of  the  WFD  and  the  Floods  Directives96.  This  report 
includes an interim assessment of: (i) the implementation 
of the programmes of measures; and (ii) the new priority 
substances.  The  assessment  report  for  Slovenia97,  which 
forms  part  of  the  6th  Implementation  Report,  showed 
that  78  measures  (71  basic  and  7  supplementary)  were 
adopted  in  the  Programme  of  Measures  (PoM)  for  the 
second management cycle. The measures in the PoM are 
not  related  to  key  type  measures  and  do  not  give  any 
structured  information  about  significant  pressures  or 
chemical  substances  that  could  prevent  environmental 
objectives  from  being  achieved.  The  targeted  pressures 
are  described  only  in  a  general  sense.  It  was  also  noted 
that  in  2018  and  2021,  the  environmental  objective  had 
not  been  met  for  addressing  any  of  the  pressures 
originating  from  chemical  substances  and  there  are  no 
specific  measures 
remediation  of 
(i) 
contaminated sites; (ii) control pollution originating from 
forestry; (iii) implement natural water retention; and (iv) 
adapt to climate change. They are only implicitly included 
in various measures. 

cover 

to: 

Based  on  the  reporting  in  the  second  round  of  RBMPs 
and  the  data  published  in  202098, 58.4% of  all  surface 
water  bodies  in  Slovenia99  have reached  good  ecological 
status  (with  only  3.2%  of  surface  water  bodies  having 
unknown  status),  while only  0.6% have  reached  good 
chemical  status 
(with  only 0.6%  having  unknown 
status). For  groundwater,  14.3%  of  groundwater  bodies 
failed to achieve good chemical status, while 100% are in 
good quantitative status. 

95  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. 
96 See the 6th Implementation Report of the WFD and FD. 
97  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Slovenia, 2022. 
98 European Commission, WISE Freshwater. 
99  Rivers,  lakes,  transitional  waters,  coastal  waters,  and  territorial 
waters. 

Figure 28 presents the percentage of surface water bodies 
in Slovenia and other European countries failing to achieve 
good  chemical  status. For  Slovenia,  the  percentage  is 
98.7%, 
includes  water  bodies  failing  due  to 
(uPBTs  –
substances  behaving  as  ubiquitous  PBTs 
persistent,  bio-accumulative  and  toxic).  Without  uPBTs, 
99% of surface water bodies achieve good chemical status. 

if  one 

Figure 28. Percentage of surface water bodies not 
achieving good chemical status101 

100 European Environment Agency, 2021. 
101 European Environment Agency, December 2019. 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
                                                                 
 
 
 
 
                                                                 
Under the IED framework, it should be stressed that over 
the  last  decade,  Slovenia  showed  a  significant  increase 
(61.1%) in releases of heavy metals like Cd, Hg, Ni, Pb and 
a decrease in total organic carbon (5.8%) to water102. 

Figure 30. Water exploitation index plus (WEI+) inside 
EU, 2017106 

Slovenia  22 

from 

The  total  water  abstracted  annually  (corresponding  to 
and 
surface 
2019  baseline) 
groundwater 
sources in Slovenia 
(EEA,  2022).  The 
is 943.22 hm3 
percentage  for  water  abstraction  per  sector  is:  (i)  0.37% 
for  agriculture,  (ii) 18.02%  for  public  water  supply, 
(iii) 77.08% 
for 
manufacturing,  and  (v) 0.11%  for  mining  and  quarrying 
(Figure  29).  Slovenia  uses  a  register  to  monitor  water 
abstractions. Small abstractions do not require permits in 
Slovenia, but all are registered. 

for  electricity 

(iv) 4.42% 

cooling, 

Figure 29: Water abstraction per sector in Slovenia103 

In  Slovenia,  the  water-exploitation  index  plus  (WEI+)104 
was  0.7%  in  2017,  which  is  less  than  the  20%  that  is 
generally considered as an indication of water scarcity105. 
Slovenia is ranked 20th (with 1st indicating a country that 
has  a  high  WEI+  and  therefore  a  country  with  water-
scarcity problems )in the EU on the WEI+. 

102 European Environment Agency, June 2021. 
103  European  Environment  Agency, Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
104 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. 
105 By May 2022, the EEA will develop a seasonal WEI+ at river-basin and 
NUTS2 level, which will provide a more complete picture of water stress 
and water scarcity for each Member State. 

It  is  worth  mentioning  that  as  a  positive  step,  in  its 
recovery  and  resilience  plan107,  Slovenia  invested  over 
EUR  50  million  to  support  improved  drinking  water 
supply and water-saving projects. 

Furthermore,  in  what  can  be  considered  an  example  of 
good practice, Slovenia has set up satellite observation of 
watercourses. 

Floods Directive 

As  mentioned  earlier,  the  Commission  published 
in 
December  2021  the  6th  Implementation  Report,  which 
assesses  the  implementation  of  both  the  WFD  and  the 
Floods Directive. The report includes a review and update 
of the preliminary flood-risk assessments drawn up by all 
Member States during the second cycle (2016-2021). 

Within  the  6th  Implementation  Report,  the  assessment 
report108  showed  that  the  approach  that  Slovenia  took 
for  designating  new  areas  of  potential  significant  flood 
risk (APSFRs) and for  making  changes to  existing APSFRs 
(from  the  first  cycle)  is  straightforward  and  included  a 
is  made  by 
public  consultation.  The  final  decision 
specialist  and  local  staff  of  the  water  management 
authorities. In addition, the following was noted as good 
practice:  in  areas  where  it  is  estimated  that  climate 
change will affect the projected extent of high waters in a 
way that will result in them being reduced in the future, 
Slovenia  has  not  reduced  the  hazard  potential  and 
therefore  has  taken  a  precautionary  approach.  Slovenia 
should  consider  including  long-term  trends,  other  than 
climate change, in their flood-risk assessments. 

Slovenia has not yet adopted or reported on the second 
round  of  flood-risk  management  plans  under  the Floods 
Directive. The European Commission will assess progress 
made  since 
flood-risk 
management plans and publish a report on this, as it did 
in 2019. 

the  adoption  of 

first 

the 

106 European Environment Agency, Water exploitation Index Plus, 2022. 
107 European Commission, Slovenia’s recovery and resilience plan. 
108  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 : Slovenia, 2022 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
 
                                                                 
 
 
                                                                 
Drinking Water Directive 

On  the  Drinking  Water  Directive109,  no  new  assessment 
of the quality of drinking water has been available since 
the  2019  EIR.  The  quality  of  drinking  water  in  Slovenia 
has not been indicated as an area of concern. 

The  recast  Directive110  entered  into  force  on  12  January 
2021, and Member States have until 12 January 2023 to 
transpose it into their national legal system. Slovenia will 
have to comply with these revised quality standards. 

Bathing Water Directive 

On the Bathing Water Directive,  Figure 32 shows that  in 
2020,  out  of  the  361  Slovenian  bathing  waters,  85.1% 
were  of  excellent  quality111.  Detailed  information  on 
Slovenian  bathing  waters  is  available  from  a  national 
portal112  and  via  an  interactive  map  viewer  of  the 
European Environment Agency. 

Figure 31: Bathing water quality in Europe in the 2020 
season113 

Figure 32: Slovenia, bathing water quality 2017-2020114 

Slovenia  23 

Nitrates Directive 

According to the last report on the implementation of the 
Nitrates  Directive  for  2016-2019,115  there  is  a  mixed 
picture on groundwater quality in Slovenia and trends in 
this respect.  

On  one  hand,  the  percentage  of  monotoring  stations 
above 50 mg of nitrate per litre (l) decreased from 11.6% 
(2012-2015)  to  9%,  which  is  an  improvement.  However, 
the percentage of monitoring stations in the range of 40-
50 mg/l increased from 4.5% (2012-2015) to 6.2% (2016-
2019),  which 
is  a  deterioration.  However,  after 
considering  these  two  ranges  together  (i.e.  the  range 
above  40  mg  of  nitrate  per  l),  there  was  a  slight 
improvement  in  2016-2019,  with  15.2%  of  monitoring 
stations  exceeding  40  mg/l  (2016-2019)  versus  16.1%  of 
monitoring  stations  (2012-2015).  There 
is  also  an 
improvement in the percentage of monitoring stations in 
the range below 25 mg/l, from 72% (2012-2015) to 73.9% 
(2016-2019). 

in 
The  situation  concerning  nitrate  concentrations 
surface  water 
eutrophication 
increasing from 4.2% (2012-2015) to 19.4% (2016-2019). 

deteriorated  with 

Slovenia has an average livestock density and a surplus of 
nitrogen  and  phosphorus  slightly  below  the  EU  average. 
There 
is  a  well-developed  network  of  monitoring 
stations.  There  are  numerous  hotspots,  with  a  nitrate 
concentration  above  50  mg/l.  and  numerous  surface 

109 OJ L 330, 5.12.1998, p. 32–54. 
110 OJ L 435, 23.12.2020, p. 1–62. 
111 EEA, State of bathing water, Country Report –Slovenia, 2021. 
112 ARSO, An interactive map of all Slovenia’s bathing water sites.  
113 European Environment Agency, Bathing Water Quality in 2020, 2022. 
114  European  Environment  Agency,  European  Bathing  Water  Quality  in 
2017, 2018, 2019, 2020. 

115  COM/2021/1000  final  and  SWD/2021/1001  final,  Slovenia  Fiche  - 
PART 33/38.  

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Slovenia  24 

waters  are  eutrophic.  A  revised  action  programme  was 
published in 2017116. 

  Make 

The Commission recommends that Slovenia continues to 
follow up on these hotspots. 

 

to 

the 

efforts 

coordinated 
improve 
implementation  of  water,  marine  and  nature 
policies. 
Implement 
for  all 
agglomerations  under  the  Directive,  by  building  up 
the necessary infrastructure. 

the  UWWTD 

completely 

Urban Waste Water Treatment Directive 

Slovenia  has,  over  the  years,  encountered  difficulties  in 
meeting  its  obligations  under  the  Urban  Waste  Water 
Treatment  Directive  (UWWTD).  Overall,  in  Slovenia,  the 
compliance  rate  is  61%,  which  is  lower  than  the  EU 
average in 2018. 0.7% of urban wastewater in Slovenia is 
not collected and/or does not meet the requirements for 
biological treatment117. 

Figure 33: The 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’), 2018118 

In  recent  years,  there  have  been 
improvements  in 
compliance  with  the  UWWTD,  for  which  the  use  of  EU 
funding  has  been  fundamental.  But  despite  these 
improvements,  the  incomplete  implementation  of  the 
UWWTD has led to several rulings of the Court of Justice 
of  the  European  Union  against  Slovenia.  In  2020,  the 
Commission has decided to refer Slovenia to the Court of 
Justice because it had not applied the UWWTD properly. 

2022 priority actions 

  Assess new physical modifications of water bodies in 
line  with  Article  4(7)  of  the  WFD. 
In  these 
assessments,  Slovenia  has  to  consider  alternative 
options and adequate mitigation measures. 
Continue  to  follow  up  on  the  nitrates  groundwater 
hotspots  and  address  the  increasing  eutrophication 
of surface waters. 

 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used in way that minimises any significant adverse effects 
on human health and the environment. In October 2020, 
its  chemicals  strategy  for 
the  Commission published 
sustainability  –  'Towards  a  Toxic-Free  Environment'119, 
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. 

legislation120 provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the internal market.  

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  States’  reports  on  the  implementation  and 
enforcement  of  these  Regulations121,  in  line  with  Article 
117(1)  of  the  REACH  Regulation  and  Article  46(2)  of  the 
CLP  Regulation.  According  to  the  latest  available  data, 
national enforcement structures have not changed much 
in recent years. However, it is apparent from this report 
that 
the 
implementation  of  the  REACH  and  CLP  Regulations,  and 
notably 
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 
non-compliant 
effective 
products/companies; 
non-compliant 
products being put on the EU market. In August 2021, the 
Commission  published  a  measurable  assessment  of  the 
enforcement122  of  the  two  main  EU  Regulations  on 
chemicals (the REACH Regulation and the CLP Regulation) 

still  many  disparities 

in  the  area  of 

detecting 

(ii) more 

there 

and 

are 

in 

in 

116  COM/2021/1000  final  and  SWD/2021/1001  final,  Slovenia  Fiche  - 
PART 33/38. 
117  WISE,  Country  profiles  on  urban  waste  water  treatment,  Slovenia 
fiche. 
118 European Commission, WISE Freshwater, 2021. 

COM(2020) 667 final 

119 
120 REACH: OJ L 396, 30.12.2006, p.1. - CLP: OJ L 252, 31.12.2006, p.1 
121 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu) 
122  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators. 

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Slovenia  25 

Figure 34: Percentage % of non-compliance cases out of 
the total number of REACH and CLP inspections during 
2019 per Member State and compared to the EU 
average127 

using  a  set  of 
enforcement.   

indicators  on  different  aspects  of 

Responsibility  for  checking  compliance  with  REACH  in 
Slovenia lies with the following authorities123:  

  Chemicals Inspection (part of the Chemicals Office of 

the Republic of Slovenia);  
the Health Inspectorate; 
the Labour Inspectorate. 

 
 

Slovenia  has  developed  and  fully  implemented  both  its 
REACH and CLP enforcement strategies124. The strategies  
include  the  annual  planning  of  enforcement  activities. 
They are also subject to an annual evaluation and review. 

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. 

to 

and 

REACH 

allocated 

In  Slovenia  only  four  full-time  equivalent  workers  (FTEs) 
are 
CLP 
enforcement125. However,  more  than  3 500  REACH  and 
CLP inspections were carried out  in the reporting period 
(2019).  Most  of  the  inspections  were  reactive/non-routine 
(i.e. investigations in response to complaints, accidents and 
referrals)  compared  with  proactive  inspections.  The  high 
percentage  of  non-compliance  cases  out  of  the  total 
number  of  inspections  should  be  underlined126  (Figure 
34). 

2022 priority action 

 

Slovenia should upgrade its administrative capacities 
in implementation and enforcement towards a policy 
of zero tolerance to instances of non-compliance. 

123 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 71. 
124 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76. 
125 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 75. 
126  Final  report_REACH-CLP  MS  reporting_2020.pdf  (europa.eu),  p.  87-
88. 

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

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4. Climate Action 

Slovenia  26 

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  its  greenhouse  gas  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  that  there  is  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 greenhouse 
gas emissions and make the transition to climate neutral 
and  sustainable  economy,  as  well  as  addressing 
unavoidable  consequences  of  climate  change.  Climate 
legislation  has  been  adopted  to  incentivize  emissions 
reductions  from  power  generation,  industry,  transport, 
the maritime sector and fluorinated gases (F-gases) used 
in  products.  In  road  transport,  current  EU  legislation 
requires the greenhouse gas  intensity of  vehicle fuels to 
be cut by 6% by 2020 compared to 2010128 and sets GHG 
emission standards for different vehicle categories to be 
respected129. Thanks to the current 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  greenhouse  gases  from  LULUCF  have  been 
included  in  the  EU  emission  reduction  efforts.  The  EU 
adaptation  policy  is  an  integral  part  of  the  European 
Green Deal. 
Starting  in  2021,  Member  States  are  required  to  report 
on  their  national  adaptation  policies.130  The  European 
Climate  Law  recognises  adaptation  as  a  key  component 
of  the  long-term  global  response  to  climate  change.  It 
requires Member States and the Union to enhance their 
adaptation  action  by  introducing  a  requirement  for  the 
implementation  of  national  strategies  and  regular 
the  overall  EU 
progress  assessments  as  part  of 
governance  on  climate  action.  In  February  2021,  the 
updated EU adaptation strategy 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 

Slovenia  has  an  integrated  national  energy  and  climate 
plan  (NECP)  for  2021-2030,  which  is  consistent  with  the 

128  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. 
129 Directive 98/70/EC 
130 Article 29 of Regulation (EU) 2018/1999. 

national  long-term  strategy131.  Slovenia  is  required  to 
reach  climate  neutrality  in  line  with  the  EU  general 
target. The national objective is to reduce GHG emissions 
by 36% below 2005 levels. 

In  its  national  recovery  and  resilience  plan,  Slovenia 
allocates  42%  of  the  funds  to  climate  objectives  and 
outlines  crucial  reforms  and  investments  to  further  the 
transition  to  a  more  sustainable, 
low-carbon,  and 
climate-resilient  economy. Investments  are  allocated  to 
clean  power,  building 
renovation  and  sustainable 
transport (more details in Chapter 5). 

Adaptation  priorities  were  laid  down  in  the  strategic 
framework  for  climate  change  adaptation,  adopted  by 
the  government  in  December  2016.  It  provides  a  long-
term vision, purpose and strategic guidelines for stepping 
up adaptation-related activities. 

Between 1990 and 2020, economy-wide greenhouse-gas 
emissions  decreased  by  15%,  less  than  the  EU  average 
(24%). 

Figure 35: Total greenhouse gas emissions (incl. 
international aviation) in Slovenia, 1990-2020 

Effort sharing target  

For emissions not covered by the EU’s  emissions trading 
scheme  (ETS),  Member  States  have  binding  national 
targets under the Effort Sharing legislation  132 . Under EU 
legislation,  Slovenia  has  a  target  to  limit  the  increase  of 
GHG  emissions  in  the  non-ETS  sectors  (buildings,  road 
and domestic maritime transport, agriculture, waste and 
small industries) to +4% by 2020 and reduce emissions by 

131  EU  countries’  long-term  strategies  to  meet  their  Paris 
Agreement commitments and the energy union objectives. 
132 Regulation (EU) 2018/842 

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Slovenia  27 

15%  by  2030,  compared  to  2005  levels.  Slovenia  is 
estimated  to  largely  overachieve  its  current  national 
2020 and 2030 targets.  

Road  transport  in  2019  in  Slovenia  represented  32%  of 
the  total  GHG  emissions.  Emissions  in  road  transport 
have increased by 29% compared to 2005. 

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

Emissions  from  agriculture  have  remained  at  the  same 
level as in 2005. 

Figure 38: Greenhouse gas emissions by sector in 
Slovenia133 – historical emissions 1990-2020, projections 
2021-2030134 

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

Key sectoral developments 

On  road  transport,  the  GHG  intensity  of  vehicle  fuels  in 
Slovenia  decreased  by  2.9%  from  2010  to  2019.  The 
country  needs  to  act  swiftly  to  meet  the  current 
reduction  target  of  a  6%  decrease  in  GHG  intensity  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; 
the  development  and 
deployment  of  renewable  fuels  of  non-biological  origin; 
and  (iv) reducing  upstream  emissions  before  refining 
processes. 

(iii) incentivising 

Emissions  from  buildings  have  been  on  a  decreasing 
trend.  The  national  energy  and  climate  plan  includes 
comprehensive  information  on  buildings,  including  a 
target  to  reduce  final  energy  consumption  by  20%  by 
2030 compared to 2005. 

In  the  land-use,  land-use-change  and  forestry  (LULUCF) 
sector,  Slovenia projects net  removals of  CO2 equivalent 
from land use and forestry by 2030. Reported quantities 
under  the  Kyoto  Protocol  for  the  LULUCF  sector  in 
Slovenia show net emissions of, on average, 0.8 Mt CO2-
eq in 2013 to 2019. Therefore, Slovenia represents -0.2% 
of  the  EU-27’s  annual  average  sink  of  344.9  Mt  CO2-eq. 
Using  a 
scheme,  carbon 
accounting for the same period shows net ‘debits’135 of, 

separate  measurement 

133  The  sectors  in  the  figure  correspond  to  the  following  IPCC  sectors: 
Energy supply: 1A1, 1B and 1C. Energy use in 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. 
134 European Environmental Agency, Total GHG trends and projections. 
135  the  no-debit  commitment  (i.e.  emissions  do  not 
exceed  removals)  under  the  LULUCF.  Regulation  (EU) 
2018/841 of the European Parliament and of the Council of 
30 May 2018 on the inclusion of greenhouse gas emissions 
and removals from land use, land use change and forestry 
in  the  2030  climate  and  and  energy  framework,  and 

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
 
 
 
 
                                                                 
 
Slovenia  28 

2022 priority actions 

  Support  energy  efficiency,  especially  through  the 

renovation of buildings. 

  Support sustainable transport. 
 
  Ensure the sustainability of biomass. 

Increase its uptake of renewable energy. 

on average, 3.9 Mt CO2-eq, which represents -3.4% of the 
EU-27 accounted sink  of 115.0 Mt  CO2-eq. Reported net 
removals for 2013 decrease markedly to net emissions in 
2014  that  remain  on  that  level  until  2018  and  slightly 
decrease  in  2019.  Accounted  quantities  show  the  same 
pattern  with  net  ‘credits’  (i.e.  the  equivalent  of  carbon 
removals) for 2013 and net debits thereafter. Slovenia is 
one  of  three  EU  Member  States  with  average  net 
emissions  and  one  of  six  EU  Member  States  that  show 
net emissions for at least one year. In addition, Slovenia 
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 Slovenia136 

Use of revenues from the auctioning of EU ETS 
allowances 

The  total  revenues  from  the  auctioning  of  emission 
allowances  in  Slovenia  under  the  EU  ETS  in  2011-2021 
were  nearly  EUR  412  million.  In  Slovenia,  100%  of  the 
auctioning  revenues  are  used  for  climate  and  energy 
projects. 

amending  Regulation  (EU)  No  525/2013  and  Decision  No 
529/2013/EU. 

136  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’.   

 Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
 
 
 
                                                                                                        
 
 
 
 
Slovenia  29 

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  gap 
between countries.  
Post-2020,  environmental  measures  will  also  be 
supported by the EU’s COVID-19 Recovery Fund (via 
the  RRF)  and  the  ‘do  no  significant  harm’  (DNSH) 
principle  which  runs  across  the  EU  budget.  The 
renewed  commitments  made  at  COP26  (Glasgow, 
Oct-Nov  2021)  and  the  Biodiversity  Convention 
(April-May  2022)137  will  also  be  reflected  in  the  EU 
budget. 

Overall environmental investment gaps (EU-27) 

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)138, with a further EUR 
130  billion  a  year  to  deliver  the  EU's  core 
environmental  objectives139. 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  year140.  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).  

core 
A  preliminary  update  of 
environmental 
in 
investment  gap 
Table 1141.  Almost  40%  of  the  environmental-

EU’s 
is  provided 

the 

investment  needs  relate  to  dealing  with  pollution, 
which  accounts  for  nearly  two  thirds  of  the  total 
gap  if  combined  with  water  management.  The 
investment  gap in the circular economy and waste 
is  estimated  to  be  between  EUR  13-28  billion  a 
year,  depending  on  the 
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 needs, by 
environmental objective, 2021-2030 (per year)142 

Environmental 
objective 

Pollution 
prevention & 
control 

Water 
management & 
industries 

Circular economy & 
waste 

Biodiversity & 
ecosystems 143 

R & D & I and other 

Total 

Estimated investment gap (EU27, 
p.a.)  

 EUR billion 

 42.8 

 % 

 39% 

 26.6 

 24% 

 13.0 

 21.5 

 6.2 

 110.1 

 12% 

 20% 

 6% 

 100% 

Environmental-investment needs in Slovenia 

There  is  a  clear  shift  of  investment  priorities  in 
Slovenia  to  support  climate,  energy  and  transport 
policies as can be seen in the national recovery and 
resilience  plan.  Over  EUR  750  million  will  be  spent 
under  the  Recovery  and  Resilience  Fund  on 

137  The  Convention  on  Biological  Diversity  (cbd.int);Post-2020 
Global Biodiversity Framework | IUCN. 
138  SWD(2021)621,  accompanying  proposal  COM(2021)557  to 
amend the REDII Directive (EU) 2018/2001. 
139 SWD(2020) 98 final/2. 
140 SWD(2018)292. 
141  With decreases due to Brexit and some reconciliation among 
the  objectives.  Source:  DG  ENV  ‘Study  supporting  EU  green 
investment  needs  analysis’  (ongoing,  2021-2023)  and  DG  ENV 
internal analysis ‘Environmental investment needs and financing 
in the EU’s green transition’ July 2020. 

142  European  Commission,  DG  Environment,  ‘Study  supporting 
EU  green  investment  needs  analysis’  (ongoing,  2021-2023)  and 
DG  Environment  internal  analysis  ‘Environmental  Investment 
needs and financing in the EU’s green transition’,  July 2020. 
143 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 – Slovenia 

 
                                                                 
 
 
                                                                 
investments  in  a  wide  range  of  economic  sectors 
such as energy efficiency and energy renovation of 
housing, clean transport, water management, flood 
protection and the circular economy. 

Pollution prevention & control 

The EU’s first Clean-Air Outlook144 under the clean- 
air  programme  estimated  that  the  total  air-
pollution-control  costs  for  Slovenia  to  reach  the 
requirements145  by 
NECD’s  emission-reduction 
2030  amount  to  EUR  384  million  per  year.  This 
includes  EUR  239  million  for  capital  investment 
(assuming the 2030 climate and energy targets are 
achieved). 

to 

that  correspond 

The  second  EU  Clean-Air  Outlook146 suggests  that 
the  EU would  largely  achieve  the  reductions  of  air 
pollutant  emissions 
the 
obligations  under  the  NEC  Directive  for  2030  if:  (i) 
is 
all  relevant  legislation  adopted  up  to  2018 
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, 
excluding Slovenia. 

Water management  

According  to  the  OECD  study  ‘Financing  Water 
Supply  Sanitation  and  Flood  Protection  (2020)’147,  
Slovenia  has  relatively  abundant  water  resources 
and  low  abstraction  rates.  It  performs  well  in  the 
provision  of  drinking  water  but 
significant 
investment  is  needed  in  sanitation  infrastructure. 
Ageing  networks  and  connection  challenges  need 
to  be  addressed.  Slovenia  also  faces  significant 
future  flood  risks.  EU  funding  has  provided  a 
significant  share  of  public  funding  over  the  past 

Slovenia  30 

decade148.  It  is  also  estimated  that  Slovenia  will 
need  to  invest  an  additional  cumulative  EUR  894 
million  by  2030  for  drinking  water  and  sanitation. 
This  corresponds  to  around  EUR  89  million  in 
investment  needs  (capital  expenditure)  per  year, 
with  almost  90%  of  it  related  to  wastewater149. 
recent  6th  Water  Framework 
Moreover, 
Directive  and  Floods  Directive 
Implementation 
Report150  and  the  financial  -  economic  study151 
accompanying  it,  are  also  a  relevant  source  of 
information in this domain.  

the 

Waste & the circular economy 

it  still  needs 

According to a Commission study152 if Slovenia is to 
meet the recycling targets for municipal waste and 
to invest  an 
packaging  waste, 
additional  EUR  109  million  (around  EUR  16  million 
per  year)  in  2021-2027 in:  collection,  biowaste 
treatment,  recycling  reprocessors,  waste-sorting 
facilities and waste-registry digitalisation. This does 
not include the investment necessary for other key 
waste  streams  (plastics,  textile,  furniture)  or  for 
enabling  a  higher  uptake  of  circularity  and  waste 
prevention across the economy. 

Biodiversity & ecosystems 

recently 

submitted 

prioritised 

action 
The 
framework  (PAF)  for  Slovenia  shows  that  costs  for 
nature protection (including  Natura 2000) in 2021-
2027 are about EUR 600 million, or around EUR 57 
to  EUR 86  million  per  year.  Within  total  annual 
costs, the annual one-off costs are EUR 29 million. 
The  main  conservation  priorities  relate  to  the 
management  of  the  Natura  2000  network  and 
restoration and/or maintenance of grassland, forest 
and freshwater habitats153. This excludes additional 
costs  to  implement  the  biodiversity  strategy  to 
2030, 
increased  protection  and 
restoration. 

including  on 

144  International  Institute  for  Applied  Systems  Analysis  (IIASA), 
Progress  towards  the  achievement  of  the  EU's  air  quality  and 
emissions objectives, 2018. 
145  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. 
146 COM(2021) 3 final. International Institute for Applied Systems 
Analysis (IIASA), Support to the development of the  
Second Clean Air Outlook, 2020 and Annex. 
147  OECD,  Financing  Water  Supply,  Sanitation  and  Flood 
Protection: Challenges and Options, 2020 

148  OECD,  Financing  Water  Supply,  Sanitation  and  Flood 
Protection: Challenges and Options, 2020.  
149 OECD, Slovenia - Country fact sheet- Financing Water Supply, 
Sanitation and Flood Protection. 
150  WFD  and  FD  Implementation  Reports  –  DG  Environment  – 
European Commission. 
151 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. 
152  European  Commission,  Study  on  investment  needs  in  the 
waste  sector  and  on  the  financing  of  municipal  waste 
management in Member States, 2019. 
153  The  N2K  Group,  Strengthening  investments  in  Natura  2000 
and  improving  synergies  with  EU  funding  instruments  report  to 
the European Commission, 2021. 

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EU environmental funding 2014-2020 

The  multiannual  financial  framework  (MFF)  for 
2014-2020  allocated  almost  EUR  960  billion  (in 
commitments,  2011  prices)154  for  the  EU  to  spend 
over  this  period.  The  commitment  in  this  2014-
2020  MFF  to  the  green  transition  included  a  20% 
spending target for climate. It also included funding 
opportunities  for  the  environment,  in  particular, 
under the European Structural and Investment (ESI) 
Funds155.  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-19156. 

Slovenia received EUR 4.5 billion from the ESI Funds 
over  2014-2020  to  invest  in  job  creation  and  a 
sustainable  and  healthy  European  economy  and 
environment.  The  planned  direct  environmental 
investment  amounted  to  EUR  514.4  million  of  this 
4.5  billion  with  a  further  EUR  258.8  million 
identified  as  indirect  environmental  investment, 
totalling  EUR  773.2  million.  Figure  40  shows  an 
overview  of 
individual  ESI  Funds 
earmarked  for  Slovenia  (EU  amounts,  without 
national amounts). 

(planned) 

154 Council Regulation (EU, Euratom) No 1311/2013. 
155  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).   
156 Regulation (EU) 2020/2221. 

Slovenia  31 

Figure 40: ESI Funds allocated to Slovenia, 
including environmental investments 2014-2020157 

Table  2:  Direct  and 
indirect  Environmental 
investments under the ESI Funds in Slovenia, 2014-
2020158 

Instrument 

Under Cohesion policy (ERDF + CF) 
Direct environmental investments 
water 
air quality 
biodiversity and nature 
land rehabilitation 
climate and risk management 

Allocations  
for the environment  
(EUR million) 

767.4 
508.5 
303.3 
38.9 
41.0 
32.4 
92.8 

157  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 Policy Funds (COWI, 2017), Regulation (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  and  coefficients  under  the 
Regulation  (EU)  No  1303/2013  and  Regulation  (EU)  2021/1060  
allowing  for  a  more  precise  identification  and  valuation  of 
Indirect 
relevant 
environmental 
I 
environmental coefficients of the Regulation (EU) 2021/1060 (as 
opposed to full value). 
158  European  Commission,  DG  Environment  -  Data  analysis.  The 
values  of  environmental  investments  identified  here  in  the 
specific environmental areas may differ from the tracking 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.  Please  see  also  previous 
footnote. 

investments  are  valued  using  the  Annex 

environmental 

investments. 

N.B. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
                                                                 
 
 
  
                                                                 
Indirect environmental investments 
renewable energy 
energy efficiency 
other energy159 
sustainable transport 
business development, R&I 

Under EAFRD/rural development 

Under EMFF 
Direct environmental investments 
environment protection & resource 
efficiency 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

258.8 
16.5 
86.8 
13.6 
115.3 
26.6 

0 

5.8 
5.8 
5.8 

773.2 
514.4 
258.8 

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  or  Horizon  2020,  which 
added up to an estimated total of EUR 832 million 
of EU environmental financing for Slovenia in 2014-
2020. 

The  LIFE  programme160  is  entirely  dedicated  to 
environmental  and  climate  objectives.  It  finances 
demonstration  and  best-practice  actions  for  green 
solutions to be deployed. In the 2014-2020 period, 
Slovenia  received  EU  support  for  11  LIFE  projects 
worth  EUR  36.4  million  from  the  LIFE  programme 
for nature and environmental projects (out of 1 028 
EU-27  LIFE  projects  financed  with  a  total  EU 
contribution of EUR 1.74 billion)161. 

In  2014-2020,  Horizon  2020  allocated  about  EUR 
22.3  million  for  Slovenia  for  the  environment,  
which  is  about  5.9%  of  Slovenia’s  total  allocation 
under  Horizon  2020162.  These  Horizon  2020  funds 
are  directed  at  Slovenian  environmental  projects 
focused  in  particular  on  the  circular  economy, 
research and innovation biodiversity, climate action 
and  biodiversity.  From  the  European  Fund  for 
Investments  (EFSI),  Slovenia  did  not 
Strategic 
receive  any  environmental  funding  out  of  its  total 
allocation  (EUR  153  million)163.  Furthermore,  from 
the EIB, Slovenia did not receive any environmental 

respectively 

field  53  and  54 

159 Intelligent energy distribution systems (smart grids) and high 
efficiency  co-generation  and  district  heating,  based  on 
intervention 
(with  40% 
environmental  coefficients)  of  Regulation  (EU)  2021/1060, 
Annex I. 
160 European Commission, LIFE Programme. 
161 Source: CINEA. 
162 Source: EASME, https://sc5.easme-web.eu/, accessed: 15-12-
2021. 
163 Approved and signed EFSI financing - EIB, 2015-2020: Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 

Slovenia  32 

support out of the total EIB loans for Slovenia (EUR 
1.6  billion).164  The  country  ranks  number  23  in  the 
amount  of  total  EIB  lending  it  received  in  this 
period. 

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 
lending165 166. 

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 
the  NextGenerationEU 
2021-2027  MFF  and 
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  protection167.  Following 
the EU Green Deal’s168 pledge to ‘do no harm’ and 
the Interinstitutional Agreement  on the 2021-2027 
MFF169,  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.  Increased  programming  of  financial 
resources  is  required  to  reach  these  levels  of 
spending  on  biodiversity,  specifically  under  the 
2021-2027 cohesion policy and the 2023-2027 CAP. 

finance 

significantly 

Sustainable 
increases 
transparency  on  environmental  sustainability  (a 
goal  promoted  by  the  EU  Taxonomy)170.  It  also 
strengthens  non-financial  reporting  requirements 
and  facilitates  the  issuance  of  green  bonds  (by 
developing 
the  EU  green  bond  standard171). 
Reinforced  by  the  renewed  sustainable  finance 
strategy (2020)172, sustainable finance will increase 
investment  flows  to  climate  and  the  environment. 

164 EIB loans in EU countries in 2014-2020. Source: EIB Open Data 
Portal: https://www.eib.org/en/infocentre/eib-open-data.htm 
165 The EIB Group jointly works with the European Commission in 
implementing  several  programmes  that  finance  environmental 
implementation:  InvestEU,  the  successor  of  EFSI,  Pillar  II  and III 
of the Just Transition Mechanism. The EIB Group stands is a key 
implementing  partner  for 
InvestEU  with  responsibility  for 
managing 75% of the overall budgetary capacity of the mandate. 
166 EIB 2020 Activity Report. 
167  European  Commission,  2021-2027  long-term  EU  budget  & 
NextGenerationEU. 
168 COM/2019/640 final 
169 Interinstitutional Agreement, OJ L 433I 
170  https://ec.europa.eu/info/business-economy-euro/banking-
and-finance/sustainable-finance/eu-taxonomy-sustainable-
activities_en   
171 EU Green Bond Standard - 2021/0191 (COD). 
172  COM  (2021)  390  Final  -  European  Commission,  Strategy  for 
Financing the Transition to a Sustainable Economy.  

Environmental Implementation Review 2022 – Slovenia 

 
 
                                                                 
                                                                 
the 

to  close 

The  new  strategy  on  adaptation  to  climate 
change173  can  help 
insurance-
protection  gap,  which  currently  leaves  many  risks 
from  climate-related  events  uninsured174.  The  EIB 
lending  for  climate  and 
will  align  50%  of 
environment  projects  by  2025175  with  a  EUR  250 
billion  contribution  to  the  Green  Deal  investment 
plan by 2027. 

its 

Table  3  provides  an  overview  of  the  EU  funds 
earmarked  specifically  for  Slovenia  for  the  2021-
2027 period. These funds are also supplemented by 
other  EU  funding  programmes  available  to  all 
Member States. 

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

Instrument 

Country funding allocation 
(million EUR) 

Cohesion policy 

Total: 3 058.4176 

ERDF 

CF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

EAFRD/rural 
development  

under  CAP  Strategic 
Plans 2023-2027180 

European  Maritime, 
and 
Fisheries 
Fund 
Aquaculture 

1 537.9  

718.2177 

727.3 

75178 

258.7179 

550.9181 

23.9182 

the 

insurance-protection  gap 

173 COM(2021) 82 final. 
174  The  strategy  would  support  improved  coverage  of  the 
insurance  gap, 
including  through  the  natural-catastrophe 
markets  as  reflected  with  the  EIOPA  (the  Association  for 
European  Insurance  and  Occupational  Pension  Authorities) 
dashboard  on 
for  natural 
catastrophes. See: The pilot dashboard on insurance protection 
gap for natural catastrophes | Eiopa (europa.eu). 
175 EIB Climate Bank Roadmap 2021-2025, November 2020. 
176 European Commission, 2021-2027 Cohesion policy EU budget 
allocations. 
177  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is 
not included. 
178 Interreg initial allocations per MS including ETC transnational 
and ETC cross-border co-operation.  
179 European Commission, 2021-2027 Cohesion policy EU budget 
allocations. 
180 European Commission, CAP strategic plans. 
181 Regulation (EU) 2021/2115, Annex XI.  
182 Regulation (EU) 2021/1139, Annex V. 

Slovenia  33 

(EMFAF) 

Recovery 
Resilience 
(RRF)  

and 
Facility 

2021 – 2026183  

1 776.9 (grants) 

705.4 (loans)184  

In  Slovenia,  the  programming  for  most  EU  funds 
(cohesion  policy  funds,  EAFRD  and  EMFAF) 
is 
ongoing.  However,  the  negotiations  have  been 
concluded under the RRF. 

Slovenia’s  national  recovery  and  resilience  plan 
(RRP)  responds  to  the  urgent  need  to  foster  a 
strong recovery and make Slovenia more resilient in 
the future. The reforms and investments in the plan 
will  help  Slovenia  become  more  sustainable, 
resilient and better prepared for the challenges and 
opportunities  of  the  green  and  digital  transitions. 
To this end, the plan consists of 55 investments and 
33  reforms.  Slovenia  requested  almost  EUR  1.8 
billion  in  grants  and  over  EUR  700  million  in 
loans. 42.5% of 
support climate 
the  plan  will 
objectives.  This  exceeds  the  RRF’s  37%  climate 
target. 

to 

support 

the  circular  economy 

In  terms  of  the  green  transition,  the  plan  includes 
reforms for renewable energy, sustainable mobility 
the 
and 
decarbonisation  of  the  country’s  economy.  The 
investments will focus on: (i) energy efficiency and 
seismic  renovation  of  buildings  (EUR  230  million); 
(ii) decarbonisation,  digitalisation  and  safety  of 
railway  infrastructure  transport  (EUR  292  million); 
supply,  water-saving  and 
(iii) drinking  water 
wastewater  projects 
(EUR  54  million);  and 
(iv) actions  to  facilitate  the  transition  to  a  circular 
economy (EUR 48 million)185. 

183 The actual reforms and investments under the RRF have to be 
implemented until 31 December 2026.   
184 Council Implementing Decision, FIN 584. 
185  European  Commission,  Slovenia’s  recovery  and  resilience 
plan. 

Environmental Implementation Review 2022 – Slovenia 

 
 
                                                                 
 
 
                                                                 
Figure 41: Climate expenditure in RRP (2021-
2026)186 

(the  Connecting  Europe  Facility)193  or  sustainable 
infrastructure (InvestEU)194. 

Slovenia  34 

National expenditure on environmental 
protection  

relevant 

current  and 

Total  expenditure  on  environmental  protection 
(including  all 
capital 
expenditure )195 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.  
Although 
largest  absolute  amounts  of 
expenditure  are  concentrated  in  a  few  countries,  
most  countries  spend  between  1-2%  of  their  GDP 
on  environmental  protection.  Slovenia  spends  2% 
of its GDP on environmental protection. 

the 

on 

protection 

environmental 

Of  this  spending,  the  EU-27's  capital  expenditure 
(Capex) 
(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,  with  Slovenia  slightly  above  that, 
investing  0.6%  of  its  GDP.  During  2014-2020,  this 
totalled to around EUR 376 billion of environmental 
investment in the EU-27, and to EUR 2.6 billion for 
Slovenia. 

and 

capital 

193 European Commission, Connecting Europe Facility. 
194 European Union, InvestEU. 
195  At economy level, including final consumption, intermediate 
expenditure  of  households, 
consumption 
corporations  and  governments  related 
to  environmental 
protection goods and services. It excludes EU funds, although it 
may  include  some  international  expenditure  beyond  strictly 
domestic  expenditure.  Data  source:  Environmental  Protection 
Expenditure Accounts (EPEA), Eurostat. EPEA accounts are based 
on  the  CEPA  2000  classification,  excluding  climate,  energy  and 
circular economy. 

Under  NextGenerationEU,  the  Commission  will 
issue up to EUR 250 billion of EU green bonds (one 
third of all bonds issued under NextGeneration EU) 
until 2026 that will comply with the general spirit of 
the ‘do no significant harm’ principle. However, this 
EUR  250  billion  in  green  bonds  will  not  be  subject 
to  the  currently  developed  delegated  acts  related 
to the EU Taxonomy and will not fully align with the 
proposed EU standard for green bonds. 

In  addition  to  EU  funds  earmarked  specifically  for 
Slovenia  in  2021-2027,  there  are  also  funding 
programmes  that  can  be  accessed  at  EU  level  and 
which are open to all Member States. These include 
the  LIFE  programme187  (EUR  5.4  billion),  Horizon 
Europe (EUR 95.5 billion)188, the Connecting Europe 
Facility189  (EUR  33.7  billion)190  or  the  funds  to  be 
mobilised  via  the  InvestEU  programme191.  These 
other sources of funding will also support the green 
transition, 
and 
innovation  activities  for  environmental  protection 
(Horizon  Europe)192,  clean  transport  and  energy 

including 

research 

through 

186  European  Commission.  The  contributions 
to  climate 
objectives  have  been  calculated  using  Annex  VI  of  the  RRF 
Regulation (EU) 2021/241. 
187 European Commission, LIFE Programme. 
188  European  Commission,  Multiannual  financial  framework 
2021-2027 (in commitments) - Current prices. 
189 The CEF (Transport) also includes 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  amount 
under  national  envelopes  that  is  unspent  by  that  date  will 
support all the Cohesion Fund’s Member States. 
190 Regulation (EU) 2021/1153. 
191 The InvestEU Fund is set  to mobilise over EUR 372 billion of 
investment through an EU budget guarantee of EUR 26.2 billion 
to  back  the  investment  of  financial  partners  such  as  the 
European Investment Bank (EIB) Group and others. 
192 European Commission, Horizon Europe. 

Environmental Implementation Review 2022 – Slovenia 

 
 
                                                                 
 
 
                                                                 
Figure 42: Direct and indirect environmental 
protection investments in the EU-27 (EUR million 
and % of GDP), 2018196 

Figure 43: EU-27 Member States' environmental 
protection investments (Capex) by institutional 
sectors (Total economy = 100%, 2018)197 

Slovenia  35 

from  specialist  producers 

By  institutional  sector,  around  32%  of  Slovenia’s 
investment  in  environmental  protection  (capital 
expenditure)  came  from  the  general  government, 
(of 
just  5%  came 
environmental-protection  services,  e.g.  waste  and 
water  companies)  and  the  lion’s  share  64%  (the 
highest  compared  with  other  EU  Member  States) 
came  from  industry  (businesses)  not  specialised  in 
environmental-protection services. At EU level, 37% 
of  investment  in  environmental  protection  comes 
from  governments,  33%  from  specialist  producers 
and 30% from industry (businesses) not specialised 
in environmental protection. 

In  2018,  at 

to  wastewater,  11% 

A breakdown of investment by environmental topic 
is  partially  available,  but  only  at  the  level  of 
institutional sectors (rather than at economy level), 
due  to  different  reporting  patterns  across  the 
sectors198. 
Slovenia’s  general-
government level, 70% of environmental-protection 
investments  went 
to 
environmental R&D, 7% to waste management and 
7%  to  biodiversity.  For  the  country’s  specialist 
producers, waste management was the key priority 
with  92%  of  relevant  investments.  For  industry 
(businesses)  not  specialised 
in  environmental 
protection,  waste  management  attracted  29%  of 
environmental  investments,  air  protection  25%, 
wastewater 15% and biodiversity protection 7%, to 
name the most significant items. 

In  2020,  the  total  annual  issuance  of  green  bonds 
worldwide199  amounted  to  USD  279.8  billion.  Of 
this,  the  total  annual  issuance  of  European  green 

197  Eurostat,  Environmental  Protection  Expenditure  Accounts 
(env_epe). 
198 Data reporting is different for the three institutional sectors, 
leading  to  aggregation difficulties.  Specialist  companies provide 
comprehensive  data  across  all  environmental  areas  (CEPA  1-9), 
although  this  is  less  the  case  for  general  government  and 
industry, which often report (the non-obligatory) data in merged 
categories  only  (because  it  is  difficult  to  split  to  disaggregate 
these data) or not at all.  
199 Green bonds were created to fund projects that have positive 
environmental and/or climate benefits. Most green bonds issued 
are green ‘use of proceeds’ or asset-linked bonds. The very first 
green  bond  was  issued  in  2007  from  multilateral  institutions 
European Investment Bank (EIB) and World Bank. 

196  Eurostat,  Environmental  Protection  Expenditure  Account, 
2021. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
 
                                                                 
 
                                                                 
bonds  (including  some  non-EU  countries)  was  USD 
156  billion  (EUR  137  billion200),  up  from  USD  117 
billion (EUR 105 billion) in 2019. Looking only at EU-
27  Member  States,  green-bond  issuance  in  2020 
was  EUR  124  billion.  In  2014-2020,  83%  of  the 
green  bonds  issued  by  European  countries  served 
objectives  in  energy,  buildings  or  transport,  while 
8%  supported  water  and  waste,  with  a  further  6% 
links  to  ecosystem 
supporting 
conservation and restoration. These data are based 
on  the  climate-bonds  taxonomy,  which  is  broadly 
similar to the EU Taxonomy201. Of this 2020 annual 
EU green-bond issuance, Slovenia had no issuance. 

land  use,  with 

Figure 44: Annual EU green bond issuance in 2020 
(EUR billion)202 

Green budget tools 

Green taxation and tax reform 

Slovenia’s  revenue  from  environmental  taxes  in 
2020 was above the EU average, as shown in Figure 
45  (2.95%  compared  to  the  EU-27  average  of 
2.24%).  Within  this,  energy  and  transport  taxation 
represent  the  highest  share  with  2.38%  and  0.45% 
of  GDP  respectively,  while  pollution/resource  tax 
accounts for 0.12% of GDP203. 

200 At Eurostat’s annual average EUR/USD exchange rates. 
201  Interactive  Data  Platform  at  www.climatebonds.net.  Further 
Taxonomy: 
information 
https://www.climatebonds.net/standard/taxonomy.  
202 Climate Bonds Initiative, 2022. 
203 Eurostat, Environmental tax revenues. 

Climate 

Bonds 

on 

Slovenia  36 

Figure 45: Environmental taxes in the EU27 
(2020)204 

just 

The  2019  European  Green  Deal  underlines  that 
well-designed  tax  reforms  can  boost  economic 
growth  and  resilience,  foster  a  fairer  society  and 
promote  a 
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  simultaneously  taking  account  of  social 
considerations205.  The  Green  Deal  promotes  the 
‘polluter-pays  principle’206,  which  stipulates  that 
polluters  should  bear  the  cost  of  measures  to 
remedy  pollution.  The 
prevent,  control  and 
polluter-pays  principle  is  facilitated  by  the  EU 
Commission’s  Technical  Support  Instrument  (TSI) 
flagship project207 on greening taxes. 

According  to  a  Commission’s  study  on  Green 
taxation  and  other  economic  instruments  (2021), 
Slovenia 
economic 
instruments for air, water and waste208. 

polluter-pays 

applies 

204 Eurostat, Environmental taxes accounts (env_eta). 
205 COM (2019/640 final), p.17. 
206  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’. 
207 European Commission, Greening taxes- applying polluter pays 
principle in practice,  green budgeting TSI participation. 
208  European  Commission,  Green  taxation  and  other  economic 
instruments. 

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Environmentally-harmful subsidies 

Addressing  and  removing  environmentally-harmful 
subsidies  is  a  further  step  towards  wider  fiscal 
reforms. 

Figure 46: Trends in natural gas, petroleum 
products, electricity and coal subsidies in 
Slovenia210 

Slovenia  37 

Fossil-fuel  subsidies  are  costly  for  public  budgets, 
and  make  it  difficult  to  achieve  the  Green  Deal 
objectives.  In  many  cases  these  subsidies  also 
counteract  incentives  for 
investments  in  green 
technologies. Annual fossil-fuel subsidies have been 
around  EUR  55  billion  in  the  EU  since  2015.  They 
rose by 4% between 2015 and 2019, although some 
countries (such as Latvia, Lithuania Sweden, Greece 
or  Ireland)  managed  to  decrease  them  in  this 
period. In the EU, subsidies for petroleum products 
in  sectors  such  as  transport  and  agriculture 
in  2015-2019.  However, 
continued  to 
subsidies for coal and lignite decreased, largely due 
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  (with  an  EU  average  of  0.4%).  In 
2019, 
in  Slovenia 
amounted to EUR 0.1 billion, representing 0.13% of 
the GDP. 

fossil-fuel 

subsidies 

increase 

total 

In  2020,  the  EU-27’s  total  amount  of  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 2020209. 

Slovenia  allocated  more  than  the  EU  average  on 
fossil-fuel subsidies — and significantly higher than 
on renewable-energy subsidies211. 

Environmentally  harmful  subsidies 
in  Slovenia 
include:  (i)  exemptions  (or  partial  refund)  from 
excise  duty  on  fuels  for  different  operators; 
(beef,  veal,  pork); 
(ii) agricultural  premiums 
(iii) subsidies 
the 
production  of  electricity  from  renewables  and 
combined  heat  and  power  plants  or  feed-in  tariffs 
(for  natural  gas  used  in  combined  heat  and  power 
plants,  biomass,  geothermal,  ocean,  small-scale 
hydro, solar (PV), waste, wind). 

the  energy  sector 

for 

in 

Current green budgeting practices  

‘Green  budgeting’  encompasses  various  climate 
and environmental tagging212 and tracking practices 
in  budgets.  Some  EU  Member  states  already  use 
practices213.  Green 
certain 
green 
budgeting  helps 
track 
expenditure  and  green  revenues  to 
increase 
transparency  on  the  environmental  implications  of 

green-budgeting 

identify  and 

210 OECD, Fossil Fuel Subsidy Tracker. 
211  European  Court  of  Auditors,  Energy  taxation,  carbon pricing 
and energy subsidies, 2022. 
212  Climate  and  environmental  tagging  is  a  tool  that  allows 
assessing  each  individual  budget  measure  and  gives  it  a  “tag” 
according to whether it is helpful or harmful to green objectives. 
213 European Commission, Green Budgeting Practices in the EU: A 
First Review, 2021, Green Budgeting in the EU Key insights from 
the  2021  Commission  survey  and  OECD,  Public  Governance 
Directorate, Climate Change and Long-term Fiscal Sustainability, 
Working  Paper,  February  2021.  Climate  Change  and  Long-term 
Fiscal Sustainability (oecd.org) 

209 See table on EU FFS data in 2019 which is based on (for info) 
COM(2021) 950 and Annex. 

Environmental Implementation Review 2022 – Slovenia 

 
 
 
                                                                 
 
 
 
                                                                 
budgetary policies. This is aimed at improving policy 
coherence and supporting green policies (including 
climate and environmental objectives)214. 

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 
criteria215.  The  Commission  developed  a  green-
budgeting  reference  framework216  and  launched  a 
TSI  project  on  green  budgeting  in  2021  to  help 
Member States develop or further develop national 
improve  policy 
green-budgeting  frameworks  to 
coherence  and  the  green  transition.  Slovenia 
participates  in  the  Commission’s  green-budgeting 
TSI, which started in 2021. 

Overall financing compared to the needs 

The  EU’s  overall 
for  environmental 
financing 
investments is estimated to have reached 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 overall EU environmental-investment needs will 
reach between 0.9-1.5% of the projected overall EU 
GDP  (2021-2027).  This  suggests  an  additional 
environmental  financing  need  (gap)  of  0.6-0.8%  of 
GDP over baseline financing patterns217. 

Figure 47: Total environmental financing baseline 
(2014-2020) and estimated needs (2020-2030) in 
the EU27 (% of GDP)218 

214 OECD Paris Collaborative on Green Budgeting initiative, 2017. 
215  European  Commission,  Technical  guidance  on  sustainability 
proofing for the InvestEU Fund. 
216  European  Commission,  Green  Budgeting  Reference 
Framework, based on the review of the OECD Paris Collaborative 
on Green Budgeting initiative, 2017. 
217  Source:  DG  Environment  data  analysis.  EU  financing  sources 
covered:  ESI  Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  and  EMFF), 
Horizon  2020,  LIFE,  EFSI  (EU  amount),  EIB  loans.  National 
financing: 
total  national  environmental-protection  capital 
expenditure (investments) - source: Eurostat EPEA dataset. Cut-
off  date  for  data:  end  2021.  N.B.  The  total  financing  may  be 
higher, 
investments, 
requiring further analysis in the future. 
218 Eurostat, ESI Funds Open Data, 2021. 

in  particular  through  further 

indirect 

Slovenia  38 

Slovenia’s financing for environmental investments 
came  to  an  estimated  1.76%  of  GDP  (EU  average:  
0.7%)  in  2014-2020,  with  over  80%  of  that  coming 
from  domestic  sources.  However,  the  country’s 
environmental-investment  needs  in  2021-2027  are 
estimated to be at least 2.06% of GDP,  indicating a 
financing  gap  of  0.3%  of  GDP  or  more,  when  also 
accounting  for  needs  that  are  currently  estimated 
at  EU-level  only  (e.g.  water  protection,  higher 
circularity, biodiversity strategy etc.). 

2022 priority actions 

  Ensure  an  increased  level  of  financing  for  the 
environment  to  cover  the  investment  needs 
across  the  environmental  objectives  by  closing 
the investment gaps. 

  Scale up the biodiversity support under the new 
cohesion  policy  and  the  common  agricultural 
policy  to  achieve  the  ambition  set 
in  the 
Interinstitutional  Agreement  on  the  2021-2027 
MFF on biodiversity219.  

  Ensure that cohesion policy and EAFRD funding 
and LIFE programme funding complement  each 
other,  especially,  as  regards  LIFE  integrated 
projects  and  actions  certified  with  a  'Seal  of 
Excellence'220. 

219  More  specifically,  the  EU  aims  to  provide  ‘7.5%  of  annual 
spending  under  the  MFF  to  biodiversity  objectives  in  the  year 
2024 and 10% of annual spending under the MFF to biodiversity 
objectives in 2026 and 2027’. 
220  Article  16  to  Regulation  (EU)  2021/783  (‘LIFE  Regulation’) 
provides that support from the ERDF, ESF+ and the EAFRD ‘may 
be  granted  to  actions  awarded  a  “Seal  of  Excellence” 
certification  under  the  LIFE  Programme  by  complying  with  the 
following cumulative conditions:  

Environmental Implementation Review 2022 – Slovenia 

 
 
 
                                                                 
 
 
                                                                 
 
Slovenia  39 

  Take 

full  advantage  of  existing 

technical 
assistance  (e.g.  available  under  the  cohesion 
policy programmes, InvestEU Advisory Hub221 or 
Peer2Peer  schemes)  to  identify  and  mitigate 
institutional 
include, 
risks.  These  risks  may 
capacity  gaps,  process  gaps, 
inadequate 
capacity of beneficiaries (e.g. smaller applicants 
in  selected  sectors  such  as  biodiversity  or 
energy  efficiency),  existing  and  foreseeable 
investment gaps, lack of clarity about EU rules. 

(a) 

(b) 

(c) 

they  have  been assessed  in a call  for  proposals under  the 
LIFE Programme; 
they  comply  with  the  minimum  quality  requirements  of 
that call for proposals; 
they cannot be financed under  that  call  for proposals due 
to budgetary constraints.’ 

221 European Union, InvestEU Advisory Hub. 

Environmental Implementation Review 2022 – Slovenia 

 
                                                                                              
Slovenia  40 

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  effectively222.  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 environment223. It includes the right to bring 
legal challenges (‘legal standing’)224. 

Environmental information 

Slovenia’s  implementation  of  the  INSPIRE  Directive  has 
improved.  Its  performance  has  been  reviewed  based  on 
the country's 2021 fiche225. The main challenge identified 
in the INSPIRE monitoring score (in 2020) was the lack of 
spatial  data  services.  It  has  been  addressed  and  both 
view and download services have been implemented for 
all INSPIRE datasets.   

Table  4:  Country  dashboard  on  the  implementation  of 
the INSPIRE Directive (2016-2020)226 

2016 

2020 

Legend 

Effective  coordination  and  data 
sharing 

Ensure  effective 
coordination  

■ 

■ 

■  Implementation  of 
is  well 
this  provision 
advanced  or 
(nearly) 
completed. 
Outstanding  issues  are 

222  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive,  (Directive 
2007/2/EC)  together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive’s implementation. 
223 These guarantees are explained in the Commission Notice on access 
to  justice  in environmental  matters,  OJ L 275,  18.8.2017  and a related 
Citizen’s Guide. 
224  This  EIR  report  focuses  on  the  means  implemented  by  Member 
States  to  guarantee  rights  of  access  to  justice,  legal  standing  and  to 
overcome  other  major  barriers  to  bringing  cases  on  nature  and  air 
pollution. 
225 European Commission, INSPIRE in your Country, Slovenia fiche. 
226 INSPIRE knowledge base 

Data 
sharing 
without obstacle   ■ 

■ 

INSPIRE performance indicators 

i.  Conformity  of 
metadata  

■ 

■ 

ii.  Conformity  of 
spatial 
data 
sets227 

■ 

■ 

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

■ 

■ 

iv.  Conformity  of 
network services 

■ 

■ 

minor  and 
addressed 
Percentage: >89% 

can  be 
easily. 

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

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

Public participation 

Public participation in environmental impact assessment 
(EIA)  and  strategic  environmental  assessment  (SEA) 
procedures is facilitated by means of electronic tools. The 
Ministry  of  the  Environment’s  webpage  ‘Environmental 
Assessments’228,  under  the  heading 
‘Environmental 
Impact  Assessment’  provides  an  introduction  to  the  EIA 
procedure,  the  parties  involved  and  possibilities  for 
public  participation229.  The  EIA  webpage  also  contains  a 
database  with  screening  decisions,  announcements  on 
public  participation,  useful  links,  a  database  with  past 
decisions,  etc.  A  similar  webpage  is  in  place  for  SEA 
procedures.  The  Environmental  Agency  publishes  a 
database of all ongoing EIA procedures230, which provides 
access to relevant documents. 

information  and 
is  good  access  to 
Although  there 
guidance on public participation, there is little systematic 
information on how public views are taken into account. 
No aggregate data is published and decisions in individual 
cases  do  not  indicate  how  public  comments  have  been 

227 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. 
228 Republika Slovenija, gov.si, Environmental assessments. 
229 Republika Sloveija, gov.si, Obtaining an environmental decision.  
230 Republika Slovenija, gov.si, Construction.  

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Slovenia  41 

taken into account. In addition, following the transfer of 
responsibility  for  EIA  procedures  from  the  Environment 
Agency to the Ministry of the Environment in September 
2021,  there  is  some  confusion  about  the  information 
available  on  websites,  with  neither  website  providing 
access to the full text of past EIA decisions.  

Access to justice  

There  is  an  ongoing  infringement  procedure  against 
Slovenia concerning requirements of access to  justice as 
provided for by both the EIA and the IED Directives. This 
in 
concerns  the  requirement  of  prior  participation 
administrative proceedings to secure access to justice for 
qualified  NGOs,  the  lack  of  judicial  review  for  negative 
screening  decisions  and  the  limited  scope  for  judicial 
review. 

lack  of  protecting  citizen’s  rights 

The 
for  public 
participation  (environmental  plans/programmes,  spatial 
plans,  nature-conservation  plans/programmes,  water 
management  programmes  and  others)  is  a  weakness  of 
the  Slovenian  legal  system  with  respect  to  the  Aarhus 
Convention.  There 
is  no  ‘direct’  way  to  obtain  an 
administrative review or challenge a final decision about 
a  plan/programme  before  a  court.  There  are  only  two 
possible indirect and less satisfactory options. First, if the 
plan  or  programme  is  adopted  as  a  general  legal  act,  it 
the  Constitutional  Court 
could  be  challenged  at 
(conformity  with  the  Constitution).  Second,  it  could  be 
challenged  at  the  Administrative  Court  as  an  act  or 
omission  of  the  state  or  local  authority  (Administrative 
Dispute  Act,  Article  4).  Legal  standing  can  be  granted  to 
NGOs  with  the  status  of 
interest  –  nature 
conservation’ 
representing  nature-conservation 
interests (Article 137 of the Nature Conservation Act). For 
legal  standing  can  be 
other  NGOs  and 
granted  on  the  basis  of  Article  43  of  the  General 
Administrative  Procedure  Act,  if  legal  interest  can  be 
demonstrated; the person should claim to be joining the 
procedure  in  order  to  protect  their  legal  benefits.  The 
legal benefits should be direct personal benefits based on 
an act or other regulation. 

individuals, 

‘public 

for 

The  plans  or  programmes  cannot  be  challenged  in  an 
administrative supervisory forum or in a court. There is a 
system  of  regular  supervision  of  regulatory 
legally 
binding acts but it is hardly accessible for members of the 
public and NGOs. They can only  contact those bodies or 
officials  who  are  entitled  to  initiate  an  extraordinary 
supervision procedure. 

There  is,  however,  no  official  website  with  rules  on 
environmental access to justice. There is only information 
about conditions and the processes for NGOs with public-
interest  status.  Nonetheless, 
the 
Environment  and  Spatial  Planning  encourages  NGOs  to 
spread 
relevant 
information is available on the Environmental Defenders 
website231. 

information.  Currently  all 

the  Ministry  of 

such 

231 The network ‘Environmental Defenders’. 

2022 priority actions 
 

 

Improve  clarity  about  how  people  can  find  out 
information  on  EIA  processes  and  take  steps  to 
encourage public participation in EIAs. 
Publish information about public participation in EIA 
and  SEA  procedures,  both  as  part  of  the  decision-
making  process  in  individual  cases  and  in  aggregate 
form; It should assess whether public participation is 
increasing or declining. 

fact  sheets  on  access 

  Better inform the public about rights on their access 
to justice, in particular by referring to online judicial 
and administrative portals, and the EU Commission’s 
eJustice 
in 
environmental matters232. 
Iimprove  public  access  to  courts  when  it  comes  to 
challenging administrative or regulatory decisions, in 
particular  as  regards  planning  related  to  water, 
nature and air quality. 

justice 

to 

 

Compliance assurance  

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste233.  It 
includes  support  measures  provided  by  the  authorities 
such as: 
(i) compliance promotion234;  
(ii)  inspections and other checks that they carry out, i.e. 
compliance monitoring235;  
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement236.  

232 European Union, Access to justice in environmental matters.  
233  The  concept  is  explained  in  detail  in  the  Communication  on  ‘EU 
improve  environmental  compliance  and  governance’ 
actions  to 
COM(2018) 10  and  the  related  Commission  Staff  Working  Document, 
SWD(2018)10. 
234 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
235 This EIR focuses on inspections of major industrial installations. 
236  This  EIR  focuses  on  the  availability  of  enforcement  data  and 
coordination between authorities to tackle environmental crime. 

 Environmental Implementation Review 2022 – Slovenia 

 
 
                                                                 
 
 
                                                                 
Citizen  science  and  complaints  enable  authorities  to 
liability237 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring 

The websites of the Ministry of Environment and Spatial 
Planning  and  the  Institute  for  Nature  Conservation 
provide  extensive  information  on  biodiversity  and  the 
implementation  of  the  Nature  Directives.  This  includes 
technical  information  and  information  targeted  at  the 
general  public.  However,  there  is  not  much  focus  on 
practical  measures  for  duty  holders  (i.e.  people  with  a 
specific responsibility under environmental law). 

There is generally less promotional material available on 
implementation  of  the  Nitrates  Directive,  although  a 
document238 available on the Ministry’s website provides 
a  comprehensive  overview  of  the  measures  to  be 
implemented in the farm sector, with real-life examples. 
In  addition,  the  Agricultural  Advisory  Service239,  a 
network of regional agricultural advisory offices, is active 
in providing advisory and educational activities on issues 
concerning 
optimising 
fertilisation with nitrogen and avoiding run-off. 

particularly 

nitrates, 

on 

Industrial 

The  Environment  Inspectorate  produces  an  annual  plan 
for 
Emissions 
the 
inspections  under 
Directorate,  setting  out  the 
frequency  of  regular 
inspections based on a risk assessment. The Inspectorate 
has  also  adopted  internal  guidelines  for  non-routine 
inspections,  to  determine  the  order  of  processing 
complaints and reports from legal and natural persons240.  
As  in  2019,  inspection  reports  will  not  be  published  in 
2022,  although  short  summary 
(date, 
location, permit number, whether licence conditions are 
complied  with,  whether  follow-up  action  is  required)  is 
made  available  online  for  Industrial  Emissions  Directive 
inspections. 

information 

In  principle,  members  of  the  public  may  ask  to  see 
specific  inspection  reports  according  to  legislation  on 
access to public documents. In addition, the Inspectorate 
sometimes  announces  the  beginning  of  an  inspection 
procedure  on  its  website,  or  reports  on  its  results,  but 
this is not systematic, and is generally focused on cases in 
the public eye241. 

237  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
238  Ministry  of  the  Environment  and  Spatial  Planning,  Guidelines  for 
implementing  measures  to  protect  water  against  pollution  by  nitrates 
from agricultural sources, July 2020.  
239 The Agricultural Advisory Service. 
240  Republika  Slovenija,  gov.si,  The  Environment  and  Spatial  Planning 
Inspectorate. 
241  See 
Inspectorate.  

‘News’  page  on  The  Environment  and  Spatial  Planning 

Slovenia  42 

Annual activity reports are published by the Inspectorate 
for  the  Environment  and  Spatial  Planning242,  which 
provide  summary  data  at  a  very  general  level.  For 
Industrial  Emissions  Directive  installations  this  includes 
the number of inspections, the number of infringements 
found and the number of inspection measures (measures 
ordered to be taken) and sanctions. 

Complaint handling and citizen science 

The Inspectorate’s website provides information on how 
to submit an online complaint, either anonymously243 or 
with an electronic signature244. The website also provides 
clear and concise instructions on how to file a complaint 
by  post  or  in  person245.  There  are  public  guidelines 
available on how complaints should be prioritised in the 
inspections  process.  While  complainants  have  a  right  to 
receive  a  written  response  after  an  investigation  has 
been completed, no timescale has been provided for this. 
Similar  complaints  procedures  are  available  on  the 
website of the Inspectorate for Agriculture, Forestry and 
Food, which is responsible for inspecting cases of nitrate 
pollution. However, there does not seem to be an active 
policy to encourage public reporting of offences. 

There  does  not  appear  to  be  any  published  statistics  on 
public  complaints  (number  received,  issues  covered, 
outcomes, etc). Since 2019, some steps have been taken 
in  Slovenia  to  encourage  citizen-science  activities, 
generally  in  the  field  of  biodiversity,  and  there  is  also  a 
‘Slovenian Partnership for the Soils’246, which encourages 
public participation in data gathering. 

 Enforcement  

Judgments  handed  down  from  the  higher  courts  are 
usually  published,  but  the  information  they  contain  is 
usually  anonymised,  and  often  incomplete.  As  in  2019, 
there  is  currently  no  public  database  of  environmental 
prosecutions  or  judgements  nor  a  public  database  of 
prosecutions  in  general.  The  statistical  instruments  on 
environmental  crimes  have  also  not  been  developed 
since  2019.  However,  the  State  Prosecution  Office 
publishes  annual  reports,  which  contain  aggregated 
information  about  the  number  of  cases  by  type  of 

242  Republika  Sloveniaja,  gov.si,  About  the  Environment  and  Spatial 
Planning Inspectorate.  
243  Republika  Slovenija,  eUprava,  Anonymous  notification  of 
infringement to the Environmental and Spatial Planning Inspectorate of 
the Republic of Slovenia.  
244  Republika  Slovenija,  eUprava,  Report 
the 
Environment  and  Spatial  Planning  Inspectorate  of  the  Republic  of 
Slovenia.  
245 Repiblika Slovenija, gov.si 
246 Repiblika Slovenija, gov.si, Slovenian Soil Partnership.   

infringement 

to 

 Environmental Implementation Review 2022 – Slovenia 

 
 
                                                                 
 
                                                                 
illegal 

offence  and  perpetrator247, 
including  a  section  on 
environmental crimes. The most common ‘environmental 
crimes’  are  those  regarding  animal  welfare,  poaching, 
and 
involving  pollution  or 
destruction  of  the  environment  are  less  present  in  the 
data: 
in  2018,  out  of  125  reported  environmental 
offences, only 8 were brought to court, which ultimately 
lead to six convictions. 

logging.  Offences 

requirements 

While  the  legislation  identifying  environmental  offences 
generally  prescribes 
for  cooperation 
between  the  organisations  responsible  for  enforcement 
(duties to inform or consult, etc.), there does not seem to 
be  any  memoranda  of  understanding  or  other 
agreements  between  relevant  institutions  on  how  to 
cooperate, or how to share information and expertise, or 
training, resulting in no progress being made since 2019. 

 Environmental Liability Directive  

In  Slovenia,  no  database  or  registry  of  environmental 
incidents  or  of  cases  brought  under  the  Environmental 
Liability  Directive  exists.  According  to 
information 
gathered from the Environment Agency in the context of 
earlier  research  for  the  Commission,  15  Environmental 
Liability  Directive  cases  had  been  processed  in  Slovenia 
until  2020,  nine  of  which  are  already  completed248. 
Slovenian legislation does not impose specific mandatory 
financial  security  for  liabilities  under  the  Environmental 
Liability Directive; therefore, no progress has been made 
since 2019. 

2022 priority actions 

 

 

Improve  the  availability  of  online  material  for  duty 
holders, e.g. farmers and land managers, on practical 
steps  to  implement  legislation  that  protects  nature; 
and it should improve the visibility of information on 
the implementation of the Nitrates Directive. 
Improve  public  availability  of  information,  e.g.  on 
environmental  inspections,  and  on  prosecution  of 
environmental crimes. 

  Establish an online registry of Environmental Liability 
Directive cases and other instances of environmental 
damage,  making  information  on  damages  and  costs 
available to the public. 

European 

247 Crown Prosecution Service.  
248 
ENV 
Commission, 
D.4/FRA/2016/0003, COWI, Prospect, Justice and Environment, Country 
reports: Improving implementation and the evidence base for the ELD, 
2021. 

Contract  No. 

Framework 

Slovenia  43 

Effectiveness of environmental 
administrations  

in 

involved 

implementing 

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

Administrative capacity and quality 

law 

in  how  EU  environmental 

Slovenia  ranks  18  out  of  180  in  the  2020  Environmental 
Performance Index249. Overall, during the last decade, an 
improvement 
is 
implemented  in  the  different  sectors  can  be  observed. 
For  instance,  there  has  been  progress  made  regarding 
the  implementation  of  the  environmental  assessments. 
The Commission checked the conformity of the Slovenian 
legislation  with  the  Environmental  Impact  Assessment 
Directive,  resulting 
in  Slovenia  being  subject  to  an 
infringement procedure. Following Slovenia’s reply to the 
Letter  of  Formal  Notice,  some  of  the  grievances  have 
been  dropped,  either  due  to  satisfactory  explanations 
given by Slovenian authorities, or legislative changes that 
had  already  taken  place.  However,  some  grievances 
persist,  as  the 
legislative  changes  to  solve  those 
grievances  have  not  taken  place  yet.  These  grievances 
relate to the lack of participation of local authorities, the 
non-conformity  of  arrangements  for  transboundary  EIA 
procedures  and  the  gaps  concerning  measures  and 
conditions 
for  preventing,  reducing  or  eliminating 
harmful  effects  on  the  environment  in  the  permits 
granted for some projects. 

Coordination and integration  

the 

revised  Environmental 

As  mentioned  in  the  2019  EIR  Report,  the  transposition 
of 
Impact  Assessment 
Directive  (EIA  Directive)250  provides  an  opportunity  to 
streamline  the  regulatory  framework  on  environmental 
in  full  transposition 
assessments.  Despite  a  delay 
(deadline  was  May  2017),  Slovenia  has  now  transposed 
the  revised  Directive.  The  quality  of  the  transposition  is 
currently  under  assessment  through  a  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 

249  Environmental  Performance  Index  |  Environmental  Performance 
Index (yale.edu) 
250  Directive  2011/92/EU  as  amended  by  Directive  2014/52/EU 
(Informal consolidated version of the EIA Directive).  

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Slovenia  44 

provided 
it 
the  quality  of 

unnecessary  administrative  burden  and  accelerates 
is 
decision-making, 
done  without 
the  environmental-
compromising 
assessment  procedures251. 
already 
environmental 
streamlining 
introduced 
assessments  under  EIA  and  Habitats  Directives  prior  the 
revision  of  the  EIA  Directive.  Coordinated  procedures 
have  been  established  for  EIA,  Water  Framework 
Directive and Industrial Emission Directive. 

Slovenia  had 
of 

the 

The  Single  Environmental  Permitting  Platform,  which 
implements  the Single Environmental Permitting Regime 
that  simplifies,  harmonises  and  draws  up  many 
environmental permits, can be highlighted as an example 
of good practice. 

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

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

through  granting 

The  TSI  supported  several  environment-related  projects 
in  Slovenia.  Under  the  TSI  2019,  a  project  related  the 
preparation of the regulation on sustainable mobility was 
supported.  The  TSI  2020  supported  a  project  on 
improving  the  organisation  and  management  of  public 
transport  and  alternative  fuels  infrastructure.  Under  the 
TSI  2021,  a  project  on  the  modelling  of  economic  and 
fiscal  impact  of  green  policies  was  selected.  In  addition, 
the TSI 2021 provided support to a project that facilitates 
renewable energy deployment in the country’s electricity 
sector.  It  incorporates  biodiversity  mapping  into  the 
assessment of the potential for renewables in Slovenia. 

TAIEX EIR peer to peer  

The Commission launched the TAIEX EIR peer to peer tool 
learning  among 
in  2017  to  facilitate  peer-to-peer 
environmental authorities252. 

Since  the  2019  EIR,  Slovenia  has  participated  in  two 
multi-country  workshops  on  reducing  ammonia  (2021) 
and  on  zero  pollution  (2022).  Slovenia  also  benefited 
from  an  expert  mission  on  environmental  noise 
protection (2019). 

251 The Commission issued a guidance document in 2016 on 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.  
252 https://ec.europa.eu/environment/eir/p2p/index_en.html. 

 Environmental Implementation Review 2022 – Slovenia