COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - BELGIUM 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: Belgium, EU environmental policy, 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) 261 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022       Country Report - BELGIUM               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) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Belgium  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  

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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. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Belgium  2 

Table of Contents 

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

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

1. 

2. 

3. 

4. 

CIRCULAR ECONOMY AND WASTE MANAGEMENT ........................................................................................................... 4 
Measures towards a circular economy ................................................................................................................... 4 
Waste management ............................................................................................................................................... 8 
BIODIVERSITY AND NATURAL CAPITAL ......................................................................................................................... 11 
Nature protection and restoration ........................................................................................................................ 11 
Marine ecosystems ............................................................................................................................................... 19 
Ecosystem assessment and accounting ................................................................................................................ 20 
ZERO POLLUTION ................................................................................................................................................... 22 
Clean air ................................................................................................................................................................ 22 
Industrial emissions ............................................................................................................................................... 24 
Preventing major industrial accidents – SEVESO .................................................................................................. 26 
Noise ..................................................................................................................................................................... 27 
Water quality and management ........................................................................................................................... 27 
Chemicals .............................................................................................................................................................. 32 
CLIMATE ACTION ................................................................................................................................................... 34 
Key national climate policies and strategies ......................................................................................................... 34 
Effort-sharing target ............................................................................................................................................. 35 
Key sectoral developments.................................................................................................................................... 35 
Use of revenues from the auctioning of EU ETS allowances ................................................................................. 36 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................................. 37 

5. FINANCING ................................................................................................................................................................ 37 
Environmental investment needs in the European Union ................................................................................... 37 
EU environmental funding  2014-2020 ................................................................................................................. 39 
EU environmental funding  2021-2027 ................................................................................................................. 41 
National expenditure on environmental protection .............................................................................................. 43 
Green budget tools ................................................................................................................................................ 44 
Overall financing compared to the needs ............................................................................................................. 46 
6. ENVIRONMENTAL GOVERNANCE .................................................................................................................................... 47 
Information, public participation and access to justice ........................................................................................ 47 
Compliance assurance........................................................................................................................................... 49 
Effectiveness of environmental administrations ................................................................................................... 51 
Reforms through the Commission’s Technical Support Instrument (TSI) .............................................................. 52 
TAIEX peer-to-peer Projects .................................................................................................................................. 53 

Environmental Implementation Review 2022 – Belgium 

 
 
 
 
 
Belgium  3 

Executive summary 

agriculture  in  Flanders;  (ii)  growing  transport  activity, 
notably  to/from  Antwerp  port;  and  (iii)  relatively  high 
population  density  in  the  Flanders  and  Brussels  regions. 
Actions  under 
the  national  air  pollution  control 
programme  (NAPCP)  to  reduce  the  main  emission 
sources are needed.  

On water management, there has been limited and slow 
progress 
in  reducing  the  number  of  non-compliant 
agglomerations under the Urban Waste Water Treatment 
Directive in Wallonia. On nitrates, available reports show 
increasingly worrying water quality trends in Flanders, so 
additional  measures  and  stronger  actions  are  urgently 
needed.  For  Wallonia,  the  review  of  nitrates  action 
programmes has fallen behind. 

Widespread  flooding  recently  devastated  the  southern 
part  of  Belgium,  killing    many  people  and  causing 
significant  economic  damage.  These  floods  suggest  that 
Belgium - and Wallonia in particular -  should implement 
up-to-date  preliminary 
flood-risk  assessments  and 
identify areas of significant flood risk.  

Belgium continues to make efficient use of EU funds and 
loan  opportunities  in  particular  to  support  the  circular 
economy, especially through its recovery and resilience 
plan (RRP). Belgium is one of the EU’s best performers on 
resource productivity, the use of secondary materials and 
waste  management.  However,  there  are  differences  in 
the  rates  of  separate  collection  of  waste  between  the 
regions.  Further  progress  could  be  made  by  introducing 
new economic instruments to prevent waste by avoiding 
the  incineration  of  reusable  or  recyclable  waste  — 
especially  in  the  Brussels  region  —  and  by  making  the 
reuse  and  recycling  of  waste  more  economically 
attractive.  

Belgium’s environmental financing for investments came 
to  0.71% of GDP in 2014-2020, mostly based on national 
sources.  In  2021-2027,  the  country’s  environmental 
investment needs are estimated to be at least  0.85% of 
GDP,  suggesting  an  environmental  financing  gap  of  at 
least  0.14% of GDP (above baseline financing level). This 
gap  will  need  to  be  addressed  by  mobilising  further 
financial 
environmental 
to 
implementation priorities.  

resources 

back 

In  previous  environmental 
implementation  reviews 
(EIRs),  the  Commission  identified  three  main  challenges 
for Belgium’s implementation of EU environmental policy 
and law. These three challenges were: 

  managing 

towards 
the  Natura  2000  network 
favourable  conservation  status  for  all  species  and 
habitats,  taking  into  due  account  external  pressures 
and threats (such as atmospheric nitrogen emissions), 
as  well  as  investing  in  further  nature-restoration 
measures on the basis of the site-level objectives for 
species and habitats;  
improving  air  quality,  in  particular  nitrogen  oxide 
levels (NO and NO2) in urban areas and the transport 
sector,  by  both  reducing  traffic  congestion  and 
improving the monitoring of air quality;  

 

  addressing  water  pollution  from  urban  waste  water 
and  from  nitrates  (i.e.  manure  and  fertilisers  in 
Wallonia  and  nutrient  pollution  in  Flanders)  and 
tackling chemical pollution. 

On  the  Natura  2000  network,  Belgium  has  made 
significant  progress  in recent years  with 38  Natura 2000 
sites  designated  as  special  areas  of  conservation  (SACs). 
The  main  challenge 
is  now  to  ensure 
in  Belgium 
favourable  conservation  status  for  habitats  and  species, 
since    74%  and  49%  of  the  assessments  for  respectively 
habitats  and  species  indicate  an  “unfavourable-bad” 
status during the last reporting period under the Habitats 
Directive, The situation with the EU-protected habitats is 
the  worst  in  the  EU  with  more  than  95 %  of  habitats  in 
unfavourable  conservation  status.  Furthermore,  the 
situation  for  Belgian  forested  areas  protected  under  the 
Nature  Directives  is  worrisome,  as  more  than  half  of 
assessments  for  these  areas  show  a  bad  conservation 
status.  Moreover,  adoption  of  conservation  measures  in 
marine  sites  remains  challenging,  as  these  measures 
often 
imply  restrictions  to  fishing  methods  (beam 
trawling) which can only be adopted under the common 
fisheries policy.  

There  has  been  limited  progress  on  air  quality,  with 
measures  taken  to  reduce  NO2  concentrations.  Belgium 
still  fails  to  ensure  compliance  with  the  limit  values  for 
NO2  in  one  main  urban  zone,  Antwerp.  To  tackle  NO2 
pollution, Belgium has taken further action to reduce air 
pollution  and  also  decided  to  set  up  new  air  quality 
monitoring  stations.  Moreover,  Belgium  has  an  average 
risk  of  non-compliance  with 
its  national  ammonia 
reduction  commitment,  both  for  the  period  2020-2029 
and  for  2030  and  beyond.  This  is  because  agriculture  is 
the main source of ammonia. Strong pressures are being 
exerted  on  ecosystems  and  biodiversity  by:  (I)  intensive 

Environmental Implementation Review 2022 – Belgium 

 
 
 
 
 
 
 
Belgium  4 

Part I: Thematic areas 

1. Circular economy and waste management

Measures towards a circular economy 

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

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’s  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 States’ level. Such measures 
range  from  sustainable  product  designthat  makes  it 
possible 
reparability, 
upgradability  and  recyclability  of  products,  to  other 
measures 
increasing 
like:  (I)  “remanufacturing”;  (ii) 
circularity  in  production  processes;  (iii)  recycling;  (iv) 
boosting eco-innovation; and (v) increasing the uptake of 
green public procurement.  

the  durability, 

increase 

to 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency  on  volatile  raw  material  markets.  As  shown 
in  Figure  2,  Belgium  generated  EUR  3.06  per  kg  of 
material  consumed  in  2020,  putting  Belgium  well  above 
the  EU’s  average  for  resource  productivity  of  EUR  2.09 
per  kg.  However,  the  latest  figures  show  there  has 
recently been a decline in Belgian resource productivity. 

Figure  1  shows  that  the  circular  (secondary)  use  of 
material in Belgium was 18.9% in 2016 and 23% in 2020, 
well  above  the  EU  average  of  12.8%..  Belgium  has  also 
made  good  progress  in  improving  its  circular  secondary-
material  usage  in  recent  years,  such  that  it  is  now  the 
for  circular 
EU’s  second  most  advanced  country 
secondary  material  usage,  just  behind  the  Netherlands 
(30.9 %) and slightly ahead of France (22.2%). 

1 Eurostat, Circular Economy Monitoring Framework.  

Environmental Implementation Review 2022 – Belgium 

 
 
 
 
                                                                 
Figure 2: Resource productivity 2010-20202 

Circular economy strategies 

implement  national/regional 

The  Commission  encourages  Member  States  to  adopt 
and 
circular-economy 
strategies covering the whole life cycle of products. This 
is because, such strategies are one of the most effective 
ways to progress towards a more circular economy. Since 
the 
the  European  Circular  Economy 
Stakeholder Platform in 20173, national, regional or local 
authorities  have  used  the  platform  to  share  their 
strategies and roadmaps.  

launch  of 

Belgium  adopted  in  December  2021  a  new  full-fledged 
action  plan  for  the  circular  economy  2021-2024  at  the 
federal  level.  This  plan  aims  to  seize  the  opportunities 
related  to  the  circular  economy  in  terms  of  innovation, 
job  creation  and  competitiveness  in  Belgium.  This  plan, 
and the transition to a circular  economy in general, also 
aims  to  combat  climate  change,  biodiversity  loss  and 
environmental  degradation.  Through  this  plan,  the 
federal state will activate the levers and competences at 
in  particular  product  policy,  consumer 
its  disposal, 
protection policy, public procurement, tax policy, and the 
National  Recovery  and  Resilience  Plan.  In  addition, 

2 Eurostat, Resource productivity. 
3 Circular Economy Stakeholder Platform 

Belgium  5 

regional  plans  are  the  driving  force  behind  Belgium's 
transition at the policy level. 

In  the  Brussels  Capital  Region,  the  regional  government 
adopted  a  circular-economy  regional  plan  (BRPCE)  in 
2016  with  111  measures 
laying  out  a  strategy  to 
transition  from  a  linear  to  a  circular  economy  by  2025. 
The BRPCE sets a ten-year implementation framework to 
move  Brussels'  economy  towards  a  circular  model.  To 
ensure  the  BRPCE 
is  kept  up-to-date  and  remains 
relevant, it is revised every 18 months.  From April 2022, 
the BRPCE will be included in the regional strategy for the 
economic  transition  The  enclosed  action  plan  will  be 
revised  and  adapted  every  2  years.  The  Renolution 
Strategy4  aims  as  a  complement  to  transform  the 
Brussels construction model into a circular model. 

In  Wallonia,  building  on  the  Plan  wallon  des  déchets-
ressources  adopted in 2018, a regional circular  economy 
strategy, 'Circular Wallonia', was launched on 21 January 
2020. This strategy used a participatory process to take a 
systemic  approach  to  the  transition  towards  a  circular 
economy.  The  “Circular  Wallonia”  strategy  was  adopted 
on  4  February  2021  and  is  guided  by  10  ambitions.  It 
identifies  six  priority  value  chains:  construction  and 
buildings;  plastics;  metallurgy  (including  rare/critical 
metals  and  batteries);  water;  textiles;  and  food  industry 
and  food  systems.  In  2022,  Wallonia  has  begun  the 
implementation phase of its Circular Wallonia strategy by 
prioritizing  actions  and  measures  within  the  6  priority 
value chains.   

In  Flanders,  the  ‘Vision  2050’  strategy  was  approved  in 
2016.  Vision  2050  highlights  seven  transitions  that 
Flanders must  make by 2050, with the circular  economy 
being  one  of  these  seven  transitions.  To  develop  the 
circular  economy,  the  Flemish  government  approved  a 
starting  paper,  Transitie  Circulaire  Economie,  at  the  end 
of  February  2017.  This  starting  paper,  focused  on  the 
circular  city, circular purchasing and circular  enterprises. 
To  promote  circular  public  procurement,  the  Flemish 
government  has  also  launched  a  “green  deal”..  The 
Flemish Regeer Agreement 2019-20245 and several policy 
papers  confirm  the  importance  of  the  transition  to  a 
circular economy to: (i) futur-proof the Flemish economy; 
(ii)  better  meet  the  needs  for  raw  materials  and  water; 
and  (iii)  maximise  social  well-being  while  reducing 
society’s  environmental  footprint.  Flanders  has  the 
ambition  to  move  towards  a  circular  economy.  The 
Flemish  Energy  and  Climate  Plan6  sets  an  ambition  to 

https://www.vlaanderen.be/publicaties/regeerakkoord-van-de-

4 https://renolution.brussels/fr 
5 
vlaamse-regering-2019-2024 
6 https://energiesparen.be/vlaams-energie-en-klimaatplan-2021-2030 

 Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
                                                                 
reduce Flanders’ material footprint by 30 % by 2030 and 
to  drastically  reduce  greenhouse-gas  emissions  by  2030. 
To  accelerate  the  transition  to  a  circular  economy  the 
public-private  partnership  Circular 
Flanders  was 
industrial 
established 
partners,  knowledge  institutions,  public  administrations, 
finnacial institutions, local authorities and civil society7. 

in  co  creation  with 

in  2017, 

Another  Flemish  policy  initiative  to  address  waste  and 
the  circular  economy  is  the  2016-2022  implementation 
plan  for  household  waste  and  comparable  industrial 
waste,  which  contains  waste-reduction  targets 
for 
different waste streams as well as targets for the reuse of 
certain materials. Actions on textiles (separate collection 
and  reducing  landfill  waste)  are  also  included  in  the 
Implementation plan. A new plan is currently developed. 
Also  the  Action  Plan  Circular  Food  Loss  and  Biomass 
(Residual)  Flows  2021-2025  was  approved  in  April  2021. 
This  action  plan  will  encourage  the  prevention,  the 
separate  collection  and  recycling  of  food 
loss  and 
biomass  residues  in  order  to  reduce  costs  and  resource 
use. This plan offers a framework for the government and 
stakeholders  to  close  the  loop  of  food  loss  and  biomass 
(residual)  flows  and  to  reach  the  Flemish  and  European 
targets  in  the  period  2021-2025.    In  addition,  a  new 
Action Plan on Plastics 2020-2025 includes 33 actions to 
increase circularity in the plastics economy spread across 
4 areas: (i) the prevention of plastic litter, which includes 
an  integrated  action  plan  on  marine  litter;  (ii)  the 
reduction  and  efficient  use  of  plastics,  focusing  on  eco-
design;    (iii)  the  creation  of  a  sustainable  recycling 
market; 
fully-fledged 
secondary  raw  material.  Flanders  has  also  set  up  a 
programme  called  Materials  Management  in  Circular 
Building  Policy.  This  program  encourages  cooperation 
between  government  and  the  construction  sector  to 
ensure  the  sustainable  management  of  materials  in  the 
construction sector. It addresses five themes, and efforts 
are bundled into action programmes that run for 2 years, 
the  first  of  which  was  concluded  in  2016.  The    third 
action programme is now ongoing. 

(iv)  promoting  plastics  as  a 

On  reforms  related  to  Belgium’s  recovery  and  resilience 
plan  (RRP),    the  Flemish  Government’s  relance  plan  for 
Flemish  Resilience8  aims  to  support  an  accelerated  shift 
towards  a  maximum  circular  economy.  On  the  basis  of 
this  relaunch  plan,  resources  will  be  made  available  at 
European  level  to  support  the  circular  transition.  The 
Belgium Builds Back Circular federal investment plan will 
invest  EUR 28.97  million  from 2022 to 2026  in order to 
stimulate  research  and  development  in  companies  and 
research  institutions  on  the  following  three  pillars:  eco-

Belgium  6 

design, substitution of substances of concern and raising 
awareness and informing SMEs about circular economy. 

Overall,  Belgium  has  made  progress  in  strengthening  its 
circular-economy policy framework. 

Many  LIFE  projects  in  Belgium  promote  the  circular 
economy.  For  example,  the  LIFE  project  FARBioTY9 
supports  the  circular  economy  in  the  transportation 
industry, while the LIFE project  Green Valleys10 connects 
the  circular  economy  with  the  conservation  of  natural 
habitats  and  biodiversity.  The  integrated  LIFE  project 
Cmartlife commits to closing material loops, with a strong 
focus  on  plastics,  in  order  to  further  reduce  residual 
waste and create a litter free environment11. 

Eco-innovation 

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

in 

its 

steep 

decline 

Following 
eco-innovation 
performance  between  2013  and  2015,  Belgium  has  not 
been able to recover its previous levels of performance. It 
is now ranked 16th in the EU countries on the 2021 Eco-
Innovation Scoreboard, with only average eco-innovation 
performance.  Belgium scores close to the EU average for 
eco-innovation  inputs,  activities,  outputs  and  resource 
country’s 
efficiency  outcomes 
socioeconomic  indicators  show  that  Belgium  has  one  of 
the 
for 
lowest  scores  among  all  Member  States 
socioeconomic  outcomes  from  eco-innovation.  With  an 
average  score  of  36,  Belgium  lagged  behind  other  EU 
countries  for  socioeconomic  outcomes 
in  2019  (e.g 
exports  of  products  from  eco-industries,  employment  in 
the  circular  economy),  and  was  relatively  far  from  the 
EU’s  average  score  of  100.  .  There  are  notable  regional 
initiatives on the circular economy in Belgium12. 

.  However, 

the 

Belgium  is  ranked  19th  in  the  EU-27  for  revenues 
generated  in  eco-industries.  These  revenues    represent 
1.87%  of  total  revenue  across  all  companies  (the  EU 
average is 2.22%). Of the main drivers of eco-innovation 
in  Belgium,  the  most  significant 
(I)  the 
integration of eco-innovation and sustainability goals into 
industrial and economic policies; (ii) the growing demand 

include: 

7 https://vlaanderen-circulair.be/en 
8 
regering-vlaamse-veerkracht 

https://www.vlaanderen.be/publicaties/relanceplan-vlaamse-

9 https://www.life-farbioty.eu/ 
10 https://www.natuurpunt.be/pagina/introduction-life-green-valleys 
11 https://ovam-english.vlaanderen.be/web/cmartlife 
12  European  Commission,  Country  Report  European  Semester  2020  – 
p.70 (SWD 2020/500 final). 

 Environmental Implementation Review 2022 – Belgium 

 
                                                                 
                                                                 
Belgium  7 

for  green  technology,  products  and  local  markets  for 
recycling;  (iii)  the  country’s  highly  performing  education 
system  and  (iv)  the  existence  of  supporting  institutions. 
Nevertheless,  eco-innovation  in  Belgium  is  hindered  by: 
(I) difficulties imposed by inter-regional coordination; (ii) 
a  lack  of  eco-innovation  and  circular  economy  related 
skills  in  SMEs  and  (iii)  a  limited  control  over  product 
design for most products entering the market. 

Figure 3: Eco-innovation performance, 2010-201913 

efficiency  (2013),  with  specific  legislative  and  policy 
documents  in the country’s three regions and at federal 
level.  

GPP  criteria  have  been  developed  by  Flanders  and  at 
federal level thanks to initiatives by several departments. 
In  most  cases,  the  EU  GPP  criteria  are  the  basis  for 
national-level  discussions  with  stakeholders.  To  date, 
federal GPP/sustainable criteria have been developed for 
about 70 product and service groups.  

region 

integrated 

responsible  public 
The  Flemish 
procurement  in  the  overall  strategy  on  procurement  of 
the  Government  of  Flanders.  The  strategy  urges 
procurers  to  evaluate  opportunities  for  sustainability  in 
every contract.  

The  Brussels  Capital  Region  has  a  framework  with  three 
levels: development  of references e.g. for  clean  vehicles 
and  sustainable  buildings  construction  and  renovation; 
providing  information,  training  sessions  and  helpdesk 
advice;  establishing  a  mandatory  framework  for  the 
public authorities dependent on the Brussels region.  

On  4  February  2021,  Wallonia  adopted  his  first  strategy 
for  the  Circular  Economy.  Public  procurement  is  here 
identified  as  a  lever  to  initiate  Wallonia's  transition  to  a 
circular  economy.  Wallonia  displays  different  ambitions 
by 2025 such as:  
-  50%  of  relevant  public  procurement  contracts  will 
integrate circular economy principles or circular criteria. 
-  75%  of  public 
technology (ICT) contracts will be circular and ethical. 
-  All  public  demolition/deconstruction  contracts  and 
subsidized  contracts  will  include  a  materials  inventory 
and selective deconstruction. 
-  Reuse  materials  will  be  used  in  all  public  works 
contracts  and  progressively  in  works  subsidized  by  the 
Walloon Region. 

information  and  communications 

EU Ecolabel and the eco-management and audit scheme 
(EMAS) 

The  number  of  EU  ecolabel  products  and  EMAS-
registered14  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 
to 
shows  how  committed  public  authorities  are 

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. 
Public  procurement  can  help  drive  the  demand  for 
sustainable  products 
reparability  and 
recyclability  standards.  At  present,  reporting  to  monitor 
the  uptake  of  green  public  procurement  (GPP) 
is 
voluntary.   

that  meet 

In  Belgium,  a  detailed  strategy  on  sustainable  public 
procurement  (SPP)  has  been  in  place  for  the  federal 
government  departments  since  2014,  combining  the 
green  and  social  aspects  of  public  procurement.  A 
revision  of  this  strategy  is  announced  by  2022.  Specific 
regulations in the context of SPP were adopted for wood 
(2005),  vehicles  (2009  &  2010  &  2022)  and  energy 

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

14  EMAS  is  the  European  Commission’s  Eco-Management  and  Audit 
Scheme, a programme to encourage organisations to behave in a more 
environmentally sustainable way. 

 Environmental Implementation Review 2022 – Belgium 

 
 
 
 
                                                                 
                                                                 
supporting instruments designed to promote the circular 
economy.  

As of September 2021, Belgium had 5582 products out of 
83 590, and 54 licenses out of 2 057, registered in the EU 
ecolabel scheme, showing a good take-up of the products 
and  licences15.  Moreover,  55  organisations,,  amounting 
to  744  sites    from  Belgium  are  currently  registered  in 
EMAS, the European Commission's eco-management and 
audit scheme16.   Since the last report in 2019, there have 
been  3  525  new  registrations  of  EU  ecolabel  products 
from Belgium, and 5 new licences. For EMAS, there were 
5 fewer registrations in Belgium in 2020 than in 2019. 

Waste management 

Turning waste into a resource requires:  
(I)  full  implementation  of  EU  waste  legislation,  which 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate collection of waste, the landfill diversion targets 
etc; 
(ii)  reducing  waste    generation  per  capita  in  absolute 
terms;  
(iii)  limiting  energy  recovery  to  non-recyclable  materials 
landfilling  of  resyclable  or 
and  phasing  out 
recoverable waste. 
This  section  focuses  on  the  management  of  municipal 
waste17  for  which  EU  law  sets  mandatory  recycling 
targets. 

the 

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 waste18 generation in 
Belgium started to increase again in recent years (Figure 
4). It came to 416 kg/year/inhabitant in 202019. However, 
this  was 
(505  
kg/year/inhabitant)..  In  2020,  waste  generation  was 

average 

below 

still 

the 

EU 

15 European Commission, Ecolabel Facts and Figures. 
16 As of May 2018. European Commission,  Eco-Management and Audit 
Scheme. 
17  Municipal  waste  consists  of  mixed  waste  and  separately  collected 
waste  from  households  and  from  other  sources,  where  such  waste  is 
similar in nature and composition to waste from households. This does 
not  affect  the  allocation  of  responsibilities  for  waste  management 
between the public and private sectors. 
18  Municipal  waste  consists  of  waste  collected  by  or  on  behalf  of 
municipal  authorities,  or  directly  by  the  private  sector  (business  or 
private non-profit institutions) not on behalf of municipalities. 
19  Eurostat, 2021 

Belgium  8 

around  476  kg/year20  around  448  kg/year/inhabitant  in 
Wallonia (202021 and around 700 kg/year22 in the Brussels 
Capital Region. 

Figure 4: Municipal waste by treatment in Belgium, 
2010-202023 

Figure  4  also  shows  municipal  waste  by  treatment  type, 
in  kg  per  capita.  The  situation  varies  by  region,  but 
significant 
managing  waste  efficiently 
challenge  for  Belgium,  and  especially  for  the  region  of 
Brussels. 

remains  a 

All  three  Belgian  regions  already  have  a  system  in  place 
that taxes incinerated waste and they all encourage heat 
recovery from waste incineration. Further progress could 
be  made  by  introducing  new  economic  instruments  to 
prevent  waste  by:  (i)  avoiding  the 
incineration  of 
reusable or recyclable waste — especially in the Brussels 
Capital Region;  and (ii) making the reuse and recycling of 
waste more economically attractive. 

However,  Belgium’s  overall  performance 
in  waste 
generation  and  management,  is  good.  This  can  be  seen 
by taking into account the indicator for the recycling and 
circular  material  use  combined  with  the  country’s 
production  of  waste  per  capita,  which  is  below  the    EU 
average. 

https://ovam.vlaanderen.be/cijfers-huishoudelijk-afval-en-

20 
gelijkaardig-bedrijfsafval 
21  State of Environment report – Wallonia 2017 p.101 
22 Plan de Gestion des Ressources et des Dechets, 2018, page 15 
23 Eurostat, Municipal waste by waste operation, april 2022. 

 Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
 
                                                                 
Figure 5: Recycling rate of municipal waste, 2010-202024 

Belgium  is  one  of  the  EU’s  top  performers  in  waste 
management, with a recycling rate for municipal waste of 
54.7%  in  2019  (EU  average  47.7%),  of  which  21%  is 
composting  waste.  This  means  that  Belgium  has  already 
met  the  EU’s  2020  target  to  recycle  50%  of  municipal 
waste.  However,  there  are  differences 
in  separate-
collection rates (i.e. the percentage of waste streams that 
are  collected  separately  to  facilitate  recycling)  between 
the  regions.  The  Brussels  Capital  Region  only  had  a 
separate-collection  rate  of  37%  in  2017,  much  worse 
than Flanders and Wallonia, both of which had separate-
collection  rates  of  70%).    This  can  be  attributed  to  the 
particularity  of  the  Region,  which  is  only  an  urban  area 
where sorting is often more complex than in rural areas. 
The  Resource  and  Waste  Management  Plan  provides 
measures  to  improve  the  performances  despite  the 
complex  situation.25.  Belgium  and  especially  Flanders 
have  focused  on  collecting  waste  separately  and  on 
recycling  waste  over  the  past  ten  to  fifteen  years. 
However, the market for recycled products is still limited 
and needs to grow to provide economic opportunities for 
the separate-collected and recycled products. In addition, 
recycled products and secondary recycled materials have 
to compete with non-recycled and primary raw materials. 
A recent trend has been that more complex products are 
being  placed  on  the  market,  making  it  more  challenging 
to repair, dismantle or recycle them. There is also a lack 
of  transparency  about  the  contents  of  products,  making 
recycling more difficult. 

Belgium  9 

Belgium will need to make further efforts will be needed 
to  meet  the  more  ambitious  recycling  targets  for  the 
period  up  to  203526,  in  particular  the  related  target  to 
reduce  the  incineration  of  municipal  waste,  which  has 
remained at the same level since 2017 (42.8 %).  

Belgium  has  only  one  mechanical  biological  treatment 
plant  in  operation  due  to  its  low  levels  of  separate 
collection  of  waste.  Both  Flanders  and  Wallonia  report 
that  around  70%  of  their  municipal  waste  is  collected 
separately27 , whereas the Brussels Capital Region reports 
that  only  around  37%  is  collected  separately28.  In  2017, 
the  Brussels  region  extended  separate  collection  to 
include voluntary separate collection of kitchen waste in 
an attempt to improve its recycling rate. Furthermore, all 
three regions have banned the use of lightweight plastic 
bags. In 2019, Belgium had the highest recycling rate for 
packaging  in  Europe  (84.2%  according  to  Eurostat),  well 
above the EU average (64.8%)29. 

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 Directive30. By 
July 2021  Belgium had  still not  done this for  the Landfill 
Directive  and  the  Waste  Framework  Directive.  For  this 
reason,  the  Commission  sent  a  reasoned  opinion  urging 
Belgium  to  fully  transpose  the  new  EU  rules  on  waste 
into  national  legislation.  Belgium  eventually  notified  its 
transposition  of  the  Packaging  and  Packaging  Waste 
Directive  to  the  Commission.  The  Commission  is  now 
conducting  conformity  assessment  of  this  transposition. 
Waste  management  plans  and  waste  prevention 
programmes are instrumental for the full implementation 
of EU waste legislation. These plans and programmes 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  streams;  on  recycling  targets;  and  on 
landfill  targets).  Belgium  was  due  to  submit  revised 
waste-management 
and  waste-prevention 
plans 
programmes by 5 July 2020.  

24  Eurostat, Recycling rate of municipal rate, april 2022. 
25  European  Commission,  Country  Report  European  Semester  2020, 
p.69.  The  following  benchmark  of  ACR+  confirm  this  hypothesis: 
https://document.environnement.brussels/opac_css/elecfile/RAP_2020
_BenchmarkACR.pdf 
https://app.bruxellesenvironnement.be/multimedia/ZeroWasteFastFor
ward_Colloque-11022020.pdf  
(slide 189, Source : ACR+) 

26  Directive  (EU)  2018/851,  Directive  (EU)  2018/852,  Directive  (EU) 
2018/850 and Directive (EU) 2018/849 
27 OVAM, 2020, p. 25; Vivre la Wallonie No 35, p. 15 
28 Plan de Gestion des Resources et des Déchets 
29 Eurostat, 2019 
30  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 – Belgium 

 
 
                                                                 
 
                                                                 
Belgium  10 

The  most  recent  resource  and  waste  management  plan 
(Plan de Gestion des Resources et des Déchets  - RWMP) 
was  adopted  by  the  Government  of  the  Brussels  Capital 
Region on 15 November 2018.  The RWMP addresses the 
issue of sober and responsible consumption upstream, as 
well  as  traditional  waste  management  downstream, 
including  new  practices  of  a  collaborative  economy  and 
sharing  at  intermediate  levels.  The  general  objectives  of 
the RWMP are threefold: 

- 

anchoring a transformation to more sustainable 
and circular consumption practices; 

-  maximising  the  preservation  and  recovery  of 

- 

materials, if possible locally; 
training  the  supply  side  of  the  economy  to 
become circular.31. 

It  is  under  assessment  by  the  Commission  services.  The 
revision for waste management plans for Flanders is still 
ongoing.  Belgium  has  not  notified  with  the  Commission 
its updated Waste Management Plan for Wallonia.  

2022 priority actions  

  Shift  reusable  and  recyclable  waste  away  from 
economic 

including 

through 

incineration, 
instruments. 

  Ensure that regional waste management plans in line 
with  the  revised  Waste  Framework  Directive  are  in 
place. 

Brussels 

31 
http://www.environnement.brussels/thematiques/dechets-
ressources/action-de-laregion/plan-dechets  

Environnement 

website: 

 Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
Belgium  11 

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 
the  key  drivers  of 
them  sustainably,  addressing 
biodiversity loss. 

The Habitats and Birds Directives are key legislative tools 
to  deliver  on  the  strategy’s  targets  and  are  the 
cornerstone  of  the  European 
legislation  aimed  at 
conserving the EU's wildlife32.   

In 

The  Interministerial  Conference  of  the  Environment  is 
made up of the environment ministers of: (I) the federal 
government; (ii) the three regions (Flanders, the Brussels 
Capital Region and Wallonia); and (iii) the three language 
communities  (Flemish-speaking,  French-speaking  and 
the 
2013, 
November 
German-speaking). 
Interministerial  Conference  updated 
the  national 
strategy  for  biodiversity  (initially  adopted  in  2006).  This 
national  strategy  summarises  the  responsibilities  of 
different governments in Belgium with a view to meeting 
the  commitments  made  at  European  and  international 
levels. The national strategy also aims to identify priority 
environmental  policy  areas,  long-term  objectives  until 
2020 and Belgium’s vision for the environment by 2050.  

The strategy has a vision and a general objective that are 
in line with the EU’s strategic plan for the Convention on 
Biological  Diversity  and  the  EU’s  own  biodiversity 
strategy to 2020. The long-term objective for nature and 
biodiversity  referred  to  in  Belgium’s  national  strategy 
relates to the establishment  of protected areas: the aim 
is  for  national  protected  areas  and  Natura  2000  sites  to 
make  up  17%  of  Belgium’s  land  area  and  10%  of  the 
country’s marine area. The national strategy also aims to 
restore at least 15% of degraded ecosystems. 

32  These  should  be  strengthened  by  the  Nature  Restoration  Law, 
according to the new EU Biodiversity Strategy. 

Nature protection and restoration  

Natura  200033,  the 
largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
in  the  Birds  and  Habitats 
achieve  the  objectives 
Directives.  These  objectives  are:  (i)  to  ensure  the  long-
term  protection,  conservation  and  survival  of  Europe's 
most  valuable  and  threatened  species  and  habitats;  and 
(ii)  to  maintain  or  restore  the  favourable  conservation 
status  of  these  species  and  habitats.  Key  milestones 
towards meeting the objectives of the Birds and Habitats 
Directives  are:  (i)  the  setting  up  of  a  coherent  Natura 
2000 network;  (ii) the designation of sites of community 
importance  (SCIs)  as  special  areas  of  conservation 
(SACs) 34 and (iii) the setting of  site-specific conservation 
objectives and measures for all Natura 2000 sites.  

Setting up a coherent network of Natura 2000 sites 

The 
implementation  of  the  EU  Birds  and  Habitats 
Directives and the setting up of the Natura 2000 network 
are  regional  responsibilities  in  Belgium,  shared  between 
the  Flanders,  the  Wallonia  and  the  Brussels-Capital 
Region.  The  Natura  2000  network  in  Belgian  marine 
waters is a federal competence. 

Belgium  is  home  to  59  habitat  types35  and  86  species36 
covered by the Habitats Directive. The country also hosts 
breeding  populations  of  188  bird  taxa,  83  of  which  are 
listed in Annex I of the Birds Directive37. 

By  January  2022,  12.7%  of  the  national  land  territory  of 
Belgium  was  covered  by  Natura  2000  sites  (EU  average 
18.5%),  with  special  protection  areas  (SPAs)  classified 
under  the  Birds  Directive  covering  10.4%  (EU  average 
12.8%)  and  special  areas  of  conservation  (SACs)  under 

33  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 and 
non-coverage do not add up to 100% due to the fact that some SCIs and 
SPAs overlap. A special area of conservation (SAC) is a SCI designated by 
the Member States. 
34  SCIs  are  designated  under  the  Habitats  Directive  whereas  SPAs  are 
designated  under  the  Birds  Directive;  figures  of  coverage  and  non-
coverage  do  not  add  up  to  100%  due  to  the  fact  that  some  SCIs  and 
SPAs overlap. A special areas of conservation (SAC) is an SCI designated 
by the Member States. 
35 EEA, Article 17 dashboard, Annex I total, 2019. 
36  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. 
37  EEA,  Article  12  dashboard,  Annex  I,  2020.  This  counting  only  takes 
into account birds taxa for which information was requested. 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
                                                                 
Belgium  12 

the Habitats Directive covering 10.7% (EU average 14.2%) 
of the territory. 

The coverage of the Belgian marine part of the North sea 
by  Natura  2000  sites  is  1  317  km  2  (38%  of  the  Belgian 
marine  area),  combining  2  SACs  (covering  1  178  km2  or 
34% of the marine area) and 3 SPAs (covering 316 km 2 or 
9% of the marine area). 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Belgium  legally  protects 
14,60%    of  its  terrestrial  areas  (EU  27  coverage  26,4%) 
and 36,80% of marine areas (EU 27 coverage 10,7%)38.  

The  EU’s  assessment  of  the  sufficiency  of  the  SAC 
network  has  not  been  updated  for  the  last  5  years.  For 
this reason,  published EU-level data on the sufficiency of 
the  network  are  not  up-to-date.  Given  the  significant 
updates of the Natura 2000 Standard Data forms that the 
Belgian authorities have undertaken during this period, it 
is  likely  that  the  remaining  insufficiencies  of  the  Belgian 
Natura 2000 network have mostly been resolved by now. 
Since the re-designation of the “Vlakte van de Raan” SCI, 
network  sufficiency  can  also  be  assumed  for  the  marine 
part of the network of sites under the Habitats Directive. 

The  contribution  of  Belgium  on  the  territorial  protected 
area  target  is  less  than  the  EU  average.  However,  for 
marine protected area, Belgium ranks above the 30% EU 
target.  Therefore,  efforts  are  still  to  be  made  regarding 
terrestrial protected areas. 

Figure 6: EU-27 marine & terrestrial protected area 
coverage, 202139 

38    European  Environment  Agency  (EEA),  Protected  Areas,  terrestrial 
protected  area  percentage 
(2021)  and  marine  protected  area 
percentage (2019), March 2022. 
39  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202140 

Designating SACs and setting conservation objectives 
and measures 

All  Belgian  Natura  2000  sites  proposed  under  the  EU 
Habitats Directive have been designated as SACs. 

Both  Wallonia  and  Flanders  have  regional  conservation 
objectives for their network of sites.  

site-specific 

For  Flanders,  these  objectives  have  been  broken  down 
into site-specific conservation objectives for all SACs and 
SPAs. The remaining SPA areas are thus not yet currently 
covered  by 
conservation  objectives. 
Furthermore,  it  seems  that  Flanders  has  not  set  any 
regional or site-specific objectives for any migratory bird 
species  not  listed  in  Annex  I  of  the  Birds  Directive, 
despite the EU significance of certain migratory breeding 
bird  populations  in  the  region.    In  2020  a  species 
protection program for meadow birds with focus on the 

40  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 

Environmental Implementation Review 2022 – Belgium 

 
 
 
 
                                                                 
 
 
 
                                                                 
black-tailed  Godwit  and  the  Eurasian  Curlew  (Numenius 
arquata)  was  adopted 
the 
conservation  status  of  this  species  group.  Specific 
conservation  objectives  and  measures  for  both  focus 
species have been put forward in this program. 

in  order 

improve 

to 

At  the  Walloon  level,  work  is  still  in  progress  to  break 
down  regional  conservation  objectives  for  habitats  and 
species  into  site-specific  conservation  objectives.  In  the 
meantime, the minimum conservation objectives per site 
are to maintain what is included in the SACs in terms of 
habitats and species of community interest. 

The  setting  of  conservation  measures  for  the  Natura 
2000 sites in Flanders and Wallonia is a work in progress. 
Although Flanders has general management plans at site 
level,  that  identify  the  priority  measures  necessary  for 
the 
improvement  of  the  conservation  status,  more 
specific management actions have only been drawn up so 
far  for  those  parts  of  the  network  under  public  or  NGO 
ownership.  Although  several  projects  are  running  or 
being set up in order to implement the identified priority 
measures  in  the  field,  the  remaining  work  is  mostly 
related  to  the  setting  of  conservation  measures  for 
private lands in Natura 2000. Although it is expected that  
specific  management  actions  for  private  land  where  a 
nature management plan has been approved in the past 
will be completed by the end of 2023, this delay is legally 
problematic 
lacking 
effective legal provisions to prevent deterioration at site 
level, except for the effective implementation of Habitats 
Directive art. 6.3 which is supported by specific guidance 
and  tools  (partly  available,  partly  under  development). 
The problem of nitrogen deposition which affects natural 
areas  and  ecosystems  is  tackled  by  a  tightened  permit 
policy  and  the  enhancement  of    nature  restoration 
projects  within  a  broad    programmatic  approach  (to  be 
fully developed and formally adopted in the near future). 

insofar  as  Flanders 

is  currently 

Wallonia,  on  the  other  hand,  has  a  highly  effective 
scheme to prevent site-level deterioration that applies to 
all  individual  land  sections  within  the  Nature  2000 
network,  irrespective  of  their  ownership  status.  This 
scheme is based on a combination of: (I) a legal regime of 
land-parcel-specific 
general 
land-use  and 
restrictions  based  on 
restoration  potential  of  individual  land  parcels  (the  so-
called  “management  units”).  In  addition,  site-specific 
management plans are currently being drawn up as part  
of the ongoing LIFE integrated project (BNIP)41. 

(ii) 
the  current 

restrictions; 

and 

There  are  currently  no  identified  deficiencies  in  the 
Brussels Capital Region for the designation of SACs or for 
conservation  objectives  and  measures.  The  Brussels 

41 BNIP: Belgian Life integrated project 

Belgium  13 

Capital  Region  has  set  site  specific  conservation 
objectives  for  all  SACs,  including  the  description  of 
general  conservation  measures  for  the  target  habitats 
and  ecological  demands  for  the  target  species.  These 
objectives, measures and ecological demands are further 
being developed in more detailed management plans for 
specific sub-sites within the network. 

through 

The most worrying deficiency in the management of the 
Belgian  Natura  2000  network  is  the  lack  of  effective 
management  of  the  marine  Natura  2000  sites.  The 
marine site Vlakte van de Raan has been designated and 
is already protected, but no  conservation objectives and 
measures  have  yet  been  adopted  for  it.    Site  specific 
conservation objectives are set  for the Vlaamse Banken. 
Based  on  the  current  scientific  knowledge  conservation 
objectives  are  formulated  for  all  protected  species  incl. 
seabirds;  at  the  moment  it  is,  however,  not  possible  to 
formulate site specific objectives for the 3 SPA’s. In these 
areas  the  overall  objective  is  to  maintain  the  current 
status  and  their  function  as  foraging  area.  For  the 
Vlaamse  Banken  and  the  3  SPA’s  management  plans 
including a variety or measures are adopted. The existing 
sites  are  currently  being  deteriorated  in  an  almost 
systematic  way, 
trawling 
(including from non-Belgian vessels which are allowed to 
fish  in  Belgian  waters  according  to  the  EU’s  common 
fisheries policy). A first proposal for measures to restrict 
bottom  disturbing  fisheries  via  a  Joint  recommendation 
under  the  Common  Fisheries  Policy  was  rejected  by  the 
European  Parliament  in  2018.    In  2019  the  federal 
government started a new process in order to come to a 
new,  scientifically  underpinned,  proposal  for  measures 
fisheries.  Given  their 
restricting  bottom  disturbing 
extremely damaging nature,  Belgium should  ensure that 
these  practices  are  not  carried  out  in  violation  of  both 
Articles  6(2)  and  6(3)  of  the  Habitats  Directive.  The 
adoption  in  2016  of  the  Royal  Decree  clarifying  the 
procedures  for  the 
implementation  of  Natura  2000 
improved  the  implementation  of  these  articles  as  the 
appropriate  assessment  is  now  mandatory  for  many 
activities  including  sand  extraction.  At  the  moment  a 
revision  of  the  Marine  Environment  Act  is  conducted 
which should further improve the compliance. 

regular  bottom 

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  reportings  on  the  progress  made 
towards  maintaining  or 
favourable 
the 
conservation status of species and habitats. 

restoring 

According  to  the  report  submitted  by  Belgium  on  the 
conservation  status  of  habitats  and  species  covered  by 
Article  17  of  the  Habitats  Directive  for  2013-2018,  the 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
Belgium  14 

Figure 9:  Assessments on conservation status for 
species for the 2007-2012 and 2013-2018 reporting 
periods44 

share  of  assessments  for  habitats  in  good  conservation 
status  in  2018  is  4.3%.  This  is  lower  than  the  8,6% 
reported  under  the  previous  reporting  period  (2007-
2012), but this difference might be a result of better data 
quality in the more recent report.  

Figure 8:  Assessments on conservation status for 
habitats  for the 2007-2012 and 2013-2018 reporting 
periods42 

On birds, 56% of the breeding species in Belgium showed 
short-term  increasing  or  stable  population  trends  in 
2013-2018  compared  to  66%  for  the  previous  reporting 
period  (2007-2012).  For  wintering  species  requiring  the 
the 
designation 
corresponding figure is 7.6% for 2013-2018, but there is a 
large  proportion  (69%)  of  bird  species  with  unknown 
short-term trends45).  

Protection 

Special 

Areas, 

of 

For  protected species, the  share of assessments in good 
conservation status in 2018 was 25,4%, which was higher 
than  the  19,4%  reported  under  the  previous  reporting 
period (2007-2012)43. Again, this difference might be due 
to a difference in data quality between the two periods. 

42  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 . 
43  Conservation status  and trends of  habitats and species  —  European 
Environment Agency (europa.eu) 

44  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 . 
45  Winter  population  trends  —  European  Environment  Agency 
(europa.eu)  

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
 
                                                                 
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 
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%. 

in  the  use  of  more  hazardous 

Belgium  has  an  estimated  7.25%  of  its  land  area  under 
organic  farming.  This  is  below  the  EU  average  of  9% 
(2020 data, Eurostat)46. 

Figure 10: Share of total utilised agricultural area 
occupied by organic farming per MS, 202047 

Belgium  15 

emissions  from  croplands  remain  much  higher  than  the 
EU average, and increased by 9% between 2013 and 2018 
due  to  increased  fertiliser  use.  Belgium  could  promote 
on-farm carbon assessment tools to help farmers identify 
the most appropriate measures to improve their climate 
performance.  Wetlands  and  peatlands  can  be 
large 
sources  or  wells  of  atmospheric  CO2  and  are  ideal  tools 
for mitigating climate change. 

Farmland bird indices point to significant decreases in the 
population  of  farmland  bird  species  in  Flanders,  and 
especially  in  Wallonia  (farmland  bird  species  fell  by  40% 
in  Wallonia  in  2010-2018).  Data  on  the  farmland  bird 
index  show  a  declining  trend  since  2015  (the  index  for 
Belgium  was  64  in  2015  and  fell  to  53  in  2019,  whereas 
the index value for EU-27 in 2019 was 70)￼48￼ 

On organic farming, the share of the agricultural area  in 
Wallonia  that  is  farmed  organically  is  well  developed 
(11%) but this share remains very low in Flanders (1.3%). 
At  national  level,  66%  of  Belgium’s  total  organic  area  is 
permanent  pasture,  34%  is  under  arable  crops  and  only 
1% is under permanent crops. A shift to a larger organic 
area should be encouraged - in particular for permanent 
crops49. 

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  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. 

As  result  of  the  high  agricultural  production  in  Belgium, 
the  sector  is  characterised  by  high  livestock  density  and 
the  use  of 
impacts  Belgium’s 
environmental  and  climate  footprint.Greenhouse-gas 

fertilisers.  This 

46 Statistics | Eurostat (europa.eu) 
: 
47 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/d
efault/table?lang=en 
farming, 
February 2022)  

(Eurostat,  Area  under  organic 

‘taken’  means 

in  the  degradation 

One  factor 
is  the  area  of  soil 
ecosystems that is sealed or artificialised50: The net land 
is  sealed  or 
taken  (land 
artificialised)  per  year  in  2012-2018  can  be  seen  as  a 
measure  of  one  significant  pressure  on  nature  and 
biodiversity 
constitutes  an 
environmental  pressure  on  people  living  in  urbanised 
areas.   

land  that 

land-use 

change 

- 

48 FBI | Eurostat (europa.eu) 
49 Idem, p.4 
50  Artificial  land  cover  is  defined  as  the  total  of  roofed  built-up  areas 
(including  buildings  and  greenhouses),  artificial  non  built-up  areas 
(including  sealed  area  features,  such  as  yards,  farmyards,  cemeteries, 
car  parking  areas  etc.  and  linear  features,  such  as  streets,  roads, 
railways, runways, bridges) and other artificial areas (including bridges 
and  viaducts,  mobile  homes,  solar  panels,  power  plants,  electrical 
substations, pipelines, water sewage plants, and open dump sites). 

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
 
 
 
                                                                 
land  take 

Despite  a  reduction  in  the  last  decade  (land  take  was 
over  1000  km2/year  in  the  EU-28  between  2000  and 
2006), 
in  the  EU28  still  amounted  to 
539km2/year  in  2012-201851.  The  concept  of  ”net  land 
take“  combines land take with the return of land to non-
artificial land categories (re-cultivation). While some land 
was  re-cultivated  in  the  EU-28  in  2000-2018,  11  times 
more land was taken than returned.   

As  shown  in  Figure  11,  Belgium,  has  a  net  land  take  of 
129.2  m2/km2  . This means that the country ranks above 
land  take  of  83.8  m2/km2. 
the  EU-27  average  for 
However,  Belgium  was  one  of  the  three  Member  States 
that led the re-cultivation of land during the last 6 years. 

its  reporting  on 

In  2018,  Belgium  updated 
land 
degradation  according  to  the  Performance  Review  and 
Implementation  System  (PRAIS3)  reporting  platform52 
with  actions 
intended  to  remedy  the  degradation 
identified. 

However,  Belgium  has  not  yet  committed  to  set  targets 
for land degradation neutrality under the United Nations 
Convention  to  Combat  DesertificationUNCCD.53  The 
Brussels region should set an intermediate target for soil 
demineralization  by  2030.  For  example,  reduce  the  rate 
of soil sealing by half by 2030. 

The Brussels region is good at dealing with soil pollution 
but  should  also  deal  with  other  soil  damage  such  as 
compaction,  loss  of  organic  matter,  biodiversity  and 
nutrients.  Brussels  should  set  a  target  for  2030  which 
could be to have at least 50% healthy soils. 

Belgium  16 

Figure 11: Land take and re-cultivation in the EU-27 
(m2/km2), 2012-201854 

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
part of the Fit for 55 package. The strategy promotes the 
many services that forests provide. Its key objective is to 
ensure  healthy,  diverse  and  resilient  EU  forests  that 
contribute  significantly  to  the  strengthened  biodiversity 
and climate ambitions.  
Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050.  

Of  the  27%  of  EU  forest  area  protected  under  the 
Habitats Directive, less than 15% of assessments show a 
favourable conservation status55. Bad conservation status 
increased from 27% to 31% in the EU compared to 2015.  

Forests  cover  44.73%  of  Belgium56  and  the  situation  of 
forest  habitats  protected  under  the  Habitats  Directive  is 
particularly  worrying  as  more  than  half  of  the  assessed 
protected forests show a bad status57. 

51 Land take in Europe — European Environment Agency (europa.eu) fig 
6. 
52 All Reports | Prais3 (unccd.int). 
53  The LDN Target Setting Programme | UNCCD. 

54 European Environment Agency, Land take in Europe, December 2021. 
55  EEA, State of Nature in the EU 
56 EEA, Forest information system for Europe. 
57 COM SWD (2021) 652 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
                                                                 
Figure  12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  the  EU  Member  States, 
2013-2018 (% assessments) 58 

The European Union Timber Regulation (EUTR)59 prohibits 
the  placing  on  the  EU  market  of  illegally  harvested 
timber. In accordance with the EUTR, EU Member States‘ 
competent  authorities  must  conduct  regular  checks  on 
operators  and  traders,  and  apply  penalties  for  non-
compliance.  With  the  amendment  of  Article  20  of  the 
EUTR,  reporting  every  2  years  has  been  changed  to 
annual  reporting,  and  covers  the  calendar  year  as  of 
2019. 

In  the  period  frm  March  2017  to  February  201960, 
Belgium  carried  out  21  checks  on  operators  importing 
timber.  Over  the  reporting  period,  it  is  estimated  that 
Belgium  had  2  340  operators  placing  domestic  timber 
types  onto  the  internal  market  and  4  800  operators 
placing imported timber types onto the internal  market. 
In  2019  and  202061,  Belgium  carried  out  respectively  27 
and 30 checks on operators importing timber.  

The  European  Commission  proposed  with  the  new 
Deforestation  Regulation51  to  repeal  and  replace  the  EU 
Timber Regulation, essentially integrating and improving 
the existing system to check the legality of  timber.   

Belgium  17 

recalled 

several  annexes 

importing  wood  and  wood 
all  Belgian  companies 
products  covered  by  the  EUTR  regulation  in  2019.  The 
letter  with 
the  EUTR 
requirements,  with  particular  attention  to  the  scope  of 
the  Regulation,  the  types  of  timber  and  products 
concerned,  the 
legal  obligations  of  operators,  the 
guidelines  and  recommendations  for  the  establishment 
of  a  due  diligence  system  and  links  to  assist  with  the 
implementation of such system. 

formation 

Belgium  is  also  partner  in  the  EU  LIFE  II  (2019-2022) 
programme  project  ’Enabling  Effective  Implementation 
and  Enforcement  of  the  EU  Timber  Regulation  in  6  Key 
Timber Importing Countries62, implemented by Preferred 
by  Nature 
intent  on 
(previously:  NEPCon)  and 
strengthening  the  implementation  of  EUTR  by  providing 
stakeholder 
for  market 
participants), tools and detailed risk analyses. The project 
complements  the  previous  NEPCon  LIFE  I  (2016-2018) 
project  ’Increasing  Awareness  and  Capacity  to  Support 
Effective  Implementation  of  the  EU  Timber  Regulation’, 
of  which  the  Belgian  CA  was  also  partner,  by  closing 
remaining 
implementation, 
the 
strengthening  capacities  where  duty  holders  are  still 
struggling to achieve effective compliance. 

(workshops 

EUTR 

gaps 

in 

Invasive alien species (IAS) 

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

A  TAIEX-EIR  peer 
the 
to  peer 
implementation of the EUTR was carried out from 29 to –
31 October 2018 in Belgium with Denmark. 

study  visit  on 

The core of Regulation (EU) 1143/2014 on Invasive Alien 
Species  (the  IAS  Regulation63)  is  the  list  of  invasive  alien 
species of Union concern.  

In  the  middle  of  2020,  The  Belgian  competent  authority 
conducted  an  extensive  information  campaign  aimed  at 

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 

58  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
59 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
60 COM/2020/629 final 
61 ec.europa.eu/environment/forests/eutr_report.htm 

62 preferredbynature.org/projects/closing-gaps-illegal-timber-trade. 
63 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 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
                                                                 
freshwater species; 1 is a brackish-water species; and 1 is 
a marine species. 

Belgium  18 

it 

identified  some  challenges  and  areas 

According  to  a  2021  report64  on  the  review  of  the 
application of the IAS Regulation, 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  invasive  alien  species.  At  the  same  time,  the  above 
report 
for 
improvement. Given that the deadlines for implementing 
the  various  obligations  of  the  IAS  Regulation  applied 
gradually  between  July  2016  and  July  2019, 
is 
premature to draw conclusions on several aspects of the 
implementation  of  the  IAS  Regulation.A  202165￼  on  the 
baseline  distribution  (Figure  13),  shows  that  of  the  40 
species  on  the  Union  list,  40  have  been  observed  in  the 
environment in Belgium. Belgium is finalizing its national 
action  plan.  This  national  plan  will  cover  three  thematic 
action  plans  in  order  to  prevent  the  non-intentional 
introduction of IAS in Belgium : 
1)  Thematic  Action  plan  on  the  introduction  and  spread 
invasive  alien  species  through  public  or  private 
of 
possession; 
2)  Thematic  Action  plan  on  the  introduction  and  spread 
invasive  alien  species  through  recreational  and 
of 
commercial/professional use of freshwater; 
3)  Thematic  Action  plan  on  the  introduction  and  spread 
of 
invasive  alien  species  through  transportation  of 
habitat and nursery material and machinery 

Figure 13: Number of IAS of EU concern, based on 
available georeferenced information for Belgium, 2021 

64    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. 
65  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. 

2022 priority actions 
 

 

 

 

the  Walloon  Region,  establish 

Increase the share of protected and strictly protected 
areas,  as  a  contribution  to  the  EU  Biodiversity 
Strategy for protected areas 
In the Flemish Region, step up the work in the Flemish 
region in terms of establishing conservation measures 
on  private  lands  in  Natura  2000,  and  complete  the 
set-up  of  conservation  objectives    of  extending  the 
conservation  objective  setting  to  migratory  bird 
species 
site-specific 
In 
conservation  objectives  for  all  Natura  2000  sites, 
covering  all  relevant  habitats  and  species  per  site, 
also  including  Annex  I  bird  species  and  migratory 
level  of 
species;  and  ensure  that  the  ambition 
management  plans  and  action  plans,  which  are 
currently  being  developed, 
line  with  the 
in 
conservation objectives at site level. 
In the Natura 2000 sites of the Belgian marine part of 
the  North  Sea,  ensure  the  full  implementation  of 
Article  6(2)  and  6(3)  of  the  Habitats  Directive 
regarding  sand  extraction;  and  propose  (via  a  Joint 
the  Common  Fisheries 
Recommendation  under 
Policy)  fisheries  measures  that  are  suitable  to  allow 
the  sea-bottom  habitats  in  the  marine  Natura  2000 
sites to recover. 

is 

  Reduce  non-CO2  emissions  from  the  livestock  sector 
and  soil  fertilisation.  It  should  maintain  and  improve 
carbon-storage  capacity  by  supporting  grassland 
maintenance 
via 
carbon-farming  approaches  and  the  shift  to  a  bio-
based and circular economy. 

conservation/zero-tillage 

and 

  Support  the  adaptation  of  agriculture  to  future 
climate  changes  by  promoting  adaptive  farming 
practices, landscape-level solutions and investments. 
  Contribute  to  the  EU  Green  Deal  target  to  reduce 
nutrient losses (of both nitrates and phosphorus). 

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
 
Belgium  19 

determined  their  level  of  adequacy  in  relation  to  the 
Commission  Decision  on  criteria  and  methodological 
standards  for  Good  Envrionmental  Status  in  marine 
waters.68  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,  provide  qualitative  and 
quantitative  national  environmental  objectives  to  be 
achieved for their marine waters. 

Figure 14: Level of adequacy of GES determination by 
Belgium (ANS region) with criteria set under the 
Commission GES Decision – Article 9 (2018 reporting 
exercise)69 

Belgium  has  one  marine  sub-region,  ANS-NE  Atlantic: 
Greater North Sea. In this marine sub-region, 9 out of 11 
determinations  of  GES  were  assessed  as  good  or  very 
good.  The  national  determination  of  GES  by  Belgium  is 
coherent for 9 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 State 
has good capabilities to assess their marine environment 
in  accordance  with  the  requirements  set  out  in  the 
Commission GES Decision. 

(ii) 

  Better  protect  biodiversity  by:  (I)  ensuring  that 
protected  habitats  and  species  return  to  favourable 
conservation  status; 
improving  habitats  on 
grassland,  on  cropland  and  even  in  forests;  (iii) 
land  under  contracts 
increasing 
supporting 
landscape 
management; and (iv) strengthening the protection of 
nature  reserves  and  the  expansion  of  Natura  2000 
areas  in  line  with  the  priorities  identified  in  the 
priority action framework. 

the  share  of 
biodiversity 

and/or 

  Contribute to the EU Green Deal target by promoting 
organic  farming  more  strongly,  especially  in  Flanders 
by accelerating the current trend for increasing areas 
of land to be brought under organic farming. 

improve  multifunctionality, 

  Keep  promoting  sustainable  forest  management  and 
afforestation; 
forest 
protection  and  restoration  of  forest  ecosystems; 
increase  carbon  sinks 
in  forests,  their  soils  and 
harvested  wood  products;  support  the  bioeconomy 
via  forestry;  build  resilience  in  its  forests  to  threats 
such as the effects of climate change. 

Marine ecosystems 

to: 

(I) 
The  EU  biodiversity  strategy  2030  aims 
substantially  reduce  the  negative  impacts  on  sensitive 
species  and  habitats  in  marine  ecosystems;  (ii)  achieve 
good  environmental  status;  and  (iii)  eliminate  or  reduce 
incidental  catches  of  protected,  endangered, 
the 
threatened  and  sensitive  species  to  a  level  that  allows 
species recovery and conservation66. 

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

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

The Commission assessed Belgium’s 2018 determinations 
of  GES  for  each  of  the  MSFD’s  11  descriptors67  and 

66  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
67  Annex  I  of  Directive  2008/56/EC  establishing  a  framework  for 
community  action in  the  field  of  marine  environmental  policy  (Marine 
Strategy Framework Directive), OJ L 164, 25.6.2008, p. 19–40. 

68  This  assessment  was  made  in  relation  to  the  ”Commission  GES 
Decision“, Commission Decision No 2017/848, pp. 43-74. 
69  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 – Belgium 

 
                                                                 
 
 
                                                                 
Figure 15: Level of adequacy of national assessment of 
Belgium’s marine environment (ANS region) with 
criteria set under the Commission GES Decision – Article 
8 (2018 reporting exercise)70  

  Ensure  regional  cooperation  with  Member  States 
sharing  the  same  marine  sub-region  to  address 
predominant pressures. 

Belgium  20 

Ecosystem assessment and accounting  

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

In  Belgium,  environmental  policy  related  to  land-use 
planning  is  regionalised.  The  status  of  activities  differs 
between  the  three  regions:  Flanders  has  finished  the 
mapping  and  assessment  of  ecosystems  and  ecosystem 
services, while Wallonia has started this process but  not 
finished  it,  and  Brussels  Capital  Region  has  taken  no 
initiative  so  far.  There  are  no  initiativesto  harmonisate 
ecosystem  mapping  and  assessment  at  national  level. 
The  Belgium  Ecosystem  Services  (BEES)  community  of 
practice is a national platform to connect different actors 
involved  in  research,  practice  and  policy-making  on 
ecosystem-services. 

In  Flanders  the  mapping  and  assessment  of  ecosystems 
and  ecosystem  services  is  carried  out  as  part  of  the 
in  Flanders.  The 
reporting  on  the  state  of  nature 
Research  Institute  for  Nature  and  Forest  (INBO) 
is 
mandated  to  report  every  two  years  on  the  state  of 
nature in Flanders. 

Belgium  is  missing  data  for  one  descriptor,  D4  Food 
webs. 

In the 2019 EIR, the Commission suggested that Belgium: 
(I) provide more information  about  measures to achieve 
GES;  (ii)  draw  up  more  measures  that  have  a  direct 
impact on pressures and quantify the expected reduction 
of  pressure  as  a  result;  and  (iii)  ensure  regional 
cooperation  with  Member  States  sharing  the  same 
marine sub-region to address predominant pressures. 

Furthermore,  in  March  2022,  the  European  Commission 
published  a  Communication  with  recommendations  for 
Member  States.  The  Commission  assessment  highlights 
that  Member  States  need  to  step  up  their  efforts  to 
determine the good environmental status and the use of 
the  criteria  and  methodological  standards  according  to 
the Commission GES  Decision. The above  considerations 
form the basis for the 2022 priority actions. 

In Wallonia, an ecosystem-services platform (WalES) was 
set  up  by  the  former  regional  government  to  put  into 
practice  the  ecosystem-services  concept  across  the 
administration  of  the  Wallonia  region.  For  the  last  two 
years,  the  Walloon  Region  has  increased  the  resources 
dedicated  to  mapping  and  assessing  ecosystems  and 
their  services    For  example,  the  map  of  ecological 
contexts73 has been produced. 

2022 priority actions 

 

the 

staff  working 

the  Commission’s 

recommendations 
Implement 
document71 
in 
outlined 
accompanying 
on 
recommendations  per  Member  State  and  region  on 
the  2018  updated  reports  for  Articles  8,  9  and  10  of 
the MSFD. 

Communication72 

the 

70 Idem. 
71 SWD(2022)1392. 
72  COM(2022)550. 

 In  Brussels,  in  2020  a  first  comparative  study  was 
finalized  to  measure  different  ecosystems  services 
delivered  by  green  infrastructure.  This  first  study  has 
delivered  recommendations  allowing  the  region  to 
develop in a near future a regional tool for measuring ES 
delivered by all GI. 

Belgium  has  not  provided  updated  information  and 
therefore  no  progress  has  been  recorded  since  January 
is  based  on  27 
2016  (Figure  16).  This  assessment 

73https://geoportail.wallonie.be/walonmap#BBOX=186522.0396871636
3,195464.9742396994,110360.51710892707,114607.08810206907#SH
ARE=CE510F0E4AEB5C13E053D5AFA49D7457 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
                                                                 
implementation questions and updated every six months. 

Figure 16: ESMERALDA MAES Barometer, January 2016 - 
March 202174 

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

Figure 17: Ecosystem accounting Barometer, September 
202175 

Belgium  21 

and  public  debate.  Thematic  policy  prioritizes  four 
research  subjects:  climate,  health,  monitoring  of 
sustainable  development  goals  and  development  of 
beyond-GDP  indicators,  monitoring  of  land-use  change.  
In  Flanders,  both  the  extent  account  and  ecosystem 
supply  and  use  accounts  are  published  (physical  and 
monetary terms).  

Identified  challenges  with  the  data  in  Flanders  concern 
carbon  storage  in  biomass;  the  health  effects  of  green 
space;  functional  biodiversity and its contribution to the 
supply  of  ecosystem  services  as  well  as  the  accuracy  of 
land  use/land  cover  map. 
the  base 
Moreover the relevant data, knowledge, skills, resources 
are  scattered  across  different  entities,  this  impedes 
building appropriate ecosystem models. 

layers  of  the 

2022 priority actions 

indicators  for 

  Continue  supporting  the  mapping  and  assessment  of 
ecosystems  and  their  services,  and  the  development 
of  ecosystem-accounting.  It  should  do  this  through 
appropriate 
integrating  ecosystem 
extent, condition and services into national accounts.  
  Continue  supporting  the  development  of  national 
business and biodiversity platforms, including natural-
capital  accounting  systems  to  monitor  and  value  the 
impact of business on biodiversity. 

is 

regionalised.  Therefore 

In  Belgium,  environmental  policy  related  to  land-use 
planning 
the  priorities, 
knowledge  gaps,  support  needed,  and  state  of  research 
depends on the region. The Brussels region has not taken 
any initiatives yet in developing Natural Capital accounts. 
Wallonia  has  just  started  implementing  Nature  Value 
Explorer  tool76.  Therefore  the 
information  provided 
mainly focuses on Flanders. 

A  key  motivation 
for  developing  natural  capital 
accounting  for  Flanders  relates  to  the  ambition  to  bring 
together  and  structure  data  in  support  of  better  policy 

74  European  Commission,  Joint  Research Centre,  Publication Office,  EU 
Ecosystem assessment: summary for policymakers, p. 80, May 2021. 
75  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. 
76 
instruments/natuurwaardeverkenner-nature-value-explorer 

https://ipbes.net/policy-support/tools-

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
 
 
 
 
Belgium  22 

3. Zero pollution 

that 

it  will 

reach  emissions 

projects 
reduction 
commitments  for  all  air  pollutants  covered  by  the 
Directive  for  the  period  2020  to  2029  and  for  2030 
onwards.  Latest  inventory  data  submitted  by  Belgium, 
prior to review by the Commission, indicate that Belgium 
reduction 
is 
compliance  with 
commitments  for  all  pollutants 
  Belgium 
submitted  its  national  air  pollution  control  programme 
on 1 April 2019. 

the  emission 
in  2020. 

in 

Figure 18: Emission trends of main pollutants/ GDP in 
Belgium, 2005-201985 

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.  
impacts  on  ecosystems  and 
Air  pollution  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 clean-air 
legislation,  which 
air-quality 
standards77  and  emissions-reduction  commitments78  by 
Member State for a number of air pollutants.  

health-based 

sets 

At the same time, air quality in Belgium continues to give 
cause  for  concern.  The  latest  available  annual  estimates 
(for  2019)  by  the  European  Environment  Agency79  point 
to Belgium suffering about 6 500 premature deaths each 
year (or 69 300 years of life lost (YLL)) attributable to fine 
particulate  matter  concentrations80;  270  premature 
deaths  each  year  (3  000  YLL)  attributable  to  excessive 
ozone  concentration81￼;  and  750  premature  deaths  a 
year (7 900 YLL) attributable to excessive 82￼83 

The  emissions  of  key  air  pollutants  have  decreased 
significantly in Belgium in recent years, while GDP growth 
has  continued  (see  graph).  According  to  the  projections 
as submitted under Article10(2) of the National Emission 
Reduction  Commitments  Directive  (NECD)84,  Belgium 

77 European Commission, 2016. Air Quality Standards 
78 European Commission, Reduction of National Emissions 
79 European Environment Agency, Air Quality in Europe –2021 Rapport. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106 
80  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
(PM2.5)  refers to  particles with a diameter  of  10  (2.5) micrometres or 
less. PM is emitted from many human sources, including combustion. 
81 Low-level ozone is produced by photochemical action on pollution. 
82  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). 
83  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. 
84 Directive 2016/2284/EU. 

85 European Environment Agency. 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
 
                                                                 
Figure 19: PM2.5 and NOx emissions by sector in 
Belgium, 201986 

In 2020, exceedances above the EU limit values set by the 
Ambient Air Quality Directive (AAQD) were registered for 
in 
nitrogen  dioxide  (NO2) 
Belgium.  Furthermore,  for  several  air-quality  zones,  the 
target values for ozone concentration have also not been 
met87. 

in  four  air-quality  zones 

Belgium  has  not  yet  ratified  the  amended  Gothenburg 
Protocol, Heavy Metals Protocol and POPs Protocol under 
the  United  Nations  Economic  Commission  for  Europe 
(UNECE) Air Convention.  

Persistent  breaches  of  air  quality  requirements,  which 
have severe negative effects on health and environment, 
are  being  followed  up  by  the  European  Commission 

Belgium  23 

covering  all  Member 

through  infringement  procedures  (mainly  for  PM10  and 
NO2  exceedances) 
States 
concerned,  including  Belgium  for  exceedances  of  NO2 
limit  values  in  several  air  quality  zones.  The  aim  is  for 
appropriate measures to be  put  in place to bring all air-
quality zones permanently into compliance. 

Of the different sources of air pollutants other than CO2, 
agriculture is the main source of ammonia emissions (93 
%).  Belgium  has  an  average  risk  of  non-compliance  with 
its  national  ammonia  reduction  commitment,  both  for 
the period 2020-2029 and for 2030 and beyond88. In the 
2019  EIR,  Belgium  received  three  priority  actions  from 
the  Commission:  The  first  was  to  take  specific  actions 
under  the  national  air-pollution  control  programme  and 
the  national  energy  and  climate  plan.  There  has  been 
limited  progress  on  this  first  priority  action.  The  second 
and third priority actions were to reduce concentrations 
of  nitrogen  oxides  (NOx  –  NO2),  particularly  in  urban 
areas and the transport  sector, and to also upgrade and 
improve  air  quality  monitoring.  Despite  measures  taken 
for  NO2,  Flanders  still  fails  to  ensure  in  one  main  urban 
zone, Antwerp, compliance with the limit values for NO2 
set  under  Directive  2008/50/EC.    A  Reasoned  Opinion 
was  adopted  in  18  February  2021,  in  response  to  it. 
Belgium has taken further relevant action on air pollution 
abatement  and  also  decided  to  set  up  new  monitoring 
stations  in  Brussels,  Charleroi  and  Liège.  However,  the  
annual air quality report for 2020 (received in September 
2021)  still  indicates  exceedances  in  concentrations  of 
harmful  pollutants.based  on  high  spatial  resolution 
modelling.  And  Belgium  also  received  a  general  priority 
action  from  the  Commission  in  2019  to  sign  and  ratify 
outstanding international agreements. 

2022 priority actions 

  As part of its national air pollution control programme 
(NAPCP),  take  actions  towards  reducing  emissions  of 
air  pollutants  from  the  main  sources  mentioned 
above. 

  Ensure  full  compliance  with  the  EU  air  quality 
standards  and  maintain  downward  emissions  trends 
of  air  pollutants,  to  reduce  adverse  air  pollution 
impacts  on  health  and  economy  with  a  view  to 
reaching WHO guideline values in the future. 

  Belgium  is  strongly  encouraged  to  accelerate  the 
ratification the amended Gothenburg Protocol, Heavy 
Metals Protocol and POPs Protocol under the  United 
Nations  Economic  Commission 
for  Europe  Air 
Convention. 

, energy and circular economy policies. 

86 European Environment Agency. 
87 European Environment Agency, Eionet Central Data Repository 

88 COM(2020)266 final, ANNEX 3 

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
                                                                 
Industrial emissions 

Figure 20: Number of IED industrial installations per 
sector in Belgium, 201892 

Belgium  24 

 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  Directive  (IED)89.  The  Commission 
tabled a proposal  in April  202290. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular economy policies. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  registry 
(2018)91. 

In  Belgium,  around  2 340  industrial  installations  are 
required  to  have  a  permit  based  on  the  IED.  This  is  an 
increase  of  almost  600  installations  since  2015,  largely 
due  to  a  sharp  increase  in  both  the  waste-management 
sector and in the intensive rearing of poultry or pigs. The 
distribution of installations is shown in Figure 20 below. 

The  industrial  sectors  in  Belgium  with  the  most  IED 
installations in 2018 were: (I) intensive rearing of poultry 
or  pigs  (44%);  (ii)  the  waste-management  sector  (19%); 
(iii) the production of chemicals (11%); (iv) food and drink 
production  (7%);  (v)  surface  treatment  of  metals  (5%); 
and (vi) the power production sector (3%). 

the  mineral  and  chemical 

89  Directive  2010/75/EU  covers  industrial  activities  carried  out 
above  certain  thresholds.  It  covers  the  energy  industry,  metal 
production, 
industry,  waste 
management,  and  a  wide  range  of  industrial  and  agricultural 
sectors  (e.g.  intensive  rearing  of  pigs  and  poultry,  pulp  and 
paper production, painting and cleaning). 
90 
 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). 
91 European Environment Agency, European Industrial Emissions Portal. 

industrial  sectors 

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

 

 

“Other activities” (mostly the surface treatment 
of metals, the intensive rearing of poultry or pigs 
and  the  production  of  pulp  paper)  for  non 
methane volatile organic compounds (NMVOCs), 
ammonia (NH3), copper (Cu), zinc (Zn), cadmium 
(Cd), nickel (Ni), particulate matter (PM2.5));  
chemicals  production  for  NMVOCs,  Nitrogen 
Oxides  (NOx),  sulphur  oxides  (SOx),  Ni,  arsenic 
(As) and mercury (Hg);  

  metal production for lead (Pb), As, SOx;  
 

the  electricity-production  sector  for  NOx,  Zn, 
As,Hg, Ni, chromium (Cr), Cd, Pb and dioxins; 
the waste management sector for dioxins. 

 

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

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
                                                                 
Figure 21: Emissions to air from IED sectors and rest of 
national total air emissions in Belgium, 201893 

Figure 22: Relative releases to water from industry in 
Belgium, 201894 

Belgium  25 

The  environmental  burdens  for  industrial  emissions  to 
water mainly result from: (I) landfills for municipal waste; 
(ii)  the  production  of  pulp  and  paper  and  chemicals 
(nitrogen, phosphorous and total organic carbon); (iii) the 
metals industry; (iv) chemicals production and (v) landfills 
for heavy metals. The breakdown, based on E-PRTR data, 
is presented in Figure 22 below.  

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers the 
public and NGOs to ensure that permits are appropriately 
granted  and  that  the  conditions  of  these  permits  are 
complied  with.  As  part  of  environmental  inspection, 
IED 
competent  authorities  undertake  site  visits  at 
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,  Belgium  undertook 
4 553  site  visits.  The  largest  number  of  visits  were  at 
waste  management  facilities  other  than  landfill  sites 
(23%  of  visits),  rearing  of  poultry  or  pigs  (19%  of  visits), 
chemicals  production  sites  (15%  of  visits)  and  sites  for 
food  and  drink  production  (15%  of  visits)  under  other 
activites. 

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

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

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
 
                                                                 
Figure 23: Number of inspections of IED installations in 
Belgium, 201895  

The  development  of  best  available  technique  (BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED96 Since the last 
EIR report, the Commission adopted BAT conclusions for: 
(i)  waste  Incineration;  (ii)  for  the  food,  drink  and  milk 
industries;  and  (iii)  for  surface  treatment  using  organic 
solvents 
including  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 reduction in pollution.  

In  2019,  Belgium  received  priority  actions  to:  (I)  review 
permits  to  comply  with  newly  adopted  BAT  conclusions 
and  (ii)  strengthen  control  and  enforcement  to  ensure 
compliance  with  BAT  conclusions.  These  actions  have 
been  followed  up  by  the  Commission  through  the 
reporting by Belgium to the EU registry. 

Belgium  participated  in  the  TAIEX-EIR  peer  to  peer 
workshop  on  ammonia-reducing 
technology  and 
measures,  on  16  November  2021  and  the  TAIEX-EIR 
Flagship  workshop  towards  zero  pollution  for  air,  water 
and soil, on 07 February 2022. 

Preventing major industrial accidents – 
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 

95 EU Registry, 2018 (data retrieved on 3 November 2021). 
96 European Commission BAT reference documents 

Belgium  26 

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)97. 

The below overview of industrial plants regulated by the 
Seveso-III  Directive,  (hereafter  ‘Seveso  establishments’), 
is  based  on  data  reported  to  the  eSPIRS  database 
(2018)98  and  the  Belgium  report  on  the  implementation 
of the Seveso-III Directive for the period 2015-201899. 

In  Belgium,  of  the  388  Seveso  establishments,  172  are 
categorised as lower-tier establishments (LTE) and 216 as 
upper-tier establishments (UTE)  – based on the quantity 
of hazardous substances likely to be present in them. The 
UTEs  are  subject  to  more  stringent  requirements.  The 
change  in  of  the  number  of  Seveso  establishments  is 
presented in Figure 24. 

Figure 24: Number of Seveso establishments in Belgium, 
2011, 2014 and 2018100 

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 Belgium, 
an EEP is required for 208 UTEs. In 2018, 215 UTEs had an 
EEP and 215 of these EEPs had been tested over the last 
3  years.  The  summary  of  EEPs  in  Belgium  is  shown  in 
Figure 25.  

97  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances 
98 European Commission, Seveso Plants Information Retrieval System 
99 As provided for by Article 21(2) of the Seveso-III Directive 
100 European Commission, Assessment and summary of Member States’ 
Implementing  Decision  2014/896/EU 
implementation  reports  for 
(implementing  Directive  2012/18/EU  on  the  control  of  major  accident 
hazards involving dangerous substances), 2022. 

Environmental Implementation Review 2022 – Belgium 

 
  
                                                                 
 
                                                                 
Figure 25: Situation regarding EEPs in Belgium, 2018101 

The  following  types  of  information  are  permanently 
available  for  100%  of  the  Seveso  establishments  in 
Belgium:  (i)  information  to  the  public  referred  to  in 
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  were  actively  made 
available  to  the  public  in  recent  years  are  presented  in 
Figure 26.  

Figure 26: Share of UTEs for which information on safety 
measures and requisite behaviours were actively made 
available to the public in Belgium, 2011, 2014 and 
2018102 

Belgium  27 

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 compared to 2017. 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 
in  the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress104. 

limited  set  of  data105, 
In  Belgium,  based  on  a 
environmental  noise  is  estimated  to  cause  at  least 
around  300  premature  deaths  and  1600  cases  of 
ischaemic heart disease annually106. Moreover, some 200 
000 Belgians suffer from disturbed sleep. In Belgium, the 
overall  noise  exposure  increased  by  10%  between  2012 
and  2017  based  on  reported  data.  On  the  basis  of  the 
latest  full  set  of  information  analysed,  both  strategic 
noise maps and action plans to manage noise issues and 
effects have been completed after public consultation.  

In the 2019 EIR, Belgium received two priority actions to 
complete  noise  maps  and  action  plans.  Therefore  no 
priority actions are proposed for 2022. 

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. 

Noise 

The  Environmental  Noise  Directive103  provides  for  a 

101 Idem. 
102 Idem. 
103 Directive 2002/49/EC 

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

Environmental Implementation Review 2022 – Belgium 

 
 
 
 
 
                                                                 
                                                                 
Water Framework Directive 

is 

(WFD)107 

The  Water  Framework  Directive 
the 
cornerstone of EU water policy in the 21st century108. The 
WFD along with  other water-related  legislation109 set  the 
framework 
integrated  water 
sustainable  and 
management, which aims at a high level of protection of 
water 
further 
of 
deterioration and restoration to good status.  

prevention 

resources, 

for 

By March 2022, Member States have to report the third 
generation  of  River  Basin  Management  Plans  (RBMPs) 
under the WFD. The Commission will assess the reported 
status  of  river  basins  and  progress  made  in  these  river 
basins,  checking  how  the  findings 
in  the 
Commission’s  assessment  of  the  second  round  of 
RBMPs110  have  been  addressed.  Belgium  has  not  yet 
reported the 3rd RDMP111.  

identified 

The  Commission  published  in  December  2021  the  6th 
Implementation  Report,  which  assesses  implementation 
of  the  WFD  and  the  Floods  Directive112.  This  report 
includes  an  interim  assessment  of:  (i)  progress  on  the 
implementation of the programmes of measures; and (ii) 
on  monitoring  of  the  ”new”  priority  substances.  The 
assessment  report  for  Belgium113  that  is  part  of  the 
Implementation  Report  says  that  incomplete  data  mean 
it  is  not  possible  to  fully  assess  progress  made,  in 
particular  for  the  Brussels  Capital  Region  and  Wallonia. 
information  reported  by  the  Flemish 
The 
authorities  showed  that  progress  is  being  made  in  the 
implementation  of  measures  for  the  second  half  of  the 
water management cycle (2016-2021). However,the pace 
of  progress  in  Flanders  has  not    been  great  considering 
how  much  time  has  passed.  In  a  nutshell,  it  seems  that 
measures  listed  in  the  second  round  of  Belgian  RBMPs 
have  not  been 
in 
substance  and  timing.  Efforts  are  still  needed  to  reach 
the objectives of the WFD. 

implemented  as  planned,  both 

level  of 

(GWD) 

(2006/118/EC); 

The  Groundwater  Directive 

107 The Water Framework Directive (2000/60/EC). 
108 The EU Water Policy. 
109 
the 
Environmental  Quality  Standards  Directive  (EQSD)  (2008/105/EC);  the 
Floods  Directive  (FD)  (2007/60/EC);  the  Bathing  Waters  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  (MSFD) (2008/56/EC), the Industrial Emissions Directive (IED) 
(2010/75/EU) the new Regulation on minimum requirements for water 
reuse ((EU)2020/741). 
110  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. 
111 Based on information provided in April 2022 by Belgian authorities. 
112  See the 6th Implementation Report of the WFD and FD. 
113 See the assessment report for Belgium 

Belgium  28 

Based  on  the  reporting  of  the  second  round  of  RBMPs 
and data published in 2020114, 26.2% of all surface water 
bodies115 in Belgium have reached good ecological status 
(with only 2.7% of surface water bodies having unknown 
status) and only  2.2% having  good  chemical  status  (with 
0.2%  having  unknown  status).  For  groundwaters,  58.8% 
of  groundwater  bodies  failed  to  achieve  good  chemical 
status and 10.0% are in poor quantitative status. 

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

Figure 27. Proportion of surface water bodies (rivers, 
lakes, transitional waters and coastal waters) in less 
than good ecological status per river basin district116 

chemical 

Figure  28  presents  the  percentage of surface  water 
bodies in Belgium and other European countries failing to 
achieve  good 
the 
percentage is 97.7%, if one includes water bodies failing 
due to substances behaving as ubiquitous PBTs (uPBTS – 
substances  that  are  persistent,  bio-accumulative  and 
toxic).  Without  uPBTs,  25%  of  Belgian  surface  water 
bodies fail to achieve good chemical status. 

status. For  Belgium, 

114  WISE Freshwater (europa.eu) 
115  Rivers,  lakes,  transitional  waters,  coastal  waters,  and  territorial 
waters. 
116 European Environment Agency, 2021.   

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
                                                                 
Figure 28. Percentage of surface water bodies not 
achieving good chemical status117 

Figure 29: Water abstraction per sector in Belgium120 

Belgium  29 

Under  the  IED  framework,  it  should  be  stressed  that 
Belgium  showed  a  significant  decrease  the  last  decade 
(40.3%) in industrial releases of heavy metals like Cd, Hg, 
Ni,  Pb  and  (4.4%)  in  Total  Organic  Carbon  (TOC)  to 
water118. 

The  total  water  abstracted  annually  (corresponding  to 
2019  baseline)  from  surface  and  groundwater  sources 
in Belgium is 5846.07 hm3  (EEA,  2022).   The  percentage 
for water abstraction per sector is 0,05% for agriculture, 
12.81%  for  public  water  supply,  58.43%  for  electricity 
for 
cooling,  15.60% 
manufacturing  cooling  and  0.68% 
for  mining  and 
quarrying (Figure 29). Belgium uses a register to monitor 
water  abstractions.   Each  Region  makes  use  of  its  own 
system119.  Small  abstractions  do  not  require  permits  in 
Belgium,  but  most    small  abstractions  are  nevertheless 
registered (at least in recent years).  

for  manufacturing,  12.43% 

117 European Environment Agency, December 2019. 
118 European Environment Agency, June 2021 EEA, 2021 
119 No federal competence. 

index 

exploitation 

plus 
In Belgium, the  water 
(WEI+)121 was 7.31% (in 2017), which is less than the 20% 
that is generally considered 
water 
scarcity122.  Belgium is  ranked 8th  (with  1st  indicating  a 
country  that  has  a  high  WEI+  and  therefore  a  country 
with water-scarcity problems) in the EU. 

indicate 

to 

Figure 30. Water-exploitation index plus (WEI+) inside 
EU, 2017123 

As part of the Belgian RRP124, Flanders aims to accelerate 
is 
its  water-retention  actions  because  the  region 
becoming  prone  to  water  shortages  due  to  droughts. 
Flanders aims to achieve this 'Blue Deal’ through: (i) the 
restoration  and  creation  of  wetlands;  (ii)  integrating 
waterbodies  and  other  natural  environments  together 
into  a  broader  network  that  spans  both  cities  and  rural 
areas; (iii) the installation of water buffers at large scale; 

in 

sector 

120  European  Environment  Agency, Water  abstraction  by  source  and 
economic 
Europe, 2022. 
https://www.eea.europa.eu/ims/water-abstraction-by-source-
and 
121 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. 
122 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. 
123 European Environment Agency (EEA), Water exploitation Index Plus, 
2022. 
124  Belgium’s  recovery  and  resilience  plan  |  European  Commission 
(europa.eu) 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
 
 
                                                                 
(iv) the use of innovative water-saving technologies; and 
(v) investing in research on water conservation. 

Bathing Water Directive 

Belgium  30 

On  the Bathing Water Directive,  Figure 32  shows that  in 
2020, out of the 118 Belgian bathing waters, 81.4% were 
of  excellent  quality128.  Detailed  information  on  Belgian 
bathing  waters  is  available  from  a  national portal129  and 
via  an 
the  European 
Environment Agency130. 

interactive  map  viewer  of 

Figure 31: Bathing water quality in Europe in the 2020 
season131 

.  

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 
report125 showed that, all three Belgian regions provided 
an  overview  with  the  required  information.  However, 
Belgium’s decision todesignate  the whole country as an 
area of potential significant flood risk is quite broad and 
could  probably  be  refined.  Yet,  smaller-scale  data  is 
already used on regional and subregional level where it is 
more effective for flood risk actions and plans. However, 
both  Wallonia  and  Flanders  have  developed  practical 
computer-based map viewers  to assess flood risk. These 
it  possible  to  visualise  relevant 
map  viewers  make 
good 
regions  provided 
information, 
methodologies  to  assess  future  flood  risks 
in  their 
preliminary flood-risk assessments. Brussels and Wallonia 
should  consider  developing  a  quantitative  methodology 
to assess the potential impact  of future floods and their 
impact  on  human  health,  the  environment,  economic 
activity and cultural heritage.  

and  both 

Belgium has  not  yet  reported on  the second generation 
of  flood  risk  management  plans  (FRMPs)  under  the 
Floods  Directive.  The  European  Commission  will  assess 
progress  made  since  the  adoption  of  the  first  flood  risk 
management plans and publish a report on this, as it did 
in 2019.  

Drinking Water Directive 

On  the  Drinking  Water  Directive126,  no  new  assessment 
of  the  quality  of  drinking  water  is  available  since  the  
2019 EIR. The quality of drinking water in Belgium has not 
been indicated as an area of concern. 

The  recast  Directive127  entered  into  force  on  12  January 
2021, and Member States have until 12 January 2023 to 
transpose it into their national legal system. Belgium will 
have to comply with these revised quality standards. 

125  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 : Belgium, 2022. 
126 OJ L 330, 5.12.1998, p. 32–54. 
127 OJ L 435, 23.12.2020, p. 1–62. 

128  European  Environment  Agency,  2021.  State  of  bathing  water  — 
European Environment Agency (europa.eu)  , p. 17. 
129 for Belgium-Flanders : www.kwaliteitzwemwater.be and for Belgium-
Wallonia : http://environnement.wallonie.be/baignade  
130  EEA,  State  of  bathing  waters  in  2020  —  European  Environment 
Agency (europa.eu) 
131 European Environment Agency, Bathing Water Quality in 2020, 2021. 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
 
                                                                 
Figure 32: Belgium, Bathing water quality 2017-2020132 

Urban Waste Water Treatment Directive 

Belgium  31 

Belgium  has,  over  the  years,  encountered  difficulties  in 
meeting  its  obligations  under  the  Urban  Waste  Water 
Treatment Directive.  

Overall,  in  Belgium,  the  compliance  rate  is  95%  which  is 
higher  than  the  EU  average  (76%)  in  2018.  13.1%  of 
urban  wastewater  in  Belgium  is  not  collected  and/or 
does not meet the requirements for biological treatment. 

Figure 33: Proportion of urban waste water that meets 
all requirements of the Urban Wastewater Treatment 
Directive (collection, biological treatment, biological 
treatment with nitrogen and/or phosphorus removal) in 
compliant urban areas of the UWWTD (‘compliance 
rate’), 2018133 

Nitrates Directive 

According  to  the  latest  information    available  on  the  
implementation  of  the  Nitrates  Directive,    pollution  by 
nitrates  of  ground  water  and  surface  water  remains 
widespread  in  Flanders.  Flanders  has  seen  significant 
increases  in  certain  areas  and  stable  values  in  other 
areas, but at levels exceeding the threshold of 50 mg/l of 
nitrates or remaining very close to that threshold. Almost 
all (97%) surface waters in Flanders were reported to be 
in a eutrophic state by the end of 2019. Thus, what was 
indentified as a  rather positive trend in the previous EIR 
reports has now turned into a clearly negative trend, with 
the  pollution  of  water  by  nitrates  in  Flanders  being 
among the highest in the EU. In Wallonia reporting shows 
that  pollution  levels  are  less  worrisome  overall,  with 
concentrations  in  ground  water  generally  showing  a 
trend  of  reduction.  However,  for  surface  water,  some 
monitoring  stations  in  Wallonia  are  starting  to  show  an 
upward  trend.  15%  of  surface  waters  are  eutrophic. 
Moreover, the Walloon authorities have fallen behind in 
carrying  out  the  mandatory  review  of  their  nitrates-
action plan (Programme de gestion durable de l'azote en 
agriculture),  which  is  subject  to  a  pending  infringement 
procedure at the stage of reasoned opinion under Article 
258  of  the  Treaty  on  the  Functioning  of  the  European 
Union. 

improvements 

In  recent  years,  there  have  been 
in 
compliance    with  the  Urban  Waste  Water  Treatment 
Directive,  for  which  the  use  of  EU  funding  has  been 
fundamental.  But  despite  these 
improvements,  the 
incomplete  implementation  of  the  Urban  Waste  Water 
Treatment  Directive  has  led  to  several  rulings  of  the 
Court  of 
Justice  of  the  European  Union  against 
Belgium134.  Moreover,  the  Commission  decided  in  June 
2021 to issue a reasoned opinion to Belgium for its failure 
since  2005  to  comply  with  Urban  Waste  Water 
Treatment Directive requirements in 11 agglomerations. 

2022 priority actions 

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

  Urgent  action  to  improve  water  quality  -  both  in 
surface  water  and  ground  water  bodies,  tackling 
pollution by nitrates in particular. 

  Efforts  should  be  made  to  improve  the  coordinated 
implementation of water, marine and nature policies. 

132  European Environment Agency, European Bathing Water Quality in 
2017, 2018, 2019, 2020. 

133 European Commission, WISE Freshwater, 2021. 
134 Cases C-395/13 and  C-533/11   

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
 
                                                                 
Belgium  32 

CLP  Regulation)  using  a  set  of  indicators  on  different 
aspects of enforcement.  

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

  Federal  Public  Service  Health,  Food  Chain  Safety  and 
Environment, 
Environment 
Inspection  Service  (also  responsible  for  checking 
compliance with the CLP Regulation); 

Environment, 

DG 

  Federal Public Service Employment, Labour and Social 
Dialogue  (also  responsible  for  checking  compliance 
with the CLP Regulation); 

  The Flemish government - Environment Department - 

Enforcement Section; 

  Brussels-Capital Region – Bruxelles Environnement; 
  Wallonia 
-  Directorate-General 

for  Agriculture, 

Natural Resources and the Environment (DGARNE) 

Belgium  has  not  yet  devised  a  REACH  enforcement 
strategy.  It  only  has  a  CLP  strategy,  which  is  partly 
implemented139.  On  enforcement,  Belgium  prioritises 
areas that are the most sensitive to consumers (children 
and the general public). 

In  Belgium,  17.5  full  time  equivalent  workers  (FTEs)  are 
allocated  to  REACH  and  CLP  enforcement140. There  are 
169 REACH controls in the reporting period and 199 CLP 
controls, well below average. Most  of  the  REACH  controls 
done  are  proactive,  compared  with  reactive/non-routine 
CLP  controls  (i.e.  investigations  in  response  to  complaints, 
accidents and referrals)141.  Although the level of expertise 
among  the  Belgian  authorities  has  increased  since  the 
last  reporting  period,  it  is  still  not  sufficient  for  some 
specific  tasks  under  REACH,  namely  in  relation  to  risk 
management and some specific areas of concern such as 
nanomaterials  and  endocrine  disruptors.  The  high 
percentage  of  non-compliance  cases  out  of  the  total 
number controls should be underlined142￼. 

  Complete implementation of the Urban Waste Water 
Treatment  Directive  for  all  remaining  non-compliant 
agglomerations. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment.  In 
October  2020,  the  Commission published  its  chemicals 
strategy  for  sustainability  -  “Towards  a  Toxic-Free 
environment”,135 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. 

legislation136 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  Regulations137,  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 since 2015. However, it is apparent from 
this  report  that  there  are  still  many  disparities  in  the 
implementation  of  the  REACH  and  CLP  Regulations,and 
notably  in  the  area  of 
law  enforcement.  Recorded 
compliance  levels  in  Member  States  seem  to  be  quite 
stable over time, but with a slight worsening trend, which 
is  likely  due  to:  (i)  enforcement  authorities  being  more 
effective 
non-compliant 
products/companies;  and 
(ii)  more  non-compliant 
products being put on the EU market. 

detecting 

in 

In August 2021, the Commission published a  measurable 
assessment  of  the  enforcement138  of  the  two  main  EU 
Regulations on chemicals (the REACH Regulation and the 

135 COM(2020) 667 final 
136  Principally  for  chemicals:  REACH  (OJ  L  396,  30.12.2006,  p.1.);  for 
Classification,  Labelling  and  Packaging,  the  CLP  Regulation  (:  OJ  L  252, 
31.12.2006,  p.1.),  together  with  legislation  on  biocidal  products  and 
plant protection products. 
137 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu) 
138  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 

139 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76 
140 European Commission, Final Report, on the operationof REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 74. 
141 European Commission, Final Report, on the operationof REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 96. 
142 European Commission, Final Report, on the operationof REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p.88 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
                                                                 
Figure 34: Percentage of non-compliance cases out of 
the total number of REACH and CLP controls during 
2019 per Member State and compared to the EU 
average143 

Belgium  33 

2022 priority actions 

  Upgrade the administrative capacities in implementation 
and  enforcement  towards  a policy  of  zero  tolerance  for 
non-compliance. 

  Fully implement the enforcement strategy for the CLP 
Regulation and also devise and implement a strategy 
for the enforcement of the REACH Regulation. 

143 European Commission, Final Report, on the operationof REACH and 
CLP,  Final  report_REACH-CLP  MS  reporting_2020.pdf  (europa.eu), 
pp.87-88 

Environmental Implementation Review 2022 – Belgium 

 
 
 
 
 
 
                                                                 
Belgium  34 

4. Climate action

 In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing  greenhouse  gas  (GHG)  emissions  by  55%  by 
2030  compared  to  1990.  The 
limits  the 
contribution  that  carbon  removals  can  make  towards 
emission  reductions  in  2030,  to  ensure  a  sufficient 
mitigation effort.  

law  also 

The  EU  and  its  Member  States  submitted  updated 
Nationally  Determined  Contribution 
the 
UNFCCC in December 2020.  

(NDC) 

to 

The  EU  is  working  across  all  sectors  and  policies  to  cut 
GHG  emissions  and  make  the  transition  to  a  climate-
neutral  and  sustainable  economy,  as  well  as  addressing 
the unavoidable consequences of climate change.  

EU  climate  legislation  incentivises  emissions  reductions 
from power generation, industry, transport, the maritime 
sector and fluorinated gases (F-gases) used in products.  

For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010144  and  sets  binding  GHG  emission 
standards for different vehicle categories145. Under the F-
gas  Regulation,  the  EU’s  F-gas  emissions  will  be  cut  by 
two thirds by 2030 compared with 2014 levels. 

From  2021,  emissions  and  removals  of  GHGs  from  land-
use,  land-use-change  and  forestry  (LULUCF)  have  been 
included in the EU emission-reduction efforts.  

The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
required to report on their national adaptation policies146 
,  as  the  EU  Climate  Law  recognises  adaptation  as  a  key 
component  of  the  long-term  global  response  to  climate 
change.  Member  States  will  be  required  to  adopt 
national  strategies,  and  the  EU  will  regularly  assess 
progress  as  part  of  its  overall  governance  on  climate 
action. The updated EU adaptation strategy, published in 
February  2021,  sets  out  how  the  EU  can  adapt  to  the 
unavoidable  impacts  of  climate  change  and  become 
climate resilient by 2050. 

144  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. 
145 Regulation (EU) 2019/631. 
146 Article 29 of Regulation (EU) 2018/1999. 

Key national climate policies and strategies  

Belgium  has  an  integrated  national  energy  and  climate 
plan  for  years  2021-2030  that  includes  investments  and 
reforms  in  line  with  its  target  under  the  Effort  Sharing 
Regulation.  The  work  under  the  national  energy  and 
climate  plan  is  also  consistent  with  Belgium’s  long-term 
strategy to 2050. The long-term strategies of the regions 
envisage the following overall emissions reductions: 
•  The  long-term  strategy  of  Wallonia  aims  to  achieve 
carbon  neutrality  by  2050,  through  a  reduction  of 
greenhouse  gas  emissions  by  95%  compared  to  1990, 
supplemented  by  measures  regarding  carbon  capture 
and use, and negative emissions; 
•  The  long-term  strategy  of  Flanders  aims  to  reduce 
greenhouse  gas  emissions  from  the  so-called  non-ETS 
sectors  by  85%  by  2050  compared  to  2005,  with  the 
ambition  to  move  towards  full  climate  neutrality.  As 
regards  the  sectors  covered  by  the  ETS,  Flanders 
subscribes  to  the  context  set  out  by  the  EU  for  these 
sectors with a decreasing emissions quota; 
•  The  long-term  strategy  of  the  Brussels-Capital  Region 
sets  the  objective  of  moving  closer  to  the  European 
target  of  carbon  neutrality  by  2050,  in  the  urbanised 
context of Brussels. 

The  ambition  of  the  Federal  State  is  to  achieve  climate 
neutrality  by  2050.  Belgium  is  required  to  contribute  to 
reaching  EU  climate  neutrality  by  2050  in  line  with  the 
EU’s Climate Law. 

In its RRP, Belgium allocates 50% of the funds to climate 
change  policies  and  outlines  crucial  reforms  and 
investments  to 
further  the  transition  to  a  more 
sustainable,  low-carbon  and  climate-resilient  economy 
(see Chapter 5). 

Belgium  adopted  its  national  climate  change  adaptation 
strategy147  in  2010  and  its  national  adaptation plan148  in 
2017. It has been evaluated in 2019 (at midterm) and in 
2021.  A  new  plan  is  foreseen  by  the  end  of  2022. 
Adaptation in Belgium is addressed at different levels: At 
the  national  level,  adaptation  is  addressed  within  the 
national  adaptation  strategy  and  plan,  which  contains 

147 
nkc.be/sites/default/files/report/file/be_nas_2010.pdf 

https://www.cnc-

148 https://climat.be/doc/NAP_EN.pdf 

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Belgium  35 

actions  that  are  complementary  to  those  contained  in 
the  regional  plans  (i.e.  the  plans  for  Flanders,  Wallonia, 
Brussels  Capital).  Adaptation  is  addressed  at  local  level 
with the municipalities that have signed the Covenant of 
Mayors on Urban Adaptation to Climate Change. To take 
national  decisions 
and 
coordination  committees  where  governments  (regional 
and federal) and ministries are represented.  

commissions 

there 

are 

Between 1990 and 2020, economy-wide greenhouse gas 
emissions in Belgium decreased by 26%, less than the EU 
average. 

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

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

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  legislation149.  Under  EU 
legislation,  Belgium  has  a  target  to  reduce  greenhouse-
gas emissions in the non-ETS sectors (buildings, road and 
domestic  maritime  transport,  agriculture,  waste  and 
small  industries)  by  15%  by  2020  and  by  35%  by  2030. 
Belgium’s  greenhouse  gas  emissions  in  these  sectors  in 
2020  were  17%  below  2005  levels  (proxy  data).  The 
national  energy  and  climate  plan  foresees  the  adoption 
of additional measures to achieve Belgium’s 2030 target 
of a -35% reduction in emissions for the non-ETS sectors.  

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

149 Regulation (EU) 2018/842 

Key sectoral developments 

In road transport, the greenhousegas intensity of vehicle 
fuels in Belgium decreased by 3% from 2010 to 2019. It is 
therefore  unlikely  that  the  2020  reduction  target  of  6% 
will  be  reached.  There  are  several  types  of  action  that 
Member  States  can  take  in  this  regard,  for  example:  (i) 
further expanding the use of electricity in road transport; 
(ii) supporting the use of biofuels, and advanced biofuels 
in  particular;  (iii)  incentivising  the  development  and 
deployment  of  renewable  fuels  of  non-biological  origin; 
and  (iv)  reducing  upstream  emissions  before  refining 
processes.  The  Belgian  NECP  and  RRP  include  several 
such measures. 

Road  transport  in  2019  in  Belgium  represented  20%  of 
the  country’s  total  greenhouse  gas  emissions.  Emissions 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
 
 
 
 
of greenhouse gases from road transport have decreased 
by 3% compared to 2005.  

Figure 39: Reported and accounted emissions and 
removals from LULUCF  in Belgium152 

Figure  38:  Greenhouse  gas  emissions  by  sector  in 
Belgium 150 – historical emissions 1990-2020, projections 
2021-2030151 

Belgium  36 

On  buildings,  energy-efficient  renovation  and 
fuel 
switching  are  major  priorities.  In  its  assessment  of  the 
the 
Belgian  national  energy  and 
Commission  has  recommended  that  Belgium:  (I)  reform 
energy 
flanking  social 
in  combination  with 
measures;  (ii)  address  the  current  shortage  of  workers 
with  the  necessary  skills  in  the  construction  sector;  and 
(iii) simplify the procedure for building permits. 

climate  plan, 

taxes 

Greenhouse  gas  emissions  from  agriculture  in  Belgium 
have seen a small reduction. 

In  the  land  use,  land  use  change  and  forestry  (LULUCF) 
sector, Belgium is projected to see moderately increasing 
net  removals  of  CO2  equivalent  by  2030.  Reported 
quantities under the Kyoto Protocol for Belgium show net 
removals of, on average, -1.7 Mt CO2-eq in 2013 to 2019. 
Belgium  therefore  contributes  roughly  0.5%  to  the  EU-
27's  annual  average  carbon  sink  of  -344.9  Mt  CO2-eq. 
Using  a 
scheme,  carbon 
accounting for the same period shows net credits (i.e. the 
equivalent  of  carbon  removals)  of,  on  average,  -0.6  Mt 
CO2-eq,  which  corresponds  to  0.5%  of  the  EU-27 
accounted  sink  of  -115.0  Mt  CO2-eq.  Reported  net 
removals  and  accounted  net  credits  show  a  decrease 
from 2015 to 2018. 

separate  measurement 

Use of revenues from the auctioning of EU ETS 
allowances 

from 

revenues 

Total 
the  auctioning  of  emission 
allowances  in  Belgium  under  the  EU  ETS  in  2012-2021 
were over EUR 2.2 billion. Between 2013-2015 auctioning 
revenues  were  not  spent  pending  a  legal  decision.  The 
auctiong  revenues  from  2013  to  2015  have  been 
earmarked  and  were  partly  committed  and  disbursed 
over  the  following  years.  In  addition,  Belgium’s  general-
government budget is used to finance climate and energy 
projects.  

2022 priority actions 

  Further reduce greenhouse-gas emissions in the road 
transport  sector,  including  by  promoting  sustainable 
mobility, investing in public transport, and rolling-out 
infrastructure  for  electrical  and  hydrogen  powered 
vehicles,  in particular  in the  context of greening   the 
company-car scheme.  

  Produce  and  distribute  new  energy  vectors,  such  as 
hydrogen,  and  support  carbon  capture,  use  and 
storage. 

  Develop substantial clean energy infrastructure. 

150  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. 
151 European Environmental Agency, Total GHG trends and projections. 

152  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 – Belgium 

 
 
                                                                 
 
 
 
                                                                 
Belgium  37 

Part II: Enabling framework: Implementation tools 

5. Financing 

Environmental investment needs in the 
European Union 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps .  

Post-2020,  environmental  measures  will  also  be 
supported by the EU’s  COVID-19 Recovery  Fund (via  the 
RRF) and the ‘do no significant harm’ principle which runs 
across the EU budget. The renewed commitments made 
at  COP26  (Glasgow,  October-November  2021)  and  the 
Biodiversity  Convention  (April-May  2022)153  will  also  be 
reflected 
in  the  EU  budget.  Overall  environmental 
investment gaps (EU-27) 

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)154  with  a  further  EUR  130  billion  a  year  to 
deliver  the  EU's  core  environmental  objectives155.  The 
costs  of  climate  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  year156.  Those 
  needs  reflect  the 
investment 
implementation  objectives  to  2020  and  to  2030  (except 
for  climate-change  adaptation,  the  costs  of  which  are 
expected to last over a longer time horizon).  

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1157.  Almost  40%  of 
the  environmental  investment  needs  relate  to  dealing 
with  pollution,  which  accounts  for  nearly  two-thirds  of 

in  circular  economy  and  waste 

the  total  gap  if  combined  with  water  management.  The 
investment  gap 
is 
estimated  between  EUR  13-28  billion  a  year,  depending 
on 
implemented.  The  annual 
biodiversity financing gap is estimated at around EUR  20 
billion.  

levels  of  circularity 

Table 1 - Estimated breakdown of the EU’s 
environmental investment needs, by environmental 
objective, 2021-2030 (per year)158 

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

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems159 

R & D & I and other 

Total 

& 

 21.5 

 6.2 

 110.1 

% 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Environmental-investment needs in Belgium  

There  is  a  clear  shift  of  investment  priorities  in  Belgium 
to support climate policies, as can be seen in the Belgian 
RRP.  The  focus  in  the  RRP  is  on  sustainable  energy  and 
transport  reducing  greenhouse  gases.  The  Belgian  RRP 
strongly  supports  the  energy-efficient  renovation  of 
buildings and the decarbonisation of the energy, industry 
and  transport  sectors.  These  are  all  areas  with  major 
needs for reaching the 2030  energy and climate targets. 

153  The  Convention  on  Biological  Diversity  (cbd.int);  Post-2020 
Global Biodiversity Framework | IUCN. 
154  SWD(2021)621,  accompanying  proposal  COM(2021)557  to  amend 
the REDII Directive (EU) 2018/2001. 
155 SWD(2020) 98 final/2. 
156  SWD(2018)292.  Impact  assessment  accompanying  the  Proposal  for 
the LIFE Regulation (COM(2018)385). 
157  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  

158 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.  
159  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  fully  covering  the  strategy 
(including restoration) may require EUR 30-35 billion, indicating a gap of 
EUR 10-20 billion a year compared to current baseline expenditure. 

 Environmental Implementation Review 2022 – Belgium 

 
 
 
 
                                                                 
 
                                                                 
investment  priorities  address  the  needs  or 
Climate 
‘investment gaps’ in a wide set of economic sectors such 
as  the  energy  renovation  of  housing,  e-mobility  and 
transportation infrastructures. 

The  following  paragraphs  set  out  the  environmental 
investment  needs 
in  four  different  environmental 
priority  sectors:  pollution  prevention  and  control;  water 
management;  waste  and  the  circular  economy;  and 
biodiversity and ecosystems.    

Pollution prevention & control 

The  EU’s  first  Clean-Air  Outlook160  under  the  clean  air 
programme  estimated  that,  to  reach  the  emissions 
reduction requirements161 in the NECD by 2030, total air-
pollution  control  costs  for  Belgium  would  be  equivalent 
to  EUR  2.1  billion  per  year.  This  includes  EUR  1.2  billion 
for  capital  investment  (assuming  Belgium  achieves  the 
2030 climate and energy targets).  

The  second  Clean-Air  Outlook  suggests162  that  the  EU 
would  largely  achieve  the  reductions  of  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NEC  Directive  for  2030  if:  (i)  all  relevant  legislation 
adopted  up  to  2018  is  implemented  (including  all  air 
pollution 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 
for  15  Member  States,  excluding  Belgium.  Belgium,  has 
an  average  risk  of  non-compliance  with  its  national 
ammonia  reduction  commitment  (and  therefore  has  a 
less  serious  ammonia  problem  than  the  15  Member 
States), both for the period 2020-2029 and for 2030 and 
beyond163.  The  NEC  Directive  also  requires  certain 
emission  reductions  already  for  the  period  2020-2029, 
including  a  requirement  that  Member  States  make  pro-
rata  progress  towards  the  2030  targets  by  2025  (based 
on  a  linear  or  more  flexible  trajectory),  implying  that 
investments need to be implemented in a timely manner.  

160 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 
2018. 
https://ec.europa.eu/environment/air/pdf/clean_air_outlook_overview
_report.pdf 
161  Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005. 
  Requirements  are  based  on  Directive  (EU) 
2016/2284. 
162 COM(2021) 3 Final and Report Annex.   
163 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 2018. 

Belgium  38 

Water management  

in  remediation 

from  households 

infrastructure).  There 

According  to  the  OECD  study  ‘Financing  Water  Supply 
Sanitation  and  Flood  Protection’  (2020)  164,  Belgium 
low  water  stress  with  moderate  water 
experiences 
resources  and  also  faces  a  risk  of  non-compliance  with 
water-quality directives due to pressure from agricultural 
for  some  quality  parameters  as 
production  and 
(investment 
phosphorus  pressure 
needed 
is  a 
projected significant increase in the value of assets at risk 
from  river,  rainfall,  and  coastal  flooding  in  Belgium. 
Rivers  account  for  about  40%  of  Belgium’s  annual 
freshwater availability, with net  precipitation accounting 
for  the  rest.  The  major  aquifers  are  in  Wallonia,  which 
supplies 55% of the country’s water, despite only housing 
37% of the population. This means that the other regions 
are  highly  dependent  on  water  flows  from  Wallonia. 
Groundwater  meets  approximately 
thirds  of 
Belgium’s  needs  for  drinking  water  (EurEau,  2017). 
Industry  is  the  largest  user  of  freshwater  resources, 
accounting for around 85% of total use (WWF, 2018). 

two 

EU  funding  has  provided  a  significant  share  of  public 
funding  for  water  treatment  in  Belgium  over  the  past 
decade165.  It  is  also  estimated  that  Belgium  will  need  to 
invest  an  additional  EUR  3.3  billion  euros  (around  330 
million per year, over baseline investments)166, by 2030 in 
water 
infrastructure,  with  85%  of  that  relating  to 
wastewater. 

According  to  the  same  study,  Belgium  is  at  risk  of  river-
related,  rainfall-related,  and  coastal  flooding  across  its 
whole territory, with these risks likely to increase due to 
both  demographic  changes  and  climate  change.  Indeed, 
the  European  Commission  forecasts  North  Sea  coastal 
cities  as  being  among  the  areas  most  at  risk  of  future 
flooding  (EEA,  2017b).  Belgium  is  one  of  the  European 
countries facing the largest increase in the value of assets 
at risk  due to possible future river flooding (WRI, 2015). 
There  is  a  unique  risk  of  flooding  in  Belgium  due  to  the 
extensive  enclosure  of  water  courses  in  urban  areas.  If 
there is heavy rain, this can cause the system to backup 
and overflow upstream (OECD, 2007). Ongoing efforts to 
restore  more  natural  hydromorphology  (i.e.  to  restore 
rivers to their original shape and direction before humans 
began altering them)  should help to mitigate these risks 
over time.  

164 European Commision, Study on investment needs in the waste sector 
and  on  the  financing  of  municipal  waste  management  in  Member 
States, 2019. 
165  OECD,  Financing  Water  Supply,  Sanitation  and  Flood  Protection: 
Challenges and Options, Factsheet Belgium, 2020 
166  OECD,  Financing  Water  Supply,  Sanitation  and  Flood  Protection: 
Challenges and Options, 2020 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
                                                                 
flooding  caused  great  damage 

 In  July  2021,  flooding  devastated  the  southern  part  of 
Belgium,    causing  great  loss  of  life  and  tremendous 
economic  damage.  This  suggests  that  Belgium,  and 
Wallonia  in  particular,  should  ensure  that  its  latest 
preliminary  flood-risk  assessments  are  still  relevant,  and 
identified  as  areas  of  significant  flood  risk  are  still 
relevant.  The 
to 
infrastructure and whole districts must now be rebuilt. As 
a  result,  Wallonia  announced  it  would  redirect  EUR  800 
million from its own recovery plan to repair the damage 
caused by the flooding. Wallonia has now set aside EUR 2 
billion  to  deal  with  the  consequences  of  the  flooding. 
Moreover,  the  recent  6th  Water  Framework  Directive 
and  Floods  Directive  Implementation  Report167  and  the 
financial - economic study168 accompanying it, are also a 
relevant source of information in this domain. 

Waste & the circular economy 

Significant  investments  are  included  in  Belgium’s  RRP. 
These  include:  (I)  the  federal  initiative  “Belgium  Builds 
Back Circular” (10 circular projects and awareness-raising 
among  SMEs);  (ii)  the  “Recycling  Hub”  created  by  the 
Flanders  (6  investments  in  new  recycling  facilities);  and 
in 
(iii)  the  “Deployment  of  the  Circular  Economy” 
Wallonia  (reuse,  upscaling  and  recycling  of  metals  and 
construction  materials;  enhancing  eco-design;  eco-
innovation;  and  the  selective  collection/sorting  of 
material flows as well). 

According to a Commission study169, if Belgium is to meet 
the  recycling  targets  for  municipal  waste  and  packaging 
waste,  it  still  needs  to   invest  an  additional  EUR  265 
million   (around  40  million  per  year)  between  2021-
2027 over 
recycling 
reprocessors, biowaste treatment, waste sorting facilities 
and  waste-registry  digitalisation.   Biowaste  treatment 
facility  replacement  costs  are  EUR  88  million  in  2021-
2027.  

its  baselines 

collection, 

in: 

This does not  include the investment  necessary in other 
key  waste  streams  (plastics,  textiles,  furniture)  or  the 
investment  needed  to  increase  circularity  and  waste-
prevention across the economy. 

Biodiversity & ecosystems 

Prioritised  action  frameworks  (PAFs)  adopted  by  the 
Member  States  according  to  Article  8  of  the  Habitats 

167 WFD and FD Implementation Reports – DG Environment – European 
Commission. 
168  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. 
169 European Commision, Study on investment needs in the waste sector 
and  on  the  financing  of  municipal  waste  management  in  Member 
States, 2019. 

Belgium  39 

its 

Directive  present:  (I)  the  conservation  priorities  for  the 
Natura  2000  network  and 
supporting  green 
infrastructure;  (ii)  the  costs  of  these  conversation 
priorities;  and 
for 
biodiversity and ecosystems in the period corresponding 
to the current multiannual financial framework (MFF) for 
2021-2027. 

(iii)  planned 

funding 

sources 

The  recently  submitted  PAF170  for  Belgium  shows  that 
nature protection costs (including Natura 2000) in 2021-
2027  are  estimated  at  EUR  2.4  billion  -  or  around  EUR 
343  million171  a  year  (of  which  165  million  is  annual 
running  costs  and  177.8  million  areone-off  costs).  This 
excludes  additional  costs  to  implement  the  biodiversity 
strategy to 2030, including additional costs for increased 
protection and restoration. 

EU environmental funding  2014-2020 

The MFF for 2014-2020 allocated almost EUR 960 billion 
(in  commitments,  2011  prices)172  for  the  EU  to  spend 
over this period. The commitment in this 2014-2020 MFF 
to  the  green transition included a  20% climate  spending 
target.  It  also  included  funding  opportunities  for  the 
environment, in particular under the European Structural 
and  Investment  (ESI)  Funds173.  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-19174.  

in 

invest 

Belgium  received  EUR  3.198  billion  from  the  ESI  Funds 
over  2014-2020  to 
job  creation  and  a 
sustainable  and  healthy  European  economy  and 
The  planned  direct  environmental 
environment. 
investment amounted to EUR 173.3 million of this 3.198 
billion  with  a  further  80.7  million  identified  as  indirect 
environmental  investment,  totalling  EUR  254  million. 
Figure  41  gives  an  overview  of  (planned)  individual  ESI 
Funds  earmarked  specifically  to  Belgium  (EU  amounts, 
without national amounts) for the 2014-2020 period and 
the  environmental 
in  these 
earmarked funds.   

investments  contained 

170 In Belgium, each region has a PAF, i.e. there are three PAFs in total. 
171  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving  synergies  with  EU  funding 
instruments  report  to  the 
European Commission, 2021. 
172 Council Regulation (EU, Euratom) No 1311/2013. 
173  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).   
174 Regulation (EU) 2020/2221. 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
                                                                 
Figure 40: ESI Funds allocated to Belgium, including 
environmental investments, 2014-2020175 

Table 2: 2014-2020 environmental investments under 
the ESI Funds in Belgium176  

Instrument 

Under Cohesion policy (ERDF) 
Direct environmental investments 
waste 
biodiversity and nature 
land rehabilitation 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Allocations  
for the environment  
(EUR million) 

149.0 
82.3 
2.1 
1.9 
31.1 
47.1 
66.8 
5.6 
27.5 

No 

the Regulation 

concerns 
(EU) 

in  Cohesion  Policy 

(EU)  No  1303/2013 and Regulation 

Funds 
1303/2013,Regulation 

175  European  Commission,  DG  Environment  -  Data  analysis  based  on 
ESI Funds Open Data Portal (cohesiondata.ec.europa.eu), Integration of 
environmental 
(COWI, 
(EU) 
2017), Regulation 
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 
(EU) 
2021/1060  allowing for  a  more  precise  identification  and  valuation  of 
relevant environmental investments.  N.B. 
Indirect  environmental 
investments are valued using the Annex I environmental coefficients of 
the Regulation (EU) 2021/1060 (as opposed to full value).    
176 European Commission, DG Environment - Data analysis. The values of 
specific 
environmental 
in 
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. See also previous footnote. 

identified  here 

investments 

the 

Belgium  40 

other energy177 
sustainable transport 
business development, R&I 

Under EAFRD/rural development 
Direct environmental investments 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 
Indirect environmental investments 
business development, R&I 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

2.6 
17.4 
13.7 

85.8 
72.7 
72.7 
13.1 
1.4 
11.7 

19.2 
18.4 
18.4 

0.8 
0.8 

254.0 
173.3 
80.7 

Funding for the environment from the ESI Funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States,  such  as  the  LIFE 
programme,  Horizon  2020  or  loans  from  the  European 
Investment Bank (EIB). The LIFE programme178 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, 
Belgium  received  EU  support  for  24  LIFE  projects  worth 
EUR 96.9 million from the LIFE programme for nature and 
environment  (out  of  1 028  EU-27  LIFE  projects  financed 
with  a  total  EU  contribution  of  EUR  1.74  billion)179.  In 
2014-2020,  Horizon  2020  allocated  about  EUR  116.3 
million to Belgium for the environment, which is 3.4% of 
Belgium’s  total  allocation180  under  Horizon  2020.  These 
Horizon  2020  funds  directed  at  Belgian  environmental 
projects  focused  in  particular  on  the  circular  economy, 
raw  materials  and  climate  action.  From  the  European 
Fund  for  Strategic  Investments  (EFSI),  Belgium  did  not 
in  2014-2020. 
have  environment-related  financing181 
Environment-related  EIB  loans  to  Belgium  in  this  period 
amounted  to  1.59  billion  (supporting  mostly  water  and 
sewerage),  out  of  an  overall  EUR  12.32  billion  in  EIB 

177  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention field 
53  and  54  respectively  (with  40%  environmental  coefficients)  of 
Regulation (EU) 2021/1060, Annex I.  
178 European Commission, LIFE Programme. 
179 LIFE Country overview Belgium 2021 (europa.eu) 
180 Source: https://sc5.easme-web.eu/. 
181  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 

Environmental Implementation Review 2022 – Belgium 

 
 
  
                                                                 
 
 
 
                                                                 
in  the  period182.  Belgium  ranks 
lending  to  Belgium 
number 9 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 lending.183184￼  

The  total  EU  environmental  financing  is  estimated  to 
reach EUR 2 billion for Belgum in 2014-2020. 

EU environmental funding  2021-2027 

The  2020  European  Green  Deal  investment  plan  calls 
upon  EUR  1  trillion  in  green  investments  (public  and 
private)  to  be  made  across  EU  by  2030.  The  2021-2027 
MFF  and  the  NextGenerationEU  spending  programme 
will  mobilise  EUR  2.018  trillion  (in  current  prices)  to 
support  the  recovery  from  COVID-19  and  the  EU's  long-
term  priorities,  including  environmental  protection.185 
Following the EU Green Deal’s186 pledge to ‘do no harm’ 
and  the  Interinstitutional  Agreement  on  the  2021-2027 
MFF187, 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  that  requires 
increased  programming  of 
for 
biodiversity,  specifically  under  the  2021-2027  Cohesion 
policy and the 2023-2027 CAP to reach those targets.  

resources 

financial 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)188. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds  (by  developing  the  EU  Green  Bond 
Standard)189.  Reinforced  by  the  renewed  sustainable 
finance  will 
finance  strategy 
the 
increase 

(2020)190,  sustainable 

climate  and 

investment 

flows 

to 

that 

finance 

several  programs 

182 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm 
183  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing 
environmental 
implementation: InvestEU,  the  successor  of  EFSI,  Pillar  II  and III  of  the 
Just  Transition  Mechanism.  The  EIB  Group  is  a  key  implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budgetary capacity of the mandate. 
184 EIB Activity Report 2021. 
185  European  Commission,  2021-2027 
NextGenerationEU. 
186 COM/2019/640 final. 
187 Interinstitutional Agreement, OJ L 433I. 
188 
finance/sustainable-finance/eu-taxonomy-sustainable-activities_en   
189 EU Green Bond Standard - 2021/0191 (COD). 
190 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 

https://ec.europa.eu/info/business-economy-euro/banking-and-

long-term  EU  budget  & 

Belgium  41 

environment. The new strategy on adaptation to climate 
change191 can help to close the insurance protection gap, 
which  currently  leaves  many  risks  from  climate-related 
events uninsured192. The EIB will align 50% of its lending 
for  climate  and  environment  projects  by  2025193  with  a 
EUR  250  billion  contribution  to  the  Green  Deal 
investment plan by 2027.  

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

Instrument 

Country funding allocation 
(million EUR) 

Cohesion policy 

Total: 2 694.9 194 

ERDF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

 EAFRD/rural 
development  

under  CAP 
plans 2023-2027197 

strategic 

European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

Recovery 
and 
Resilience Facility (RRF)  

2021 – 2026200  

1 152.3 

1 168.3 

374.3 195 

182.6 196 

414.0  198 

EUR 40.3199 

EUR 5 924.952 201 (grants) 

In  Belgium,  the  programming  for  most  EU  funds 
(cohesion  policy 
funds,  EAFRD  and  the  European 
Maritime,  Fisheries  and  Aquaculture  Fund)  is  ongoing. 

191 COM(2021) 82 final. 
192 The strategy would support improved coverage of the insurance gap, 
including through the natural-catastrophe markets as reflected with the 
EIOPA  (European  Insurance  and  Occupational  Pensions  Authority) 
dashboard  on  the  insurance  protection  gap  for  natural  catastrophes. 
See:  The  pilot  dashboard  on  insurance  protection  gap  for  natural 
catastrophes | Eiopa (europa.eu) 
193 EIB Climate Bank Roadmap 2021-2025, November 2020 
194  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
195 
Interreg 
transnational and ETC cross-border cooperation.  
196  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
197 European Commission, CAP strategic plans.  
198 Regulation (EU) 2021/2115, Annex XI.   
199  Regulation (EU) 2021/1139, Annex V. 
200  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented until 31 December 2026.   
201 Council Implementing Decision, FIN 522. 

initial  allocations  per  Member  State 

including  ETC 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
 
                                                                 
However,  negotiations  have  been  concluded  under  the 
RRF.  

Figure 41: Climate expenditure in RRP (2021-2026)202 

Belgium  42 

the 

regions,  communities,  and 

The  RRP  is  the  result  of  an  interfederal  coordination 
federal 
between 
authority. Besides the RRP, the federal level and each of 
the regions adopted their own recovery plan. As part  of 
the  EU’s  Recovery  Package,  Belgium  RRP  was  approved, 
and  the  country  will  receive  EUR  5.92  billion  of  grants 
through the RRF instrument. The Belgian RRP in Flanders 
includes a Blue Deal for water and dealing with ecological 
fragmentation. The Walloon plan includes  a biodiversity 
project.  Three  circular  economy  projects  are  also 
proposed  (Federal,  Flanders  &  Wallonia),  plus  a  reform 
on  this  topic  in  Brussels.  Innovative  reforms  include 
dealing  with  company  car  taxation,  mobility  allowance, 
tax-shift  (Federal);  project  permitting  (Flanders  and 
Wallonia);  the  “Smart  Move”  and  grants  for  modal  shift 
(Brussels).  50%  of  the  projects  have  a  climate-related 
tagging, one of the highest in the EU. 

Of  greatest  interest  for  the  environment  are  those  the 
measures Belgium is planning on: (I) building renovation; 
(ii)  emerging  energy  technologies;  (iii)  “soft”  mobility 
infrastructure (i.e. infrastructure for walking and cycling); 
(iv)  encouraging  a  modal  shift  in  transport,  in  particular 
towards  rail;  (v)  the  greening  of  road  transport;  and  (vi) 
the  circular  economy.  The  plan  contains  142  measures 
(37 reforms and 105 investments).  

There  are  two  parts  of  Belgium’s  RRP  that  have  an 
especially  strong  focus  on  environmental  topics.  These 
are set out in the bullet points below:  

 

 

Component  1.3  ‘Climate  and  environment’  focuses 
on restoring biodiversity, strengthen adaptability and 
resilience  to  climate  change,  as  well  as  water 
management.  In  particular,  investments  will  aim  at 
the accelerated creation of a coherent set of natural 
areas,  forests  and  riverbeds  to  act  as  carbon  sinks 
and  mitigate  the  consequences  of  floods  and 
droughts.  This  component  has  a  budget  of  EUR  400 
million. 
Component 5.3 ‘Circular economy’  includes  reforms 
and  investments  to  contribute  to  the  development 
of  a  circular  and  low-carbon  economy.  The  projects 
strive  for  the  development  of  recycling,  reuse  and 
repair,  rental,  lending,  mutualization  or  industrial 
symbiosis.  In  addition,  elements  of  this  component 
aim to support innovation in waste and raw material 
to  develop  circular  economy 
processing,  and 
trainings.  This  component  has  a  budget  of  EUR  197 
million. 

Under  NextGenerationEU,  the  Commission  will  issue  up 
to  EUR  250  billion  of  EU  green  bonds  (one  third  of  all 
bonds  issued  under  NextGenerationEU)  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  2021-2027, 

there  are  also 

In  addition  to  EU  funds  earmarked  specifically  for 
Belgium 
funding 
programmes that can been accessed at the EU level and 
which are open to all  Member States. These include the 
LIFE  programme  (EUR  5.4  billion),  Horizon  Europe  (EUR 
95.5  billion)203,  the  Connecting  Europe  Facility204  (EUR 
33.7  billion)205  or  the  funds  to  be  mobilised  via  the 
InvestEU206programme.  These  other  sources  of  funding 
will  also  support  the  green  transition,  including  through 
research  and  innovation  activities  for  environmental 
protection  (Horizon  Europe)207,  clean  transport  and 

202 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
203  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
204  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. 
205 Regulation (EU) 2021/1153. 
206  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. 
207 European Commission, Horizon Europe. 

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
energy  (the  Connecting  Europe  Facility)208  or  sustainable 
infrastructure (InvestEU)209. 

Figure 42: Environmental protection investments in the 
EU-27 (EUR million and % of GDP), 2018211 

Belgium  43 

National 
protection 

expenditure  on 

environmental 

Total  national  expenditure  on  environmental  protection 
(including all relevant current and capital expenditure)210 
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 the largest absolute amounts 
of expenditure are concentrated in a few countries, most 
countries  spend  1-2%  of  their  GDP  on  environmental 
protection,  with  Belgium  and  Austria  spending  the 
greatest share (both direct more than 3% of their GDP on 
environmental expenditure). 

Of  this  spending,  the  EU-27's  capital  expenditure  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR  56.3  billion  in  2018,  falling  to  EUR  54.5  billion  in 
2020,  representing  around  0.4%  of  EU-27  GDP.  Most 
Member  States 
in 
environmental  protection.  Belgium  invested  0.6%  of  its 
GDP in  environmental protection in 2020. In  2014-2020, 
this  totalled  around  EUR  376  billion  in  environmental 
investment  in  the  EU-27,  and  EUR  16.2  million  for 
Belgium. 

invested  0.2-0.5%  of  their  GDP 

208 European Commission, Connecting Europe Facility. 
209 European Union, InvestEU. 
210    At  economy  level,  including  final  consumption,  intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental protection goods and services. It 
excludes  EU  funds,  although 
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. 

include  some 

itmay 

in 

environmental  protection 

institutional  sector,  around  43%  of  Belgium’s 
By 
(capital 
investment 
expenditure)  came  from  businesses  not  specialised  in 
environmental-protection  services,  35%  from  specialist 
producers  (of  environmental  protection  services,  e.g. 
waste  and  water  companies)  and  21%  from  general 
government. At EU level, 37% comes from governments, 
33%  from  specialist  producers  and  30%  from  businesses 
not specialised in environmental protection). 

211  Eurostat,  Environmental  Protection  Expenditure 
Accounts, 2021. 

Environmental Implementation Review 2022 – Belgium 

 
                                                                 
 
 
                                                                 
Figure 43: EU-27 Member States' environmental 
protection investments (Capex) by institutional sector 
(Total economy = 100%), 2018212 

Belgium  44 

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% supporting sustainable land use, with links to 
ecosystem  conservation  and  restoration.  These  data  are 
based  on  the  climate  bonds  taxonomy,  which  is  broadly 
similar  to  the  EU  Taxonomy216.  In  2020,  Belgium  issued 
EUR 1.29 billion of green bonds. 

Figure 44: Annual EU green-bond issuance in 2020 (EUR 
billion)217 

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  patterns213across  the  sectors.  At  Belgium’s 
level,  44%  of  environmental 
general  government 
protection investments went to waste management, 27% 
to  wastewater  and  14%  to  pollution.  For  the  country’s 
specialist 
environmental-protection 
producers 
49%  of 
services,  waste  management 
investment,  wastewater  44%,  and  water  and  soil 
protection  4%.  For  businesses  not 
in  the 
involved 
specialist 
environmental-protection 
thirds  of  environmental-protection 
services, 
investments  went  to  wastewater,with  15%  going  to 
reduce air pollution. 

production 
two 

received 

of 

of 

In  2020,  the  total  annual  issuance  of  European  green 
bonds (including some non-EU countries)214 was USD 156 
billion (EUR 137 billion215), up from USD 117 billion (EUR 

212 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 
213 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 
disaggregate these data) or not at all.  
214  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  with  a  AAA-rated  issuance  from  multilateral 
institutions, the European Investment Bank (EIB) and the World Bank. 
215 At Eurostat’s annual average EUR/USD exchange rates. 

Green budget tools 

Green taxation & environmental tax reform 

Belgium’s  revenue  from  environmentally-related  taxes 
was 2.54% of its GDP (above the EU average) in 2020, as 
shown  in  the  graphic.  Within  this,  energy  and  transport 
taxation  account  for  the  largest  shares,  accounting  for 
68.6% and 26.3% of total environment taxes respectively 
in 2020, the share of pollution/resource taxes accounted 
for 5% of total environmentally-related taxes. 

Interactive  Data  Platform  at  www.climatebonds.net.  Further 
Taxonomy: 

216 
Bonds 
information 
https://www.climatebonds.net/standard/taxonomy  
217 Climate Bonds Initiative, 2022. 

Climate 

on 

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
  
 
 
                                                                 
Figure 45: Environmental taxes in the EU-27, 2020218 

Belgium  45 

and Ireland), managed to decrease them in this period. In 
the EU, subsidies for petroleum products in sectors such 
as  transport  and  agriculture    continued  to  increase  in 
2015-2019.  However  subsidies  for  coal  and 
lignite 
decreased,  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 
Belgium, fossil-fuel subsidies amounted to EUR 3.5 billion 
in 2019, reaching 0.72% of GDP. 

In 2020, the EU-27’s total fossil fuel subsidies decreased 
to EUR 52 billion (due to falling consumption trends amid 
the  COVID-19-related  restrictions).  Without  Member 
State  actions,  these  subsidies  are  likely  to  rebound  as 
economic activity picks up from 2020.222 

Figure 46: Trends in fossil-fuel (electricity, natural gas 
and petroleum) subsidies–Belgium223 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society,  and  promote  a  just 
transition, Tax reforms can contribute to this by sending 
the right price signals and incentives to economic actors. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil-fuel subsidies, and a shift in 
the  tax  burden  from  labour  to  pollution.  It  achieves  this 
while 
social 
taking 
considerations219. The Green Deal promotes the ‘polluter 
pays  principle’220,  which  stipulates  that  polluters  should 
bear  the  cost  of  measures  to  prevent,  control  and 
remedy  pollution.  The  polluter-pays  principle 
is 
facilitated  by  the  European  Commission’s  Technical 
Support Instrument (TSI) flagship on greening taxes.  

simultaneously 

account  of 

Environmentally-harmful subsidies 

removing  environmentally-harmful 
Addressing  and 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms221.  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  green 
investments.  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 

218 Eurostat, Environmental taxes accounts (env_eta). 
219  European  Commission,  The  European  Green  Deal,  COM  (2019/640 
final), p.17 
220  Article  191(2)  of  the  Treaty  on  the  Functioning  of  the  European 
Union states that: “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”. 
221  European  Commission,  Study  on  assessing  the  environmental  fiscal 
reform potential for the EU28, January 2016 –Study  

% GDP 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Electricity 

0,00 

0,00 

0,01 

0,01 

0,01 

0,01 

0,01 

0,01 

Natural 
gas 

0,01 

0,00 

0,02 

0,02 

0,02 

0,02 

0,02 

0,02 

Petroleum   0,58 

0,48 

0,50 

0,52 

0,60 

0,60 

0,64 

0,63 

Current green budgeting practices  

“Green  budgeting”  encompasses  various  climate  and 
environmental tagging and tracking practices in budgets. 
Some  EU  Member  States  already  use  certain  green-
budgeting  practices224.  Green  budgeting  helps  identify 
and  track  green  expenditure  and  green  revenues  to 
increase transparency on the environmental implications 
of  budgetary  policies.  This  is  aimed  at  improving  policy 

222 State of the Energy Union report, COM(2021) 950 and Annex 
223 OECD, Fossil Fuel Subsidy Tracker. 
224 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
 
                                                                 
Belgium  46 

coherence  and  supporting  green  policies  (including 
climate and environmental objectives)225. 
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 criteria226. The Commission 
developed a green budgeting reference framework227 and 
launched  a  TSI  project  on  green  budgeting  in  2021  to 
help  Member  States  develop  national  green-budgeting 
frameworks to improve policy coherence and support the 
the 
green 
Belgium 
Commission’s  green-budgeting  TSI,  which  started 
in 
2021.   

participates 

transition. 

in 

Belgium’s financing for environmental investments came 
to  an  estimated  0.71%  of  GDP  in  2014-2020  (slightly 
above the EU average), mostly based on national sources. 
In  2021-2027,  the  country’s  environmental  investment 
needs  are  estimated  to  be  at  least  0.85%  of  GDP  (with 
partial information, available at country level), suggesting 
an environmental financing gap of at least 0.16%  of GDP, 
likely  to  be  higher  when  also  accounting  for  needs 
identified  at  EU  level  (e.g.  water  protection,  circularity, 
biodiversity  strategy  etc.).  Belgium  plans  to  address  this 
gap  by  mobilising  further  financial  resources  to  back 
environmental implementation priorities.  

2022 priority actions 

 

Tackle 
the  main  environmental  challenges 
affecting  the  country,  through  appropriate 
funding,  including  through  the  mobilisation  of 
investments and the use of EU funds. 

Overall financing compared to the needs 

The EU’s overall financing for environmental investments 
is estimated to have been  0.6-0.7% of GDP in 2014-2020, 
comprising  both  major  EU  funds  and  national  financing. 
This  ranged  from    0.3%  (Ireland)  to  1.91%  (Bulgaria), 
depending  on  the  level  of  environmental  challenges  in 
different  Member  States.  In  2021-2027,  it  is  estimated 
that the EU’s environmental investment needs will  range 
between  0.9-1.5%  of  the  projected  2021-2027  GDP, 
suggesting  a  potential  environmental  financing  gap  of  
0.6-0.8%  of  GDP  at  EU  level,  compared  to  previous 
financing levels228. 

Figure 47: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU27 (% 
of GDP)229 

225  European  Commission,  European  Commission  Green  Budgeting 
Reference  Framework.  European  Commission,  Green  Budgeting  in  the 
EU Key insights from the 2021 Commission survey. 
226 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
227  European  Commission,  Green  Budgeting  Reference  Framework, 
based  on  the  review  of  the  OECD  Paris  Collaborative  on  Green 
Budgeting initiative, 2017. 
228  DG  Environment  data  analysis.  EU  financing  sources  covered:  ESI 
Funds  (ERDF,  CF,  ESF,  YEI,  EAFRD,  EMFF),  Horizon 2020,  LIFE,  EFSI  (EU 
amount),  EIB  loans.  National  financing:  total  national  environmental 
protection  capital  expenditure  (investments)  -  source:  Eurostat  EPEA 
dataset.  Cut-off  date  for  data:  end  2021.  N.B.  Total  financing  may  be 
higher,  in  particular  through  further  indirect  investments,  requiring 
further analysis in the future.   
229 Eurostat, ESI Funds Open Data, 2021. 

Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
 
6. Environmental Governance  

Belgium  47 

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  business  that  environmental  information  is  shared 
efficiently  and  effectively230.  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 environment231. It includes the right to bring 
legal challenges ("legal standing")232.  

Environmental information 

a 

European 

infrastructure 

This section focuses on Belgium’s implementation of the 
INSPIRE  Directive.  The  INSPIRE  Directive  aims  at  setting 
for 
spatial-data 
up 
sharing   environmental  spatial 
information  between 
public authorities across Europe. It is hoped that this will 
help  policy-making  across  boundaries  and  facilitate 
public access to this information. Geographic information 
is needed for good governance at all levels and should be 
readily and transparently available.  

There  are  four  Geoportals  in  Belgium:  one  for  each 
legally  responsible  entity  for  the  implementation  of 
INSPIRE.  Belgium’s 
INSPIRE 
Directive  could  be  better.  Belgium’s  performance  has 
been  reviewed  based  on  the  country's  2021  country 
fiche233.  Belgium  has  made  good  progress 
in  data 

implementation  of  the 

230  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.  
231  The  guarantees  are  explained  in  Commission  Notice  on  access  to 
justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen's Guide. 
232  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. 
233 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/BE. 

identification  and  documentation  ,  and  implementation 
levels are good. However, more efforts are needed to:  

(i) make the data more widely accessible; 

(ii)  prioritise  environmental  datasets  in  implementation, 
especially  those  identified  as  high-value  spatial  datasets 
for implementing environmental legislation234. 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive, 2016-2020235 

2016 

2020 

Legend 

Effective  coordination  and  data 
sharing 

Ensure  effective 
coordination  

■  ■ 

Data 
without obstacle   ■  ■ 

sharing 

INSPIRE performance indicators 

i.  Conformity  of 
metadata  

■  ■ 

ii.  Conformity  of 
spatial 
data 
sets236 

■  ■ 

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

iv.  Conformity  of 

■  ■ 

network services  ■  ■ 

■  Implementation  of 
this  provision  is  well 
advanced  or  (nearly) 
completed. 
Outstanding  issues  are 
minor  and  can  be 
addressed 
easily. 
Percentage: >89% 
■  Implementation  of 
has 
this 
provision 
and  made 
started 
some  or 
substantial 
progress but is still not 
close  to  be  complete. 
Percentage: 31–89% 
■    Implementation  of 
this  provision  is  falling 
behind. 
significantly 
are 
efforts 
Serious 
close 
necessary 
to 
implementation 
gap. 
Percentage: <31% 

234 European Commission, List of high value spatial data sets. 
235 INSPIRE knowledge base. 
236  In  2016,  the  deadlines  for  implementation  of  the  spatial  data 
interoperability were: 23/11/2017 for Annex I data and 21/10/2020 for 
Annex II and III data. In many cases, this conformity indicator will never 
reach  100%  conformity  as  most  countries  provide  as-is-data  sets  in 
addition to the INSPIRE harmonised data sets. 

Environmental Implementation Review 2022 – Belgium 

 
 
                                                                 
 
  
  
  
                                                                 
Public participation 

Belgium has a federal website for implementation of the 
Aarhus  Convention237.  This  website  provides  a  one-stop 
shop  describing  how  public  engagement  is  organised 
across the country. The website includes information on 
past  or  current  public  consultations  on  draft  legislation, 
plans  or  programmes  that  are  organised  at  federal 
and/or regional level.  

At  the  regional 
level,  only  Flanders  currently  has 
platforms  in  place  to  enable  public  participation  in 
licensing  procedures238  and  planning  procedures  for 
regional plans and programmes239. In the Brussels Capital 
Region,  Bruxelles  Environnement  is  planning  to  set  up  a 
single consultation webpage.  

However, statistics on the level of public participation in 
environmental  impact  assessment  (EIA)  and  strategic 
environmental  assessment  (SEA)  procedures  are  not 
available at either federal or regional level in Belgium.  

The  2019  EIR  recommended  to  Belgium  that  Belgium 
facilitate public participation in the implementation of EU 
environmental  legislation.  Since  2019,  Belgium  made 
some progress on this issue. 

Access to justice  

On the standing of NGOs, the jurisprudence of Belgium’s 
Council  of  State,  which  had  been  developed  in  a  strict 
way  in  the  past  (i.e.  in  a  way  that  made  it  difficult  for 
NGOs to gain standing), was relaxed more than a decade 
ago  under  the  influence  of  the  case-law  of  the  Belgian 
Constitutional Court, the Court of Justice of the European 
Union,  and  the  European  Court  of  Human  Rights.  It  has 
now been brought into line with the Aarhus Convention, 
making it easier for NGOs to gain standing.  

The  procedure  for 
judicial  review  of  administrative 
decisions by Belgium’s Council of State is laid down in its 
basic  act  (lois  coordonnées  sur  le  Conseil  d'Etat)  and 
complementary regulations.  This procedure can be used 
to challenge any unilateral,  final, legally binding act of a 
Belgian administrative authority, whether of an individual 
or  regulatory  nature  (i.e.  administrative  decisions  in 
individual  cases  as  well  as  executive  orders  and 
laying  down  generally 
administrative 

regulations 

237  Bienvenue  sur  le  portail  national  sur  la  Convention  d’Aarhus  |  SPF 
Santé publique (belgium.be) 
238 https://www.omgevingsloket.be/omvPubliek/?openbaaronderzoek 
239 https://inspraak.omgeving.vlaanderen.be/. 

Belgium  48 

interest 

legitimate 

is  not  required.  A 

applicable rules). An action to annul an administrative act 
can be brought by any party (any natural or legal person) 
which  has  been  "harmed"  or  has  an  "interest"  at  stake. 
Meeting  this  requirement  does  not  pose  particular 
problems  for 
individual  claimants  (legal  or  natural 
persons) 
in  environmental  cases,  and  the  standing 
requirements  do  not  vary  according  to  the  type  of 
environmental  legislation  concerned.  Proof  of  actual 
harm 
in  the 
contested act is sufficient. This need to have a legitimate 
is not necessarily based on a legally recognised subjective 
right. Whether a natural person has the interest required 
to  seek  judicial  review  of  an  administrative  decision 
affecting  their  environment 
is  essentially  a  factual 
matter,  which  will  be  judged  by  the  Council  of  State 
based  on  the  specific  circumstances  of  the  case.  The 
Council  will  examine  whether  the  claimant  will  be  -  or 
may  be  -  affected  by  the  environmental  effects  of  the 
implementation of the decision. The nature and range of 
those  effects  will  be  taken  into  account.  If  there  is  any 
uncertainty,  the  decision  on  standing  tends  to  be  in 
favour of the claimant.  

in  the 

instance.  As  a  result,  an 

In  Flanders,  a  Council  for  Permit  Disputes  (‘RVVB’)  has 
been recently  established (currently part of the so-called 
  The 
Flemish  Administrative  Law  Tribunal,  ‘DBRC’). 
Council  rules  on  all  explicit  or  tacit  decisions  concerning 
last 
the  single  environmental  permit,  taken 
important 
administrative 
environment-related dispute settlement has been shifted 
from  the  Council  of  State  to  this  specialised  Flemish 
administrative  Court.    The  affected  or  likely  to  be 
affected  public  can  lodge  an  appeal  with  the  RVVB  if  a 
direct or indirect causal link can be established with the 
contested  decision.    It  is  provided  that  the  RVVB  may 
decide to waive court fees if the applicant can prove that 
his or her income is insufficient. 

 Costs  might  be  an  obstacle  for  access  to  environmental 
justice  by  ordinary  people  and  NGOs  in  Belgium.  These 
costs  include  court  fees,  and  the  risk  of  having  to  pay  a 
judicial allowance as intervention in the lawyers’ fees and 
costs of the winning party if the case is lost. If these costs 
are  not  covered  by  insurance  (which  can  often  be  the 
case  when a private party is  suffering damages that can 
be  considered  as  environmental),  a  party  might  often 
launching  procedures.  Although 
hesitate  before 
considered 
procedures 
“prohibitively  expensive”,  lawyers’  fees  and  the  new 

in  Belgium 

cannot 

be 

 Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
Belgium  49 

that 

system  of  court  fees,  judicial  allowances  and  VAT  might 
have  a  dissuasive  effect.  However,  while  it  cannot  be 
the  costs  of  environmental  court 
excluded 
procedures  might  constitute  a  hindrance  to  access  to 
justice  for  a  middle-income  individual,  there  are  fee 
waiver regulations and other similar support measures in 
operation. 

  Set  up  websites  providing 

information  on  and 
facilitating  participation  in  EIA  and  SEA  processes  in 
Wallonia and the Brussels Capital Region.  

  Record and regularly publish information on levels of 
public participation in EIA and SEA processes, as well 
as  on  their  outcomes  and  on  the  extent  to  which 
public comments were taken into account in the final 
decision, at both the federal and regional levels. 

In  Belgium,  there  is  abundant  information  available  on 
access to environmental justice at all state levels. On the 
federal level, information - including the applicable rules 
- can be found through several multilingual websites240. 

to  environmental 

Information  about  the  Federal  Appeals  Commission  for 
is  accessible 
access 
through  a  separate  website241.  There  are  also  separate 
websites  on  access  to  justice  in  the    Flemish  Region242, 
the  Walloon  Region243,  and 
the  Brussels-Capital 
Region244. 

information 

In  2019  a  priority  action  was  addressed  to  Belgium  to 
better  inform  the  public  about  its  rights  to  access 
environmantal  justice,  and  this  action  is  considered  to 
have made substantial progress. 

2022 priority actions 

 

the 

stronger 

linkages  between 

Improve  access  to  spatial  data  and  services  by:  (I) 
making 
four 
geoportals; (ii) identifying and documenting all spatial 
implementation  of 
datasets 
law245;  (iii)  making  the  data  and 
environmental 
documentation  at  least  accessible  'as  is'  to  other 
public  authorities  and  the  public  through  the  digital 
services provided for in the INSPIRE Directive. 

required 

the 

for 

  Ensure  that  costs  are  not  a  hindrance  to  effective 

access to justice in environmental matters. 

https://www.health.belgium.be/nl/milieu/milieurechten/toegang-

240 
tot-milieu-informatie  
https://www.health.belgium.be/fr/environnement/droits-
environnementaux/lacces-aux-informations-environnementales 
https://www.health.belgium.be/de/umwelt/umweltrechte/das-
allgemeine-recht-auf-information  
241 
informations-environnementales/introduction/   
242 https://overheid.vlaanderen.be/openbaarheid-van-bestuur  
243 

https://www.ibz.rrn.fgov.be/fr/commissions/acces-aux-

http://environnement.wallonie.be/rapports/dpe/iew/acces_info.htm  

244https://leefmilieu.brussels/leefmilieu-brussel/toegang-tot-
informatie/toegang-tot-milieu-informatie   

245 European Commission, INSPIRE. 

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  waste246.  It 
includes  support  measures  provided  by  the  authorities 
such as: 
(i) compliance promotion247;  
(ii) the inspections and other checks that they carry out, 
i.e. compliance monitoring248;   
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remediated,  i.e. 
enforcement249.  
Citizen  science  and  complaints  enable  authorities  to 
liability250 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage.  

Compliance promotion and monitoring  

Additional  efforts  appear  to  have  been  made  by  the 
Walloon  and  Flemish  authorities  to  provide  information 
to duty holders  (i.e. people with a specific responsibility 
under  environmental 
compliance  with 
obligations on nitrates and on nature protection.  

law)  on 

In  Flanders,  government  websites  provide  guidance  on 
compliance  with  nature-protection  obligations 
for 
licensing  authorities  to  help  them  assess  the  impact  on 
nature  of  permits  in  agricultural  areas251.  Farmers  can 
also  get  free  advice  via  the  KRATOS  e-counter,  which 
contains  modules  on  various  issues,  such  as  the  links 

246  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.  
247 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation.  
248 This EIR focuses on inspections of major industrial installations.  
249  This  EIR  focuses  on  the  availability  of  enforcement  data  and 
coordination between authorities to tackle environmental crime. 
250  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
251  Helpdesk  voor  vergunningverleners  |  Agentschap  voor  Natuur  en 
Bos. 

 Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
                                                                 
facilitates  compliance  with 

between  biodiversity  and  agri-ecosystem  resilience252￼. 
Flanders 
the  Nitrates 
Directive  by  a  wealth  of  online  tools  made  available  to 
farmers, including a ‘Manure Bank’ (an advisory platform 
which  also  organises  regular  information  and  training 
events for farmers) or DEMETER (which helps farmers to 
calculate of optimal and sustainable fertilisation levels for 
single parcels). In addition, an advisory body – B3W – was 
set up in 2021 to promote peer-to-peer learning between 
farmers  for  a  better  soil  and  water  quality.  In  Wallonia, 
their 
information 
environmental obligations is still mainly provided through 
NGOs  such  as  Natagriwal253  and  Agr’Eau.  However,  a 
governmental  website  provides  information  on  species, 
habitats, sites, and relevant legislation254255. The Walloon 
website  dedicated  to  agriculture  also  has  a  specific 
section  on  the  environment, 
including  biodiversity 
protection256.  

farmers  comply  with 

to  help 

inspection  plans  and 

For  Brussels  Capital  Region,  websites  provide  guidance 
on compliance with environmental obligations in order to 
infringements257.  The 
prevent  environmental 
law 
Brussels  Capital  Region  continues  the  good  practice  of 
inspection 
regularly  publishing 
reports for industrial installations. However, progress on 
this  issue  is  still  needed  for  Wallonia  and  Flanders.    The 
IED  section  of  the  relevant  governmental  website  in 
Wallonia  mentions  the  obligation  to  draw  up  an 
environmental inspection plan and to revise and update 
this  plan  regularly,  although  it  provides  no  link  to  such 
plans258.  The  website  of  the  Flemish  Department  of  the 
Environment  (‘Departement  Omgeving’)  publishes  the 
annual  environmental  enforcement  plans  of 
its 
enforcement division, which contain a section on the IED 
inspections  programme.  However,  the  IED  inspection 
programmes themselves are not directly available.  

Belgium  50 

Complaint handling and citizen science 

Information  on  how  to  submit  complaints  or  report 
environmental damages is readily available in Wallonia259 
and  Flanders260,  although  no  specific  online  tools  to  this 
end  were  identified.  However,  Wallonia  does  provide 
several emergency contact numbers to  report  situations 
or  activities  that  are  damaging  to  nature  or  the 
environment.  The  general  public  in  the  Brussels  Capital 
Region now also has access to clear information on how 
to  make  environmental  nuisance  complaints  via  the 
Bruxelles  Environnement  website,  along  with  complaint 
forms for specific complaint types in addition to a general 
form261. The Info Bruit portal262 further enables the public 
to directly submit complaints about nuisances noise.  

Although  no  specific  policy  was  identified  on  this  issue, 
there  are  many  citizen  science  projects  in  Belgium  with 
the  Flemish 
governmental  support.  For  example, 
Knowledge  Centre  for  Citizen  Science  (‘Scivil’)  was 
launched 
in  2019  with  support  from  the  Flemish 
government. It carries out projects in its main focus areas 
of  communication,  education,  data  management,  air 
quality  and  biomonitoring.  There  are  several  citizen 
science  projects 
in  air-quality  monitoring  and  this 
contributes  to  citizen  awareness  and  compliance  with 
issue.  Civil  works  together  with  the  Flemish 
this 
Environment Agency to improve the measurements of air 
quality 
in 
Brussels  is  another  air-quality  monitoring  project,  which 
the  Brussels  Capital  Region  and  Bruxelles 
has 
Environnement  among  its  partners.    Other  citizen  air 
quality monitoring campaigns were set up by civil-society 
in Brussels265 and Liège266.  

in  Hasselt263.  The  Curieuzenair  project264 

|; 

Natagriwal 

A5-Mesures-Gestion-Cover-FR-032021-WEB-

252 Landbouwers | Departement Landbouw & Visserij (vlaanderen.be)  
253 
Complet.pdf (natagriwal.be)  
254  Les sites Natura 2000  |  Natura 2000  |  La  biodiversité  en Wallonie; 
Klachten over milieuhinder | Vlaanderen.be  en  
255 Rechercher un site intéressant ou protégé | Sites | La biodiversité en 
Wallonie  
256 Environnement - Portail de l'agriculture wallonne (wallonie.be)  
257 
Environment 
Professionals 
(environnement.brussels)  and Les conditions  spécifiques d'exploitation 
| Bruxelles Environnement 

Brussels 

Guide 

for 

| 

258 Emissions Industrielles (wallonie.be)  

Portail 

environnement 

de  Wallonie 

-  LE  PERMIS  D’ENVIRONNEMENT 
; 

259  Réagir  à  des  nuisances 
(wallonie.be); 
http://environnement.wallonie.be; 
https://www.wallonie.be/fr/demarches/porter-plainte-en-cas-de-
negligence-ou-de-maltraitance-dun-animal  
260  Klachten  over  milieuhinder  |  Vlaanderen.be;  Wie  contacteer  ik  bij 
milieuverontreiniging  of  -hinder?  —  Vlaamse  Milieumaatschappij 
(vmm.be)  
261  Nuisances  environnementales  :  introduire  une  plainte  |  Bruxelles 
Environnement  
262 Accueil — InfoBruit  
263 HASSELair | Scivil  
264 https://curieuzenair.brussels/nl/doe-mee/  
265 Envie de savoir ce que vous respirez ? (leschercheursdair.be)  
266 https://www.iew.be/particules-ultrafines-et-science-citoyenne-dans-
la-cite-ardente/  

 Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
  
                                                                 
Enforcement 

Environmental Liability Directive  

Belgium  51 

reports 

Reporting  on  enforcement  of  environmental  offences  is 
available  for  each  of  Belgium’s  three  regions.  Flanders 
continues 
reports 
to  publish  annual  enforcement 
containing  detailed  information  on  the  origin,  state  of 
for  dismissal  of  official 
progress  and  grounds 
(‘procès-verbaux’)267.  Wallonia 
infringement 
publishes  statistics  on  the  infringements  found  during 
checks  carried  out  by  the  Department  of  Police  and 
Controls (DPC) – which is responsible for enforcing of the 
legislation 
the  Environmental  Crimes 
Directive  –  and  its  specialised  units268.  In  2019,  the 
Brussels Capital Region published a technical report with 
statistics  on  environmental  offences  for  2014-2018269. 
The  vast  majority  of  environmental  offences  in  Belgium 
are  dealt  with  via  a  system  of  alternative  administrative 
fines rather than being prosecuted.   

transposing 

There does not appear to be a central database recording 
cases under the Environmental Liability Directive (ELD) or 
other  serious  environmental  damage.  Nevertheless, 
databases  exist 
for  soil 
contamination273. The database for Flanders in particular 
records 
to 
incidents of damage to soil that fall under to the scope of 
the Environmental Liability Directive.  

in  each  of  the  regions 

contaminations” 

corresponding 

“new 

Although there are no legal requirements for mandatory 
financial  securities  for  ELD  liability  in  Belgium,  stand-
alone environmental insurance policies for ELD and other 
environmental liabilities are widely available. These cover 
the costs of preventive measures under the ELD, as well 
as 
compensatory 
primary, 
remediation.  

complementary 

and 

Cooperation  systems  exist  at  federal 
Wallonia, but none were identified for Flanders.  

level  and 

in 

In September 2020, a new federal police unit was set up 
to counteract trafficking in wildlife, pesticides and waste. 
This unit conducts surveillance operations, phone tapping 
and  increased  surveillance  of  parallel  markets  on  the 
web. The Federal Unit for Public Health & Environmental 
Crime  aims  to  achieve  more  effective  and  coordinated 
action  on  these  issues270.  Another  important  federal 
structure is the Environmental Expertise Network, which 
coordinates  criminal  enforcement  actions  in  areas  of 
federal  jurisdiction  (e.g.  the  transport  and  export  of 
hazardous waste). It also: (i)  analyses legal and practical 
problems and promotes the flow of information between 
members of the public prosecutor's office271 and (ii) also 
issues  recommendations  and  drafts  circulars  to  enable 
the College of Procurators General to pursue a coherent 
and coordinated criminal policy.  

In  Wallonia,  a  Network  Against  Environmental 
Delinquency was recently set up, to coordinate the action 
of all professionals active in this field in the region272. 

The  2019  EIR  recommended  Belgium  improve  financial 
security  for  liablities  and  ELD  guidance,  and  publish 
information  on  environmental  damage.  Since  2019, 
Belgium made no progress on those issues. 

2022 Priority actions 

  Provide further information and support to farmers in 
Wallonia  via  governmental  tools  and  websites  on 
compliance  with  obligations  under  the  Nature  and 
Nitrates Directives.  

  Publish  inspection  plans  and  inspection  reports  on 
industrial installations in both Wallonia and Flanders.  
  Develop  online  systems  and  information  to  enable 
citizens’ complaints from the public on environmental 
damages  or  on 
compliance  with 
issues  of 
environmental legislation in Wallonia and Flanders. 

Effectiveness of environmental 
administrations  

https://www.vlaanderen.be/publicaties/environmental-

267 
enforcement-report  
https://www.vlaanderen.be/publicaties/environmental-enforcement-
report  
268 Constatation et répression des infractions environnementales par le 
pouvoir régional (wallonie.be)  
269 Template Rapport Technique (environnement.brussels)  
270 
FLYER_FR_FUPHEC_2021.pdf (police.be)   
271  Collège  des  procureurs  généraux  -  Les  réseaux  d'expertise  | 
Ministère public (om-mp.be)  
272  Réseau  de  lutte  contre  la  délinquance  environnementale  (reseau-
delinquance-environnementale.be)  

FLYER_FR_FUPHEC_2021.pdf 

(police.be)   

in 

involved 

implementing 

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

: 

Flanders 

https://www.ovam.be/gir 

273 
http://services.ovam.be/geoloket/ 
;;http://services.ovam.be/geoloket/; Wallonia : Banque de Données de 
l’Etat  des  Sols  (wallonie.be);  Brussels  Capital  Region  :  Wat  is  de  kaart 
van de bodemtoestand? | Leefmilieu Brussel  

; 

 Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
 
                                                                 
Administrative capacity and quality 

is  a  country  with  complex 

institutional 
Belgium 
arrangements.  Since  1993,  Belgium  has  constitutionally 
been  a  Federal  State  composed  of  three  Regions  and 
three  Communities.  This 
federal  mechanism  has 
repercussions  on  environmental  competences,  as  these 
are  shared  between  the  federal  authority  and  the  three 
regions.  The  three  regions  are  federated,  separate 
entities  which  are  not  subordinated  to  the  federal 
authority  or  the  other  Regions.  They  exercise  their  own 
authority  in  accordance  with  their  territorial  base  which 
defines their scope of geographic action. The distribution 
of  competences,  notably  in  environmental  matters,  is 
governed  by  the  law  of  08/08/1980  on  institutional 
its  subsequent  modifications.  Flanders, 
reforms  and 
Wallonia  and  the  Brussels  Capital  Region  are  mainly 
responsible  in  each  of  their  territories  for:  (I)  land-use 
planning;  (ii)  the  protection  and  conservation  of  nature; 
(iii)  the  protection  of  soil,  water  and  air;  (iv)  noise 
control;  (v)  waste  policy;  (vi)  the  production  and  supply 
of water; and (vii) the monitoring  of industrial activities. 
As  part  of  the  6th  State  reforms,  the  responsibilities 
relating to the transit of waste and animal welfare were 
transferred274 to the regions. 

(ii)  protection  against 

The  federal  government  is  solely  responsible  for:  (I) 
ionising 
product  standards; 
radiation;  (iii)  import,  export  and  transit  of  non-native 
plant  and animal species and their remains; and (iv) the 
protection  of  the  North  Sea.  Furthermore,  the  Belgian 
federal  authority  remains  the  relevant  body  as  regards 
the  jurisdictional  aspect  of  the  'access  to  justice'  part.   
To  ensure  that  Belgium  speaks  with  one  voice  in  a 
European  and  international  context,  the  federal  and 
regional  authorities  consult  each  other  in  a  permanent 
coordination  committee  for  international  environmental 
policy  (CCIM/CCPIE).  This  network  is  managed  by  the 
federal service. 

Environmental  issues  that  require  cooperation  between 
the regions and the federal government are dealt with by 
the  Interministerial  Conference  for  the  Environment 
for 
formed  of  representatives  of  ministers 
(ICE), 
environment in the regions and at the federal level. 

The  federal  and  regional  inspection  services  control  the 
in  Belgium. 
implementation  of  environmental  policy 
When implementing environmental policy, Belgian public 
authorities consult with business federations, unions and 

274 This transfer came into effect on 1st July 2014. 

Belgium  52 

non-governmental 
This 
specialised 
consultation 
is  organised  by  topic  or  by  file.  The 
CCIM/CCPIE  also  organise  a  stakeholder’s  dialogue  that 
occurs every 6 months. 

organisations. 

Belgium  ranks  15th  out  of  180  countries  in  the  2020 
Environmental Performance Index184.  

Coordination and integration  

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised  Environmental  Impact  Assessment  Directive  (EIA 
Directive)275  provides  an  opportunity  to  streamline  the 
regulatory  framework  on  environmental  assessments. 
Despite a delay in ensuring full transposition, Belgium 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 
unnecessary  administrative  burden  and  accelerates 
done  without 
is 
decision-making, 
the  environmental-
compromising 
had 
assessment 
already 
introduced 
environmental 
assessments under the EIA and Habitats Directives before 
the revision of the EIA Directive. Coordinated procedures 
have  been  decided  for  EIA  Directive,  the  WFD  and  the 
IED. 

it 
provided 
the  quality  of 

procedure276. 
the 

Belgium 
of 

streamlining 

A  good  practice  that  can  be  highlighted  is  Belgium’s 
single  environmental  permitting  platform,  which  has 
been 
single 
environmental  permitting  regime,  which  simplifies  and 
harmonises many environmental permits in the country. 

operationalise 

developed 

the 

to 

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

The Commission supports environmental implementation 
and  the  green  transition,  not  only  through  the  EU 

275 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment 
276 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.  

 Environmental Implementation Review 2022 – Belgium 

 
 
 
                                                                 
                                                                 
Belgium  53 

to 

the 

2022,  three  projects  have  been  selected:  a  project 
dedicated 
implementation  of  sustainability 
framework for Belgian National Promoting Banks (NPBs), 
a project for smart and fair mobility under the “Recharge 
and  Refuel”  flagship  and  a  project  supporting  building 
renovation in Wallonia. 

financing programs, but also granting technical assistance 
such as the Technical Support Instrument (TSI). 

The  Commission’s  TSI  supported  several  environment-
related  projects  during  the  reporting  period  in  Belgium, 
including a  project  on the Green Finance Strategy and a 
project  on  green  skills  roadmap  in  2021.  Under  the  TSI 

TAIEX peer-to-peer Projects 

The  TAIEX-EIR  peer-to-peer  tool277  has  been  launched  in 
2017  by  the  Commission  to  facilitate  peer-to-peer 
learning between environmental authorities. During tthe 
reporting  period,  Belgium  has  taken  part  in  four  TAIEX 
EIR  Peer-to-Peer  events  on  different  topics:  a  workshop 
on  sustainable  urban  development  (2019),  another  on 
environmental governance (2020), and two multicountry 
workshops  on  Ammonia  reducing 
technology  and 
measures (2021) and zero pollution (2022).  

277 

https://ec.europa.eu/environment/eir/p2p/index_en.ht
m 

 Environmental Implementation Review 2022 – Belgium