COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - CROATIA 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: Croatia, 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) 258 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022         Country Report - CROATIA                   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) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Croatia  1 

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

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

Photographs:  

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

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Croatia  2 

TABLE OF CONTENTS 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT........................................................................................................ 4 
Measures towards a circular economy ........................................................................................................... 4 
Waste management ....................................................................................................................................... 6 
2. BIODIVERSITY AND NATURAL CAPITAL ....................................................................................................................... 9 
Nature protection and restoration ................................................................................................................. 9 
Marine ecosystems ....................................................................................................................................... 14 
Ecosystem assessment and accounting ........................................................................................................ 16 
3. ZERO POLLUTION ............................................................................................................................................... 18 
Clean air........................................................................................................................................................ 18 
Industrial emissions ...................................................................................................................................... 19 
Prevention of major industrial accidents– SEVESO ....................................................................................... 22 
Noise ............................................................................................................................................................. 23 
Water quality and management .................................................................................................................. 23 
Chemicals...................................................................................................................................................... 27 
4. CLIMATE ACTION ................................................................................................................................................ 29 
Key national climate policies and strategies ................................................................................................ 29 
Effort Sharing target ..................................................................................................................................... 29 
Key sectoral developments ........................................................................................................................... 30 
Use of revenues from the auctioning of EU ETS allowances ......................................................................... 31 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ........................................................................ 32 

5. FINANCING ....................................................................................................................................................... 32 
Environmental investment needs in the EU .................................................................................................. 32 
EU environmental funding 2014-2020 ......................................................................................................... 33 
EU environmental funding 2021-2027 ......................................................................................................... 35 
National environmental protection expenditure .......................................................................................... 37 
Green budget tools ....................................................................................................................................... 38 
Overall financing compared to the needs ..................................................................................................... 39 
6. ENVIRONMENTAL GOVERNANCE ............................................................................................................................ 41 
Information, public participation and access to justice ................................................................................ 41 
Compliance assurance .................................................................................................................................. 42 
Effectiveness of environmental administrations .......................................................................................... 44 
Reforms through the Commission’s Technical Support Instrument (TSI) ..................................................... 44 
TAIEX EIR peer to peer projects .................................................................................................................... 44 

 
 
 
 
 
Executive summary 

In  previous  Environmental 
Implementation  Reviews 
(EIRs),  the  main  challenges  identified  for  Croatia  in 
implementing EU environmental policy and law were:  

development,  changes  in  the  water  regime,  climate 
change and alien species, and a mechanism is needed to 
limit the impact of these factors on nature. 

Croatia  3 

As regards water management, the risk of floods is rising 
due to climate change.  Flood protection  efforts  must  be 
strengthened, taking into account alternative options and 
adequate  mitigation  measures.  Compliance  with  the 
Urban  Waste  Water  Treatment  Directive  is  significantly 
lower than the EU average: 93% of urban waste water is 
not collected or treated. Greater efforts must therefore be 
made  to  reach  compliance. 
Implementation  of  the 
Nitrates Directive has improved slightly. 

Progress on air quality has been limited. Although key air 
pollutants have decreased significantly in Croatia in recent 
years, exceedances above the EU limit values established 
by  the  Ambient  Air  Quality  Directive  (AAQD)  were 
registered 
fine 
particulate  matter  (PM2.5)  and  the  Commission  has 
opened  an  infringement  procedure.  Additional  steps 
should be taken to address these non-compliance issues.  

for  particulate  matter 

(PM10)  and 

is 

to 

due 

Croatia 

receive 

EU financing continues to provide substantial support  to 
close  the  gap  in  the  implementation  of  environmental 
measures. 
over 
EUR 6 393.7 million in grants from its RRP (2021-2026) and 
EUR 8 707.6 million from the cohesion policy (2021-2027). 
Croatia’s  national  RRP  responds  to  the  urgent  need  to 
foster  a  strong  recovery  and  make  Croatia  future-ready. 
40.3%  of  RRP  spending  will  support  climate  objectives, 
while  the  76 reforms  and  146 investments  contained  in 
the  RRP  will  help  Croatia  become  more  sustainable  and 
resilient  and  better  prepare  it  for  the  challenges  and 
opportunities  presented  by  the  green  and  digital 
transitions.  

Total  environmental  financing  in  Croatia  amounted  to 
around  1.32%  of  GDP 
(around 
EUR 4.5 billion),  balanced  between  EU  and  national 
sources. Investment needs for 2021-2027 are estimated to 
be  at  least  1.79%  of  GDP,  signalling  a  financing  gap  of 
0.48% of GDP (assuming baseline financing levels).  

in  2014-2020 

 

 

 

 

 

improving 

to improve waste management, in particular the 
separate  collection  of  waste,  and  support 
recycling 
in 
municipalities 
performance and reducing landfilling; 
to strengthen the policy sector in order to speed 
up  the  uptake  of  the  circular  economy  by  all 
economic sectors;  
to finish designating Natura 2000 (Special Area 
of Conservation – SAC) sites, set up mechanisms 
for  cooperation  on  Natura  2000  management 
with other sectors and ensure adequate funding; 
to  implement  projects  in  the  water  sector,  in 
particular related to flood protection, and reach 
compliance with the requirements of the Urban 
Waste  Water  Directive,  especially  those  laid 
down 
in  Article 5  regarding  more  stringent 
treatment, in particular in big cities; 
to accelerate the reduction of particulate matter 
(PM2.5  and  PM10)  emissions  and  concentrations, 
nitrogen oxide (NOx) emissions, nitrogen dioxide 
(NO2)  concentrations  and  ammonia 
(NH3) 
emissions. 

Progress on the separate collection and recycling of waste 
has  been  rather  slow.  Despite  steady  improvement, 
Croatia’s recycling rate of 30.2% remains far below the EU 
average for 2019 (47.7%) and falls significantly short of the 
EU  target  for  2020  (50%).  Most  municipal  waste  is  still 
landfilled,  often  without  prior  treatment.  In  2021,  the 
Commission  opened  an  infringement  procedure  for  the 
landfilling  of  waste  without  prior  treatment  in  five 
Croatian  counties  (based  on  the  Malagrotta  case  law), 
though  most  of  the  country’s  counties 
lack  waste 
infrastructure.  More  efforts  are  needed  to  ensure  that 
waste is managed in compliance with EU waste legislation 
in  Croatia.  There  is  no  comprehensive  circular  economy 
strategy, but Croatia has included reforms relating to the 
circular  economy  in  its  national  recovery  and  resilience 
plan (RRP), including a new legal framework and a reform 
of the tourism sector. 

Progress with the designation of SAC sites has been slow, 
as 99% of Sites of Community Importance (SCIs) (740 out 
of 745) have not yet been designated as SACs. Extensive 
work is underway, but more efforts are  necessary to put 
in place concrete conservation measures, in particular in 
the  marine  environment.  Regarding  conservation  status, 
in particular that of species, large gaps in the monitoring 
system  are  evident.  The  main  human-induced  pressures 
on  nature  come  from  agriculture,  forestry,  urban 

Environmental Implementation Review 2022 – Croatia 

 
 
 
 
 
 
 
 
Part I: Thematic areas 

1. Circular economy and waste management 

Croatia  4 

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

Measures towards a circular economy 

The new circular economy action plan, adopted in March 
2020, is one of the main building blocks of the European 
Green Deal. The EU’s transition to a circular economy will 
reduce  pressure  on  natural  resources  and  create 
sustainable growth and jobs. It is also a prerequisite for 
achieving  the  EU’s  2050  climate  neutrality  target  and 
halting biodiversity loss. 

to 

reduce 

life  cycle,  aiming 

The action plan sets out initiatives for every stage of the 
the  EU’s 
product 
consumption  footprint  and  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.  

Resource  productivity  refers  to  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
impacts  on  the  environment  and  reduce 
negative 
dependency on volatile raw material markets. As shown 
in  Figure 2,  Croatia’s 
resource  productivity,  with 
EUR 1.02  generated  per  kg  of  material  consumed  in 
2020, is well below the EU average of EUR 2.09 per kg. 

The  circular  material  use  rate  (also  known  as  the 
circularity  rate)  is  a  good  indicator  of  an  economy’s 
circularity,  as  it  includes  all  the  materials  that  are  fed 
back into the economy. The circularity rate differs greatly 
from  one  country  to  another.  To  help  achieve  the  EU 
circular economy action plan’s goal of doubling the EU’s 
circular  material  use  rate  by  2030,  the  Member  States 
need  to  take  ambitious  measures  targeting  the  whole 
product life cycle. Such measures range from sustainable 
product  design,  which  would  increase  the  durability, 
reparability, upgradability and recyclability of products, 
to  other  measures  like  remanufacturing,  increasing 
circularity  in  production  processes,  recycling,  boosting 
eco-innovation and increasing the uptake of green public 
procurement. 

Croatia’s circular (secondary) use of material was 4.8% in 
2014 and 5.1% in 2020, compared to the EU average of 
12.8 %. Since Croatia’s circularity rate is increasing more 
slowly than the average EU increase, Croatia’s gap to the 
EU average has grown. The lowest rate was recorded in 
Romania  (1%),  followed  by  Ireland  and  Portugal  (both 
2%).  Differences  in  the  circularity  rate  among  the 
Member  States  are  based  not  only  on  the  amount  of 
recycling in each country but also on structural factors in 
national economies. 

1 Eurostat, Circular Economy Monitoring Framework.  

Environmental Implementation Review 2022 – Croatia 

 
 
                                                                 
 
 
Figure 2: Resource productivity 2010-20202 

Eco-innovation 

Croatia  5 

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

innovations, 

creating 

new 

With a total score of 86, Croatia ranked 21st on the 2021 
European  eco-innovation  scoreboard,  placing  it  among 
the  countries  catching  up  with  eco-innovation.  While 
Croatia  performed  below  the  EU  average  on  all 
components  of  the  2021  EU  eco-innovation  index,  its 
highest scores were seen in eco-innovation activities (1% 
below the EU average) and resource efficiency outcomes 
(11% below the EU  average). Croatia’s performance on 
eco-innovation inputs, eco-innovation outputs and socio-
is  significantly  below  the  EU 
economic  outcomes 
average.  

Figure 3: Eco-innovation performance, 2010-20194 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
consumption,  with  public  authorities’ 
purchasing  power  representing  14%  of  EU  GDP.  Green 
public  procurement  (GPP)  can  therefore  help  drive  the 
demand for sustainable products that meet reparability 

Circular economy strategies  

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies covering the whole product life cycle, as they 
are one of the most effective ways to progress towards a 
more circular economy at Member State level. Since the 
European  Circular  Economy  Stakeholder  Platform  was 
launched in 20173, national, regional or local authorities 
have used it to share their strategies and roadmaps.  

isolated 

initiatives,  Croatia  has  no 
Beyond  some 
comprehensive  circular  economy  strategy,  nor  any 
sectoral strategies.  

Croatia  has  included  the  following  circular  economy-
related reforms in its national RRP:  

- 

- 
- 

legal  framework  to  facilitate  the 

a  new 
prevention, reuse and recycling of waste; 
a reform to improve food donation systems; 
a  reform  enhancing  the  sustainability  of  the 
tourism  sector,  with  the  aim  of  developing  a 
new  model  of  tourism  that  contributes  to  the 
green  transition  and  adheres  to  circular 
economy principles; 

the  development  of  a  framework  for  the  design  and 
implementation of green urban renewal strategies, with 
the  aim  of  to  developing  models  for  the  circular 
management of space and buildings.  

2 Eurostat, Resource productivity. 
3 Circular Economy Stakeholder Platform. 

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

 Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
 
 
 
and  recyclability  standards.  Croatia  has  had  a  national 
action plan on green public procurement since 2015.  

A  2020  study  developed  a  methodology  for  calculating 
five  public 
carbon  dioxide 
procurement  categories  in  which  most  purchases  are 
made  and  for  which  there  are  EU  GPP  criteria.  These 
categories are:  

(CO2)  savings 

in  the 

- 
- 
- 

- 

- 

electricity supply; 
cars and light commercial vehicles;  
energy  renovation  of  the  outer  shells  of  office 
buildings;  
IT devices (computers and monitors) and mobile 
phone chargers;  
reconstruction/modernisation 
lighting.  

public 

of 

According  to  this  study,  the  CO2  savings  from  GPP  in 
these product categories amounted to 121 000 tonnes in 
2018.  

In  Croatia,  uptake  of  green  public  procurement  is 
monitored annually through the official Electronic Public 
Procurement  Advertisement  channel.  According  to  the 
data gathered, green public procurement uptakeuptake 
increased  sharply  between  2016  and  2019.  In  2019, 
contracting  authorities  concluded  1 731  contracts 
incorporating  green  public procurement   criteria,  while 
in  2021,  the  Croatian  government  adopted  a  decision 
under  which  the  Central  Public  Procurement  Office 
(Croatia’s  fourth 
largest  contracting  authority)  will 
implement green public procurement.  

EU Ecolabel and the Eco-Management and Audit 
Scheme (EMAS) 

The number of EU Ecolabel products and EMAS-licensed5 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and  national 
stakeholders are actively engaged in the transition to a 
circular  economy.  It  also  shows  how  committed  public 
authorities  are  to  supporting  instruments  designed  to 
promote the circular economy.  

In  September  2021,  Croatia  had  43  products  and  18 
licences registered in the EU Ecolabel scheme out of 83 
590  products  and  2  057  licences  in  the  EU.  Take-up  of 
these  licences  is  therefore  low6.  However,  take-up  in 
Croatia  has 
increased  compared  to  the  numbers 
mentioned  in  the  2019  EIR  country  report  (5  products 

5  EMAS  is  the  European  Commission’s  Eco-Management  and  Audit 
Scheme, a programme to encourage organisations to behave in a more 
environmentally sustainable way. 
6 European Commission, Ecolabel Facts and Figures. 
7 As of May 2018. European Commission, Eco-Management and Audit 
Scheme. 
8  Municipal  waste  consists  of  mixed  waste  and  separately  collected 
waste from households and from other sources, where such waste is 

Croatia  6 

and 2 registered licences). Moreover, three organisations 
from  Croatia  are  currently  registered  in  EMAS,  the 
European  Commission’s  Eco-Management  and  Audit 
Scheme7,  whereas  the  2019  EIR  country  report  states 
that  there  were  none  previously.  Some  progress  has 
therefore been  made, as the country is starting from a 
low level of Ecolabel and EMAS take-up. 

Croatia has  made limited progress on  strengthening its 
circular economy policy framework, so the priority action 
from  2019  has  been  retained  and  a  new  one  on 
improving the circular material use rate has been added. 

2022 priority actions 

  Strengthen  the  policy  framework  to  speed  up  the 
transition  towards  the  circular  economy  by  all 
economic  sectors, 
like 
plastics, textiles, and construction. 

including  priority  sectors 

  Adopt measures to increase the circular material use 

rate. 

Waste management 

Turning waste into a resource is supported by:  
(i)  fully 
legislation,  which 
implementing  EU  waste 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets, etc.;  
(ii)  reducing  waste  generation  per  capita  in  absolute 
terms;  
(iii) limiting energy recovery to non-recyclable waste and 
phasing out landfilling of recoverable waste. 
This section focuses on management of municipal waste8 
for which EU law sets mandatory recycling targets. 

resource 

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

reduce 

and 

After a downward trend, municipal waste9 generation in 
Croatia has started to increase in recent years. It came to 
418 kg/year/inhabitant  in  2020  but  remains  below  the 
EU average (505 kg/year/inhabitant), as Figure 4 shows. 

similar  in  nature  and  composition  to  waste  from  households.  This  is 
without  prejudice  to  the  allocation  of  responsibilities  for  waste 
management between public and private sectors. 
9  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. 

 Environmental Implementation Review 2022 – Croatia 

 
                                                                 
 
This indicates that Croatia’s economic growth is not yet 
decoupled from its generation of waste. 

Figure 4: Municipal waste by treatment in Croatia, 
2010-202010 

Croatia  7 

Despite efforts to close and remedy illegal dumping sites, 
there is still scope for improvement. On 2 May 2019, the 
Court of Justice of the EU delivered its judgment in Case 
C-250/18  and  condemned  Croatia 
for  breach  of 
Articles 5(1),  13  and  15(1)  of  the  Waste  Framework 
Directive  (2008/98/EC).  The  case  concerns  the  illegal 
in  Biljane  Donje,  where  approximately 
dump  site 
140 000 tonnes  of  production 
the 
processing of ferromanganese and silicomanganese has 
been  deposited  directly  on  the  ground,  less  than  50 
metres from houses, since 2010. As Croatia still had not 
executed the judgment, in August 2021 a letter of formal 
notice was issued under Article 260 TFEU.  

residue 

from 

Additionally, in January 2022 the Commission opened an 
infringement procedure against Croatia in respect of the 
non-communication  of  transposition  measures 
for 
Directive (EU) 2019/904 on the reduction of the impact 
of certain plastic products on the environment. 

from 

Over the past decade, Croatia has made slow but steady 
progress on stepping up its recycling rate and diverting 
municipal  waste 
landfilling.  However,  after 
increasing  modestly  since  2017,  the  recycling  rate  for 
municipal  waste  stood  at  34.3%  in  2020.  This  is  well 
below the EU average for 2020 (47.8%) and falls far short 
of  the  EU  target  for  2020  (50%).  Figure 5  shows  that 
Croatia needs to invest more in recycling to meet the EU 
recycling targets for 2020 and 2025. 

Figure 5: Recycling rate of municipal waste, 2010-
202014 

For this reason, the Commission’s Early Warning Report15 
identified  Croatia  as  one  of  the  countries  at  risk  of 
missing the EU target of recycling 50% of municipal waste 

According  to  the  European  Environment  Agency  (EEA), 
95% of municipal waste was landfilled in 2010 and 59% 
in  2019.  Furthermore, 
in  2015,  the  amount  of 
biodegradable  municipal  waste  landfilled  was  110%  of 
the  amount  landfilled  in  1997,  which  is  taken  as  a 
reference year. The EU Accession Treaty target for 2013 
–  to  landfill  a  maximum  of  75%  of  biodegradable 
municipal  waste  –  was  therefore  missed  by  a  wide 
margin.  According  to  the  Accession  Treaty,  after 
31 December 2018 waste must no longer be deposited in 
landfills that do not comply with the requirements of the 
Landfill Directive. Moreover, the information available to 
the  Commission  suggests  that  a  significant  number  of 
irregular  and  substandard  landfills  operate  in  Croatia, 
presenting  serious  risks  for  human  health  and  the 
environment. Studies and investigations launched by the 
European  Commission  found  that  municipal  waste  was 
being  landfilled  without  any  treatment  in  all  the  sites 
visited  (Diklo,  Karepovac,  Mraclinska  Dubrava,  Sv.  Juraj 
infrastructure 
and  Totovec).  These  sites  also 
capacities, as do the counties where they are located￼11 
and  the  rest  of  Croatia’s  counties12.  The  Commission 
therefore  opened  an  infringement  procedure  against 
Croatia in November 202113  

lack 

10 Eurostat, Municipal waste by waste operation, April 2022. 
11 Directive 1999/31/EC. 
12 Directive 2008/98/EC. 
13 Malagrotta case law. 
14 Eurostat, Recycling rate of municipal rate, April 2022. 

15  European  Commission,  Report  on  the  implementation  of  waste 
legislation, including the early warning report for Member States at risk 
of  missing  the  2020  preparation  for  re-use/recycling  target  on 
municipal waste, SWD(2018)422 accompanying COM(2018)656. 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
 
                                                                 
 
 
by  2020.  The  report  listed  key  priority  measures  which 
Croatia should take to close the implementation gap. The 
Commission  is  currently  finalising  its  analysis  of  the 
progress made on the recommendations from the 2018 
Early  Warning  Reports  and  an  analysis  of  progress 
towards achieving the 2025 waste recycling targets. The 
report will be presented at the end of 2022. 

Implementation of the 2018 waste legislative package 

Member  States  had  until  5 July  2020  to  bring  their 
national laws into line with the amendments included in 
the  revised  Waste  Framework  Directive,  the  Packaging 
and  Packaging  Waste  Directive  and  the  Landfill 
Directive16. Croatia still had not done this for the whole 
waste  package  by  July  2021,  so  the  Commission  sent  a 
reasoned opinion urging  Croatia to fully  enact the new 
EU  rules  on  waste  into  national  legislation,  as  the  case 
may be referred to the Court of Justice otherwise. Croatia 
adopted a new waste management act in July 2021. 

for 

are 

the 

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

The waste management plan for 2017-2022 was adopted 
in  January  2017  and  includes  the  waste  prevention 
programme.  A  revised  version  of  the  Croatian  waste 
management  plan  -  for  2022  only  -  was  adopted  in 
December  2021.  This  plan  is  currently  being  assessed. 

Croatia  8 

Work  has  begun  on  preparing  the  next  waste 
management  plan  for  2023-2027.  Moreover,  a  food 
waste prevention and reduction plan for 2019-2022 was 
adopted  in  2019,  and  efforts  are  underway  to  prepare 
the food waste prevention and reduction plan for 2023-
2028.  

Four  priority  actions  were  identified  for  Croatia  in  the 
2019 EIR. As there has been little to no progress in their 
implementation,  they  have  been  retained  and  a  new 
priority  action  on  compliance  with  EU  waste  rules  has 
been added. 

2022 priority actions  

 

Improve  and  extend  separate  collection  of  waste, 
including  bio-waste.  Establish  minimum  service 
standards  for  separate  collection  (e.g.  frequency  of 
collections,  types  of  containers)  in  municipalities  to 
ensure high capture rates for recyclable waste.  

  Develop 

run 

and 

implementation 

support 
programmes for municipalities to support  efforts to 
organise separate collection, implement ‘pay-as-you-
throw’ schemes and improve recycling performance.  
Improve  the  functioning  of  extended  producer 
responsibility  systems,  in  line  with  the  relevant 
general minimum requirements. 
Introduce  and  gradually  increase  landfill  taxes  to 
phase  out  landfilling  of  recyclable  and  recoverable 
waste. 
Implement a national waste management plan that is 
in line with the revised Waste Framework Directive. 

 

 

 

16  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 – Croatia 

 
 
 
 
                                                                 
2. Biodiversity and natural capital 

Croatia  9 

The 2030 EU biodiversity strategy adopted in May 2020 
aims to put the EU’s biodiversity on a path to recovery 
and sets out new targets and governance mechanisms to 
achieve healthy and resilient ecosystems. 
In particular, the strategy sets out ambitious targets to:  
(i) protect a minimum of 30% of the EU’s land area and 
30% of its sea area and integrate ecological corridors, as 
part of a true trans-European nature network; 
(ii) strictly protect at least a third of the EU’s protected 
areas, including all remaining EU primary and old-growth 
forests; 
(iii) effectively manage all protected areas, defining clear 
conservation  objectives  and  measures,  and  monitoring 
them appropriately. 
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore degraded ecosystems across the EU by 2030, and 
manage them sustainably, addressing the key drivers of 
biodiversity loss. 

Croatia’s  nature  protection  strategy  and  action  plan, 
adopted  by  the  Parliament  on  7  July  201717,  contains 
many relevant national activities. 

In  May  2020,  the  Commission  opened  an  infringement 
procedure  against  Croatia  for  systematically  failing  to 
appropriately assess the impact of changes to wind farm 
projects  on  Natura2000  sites,  contrary  to  Articles 6(3) 
and 7  of  Directive  92/43/EEC  on  the  conservation  of 
natural habitats and of wild fauna and flora. 

Nature protection and restoration  

The EU Habitats and Birds Directives are the cornerstone 
of EU legislation to conserve of the EU’s wildlife, natural 
habitats and ecosystems. As such, they are key legislative 
tools for delivering on the targets of the EU Biodiversity 
Strategy for 203018. 

Natura  200019,  the  largest  coordinated  network  of 
protected areas in the world, is the core instrument for 
achieving the Birds and Habitats Directives’ objectives of 
ensuring  the  long-term  protection,  conservation  and 
survival  of  Europe’s  most  valuable  and  threatened 
species and habitats and the ecosystems they underpin. 

17  Nature  Protection  Strategy  and  Action  Plan  (2017-2025),  Croatian 
Official Gazette No 72/2017. 
18 They should be reinforced by the Nature Restoration Law, according 
to the new EU Biodiversity Strategy. 
19  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs), 
designated pursuant to the Habitats Directive, and Special Protection 
Areas (SPAs), classified pursuant to the Birds Directive. The coverage 
figures  do  not  add  up  because  some  SCIs  and  SPAs  overlap.  Special 

Setting up a coherent Natura 2000 network, designating 
Sites of Community Importance (SCIs) as Special Areas of 
Conservation  (SACs)20  and 
identifying  conservation 
objectives  and  measures  for  the  Natura  2000  sites  are 
key  milestones  towards  meeting  the  objectives  of  the 
Directives. 

Setting up a coherent network of Natura 2000 sites 

Croatia hosts 76 habitat types and 244 species covered 
by  the  Habitats  Directive.  The  country  is  also  home  to 
populations of 125 bird taxa listed in Annex I to the Birds 
Directive. 

By  2021,  36.7%  of  Croatia’s  land  area  was  covered  by 
Natura 2000 (EU average: 18.5%), with Special Protection 
Areas  (SPAs)  classified  under  Birds  Directive  covering 
30.2% (EU average: 12.8%) and SCIs under the Habitats 
Directive  covering  28.4%  (EU  average:  14.2%)  of  the 
country’s territory. Although the terrestrial network can 
be considered largely complete, there are still gaps in the 
marine network. 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  Croatia  legally  protects 
37.8% of its terrestrial areas (EU-27 average: 26.4%) and 
9.5 % of its marine areas (EU-27 average: 10.7%)21.  

Areas  of  Conservation  (SACs)  are  SCIs  designated  by  the  Member 
States.  

21  European  Environment  Agency,  Protected  Areas,  terrestrial 
protected  area  percentage  (2021)  and  marine  protected  area 
percentage (2019), March 2022. 

Environmental Implementation Review 2022 – Croatia 

 
 
                                                                 
 
Figure 6: Marine & terrestrial protected area coverage, 
202122  

Designating Special Areas of Conservation (SACs) and 
identifying conservation objectives and measures 

Croatia  10 

The  six-year  deadline  set  by  the  Habitats  Directive  for 
designating  SCIs  as  SACs  and  establishing  appropriate 
conservation  objectives  and  measures  expired  on 
4 December 2020 for all but a few sites in Croatia.  

Nevertheless, 99% of SCIs (740 out of 745) have not yet 
been  designated  as  SACs.  Moreover,  site-specific 
conservation  objectives  have  not  been  established  for 
the  sites.  As  regards  the  necessary  conservation 
measures,  Croatia  has  defined  management  plans  for 
only a few SCIs.  

Several  national  projects,  supported  by  EU  funds,  are 
engaged in extensive work to: 

- 

the  Natura  2000  management 

 establish 
framework; 
draw up management plans for the sites; 
 develop monitoring and reporting systems; and 
seabed  habitats  and 
Croatian 

coastal  and 

in  waters 

under 

- 
- 
-  map 

biodiversity 
jurisdiction.  

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202123  

However,  more  efforts  are  necessary  to  put  in  place 
concrete conservation measures for the sites with regard 
to  activities  linked  to  the  most  important  pressures,  in 
particular  agriculture,  forestry,  fisheries,  energy,  and 
water management. Therefore, Croatia is still to identify 
the necessary conservation objectives and measures for 
the designated sites and fill the gap in designation for the 
marine environment.  

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

The  results  of  Habitats  Directive  Article 17  and  Birds 
towards 
Directive  Article 12 
maintaining or restoring favourable conservation status 
of  species  and  habitats  are  key  for  measuring  the 
performance of Member States24. 

reports  on  progress 

According to Croatia’s report on the conservation status 
of habitats and species covered by the Article 17 of the 
Habitats Directive in 2013-2018 (the first  such report it 
had ever submitted), 39.2% of habitat assessments show 
good  conservation  status.  However,  the  share  of 
protected-species 
good 
assessments 
conservation  status  in  2018  was  only  7.14%.  Many 
conservation status assessments, particularly for species 
(46.67%),  are  reported  as  unknown,  which  indicates  a 
very large gap in the monitoring system. As far as birds 

showing 

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

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

Environmental Implementation Review 2022 – Croatia 

 
  
 
 
 
 
 
 
 
                                                                 
are  concerned,  only  10%  of  breeding  species  showed 
increases  or  stability  in  their  short-term  population 
trends  (for  key  wintering  species,  this  figure  was  11%). 
However, there is a  very large knowledge gap (83% for 
breeding and 84% for key wintering species).  

The habitat groups faring poorly are, in particular, dunes, 
bogs, mires and fens, grasslands, freshwater habitats and 
coastal habitats. The species groups faring poorly are, in 
particular, mammals, fish, vascular plants and molluscs. 
However,  it  should  be  noted  that  there  are  large 
knowledge gaps on the conservation status of species. 

Figure 8:  Assessments  on  the  conservation  status  of 
habitats  for  the  2007-2012  and  2013-2018  reporting 
periods25  

Figure 9:  Assessments  on  the  conservation  status  of 
species  for  the  2007-2012  and  2013-2018  reporting 
periods26 

Croatia  11 

In May 2020, the Commission issued Croatia with a letter 
of  formal  notice  for  incorrect  application  of  Council 
Directive 92/43/EEC of 21 May 1992 on the conservation 
of natural habitats and of wild fauna and flora, as it had 
failed to ensure that changes to wind farm projects were 
assessed appropriately. 

restoring 

Progress  on  maintaining  or 
favourable 
conservation  status  of  species  and  habitats  is  slow,  In 
part  due  to  a  large  knowledge  gap  on  monitoring.  The 
main  human-induced  pressures  as  reported  under 
Art. 17 HD and Art. 12 BD are from agriculture, forestry, 
urban  development,  changes  in  the  water  regime, 
climate change and alien species. 

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 of the overall use of – and risk from – 
chemical pesticides; 
-  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
-  a  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  a  20%  reduction  of  the  use  of 
fertilisers); 
- bring back at least 10% of agricultural area under high-
diversity landscape features and increasing areas under 
organic farming to at least 25%. 

With  an  estimated  7.21%  of  its  agricultural  area  under 
organic  farming,  Croatia  is  below  the  EU  average  of 
9.07% (2020 data, Eurostat). 

25  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats  and  species,  December  2021.  When  comparing  the  figures 
shown for 2007-2012 and 2013-2018, please note that these may also 
be affected by changes in method or better data availability. Data for 

2007-2012 are not available as Croatia did not join the European Union 
until 2013. 
26 Idem. 

Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
Figure 10: Share of total utilised agricultural area 
occupied by organic farming per Member State, 202027  

Croatia  12 

Land  take  in  the  EU-28  amounted  to  539km2/year 
between 2012 and  -2018 despite decreasing in the last 
decade (from over 1 000 km2/year in 2000-2006).  

Net land take compares the area of land taken with the 
area  returned  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. 
Croatia ranks above29 the EU average as regards net land 
take, with 179.4 m2/km2 (EU-27 average: 83.8 m2/km2). 

Figure 11: Land take and re-cultivation in the EU-27 
(m²/km²), 2012-201830 

Croatia’s agricultural sector lags behind the EU average 
in competitiveness and productivity, but performs better 
on environmental/climate-related issues connected with 
agriculture (e.g. biodiversity, greenhouse gas emissions). 
As  in  many  other  EU  Member  States,  generational 
renewal  remains  a  challenge  and  rural  areas  face 
negative demographic trends, depopulation and a lack of 
basic infrastructure. 

Soil ecosystem 

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. 

One factor of degradation is the area of soil that is sealed 
or  artificialised28.  In  Croatia,  the  land  taken  per  year 
between 2012 and 2018 (see Figure 11) can be seen as a 
measure of one important source of pressure on nature 
and biodiversity: land use change. This also constitutes a 
source  of  environmental  pressure  on  people  living  in 
urbanised areas.  

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 ambition. 
Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 

27https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/defaul
t/table?lang=en  (Eurostat,  Area  under  organic  farming,  February 
2022.). 
28 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). 
29 Land take in Europe — European Environment Agency (europa.eu), 
Fig. 6. 
30 European Environment Agency, Land take in Europe, December 2021. 

Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
 
  
Although  27% of EU  forest  area  is protected under the 
Habitats Directive, less than 15% of assessments show a 
favourable 
share  of 
assessments showing bad conservation status increased 
from 27% to 31% in the EU compared to 2015.  

status31.  The 

conservation 

Forests  cover  47.86%  of  Croatia’s  territory32  and  more 
than  25%  of  the  assessments  show  a  favourable 
conservation status, which is well above the EU average33 
In  2020,  Croatia  had  7 000  ha  of  primary  forests34.A 
complaint concerning illegal logging in Natura 2000 areas 
was  filed 
is  being  assessed  by  the 
Commission. 

in  2021  and 

Figure 12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)35 

The European Union Timber Regulation (EUTR)36, which 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested timber, requires the competent authorities in 
the  EU  Member  States  to  conduct  regular  checks  on 
operators and traders and apply penalties in the event of 
non-compliance.  With  the  amendment  of  Article 20  of 
the EUTR, biennial reporting became annual; as of 2019, 
reports cover the calendar year. 

Between  March  2017  and  February  201937,  Croatia 
carried out 104 checks on operators importing timber. It 
is  estimated  that  Croatia  had  3 589  operators  placing 
imported timber types on the internal market over the 
reporting period. 

A proposal for the Regulation on the making available on 
the  EU  market  and  the  export  of  products  associated 

31 EEA, State of Nature in the EU. 
32 EEA, Forest information system for Europe. 
33 COM SWD (2021) 652. 
34 JCR, Mapping and assessment of primary and old-growth forests in 
Europe, p. 13. 
35  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
36 Regulation (EU) No 995/2010.  
37 COM/2020/629 final. 

Croatia  13 

forest 

adopted 

deforestation 

degradation 
and 
with 
(Deforestation 
on 
Regulation)  was 
17 November  2021  following  a  2019  request  from  the 
Council  to  table  a  legislative  proposal  to  address  the 
resolution 
problem  and  a  European  Parliament 
recommending  the  Commission  come  forward  with  an 
EU legal framework to halt and reverse EU-driven global 
deforestation. This Regulation will repeal and replace the 
EU  Timber  Regulation,  as  it  will  essentially  incorporate 
and  improve  the  existing  system  for  controlling  timber 
legality.  

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 invasive alien species also facilitate the 
outbreak  and  spread  of  infectious  diseases,  posing  a 
threat to humans and wildlife. 
The  implementation  of  the  EU  Invasive  Alien  Species 
Regulation  and  other  relevant 
legislation  must  be 
stepped up. 
The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  invasive  alien  species  and  decrease  the 
number of ‘red list’ species they threaten by 50%. 

The core of the Regulation on invasive alien species (the 
IAS  Regulation)38 is  the  list  of  Invasive  Alien  Species  of 
Union concern.  

There  are  currently  66 invasive  alien  species  (IAS)  of 
Union concern, of which 30 are animal species and 36 are 
plant species.  

According  to  a  2021  report39  on  the  review  of  the 
application  of  the  IAS  Regulation,  the  Regulation’s 
implementation  is  already  starting  to  deliver  on  its 
objectives, such as a coherent framework for addressing 
IAS at EU level and increased awareness of the problem 
of  IAS.  At  the  same  time,  the  report  identified  some 
challenges  and  areas  for  improvement.  Given  that  the 
deadlines for implementing the various obligations of the 
IAS  Regulation  were  staggered  between  July  2016  and 
July  2019,  it  would  be  premature  to  draw  conclusions 
about several aspects of the implementation of the IAS 
Regulation. 

38 Regulation (EU) No 1143/2014. 
39  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 October 2021. 

Environmental Implementation Review 2022 – Croatia 

 
 
                                                                 
Croatia  14 

A 2021 report40 on the baseline distribution shows that 
of the 66 species on the EU list, 23 have been observed 
in the environment in Croatia. The spread can be checked 
in Figure 13. 

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

  Fill  in  the  gaps  in  the  system  for  monitoring  the 
conservation  status  of  protected  habitats  and 
species. 

  Enhance  control  of  logging  in  Natura  2000  areas, 
efficiently preventing and prosecuting illegal logging 
in particular. 
Implement the action plans necessary to control the 
spread of IAS in accordance with the IAS Regulation. 

 

Marine ecosystems 

The EU Biodiversity Strategy  2030 aims to substantially 
reduce  the  negative  impacts  on  sensitive  species  and 
habitats  in  marine  ecosystems  and  to  achieve  good 
environmental status as well as eliminate or reduce the 
incidental catches of protected, endangered, threatened 
and  sensitive  species  to  a  level  that  allows  species 
recovery and conservation42. 

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

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

The Commission assessed Croatia’s 2018 determinations 
of GES for each MSFD’s 11 descriptors43 and established 
their  level  of  adequacy  in  relation  to  the  Commission 
Decision  on  criteria  and  methodological  standards  on 
good environmental status of marine waters44. 

A  good  or  very  good  score  indicates  that  the  national 
determinations  of  GES  are  well  aligned  with 
requirements of the Commission GES Decision, providing 
qualitative  and  quantitative  national  environmental 
objectives to be achieved for their marine waters. 

2022 priority actions 

  Complete  the  process  of  designating  SCIs  in  the 
marine  environment.  Designate  all  SACs  and  put  in 
place  site-specific  conservation  objectives  and 
necessary conservation measures for all Natura 2000 
sites. 

  Complete an adequate framework for managing the 
Natura 2000 network, including by ensuring sufficient 
financial and human resources in accordance with the 
needs 
action 
framework41. 

prioritised 

identified 

the 

in 

  Set  up  a  mechanism  for  effective  cooperation  with 
economic  sectors,  in  particular  water  management, 
forestry, agriculture, fisheries and energy, on Natura 
2000  management  and  the  restoration  of  habitats 
and species.  

40 De Jesus Cardoso A., 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  v.  JRC  baselines,  EUR 
30689  EN,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, ISBN 978-92-76-37420-6, doi:10.2760/11150, JRC123170. 
41  The  prioritised  action  framework  for  the  Croatian  Natura  2000 
network is currently in the national process of adoption. The version of 
the document distributed for public consultation  is available HERE (in 
Croatian only).  

42  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
43  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. 
44 The Commission GES Decision, Commission Decision (EU) 2017/848, 
OJ L 125, 18.5.2017, p. 43-74. 

Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
 
Figure 14: Level of adequacy of GES determination by 
Croatia (MAD region) with criteria set out in Article 9 
of the Commission GES Decision (2018 reporting 
exercise)45 

Figure 15: Level of adequacy of national assessment of 
Croatia’s marine environment (MAD region) with the 
criteria set out in Article 8 of the Commission GES 
Decision (2018 reporting exercise)46 

Croatia  15 

Croatia has one marine subregion, MAD (Mediterranean: 
Adriatic  Sea).  In  this  marine  subregion,  6  out  of  11 
determinations  of  GES  were  assessed  as  good  or  very 
good, indicating that the national determination of GES 
by Croatia is consistent for 6 out of 11 descriptors. 

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

to  assess 

7 descriptors out of 11 were scored as good or very good. 
is 
Croatia’s  assessment  of 
therefore consistent with the requirements set under the 
Commission GES Decision for 7 out of 11 descriptors. 

its  marine  environment 

In  the  EIR  2019,  the  Commission  recommended  that 
Croatia ensure timely reporting of the different elements 
under the Marine Strategy Framework Directive so that 
Croatia could be part of future Commission assessments. 
This  priority  action  has  been  fulfilled.  As  highlighted  in 
the Commission’s report  on the implementation of the 
MSFD47, while regional cooperation has improved since 
the adoption of the MSFD, more cooperation is needed 
to attain full regional coherence of the marine strategies, 
as required by the Directive. 

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

2022 priority actions 

 

Improve the status of descriptors that were assessed 
as very poor. 

45  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. 
46 Idem. 
47 COM(2020)259. 

Environmental Implementation Review 2022 – Croatia 

 
 
                                                                 
 
 

the  Commission’s  recommendations 
Implement 
regarding  the  preparation  of  marine  strategies, 
encompassing:  assessment,  determination  of  good 
environmental 
establishment  of 
status 
environmental targets.  

and 

  Ensure  regional  cooperation  with  Member  States 
sharing  the  same  marine  (sub)region  in  order  to 
address predominant pressures. 

Ecosystem assessment and accounting  

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

initiative  towards 

The  first  study  on  the  mapping  and  evaluation  of 
ecosystems on the national level was made in 2015. This 
was  the  first 
implementing  the 
Member  States’  obligations  under  the  EU  Biodiversity 
Strategy  by  2020.  The  result  of  the  project  is  a  map  of 
ecosystems  and  a  summary  overview  of  the  state  of 
ecosystem types in Croatia. Unfortunately, this map was 
made  in  1:100 000  scale  and  provides  only  rough 
information  about  the  distribution  of  ecosystems  of 
Croatia.  

In  2018,  the  Croatian  Agency  for  the  Environment  and 
Nature started a project to evaluate the quality of data 
available  for  assessing  ecosystem  services  and  identify 
and  connect  the  scientists  and  other  relevant  experts 
who could implement ecosystem services essessment in 
Croatia. 

There has been a great increase in the number of local-
level studies of ecosystem services in recent years. All of 
these  studies,  together  with  the  above  projects,  are 
contributing to work on the national project to map and 
assess  the  state  of  ecosystems  and  ecosystem  services 
nationwide.  

Croatia  has  provided  up-to-date 
information  and 
significant  progress  has  been  recorded  since  January 
is  based  on  27 
2016  (Figure 16).  This  assessment 
implementation  questions  and  is  updated  every  six 
months. 

Croatia  16 

Figure 16: ESMERALDA MAES barometer (January 2016 
- March 2021)48 

the 

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

Figure 17: Ecosystem accounting barometer49 

2022 priority actions 

indicators  for 

  Continue supporting the mapping and assessment of 
ecosystems  and  ecosystem  services,  and 
the 
development  of  ecosystem  accounting,  through 
integrating  ecosystem 
appropriate 
extent, ecosystem condition and ecosystem services 
(including  some  monetary  values) 
into  national 
accounts;  continue  supporting  the  development  of 
national  business  and  biodiversity  platforms, 
including  natural  capital  accounting  systems,  to 
monitor  and  evaluate  the  impact  of  business  on 
biodiversity. 

48 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem Assessment: summary for policymakers, May 2021, p. 80. 
49  MAIA  portal,  Mapping  and  Assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Ecosystem  Accounting  (SEEA 
EA) as the methodological basis for ecosystem accounting. The SEEA EA 

is an integrated and comprehensive statistical framework that is based 
on  five  core  accounts:  ecosystem  extent,  ecosystem  condition, 
ecosystem services (physical and monetary) and monetary ecosystem 
asset. 

Environmental Implementation Review 2022 – Croatia 

 
                                                                 
  
 
 
 
 
 
 
Croatia  17 

Environmental Implementation Review 2022 – Croatia 

 
 
Croatia  18 

indicate  that  Croatia  is  in  compliance  with  the  emission 
reduction commitments for all pollutants in 2020.  

Croatia  submitted 
programme on 11 October 2019. 

its  national  air  pollution  control 

Figure 18: Emission trends for main pollutants/GDP in 
Croatia, 2005-201958 

3. Zero pollution 

Clean air 

its 

EU  clean  air  policies  and  legislation  need  to  significantly 
improve air quality in the EU, by moving the EU closer to 
the  air  quality  recommended  by  the  WHO  and  curbing 
emissions of key air pollutants. 
Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity should be further reduced with the long-term 
aim of not exceeding critical loads and levels. This requires 
strengthening  efforts  to  reach  full  compliance  with  EU 
clean  air  legislation  and  defining  strategic  targets  and 
actions for 2030 and beyond. 
The 2030 zero pollution action plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the  EU  ecosystems  threatened  by  air  pollution  by  25% 
compared to 2005. 

The EU has developed a comprehensive body of air quality 
legislation,  which  establishes  health-based  standards50 
and  emission  reduction  commitments51  for  a  number  of 
air pollutants. 

Air  quality  in  Croatia  gives  cause  for  concern.  The  latest 
available  annual  estimates  (for  2019)  by  the  European 
Environment  Agency52  point  to  about  4 200  premature 
deaths  (or  43  400  years  of  life  lost  (YLL))  attributable  to 
fine  particulate  matter  concentrations53,  240  (2 600  YLL) 
to ozone concentration54 and 170 (1 700 YLL) to nitrogen 
dioxide55 concentrations56.  

(see  Figure 18)  According  to  the 

Emissions  of  key  air  pollutants  have  decreased 
significantly in Croatia in recent years, while GDP growth 
continued 
latest 
projections submitted under Article 10(2) of the National 
Emission  Reduction  Commitments  Directive  (NECD)57, 
Croatia  expects 
reduction 
commitments  for  all  air  pollutants  covered  by  the 
Directive  for  the  period  2020  to  2029  and  for  most 
pollutants  for  the  period  from  2030  onwards.  However, 
indicate  that  the  emission 
the  projections  do  not 
reduction  commitments  for  NOx  will  be  fulfilled  for  the 
period  from  2030  onwards.  The  latest  inventory  data 
submitted by Croatia, prior to review by the Commission, 

its  emission 

fulfil 

to 

50 European Commission, 2016, Air Quality Standards. 
51 European Commission, Reduction of National Emissions. 
52  European  Environment  Agency,  Air  Quality 
in  Europe  –2021 
RapportEuropean  Environment  Agency,  Air  Quality  in  Europe  –  2021 
report.  Please  see  the  report  for  details  of  the  underpinning 
methodology (p.106). 
53  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.  
54 Low-level ozone is produced by photochemical action on pollution. 

55 NOx is emitted during fuel combustion by e.g. industrial facilities and 
the road transport sector. NOx is a group of gases comprising nitrogen 
monoxide (NO) and nitrogen dioxide (NO2). 
56  Please  note  that  these  figures  refer  to  the  impact  of  individual 
pollutants. To avoid double-counting, they cannot be added up to derive 
a sum. 
57 Directive 2016/2284/EU. 
58 European Environment Agency. 

 Environmental Implementation Review 2022 – Croatia 

 
 
                                                                 
 
  
 
Figure 19: PM2.5 and NOx emissions by sector in Croatia 
(2019)59 

Croatia  19 

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

There  is  an  ongoing  infringement  procedure  concerning 
daily exceedances of PM10 and PM2.5 limit values for three 
air  quality  zones  in  Croatia.  Continuous  monitoring  of 
PM10 in Croatia shows persistent exceedance of PM10 limit 
values: in two agglomerations (Zagreb and Osijek) and one 
zone  (Industrijska  zona),  limit  values  were  exceeded  for 
more  than  35  days  (and  in  some  years  as  many  as  100 
days) per year from 2013 until at least 2018, while the limit 
value  for  the  annual  average  was  also  exceeded  in 
Industrijska zona.  

for  PM2.5 

Monitoring of PM2.5 in Croatia shows that the annual limit 
in  the 
value 
agglomeration  of  Zagreb  and  in  Industrijska  zona  from 
2015 until at least 2018; some years, PM2.5 concentrations 
even reached 41 μg/m³). 

(25 μg/m³)  was  exceeded 

The trends of exceedance in these areas  show no signs of 
changing,  indicating  that  the  measures  taken  under  the 
Croatian authorities’ air quality plans are not effective. 

As emissions of particulate matter have not decreased, it 
is  evident  that  the  2019  priority  actions  have  not  been 
addressed completely. 

2022 priority actions  

  Take  additional  measures  to  attain  the  emission 
reductions required to fulfil NECD emission reduction 
commitments,  as  the  latest  air  pollutant  emission 
projections suggest that such measures are necessary.  
  Take, in the context of the national air pollution control 
programme,  actions  towards  reducing  the  main 
emission sources.  

  Maintain downward trends for air pollutant emissions 
and  reduce  the  adverse  effects  of  air  pollution  on 
health and the economy with a view to reaching WHO 
guideline values in future and fully comply with EU air 
quality standards where these are not met.  

Industrial emissions 

The  main objectives of EU policy on industrial emissions 

For  the  year  2020,  exceedances  of  the  EU  limit  values 
established  by  the  Ambient  Air  Quality  Directive  (AAQD) 
were  registered  for  particulate  matter  (PM10)  and  fine 
particulate matter (PM2.5) in two agglomerations and one 
target  values 
zone  respectively.  Furthermore, 
regarding ozone concentration have not been met for one 
air quality zone60 . 

the 

59 European Environment Agency. 

60 European Environment Agency, Eionet Central Data Repository 

 Environmental Implementation Review 2022 – Croatia 

 
 
  
 
 
 
                                                                 
 
 
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)61.  The  Commission 
tabled a proposal  in April  202262. 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  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  data  reported  to  the  EU  Registry 
(2018)63. 

In Croatia, around 230 industrial installations are required 
to  have  a  permit  based  on  the  IED.  The  distribution  of 
installations is shown in the figure below. 

In 2018, the industrial sectors in Croatia with the most IED 
installations were the intensive rearing of poultry and pigs 
(23%), followed by landfill sites (23%), mineral production 
(12%) and the food and drink industries (7%). 

Croatia  20 

Figure 20: Number of IED industrial installations per 
sector in Croatia, 201864 

The  industrial  sectors  identified  as  placing  the  largest 
burden on the environment in terms of emissions to air 
were the energy sector (power and refineries) for sulphur 
oxides  (SOx),  particulate  matter  (PM2.5),  arsenic  (As), 
chromium  (Cr)  and  nickel  (Ni);  surface  treatment  using 
organic  solvents 
for  non-methane  volatile  organic 
compounds (NMVOCs); intensive rearing of poultry or pigs 
for ammonia (NH3); other industrial product use for lead 
(Pb),  copper (Cu) and  cadmium (Cd); mineral production 
for nitrogen oxides (NOx), mercury (Hg) and zinc (Zn); and 
waste management for dioxins. The breakdown is shown 
in the following graph. 

61  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers the energy industry, metal production, the 
mineral and chemical industry, waste management, and a wide range of 
industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pigs  and 
poultry, pulp and paper production, painting and cleaning). 
62  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). 
63 European Environment Agency, European Industrial Emissions Portal. 
64  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
 
                                                                 
 
 
 
 
Figure 21: Emissions to air from IED sectors and other 
national total air emissions in Croatia, 201865 

Figure 22: Number of inspections in IED installations in 
Croatia in 201866 

Croatia  21 

stakeholders 

conclusions  ensures 

The development  of  best  available  techniques reference 
documents  and  BAT 
good 
better 
collaboration  with 
implementation of the IED67. Since the last EIR report, BAT 
conclusions were adopted for waste incineration, for the 
food, drink and milk industries and for surface treatment 
using organic solvents, including wood and wood product 
preservation with chemicals. 

and 

a 

The  environmental  burdens  for  industrial  emissions  to 
water mainly result from the production of chemicals, in 
the case of nitrogen, and refineries, in the case of heavy 
metals (based on E-PRTR data).  

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

to 

As  part  of  their  environmental  inspection  work,  the 
competent  authorities  conduct  site  visits 
IED 
installations  to  take  samples  and  gather  the  necessary 
information. Article 23(4) of the IED requires site visits to 
be  carried  out  between  once  a  year  and  once  every  3 
years, depending on the environmental risks posed by the 
installations.  In  2018  Croatia  undertook  around  200  site 
visits, the majority of which to landfill sites (38%), followed 
by mineral production installations (12%), refineries (7%) 
and food and drink production sites (7%). 

implement  the 

The  Commission  relies  on  the  national  competent 
authorities  to 
legally  binding  BAT 
in 
conclusions  and  associated  BAT  emission 
environmental  permits.  Their  efforts  have  resulted  in 
considerable and continuous reduction in pollution.  

levels 

In  2019,  Croatia’s  priority  actions  included  reviewing 
permits  to  ensure  that  they  complied  with  the  newly 
adopted  BAT  conclusions  and  strengthening  control  and 
enforcement  to  ensure  compliance  with  the  BAT 
conclusions.  The  Commission  followed  up  these  actions 
through Croatia’s reporting to the EU Registry, finding no 
systematic  breaches  of  EU  law  in  the  relevant  areas.  No 
non-compliant  permits  were  reported  in  2018.  In  2019 
in  the  waste 
Croatia 
management sector as a key challenge. The Commission 
developed  tools  to  support 
in  this 
domain,  such  as  an  implementation  exchange  platform 
and dedicated workshops. 

implementing  BAT 

implementation 

identified 

Croatia  has  still  not  transposed  some  articles  of  the  IED 
correctly  and 
infringement 
is  subject  to  a  pending 
procedure.  Among  other  things,  the  definitions  of 
‘installation’,  ‘best  available  techniques’  and  ‘baseline 
condition’ have been transposed incorrectly. In addition, 
national  legislation  lacks  special  requirements  on  the 
frequency of site visits  and the timeliness of inspections 
and fails to lay down a clear obligation for the inspection 
report to describe the relevant findings. 

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

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

 Environmental Implementation Review 2022 – Croatia 

 
 
  
 
 
                                                                 
  
 
Prevention of 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 
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)68. 

The below overview of industrial plants regulated by  the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  to  the  eSPIRS  database  (2018)69  and 
Croatia’s report  on the implementation of the  Seveso III 
Directive for 2015-201870. 

Of Croatia’s 72 Seveso establishments, 37 are categorised 
as  lower-tier  establishments  (LTEs)  and  35  as  upper-tier 
establishments (UTEs) based on the quantity of hazardous 
substances  likely  to  be  present.  The  UTEs  are  subject  to 
more  stringent  requirements.  Figure 24  presents  the 
change in the number of Seveso establishments. 

Figure 23: Number of Seveso establishments in Croatia, 
2014 and 201871 

Croatia  22 

implementation  of  the  necessary  actions  to  protect  the 
environment and the population should a major industrial 
accident happen. 

Figure 24: Situation regarding EEPs in Croatia, 201872 

The information to the public referred to in Annex V of the 
Seveso III Directive – especially information about how the 
public concerned will be warned in  the event of a major 
accident,  the  appropriate  behaviour  in  the  event  of  a 
major  accident  and  the  date  of  the  last  site  visit  –  is 
permanently available for all the Seveso establishments in 
Croatia. 

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

Figure 25: Share of UTEs for which information on safety 
measures and appropriate behaviours was actively 
made available to the public in Croatia, 2014 and 201873 

According to Croatia, an external emergency plan (EEP) is 
required for 37 UTEs. In 2018, all 37 UTEs had an EEP and 
all 37 of these EEPs had been tested in the past 3 years. 
The summary is shown in Figure 25. The establishment of 
EEPs is essential to allow proper preparation and effective 

68  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances. 
69 European Commission, Seveso Plants Information Retrieval System. 
70 As provided for by Article 21(2) of the Seveso III Directive. 
71 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. 
72 Idem. 
73 Idem. 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
 
  
 
 
                                                                 
 
  
 
 
 
 
 
 
Croatia’s transposition of several provisions of the Seveso 
III  Directive  was  non-compliant.  This  includes  definitions 
that  are  important  for  defining  the  Directive’s  scope, 
provisions  on  the  time  limits  for  submitting  the  safety 
if 
report,  a  provision  on  operators’  obligations 
establishments and installations are modified and certain 
requirements  regarding  emergency  plans.  In  addition, 
Croatian  legislation  does  not  contain  all  the  guarantees 
relating  to  the  public’s  rights  to  access  information  and 
participate 
infringement 
in  decision-making.  An 
procedure opened by the Commission has been pending 
since October 2019. 

Noise 

The  Environmental  Noise  Directive74  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise 
although  it  does  not  set  noise  limits  as  such.  Its  main 
instruments  in  this  respect  are  strategic  noise  mapping 
and planning. A key target under the 2030 zero pollution 
action  plan  is  to  reduce  by  30%  the  share  of  people 
chronically  disturbed  by  transport  noise  compared  to 
2017. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  leads  to  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress75. 

limited  set  of  data76, 
In  Croatia,  according  to  a 
environmental noise is estimated to cause at least around 
100 premature deaths and  200 cases of ischaemic heart 
disease annually77. Moreover, some 15 000 people suffer 
from disturbed sleep. The reported data show that overall 
noise  exposure  in  Croatia  decreased  by  22%  between 
2012 and 2017. Based on the latest full set of information 

74 Directive 2002/49/EC. 
75 WHO 2018, Environmental Noise Guidelines for the European Region. 
76 For further information, see European Environment Agency, Noise Fact 
Sheets 2021. 
77 These figures are an estimate by the European Environmental Agency, 
based  on:  (i)  the  data  reported  by  Member  States  on  noise  exposure 
covered  by  Directive  2002/49/EC;  (ii)  European  Topic  Centre  on  Air 
Pollution,  Transport,  Noise  and  Industrial  Pollution  (ETC/ATNI)  2021, 
ETC/ATNI  Report  06/2021:  Noise  indicators  under  the  Environmental 
Noise Directive 2021: Methodology for estimating missing data; Croatian 
Official  Gazette  the  methodology  for  health 
impact  calculations 
methodology  for  assessing  the  impact  on  health  set  out  in  ETC/ACM 
2018,  Eionet  Report  ETC/ACM  2018/10,  Implications  of  environmental 
noise on health and wellbeing in Europe. 
78 The Water Framework Directive (2000/60/EC). 
79 EU Water Policy. 

Croatia  23 

that has been analysed, noise mapping of agglomerations, 
roads and railways is complete. 

Water quality and management 

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

Water Framework Directive 

is 

(WFD)78 

The  Water  Framework  Directive 
the 
cornerstone of EU water policy in the 21st century79. Along 
with other  water-related  legislation80, the  WFD   sets  out 
the  framework  for  sustainable  and  integrated  water 
management, which aims at a high level of protection of 
water resources, prevention of further deterioration and 
restoration to good status. 

Member  States  have  to  report  the  third  generation  of 
River Basin Management Plans (RBMPs) drawn up under 
the WFD by March 2022. The Commission will assess the 
reported status and progress, checking how the findings 
identified in the assessment of the second RBMPs81 have 
been  addressed.  Croatia  has  not  yet  reported  the  third 
RBMPs. 

The  Commission  published 
its  sixth  report  on  the 
implementation of the WFD and the Floods Directive (FD) 
in December 202182. It includes an interim assessment of 
the  progress  made  in  implementing  the  Programmes  of 
Measures  and  of  the  monitoring  of  the  new  priority 
substances. The assessment report for Croatia83 estimated 

80  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban Waste Water Treatment Directive (91/271/EEC), the new Drinking 
Water  Directive  (2020/2184/EC),  the  Nitrates  Directive  (91/676/EEC), 
the  Marine  Strategy  Framework  Directive  (2008/56/EC),  the  Industrial 
Emissions Directive (2010/75/EU) and the new Regulation on minimum 
requirements for water reuse (2020/741). 
81  Detailed  information  can  be  found  in  the  fifth  report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
82 See the sixth report on the implementation of the WFD and the FD. 
83  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
 
that implementing the Programme of Measures would not 
enable the water protection objectives to be achieved by 
the end of 2021. 

Figure 27: Percentage of surface water bodies not 
achieving good chemical status87  

Croatia  24 

According to the reporting on the  second RBMPs and  to 
data  published  in  202084,  in Croatia 42.1% of  all  surface 
water 
ecological 
status and  91.8% have good chemical status, while 9.1% 
of  groundwater  bodies  failed  to  achieve  good  chemical 
status and 3% have poor quantitative status.  

bodies85 have 

good 

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

failing 

Figure 26: Proportion of surface water bodies (rivers, 
lakes, transitional and coastal waters) not in good 
ecological status in each river basin district86 

The  following  figure  presents  the  percentage of surface 
water  bodies  failing  to  achieve  good  chemical  status 
in Croatia and other European countries. For Croatia, the 
percentage is 8.2%; this includes the water bodies failing 
due to ubiquitous  persistent,  bio-accumulative and toxic 
substances. If the bodies failing due to these substances 
are excluded, the percentage is 6%. 

The 
total  volume  of  water  abstracted  annually 
(corresponding  to  2019  baseline)  from  surface  and 
groundwater sources in Croatia is 680.74 hm3 (EEA, 2022). 
The percentage of this water abstracted by each sector is 
4.39%  for  agriculture,  66.26%  for  public  water  supply, 
11.37% for electricity cooling, 10.70% for manufacturing, 
6.74% for manufacturing cooling and 0.53% for mining and 
quarrying,  as 
figure. 
Croatia uses  a  register to  record  water  abstractions  that 
are subject to permits. This is automatically updated any 
time  there  are  changes  to  the  permits. Low-volume 
abstractions do not require permits in Croatia and are not 
listed in the register. 

illustrated 

following 

the 

in 

during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Croatia, 2022. 
84 WISE Freshwater (europa.eu) 
85 Rivers, lakes, and transitional, coastal and territorial waters. 

86 European Environment Agency, 2021.   
87 European Environment Agency, December 2019. 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
  
 
                                                                 
 
 
 
Figure 28: Water abstraction per sector in Croatia88 

Floods Directive 

Croatia  25 

As  mentioned  previously,  the  Commission  published  its 
sixth  implementation  report  in  December  2021.  The 
report includes the review and update of the preliminary 
flood  risk  assessments  (PFRAs)  performed  during  the 
second cycle (2016-2021). 

The assessment report91 showed that climate change was 
taken into consideration in the assessment of future flood 
risks.  Also,  flood  risk  was  assessed  for  every  settlement 
and for all historic floods  for which  data  could be found 
(since  1667).  The  significance  of  historical  floods  was 
assessed  using  expert  judgement.  However,  the  PFRA 
could  be  improved  in  future  cycles  by  adopting  an 
approach  to  risk  assessment  based  on  improved  data 
collection. 

Croatia  has  not  adopted  and  reported  the  second 
generation  of  Flood  Risk  Management  Plans  under  the 
Floods  Directive.  The  European  Commission  will  assess 
progress  since  the  adoption  of  the first  Flood  Risk 
Management Plans and publish a new report, as it did in 
2019.  

Drinking Water Directive 

As  regards  the  Drinking  Water  Directive92,  no  new 
assessment of drinking water quality has been issued since 
the EIR 2019. The quality of drinking water in Croatia has 
not been indicated as an area of concern. 

The  recast  Directive  93entered  into  force  on  12 January 
2021  and  Member  States  have  until  12 January  2023  to 
transpose it into their national legal systems. Croatia will 
have  to  comply  with  the  revised  quality  standards  it 
contains. 

Croatia’s Water Exploitation Index plus (WEI+)89 is 0.36%, 
which is much less than the 20% generally considered to 
be indication of water scarcity.  

The bar  chart below  presents  the  WEI+  for Croatia and 
other  European  countries. Croatia is  ranked 25th  (from 
high to low score) in the in terms of WEI+. 

Figure 29: Water exploitation index plus for Croatia and 
the EU, 201790 

Croatia has developed a reporting system based on best 
practices  (EstuarIS  project)  in  order  to  share  knowledge 
about environmental data management and reporting in 
the  field  of  water.  This  can  be  highlighted  as  a  good 
practice. The system can be used to manage data storage, 
receive,  store  and  process  data,  view  information,  and 
prepare, draft and distribute reports. 

Bathing Water Directive 

Regarding  the  Bathing  Water  Directive,  Figure 31  shows 
that in 2020, 95.1% of Croatia’s 935 bathing waters were 
of  excellent  quality94.  Detailed  information  on  Croatia’s 
bathing waters is available from a national portal95 and via 
an  interactive  map  viewer  provided  by  the  European 
Environment Agency96. 

88  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
89  The  WEI+  is  a  measure  of  total  fresh  water  use  as  a  percentage  of 
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 to the environment after use. 
90 European Environment Agency, Water Exploitation Index plus, 2022. 
91  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: Croatia, 2022. 
92 OJ L 330, 5.12.1998, p. 32–54. 
93 OJ L 435, 23.12.2020, p. 1–62. 
94  European  Environment  Agency,  2021.  State  of  bathing  water  — 
European Environment Agency (europa.eu) , p. 17. 
95 Kakvoća mora u Republici Hrvatskoj (izor.hr).  
96 EEA, State of bathing waters in 2020 — European Environment Agency 
(europa.eu). 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
 
 
 
                                                                 
 
Figure 30: Bathing water quality in Europe in the 2020 
season97 

Croatia  26 

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

According  to  the  2016-2019 
implementation  report, 
groundwater  quality  has  improved  slightly  compared  to 
the previous reporting period: the percentage of stations 
reaching  or  exceeding  40  or  50  mg  of  nitrates  per  litre 
decreased from 23.91% to 21.4% and from 20.4% to 17.9% 
respectively. 
nitrate 
situation 
concentrations in surface water is rather good and stable, 
and some improvements were recorded in the reduction 
of eutrophication of surface water. 

concerning 

The 

Figure 31: Bathing water quality in Croatia and the EU, 
2017-202098 

Croatia has a low livestock density, the surplus of nitrogen 
is about the EU average and the surplus of phosphorus is 
low.  There  is  a  well-developed  network  of  monitoring 
stations  in  nitrate  vulnerable  zones,  but  no  monitoring 
station  outside  these  zones.  Groundwater  quality  is 
generally  good.  However,  many  bodies  of  surface  water 
are eutrophic. 

Urban Waste Water Treatment Directive 

Croatia  has,  over  the  years,  encountered  difficulties  in 
meeting  its  obligations  under  the  Urban  Waste  Water 
Treatment  Directive  (UWWTD).  In  2018  Croatia’s  overall 
compliance rate was 7%, which is significantly lower than 
the  EU  average  of  76%.  93%  of  urban  wastewater  in 
Croatia  is  not  collected  and/or  does  not  meet  the 
requirements for biological treatment. 

Pursuant to its Accession Treaty, Croatia should reach full 
compliance with the requirements of the Directive by the 
end of 2023. However, it is already clear that Croatia will 
need to step up its efforts if it is to meet the deadlines set 
out in its Accession Treaty. 

Nitrates Directive 

The  latest  Commission  report  on  the  implementation  of 
the Nitrates Directive89, covering 2016-201990, warns that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 

97 European Environment Agency, Bathing water quality in 2020, 2022. 
98  European  Environment  Agency,  European  bathing  water  quality  in 
2017, 2018, 2019 and 2020. 

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Croatia  27 

ensures  stability  and  predictability 
operating within the internal market.  

for  businesses 

(REACH)  and 

The  Commission  has  gathered 
information  on  the 
enforcement of the Registration, Evaluation Authorisation 
and  Restriction  of  Chemicals 
the 
Classification,  Labelling  and  Packaging  (CLP)  Regulations 
since 2007. In December 2020, the Commission assessed 
the  Member  States’  reports  on  the  implementation  and 
enforcement  of  these  Regulations102  in  line  with  REACH 
Article 117(1) and CLP Article 46(2). According to the new 
data  (for  2015-2019),  national  enforcement  structures 
have not changed much. However, it is apparent from the 
latest report (2020) that there are still many disparities in 
REACH-CLP 
in  the  area  of 
enforcement. 

implementation,  notably 

In August 2021, the Commission published a measurable 
assessment  of  the  enforcement103  of  the  two  main  EU 
Regulations on chemicals using a set of indicators covering 
different aspects of enforcement. 

Responsibility  for  checking  compliance  with  REACH  in 
Croatia lies with the state inspectorate104. 

Croatia has not devised or implemented any strategy for 
the  enforcement  of  the  REACH  or  CLP  Regulations,  but 
there are plans to devise one105. 

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

in 

the 

reporting  period 

In Croatia, 4 inspectors have been allocated to REACH and 
CLP  enforcement  at  national  level  and  30  at  regional 
level106. As a result, the number of REACH controls carried 
out 
remains  well 
below average. Most  of  the  controls  carried  out  are 
proactive (inspections) rather than reactive/non-routine (i.e. 
investigations  in  response  to  complaints,  accidents  and 
referrals). The percentage of cases of non-compliance out 
of the total number controls is below the EU average107. 

(62) 

Figure 32: Proportion of urban waste water that meets 
all requirements of the UWWTD (collection, biological 
treatment, biological treatment with nitrogen and/or 
phosphorus removal), in compliant urban areas of the 
UWWTD (‘compliance rate’), 201899 

2022 priority actions  

  Assess new physical modifications  to water bodies in 
line  with  Article 4(7)  of  the  WFD,  ensuring  these 
assessments include alternative options and adequate 
mitigation measures. 

  Continue current efforts to ensure that hydrotechnical 
flood  protection  activities  do  not  lead  to  additional 
serious hydromorphological deterioration. 

  Better  coordinate  the  implementation  of  between 

 

water, marine and nature policies. 
Implement  the  Urban  Waste  Water  Treatment 
Directive in full in all agglomerations by building up the 
necessary infrastructure. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment.  On 
14 October 2020, the European Commission published its 
chemicals strategy for sustainability ‘Towards a Toxic-Free 
Environment’100,  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. 

legislation101 provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 

99 European Commission, WISE Freshwater, 2021. 
100 COM(2020) 667 final. 
101 REACH: OJ L 396, 30.12.2006, p.1. - CLP: OJ L 252, 31.12.2006, p.1. 
102  European  Commission,  final  report  on  the  implementation  and 
enforcement  of  REACH  and  CLP,  Final  report_REACH-CLP  MS 
reporting_2020.pdf (europa.eu). 

103  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators. 
104 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p.68. 
105 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p.76. 
106 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 74. 
107 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p.87-88. 

 Environmental Implementation Review 2022 – Croatia 

 
 
  
 
 
 
                                                                 
Figure 33: Percentage of cases of non-compliance out of 
the total number of REACH and CLP controls carried out 
in  2019,  per  Member  State  and  compared  to  the  EU 
average108 

Croatia  28 

2022 priority actions 

  Upgrade  the  implementation  and  enforcement 
for 
Enhance 
implementation  and  enforcement  to  move 
towards zero tolerance for non-compliance. 

administrative 

capacities 

  Devise  and 

implement  a  REACH  and  CLP 

enforcement strategy. 

108 Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p.87-88, 
2022. 

 Environmental Implementation Review 2022 – Croatia 

 
 
  
 
 
 
 
                                                                 
Croatia  29 

 4. Climate action 

economy  will  need  to  be  decarbonised  more  quickly  if 
climate neutrality is to be reached by 2050.  

In  its  RRP,  Croatia  allocates  around  40%  of  spending  to 
climate  objectives  and  outlines  crucial  reforms  and 
investments  to  support  the  transition  to  a  more 
sustainable, low-carbon and climate-resilient economy.  

climate 

The  Climate  Change  and  Ozone  Layer  Protection  Act 
(Croatian  Official  Gazette  No 127/19)  is  the  Republic  of 
Croatia’s basic legal act regulating the issue of adaptation 
relevant 
to 
responsibilities  and 
implementing  documents  and 
identifies  the  sectors  most  exposed  to  climate  change. 
Croatia has had a strategy on climate change adaptation 
since 2020.  

It  determines 

change. 

the 

By 2020, the country’s total GHG emissions had decreased 
substantially compared to 1990, although less than in the 
EU as a whole. Between 1990 and 2020, GHG emissions in 
Croatia  decreased  by  25%.  However,  the  Croatian 
economy remains GHG-intensive. 

Figure 34: Total GHG emissions (incl. international 
aviation) in Croatia, 1990-2020 

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing greenhouse gas (GHG) emissions by 55% by 2030 
compared  to  1990.  The  law  also  limits  the  contribution 
that  carbon  removals  can  make  towards  emission 
reductions in 2030 to ensure a sufficient mitigation effort. 
The  EU  and  its  Member  States  submitted  updated 
Nationally Determined Contribution (NDC) to the UNFCCC 
in December 2020. 
The EU is working across all sectors and policies to cut GHG 
emissions  and  make  the  transition  to  a  climate-neutral 
and  sustainable  economy,  as  well  as  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  2010109  and  sets  binding  GHG  emission 
standards for different vehicle categories110. 
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 GHG 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  policies111,  as  the  EU  Climate  Law 
recognises  adaptation  as  a  key  component  of  the  long-
term global response to climate change. Member States 
will  be  required  to  adopt  national  strategies  and  the EU 
will  regularly  assess  progress  as  part  of 
its  overall 
governance on climate action. The updated EU adaptation 
strategy, published in February 2021, sets out how the EU 
can adapt to the unavoidable impacts of climate change 
and become climate resilient by 2050. 

Key national climate policies and strategies  

Effort Sharing target  

Croatia has an integrated national energy and climate plan 
(NECP)  for  2021-2030.  In  2021,  it  adopted  a  long-term 
strategy  for  decarbonisation,  which  sets  the  goal  of 
reducing  GHG  emissions  by  between  57%  and  73%  by 
2050  (excluding  land  use  and  forestry).  While  Croatia  is 
likely to meet the proposed and more ambitious target for 
2030  if  all  additional  measures  are  implemented,  the 

For emissions not covered by the EU ETS, Member States 
have  binding  national  targets  under  the  Effort  Sharing 
legislation112. In 2019, Croatia’s emissions from sectors not 
covered  by  the  EU  emissions  trading  system  (such  as 
buildings,  road  transport,  agriculture,  small  industry  and 
waste)  were  lower  than  its  2020  target  of  limiting  the 

109  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. 
110 Regulation (EU) 2019/631 

111 Article 29 of Regulation (EU) 2018/1999. 

112 Regulation (EU) 2018/842 

 Environmental Implementation Review 2022 – Croatia 

 
 
                                                                 
 
 
increase to 11% compared to 2005. Croatia therefore met 
its Effort Sharing emissions reduction target for 2020.  

Croatia’s national energy and climate plan aims to achieve 
greater reductions than the 2030 target of 7% set down in 
the Effort Sharing Regulation.  

Figure 35: Emissions and targets for Croatia under the 
Effort Sharing Decision/ Effort Sharing Regulation, 2020 
and 2030 as percentage change from 2005 

Croatia  30 

reduction by 2020. Member States can take several types 
of action in this regard, such as further expanding the use 
of  electricity  in  road  transport,  supporting  the  use  of 
biofuels (in particular advanced biofuels), incentivising the 
development and deployment of renewable fuels of non-
biological origin and reducing upstream emissions before 
refining processes. 

In 2019, road transport accounted for 27% of total GHG in 
Croatia.  Emissions  have 
increased  by  almost  20% 
compared to 2005 and emissions in the transport sector 
are  projected  to  continue  to  increase.  The  share  of 
renewable  energy  sources  in  transport  is  among  the 
lowest in the EU. Although the number of electric vehicle 
charging  points  in  Croatia  is  above  the  EU  average,  the 
market share of newly registered electric passenger cars is 
among the lowest in the EU.  

Figure  37:  Greenhouse  gas  emissions  by  sector  in 
Croatia113  –  historical  emissions  1990-2020,  projections 
2021-2030114 

Figure 36: Emissions, annual emission allocations (AEAs) 
and accumulated surplus/deficit of AEAs for Croatia 
under the Effort Sharing Decision, 2013-2020 - 

Key sectoral developments 

In  road  transport,  the  GHG  intensity  of  vehicle  fuels  in 
Croatia decreased by 2.5% from 2010 to 2019. The country 
needs  to  act  swiftly  to  meet  the  current  target  of  a  6% 

More building renovation is needed to reduce emissions 
in buildings. Croatia’s residential sector accounts for over 
a  third  of  total  energy  consumption,  well  above  the  EU 
average.  

In  the  land  use,  land  use  change  and  forestry  (LULUCF) 
sector,  Croatia’s  projections  in  its  national  energy  and 
climate  plan  indicate  that  net  removals  will  decrease 
further by 2030. The quantities reported under the Kyoto 
Protocol  for  the  LULUCF  sector  in  Croatia  show  average 
net  removals  of  -6.36  Mt  CO2-eq  for  2013-2019.  In  this 
regard,  Croatia  contributes  1.9%  to  the  EU-27’s  annual 
average sink of -344.9 Mt CO2-eq. Accounting for the same 
period shows average net credits of -1.1 Mt CO2-eq, which 

113  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. 
114 European Environmental Agency, Total GHG trends and projections. 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
 
 
 
 
                                                                 
 
 
corresponds to 1.0% of the EU-27 accounted sink of -115.0 
Mt  CO2-eq.  Reported  net  removals  decreased  between 
2013 and 2017 and increased slightly towards 2019. This 
trend is more defined for accounted net credits.  

Figure 38: Reported and accounted emissions and 
removals from LULUCF in Croatia115 

Croatia  31 

Use of revenues from the auctioning of EU ETS 
allowances 

Croatia’s  revenues  from  the  auctioning  of  emission 
allowances  under  the  EU  ETS  in  2012-2021  totalled 
EUR 463 million.  Pursuant  to  the  Climate  Change  and 
Ozone Layer Protection Act, 100% of Croatia’s auctioning 
revenues are spent on the climate and energy.  

2022 priority actions  

  Support  funding  of  incentives  for  purchasing  electric 
vehicles, subsidies and car scrapping schemes together 
with  further  roll-out  of  adequate  and  matching 
recharging and refuelling infrastructure. 

  Encourage  energy  renovation  of  residential  buildings 

especially, and decarbonise heating system. 

115  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 – Croatia 

 
 
 
 
 
 
 
                                                                 
Croatia  32 

Part II: Enabling framework: implementation tools 

5. Financing 

Environmental investment needs in the EU 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gap between countries. 
Post-2020,  environmental  measures  will  also  be 
supported by the EU’s  COVID-19 Recovery  Fund (via  the 
RRF)  and  the  ’do  no  significant  harm’  (DNSH)  principle, 
which  runs  across  the  EU  budget.  The  renewed 
commitments  made  at  the  COP26  (Glasgow,  October-
November  2021)  and  the  Biodiversity  Convention  (April-
May 2022)116 will also be reflected in the EU budget. 

Overall environmental investment gaps (EU-27) 

The EU’s green transition investment needs cover a range 
of interlinked areas. The additional investment needs over 
the  baselines  (i.e.  the  investment  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 at EUR 390 billion per annum (EU-27)117, plus a 
further  EUR 130 billion 
the  EU’s  core 
environmental objectives118. Climate adaptation costs can 
also  be  significant,  reaching  a  total  of  EUR 35-62 billion 
(narrower scope) or EUR 158-518 billion (wider scope) per 
year119. 
the 
implementation  objectives  to  2020  and  to  2030  (except 
for climate adaptation, the costs of which are expected to 
linger over a longer period). 

to  achieve 

investment 

reflect 

needs 

These 

pollution,  while  pollution  and  water  management 
together  account  for  nearly  two-thirds  of  the  total  gap. 
The investment gap in the circular economy and waste is 
estimated 
to  be  between  EUR 13-28  billion p.a., 
depending  on  the  levels  of  circularity  implemented.  The 
annual  biodiversity  financing  gap  is  estimated  at  around 
EUR 20 billion.  

Table 1: Estimated breakdown of the EU’s 
environmental investment gaps by environmental 
objective, 2021-2030 per annum121 

Estimated investment gap EU-27, 
EUR billion p.a. 

Environmental 
objective 

Pollution  prevention  & 
control 

Water management 

Circular  economy  & 
waste 

EUR billion 

42.8 

26.6 

13.0 

Biodiversity 
ecosystems122 

R&D&I and other 

Total 

& 

21.5 

6.2 

110.1 

Environmental investment needs in Croatia  

 % 

39% 

24% 

12% 

20% 

6% 

100% 

The following table provides a preliminary update of the 
EU’s core environmental investment gap120. Almost 40% of 
the environmental investment gap relate to dealing with 

Priorities  include  sustainable  management  of  natural 
resources  (particularly  waste  management  and  the 
circular  economy),  a  shift  away  from  landfilling  towards 

116  The  Convention  on  Biological  Diversity  (cbd.int); Post-2020  Global 
Biodiversity Framework | IUCN. 
117 SWD(2021)621, accompanying proposal COM(2021)557 to amend the 
REDII Directive (EU) 2018/2001. 
118 SWD(2020) 98 final/2. 
119  SWD(2018)292.  Impact  assessment  accompanying  the  Proposal  for 
the 
(COM(2018)385). 
Regulation 
https://ec.europa.eu/commission/sites/beta-political/files/budget-
may2018-life-swd_en.pdf. 
120  Taking  account  of  decreases  due  to  Brexit  and  some  reconciliation 
among  the  objectives.  Source:  DG  ENV,  Study  supporting  EU  green 
investment  needs  analysis  (ongoing,  2021-2023),  and  DG  ENV  internal 
analysis,  Environmental  investment  needs  and  financing  in  the  EU’s 
green transition, July 2020. 

LIFE 

DG 

121 European Commission, DG Environment, Study supporting 
EU  green  investment  needs  analysis  (ongoing,  2021-2023), 
and 
internal analysis, 
Environment 
Environmental Investment  needs  and  financing  in  the  EU’s 
green transition, July 2020.  
122  To  meet  the  needs  of  the  2030  Biodiversity  Strategy 
(Natura 2000, green infrastructure), at least EUR 20 billion a 
year  should  be  unlocked  for  nature  (COM/2020/380  final) 
while  to  fully  cover  the  strategy  (including  restoration) 
EUR 30-35 billion may be needed, indicating a gap of EUR 10-
20 billion a year compared to current baseline expenditure. 

Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
  
 
 
separate  collection  and  recycling,  decarbonisation,  and 
climate change adaptation (including risk prevention and 
disaster resilience). The investment gap remains  large as 
Croatia  is  still  substantially  below  the  EU  average  for 
municipal  and  packaging  waste  recycling,  its  sewage 
systems  are  underdeveloped  and 
its  water  supply 
networks have high leakage rates. 

Pollution prevention & control 

The  EU’s  first  Clean  Air  Outlook123  under  the  Clean  Air 
Programme  estimated  that  in  order  to  fulfil  the  NECD 
emissions reduction requirements124 by 2030, the total air 
pollution control costs for Croatia would be equivalent to 
EUR 448 million  per  year,  including  EUR 291 million  for 
capital investment.  

As the second Clean Air Outlook suggests125, implementing 
all  2018  legislation,  the  2030  climate/energy  measures 
and the NAPCP will largely facilitate reaching the targets 
by  2030  (except  for  ammonia  for  15  Member  States, 
though Croatia is not one of these). 

However, the NEC Directive also requires certain emission 
reductions as early as 2020-2029. This includes reductions 
aimed  at  reaching  pro-rata  progress  towards  the  2030 
targets by 2025 (based on a linear trajectory, or another 
trajectory 
implying  that 
investments need to be implemented in a timely manner.  

if  flexibilities  are  applied), 

Water management  

According  to  the  OECD’s  2020  study  ‘Financing  water 
supply,  sanitation  and  flood  protection’126,  Croatia  faces 
significant  challenges  in  financing  expansion  of  water 
supply,  sewerage,  wastewater  treatment  and  flood 
protection infrastructure to meet the requirements of the 
EU  water  directives127.  The  affordability  of  water  supply 
and  sanitation  tariffs  remains  a  concern  for  poor 
households  and  limits  Croatia’s  ability  to  raise  tariffs.  In 
addition,  water  losses  are  high  (50%).  Croatia  is  hit 
regularly  by  flooding  events  (river,  pluvial  and  coastal), 
with serious economic damage costs. Climate change will 
increase  the  severity  and  frequency  of  extreme  flood 
events.  Moreover,  the  recent  6th  Water  Framework 

Croatia  33 

Directive and Floods Directive Implementation Report and 
the financial - economic study accompanying it, are also a 
relevant source of information in this domain. 

Waste & the circular economy 

According to a Commission study128, if Croatia is to meet 
the  recycling  targets  for  municipal  waste  and  packaging 
waste,  it  needs  to  invest  an  additional  EUR 99 million 
(around EUR 14.1 million per annum) over the baseline in 
collection,  recycling  reprocessors,  biowaste  treatment, 
waste  sorting  facilities  and  waste  registry  digitalisation 
between 2021 and 2027.  

This does not include the investment required to address 
other  key  waste  streams  (plastics,  textiles,  furniture)  or 
unlock a higher uptake of circularity and waste prevention 
across the economy. 

Biodiversity & ecosystems 

The prioritised action frameworks (PAFs) adopted by the 
Member  States  under  Article 8  of  the  Habitats  Directive 
present  the  conservation  priorities  for  the  Natura  2000 
network  and  its  supporting  green  infrastructure,  the 
associated costs and the planned funding sources for the 
period corresponding to the current multiannual financial 
framework  (MFF),  i.e.  2021-2027.  For  Croatia,  the  total 
identified  costs  amount  to  EUR 182.4 million  per  year 
(including  EUR 24.5 million  in  one-off costs)129. The main 
conservation priorities relate to the establishment of the 
Natura 2000 management framework (management plans 
and  resources),  the  establishment  of  new  sites  and  the 
restoration  and/or  maintenance  of  grassland  and  forest 
habitats. 

the  priorities 

This  covers  some  of  the  preliminary  additional  costs  of 
implementing 
the 
Biodiversity  Strategy  up  to  2030,  including  costs  for 
increased protection and restoration. However, the final 
EU ambition levels are not yet known. 

stemming 

from 

EU environmental funding 2014-2020 

The  MFF  for  2014-2020  allocated  almost  EUR 960 billion 
(in  commitments,  2011  prices)130  for  the  EU.  The  green 

123 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. 
124  Covering  the  reduction  of  and  the  emission  ceilings  for  five 
atmospheric  pollutants  (SOx,  NOx,  PM2.5,  NH3  and  VOC)  by  2030 
compared  to  2005.  Requirements  are  based  on  Directive  (EU) 
2016/2284. 
125 COM(2021) 3 Final and Report Annex.  
126 OECD, Financing a Water Secure Future, 2022. 

127 Implementation of the Water Framework Directive (2000/60/EC), the 
Environmental  Quality  Standards  Directive  (2008/105/EC  amended  by 
Directive  2013/39/EU)  and  the  Floods  Directive  (2007/60/EC),  report-
implementation-wfd.pdf. 
128 European Commission, Study on investment needs in the waste sector 
and on the financing of municipal waste management in Member States, 
2019. 
129  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving synergies with EU funding instruments report to the European 
Commission, 2021.  
130 Council Regulation (EU, Euratom) No 1311/2013. 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
 
transition  commitment  included a  20% climate spending 
target and funding opportunities for the environment, in 
particular, under the European structural and investment 
funds (ESIFs)131. The 2014-2020 budget was subsequently 
topped up with over EUR 50 billion (current  prices) from 
REACT-EU  (Recovery  Assistance  for  Cohesion  and  the 
Territories  of  Europe)  for  cohesion  policy  action  against 
COVID-19132.  

Croatia received EUR 12 091.9 million from the ESIFs over 
2014-2020 to invest in job creation and a sustainable and 
healthy  European  economy  and  environment.  The 
planned  direct  environmental  investment  amounted  to 
EUR 1 829.8 million  and  a  further  EUR 611 million  was 
identified  as  indirect  environmental  investment  value, 
bringing total investment to EUR 2.4408 billion. Figure 41 
provides  an  overview  of  the  (planned)  individual  ESIFs 
from which amounts were earmarked for Croatia for 2014-
2020  (the  graph  shows  EU  amounts,  without  national 
amounts)  and  the  environmental 
investments  these 
included.  

Figure 39: ESIFs allocated to Croatia, including 
environmental investments, 2014-2020133 

Croatia  34 

Table 2: Direct and indirect environmental investments 
under the ESIFs in Croatia, 2014-2020134 

Instrument 

Under cohesion policy (ERDF + CF) 
Direct environmental investments 
water 
waste 
air quality 
biodiversity and nature 
land rehabilitation 
climate and risk management 
Indirect environmental investments 
renewable energy 
energy efficiency 
other energy135 
sustainable transport 

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

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

Total under ESIFs  
Direct environmental investments 
Indirect environmental investments 

Allocations  
for the environment  
(EUR million) 

2 145.5 
1 553.0 
849.3 
276.0 
18.7 
125.0 
74.8 
209.1 
592.6 
38.0 
127.9 
40.0 
256.0 

240.1 
224.9 
224.9 
16.1 
16.1 

54.3 
52.0 
52.0 

2.3 
2.3 

2 440.8 
1 829.8 
611.0 

Environmental 
funding  under  the  ESIFs  has  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 

131  The  ESIFs  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).  
132 Regulation (EU) 2020/2221. 
133 European Commission, DG Environment - Data analysis based on the 
ESIF  Open  Data  Portal  (cohesiondata.ec.europa.eu),  Integration  of 
in  Cohesion  Policy  Funds  (COWI,  2017), 
environmental  concerns 
Regulation 
(EU)  2021/1060  and 
Implementing Regulation (EU) No 215/2014. Environmental investments 
intervention  fields  and 
are  calculated  via  the  combined  use  of 
coefficients  under  Regulation  (EU)  No 1303/2013  and  Regulation  (EU) 
2021/1060,  allowing  more  precise  identification  and  valuation  of 
environmental 
investments. 
relevant 

(EU)  No 1303/2013,  Regulation 

environmental 

Indirect 

for 

investments 

identified  here 

investments  are  valued  using  the  environmental  coefficients  found  in 
Annex I of Regulation (EU) 2021/1060 (as opposed to the full value).   
134 European Commission, DG Environment - Data analysis. The values of 
environmental 
specific 
environmental  areas  may  differ 
from  the  tracking  values  at 
cohesiondata.ec.europa.eu, e.g. for clean air or biodiversity. This is 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 ESIFs. See also the previous footnote. 
135  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention fields 
53  and  54  respectively  (with  environmental  coefficients  of  40%)  of 
Regulation (EU) 2021/1060, Annex I. 

the 

 Environmental Implementation Review 2022 – Croatia 

 
 
                                                                 
  
 
 
(EIB). This additional funding comes to an estimated total 
of EUR 2.5 billion for Croatia for 2014-2020. 

is  entirely  dedicated 

The  LIFE  programme136 
to 
finances 
environmental  and  climate  objectives. 
demonstration  and  best-practice  actions  for  green 
solutions  that are to be deployed. In 2014-2020, Croatia 
received  EU  support  for  five  LIFE  nature  projects,  with 
EUR 10.0 million from the LIFE programme (from a total of 
out  of  1 028  LIFE  projects  in  the  EU-27  and  a  total  EU 
contribution of EUR 1.74 billion)137.  

It 

2020 

allocated 

2014-2020,  Horizon 

about 
In 
in 
EUR 7.3 million  to  Croatia  for  the  environment, 
particular for thematic area within the societal challenges 
pillar  (climate  action,  environment,  resource  efficiency 
and  raw  materials).  The  share  for  the  environment  was 
therefore  around  5.3%  of  Croatia’s  total  allocation138. 
Croatia  received  a  total  of  EUR 89 million  from  the 
European  fund  for  strategic  investments  (EFSI);  this  did 
not  cover  projects  with  an  environmental  objective139. 
Overall EIB lending to Croatia in the period amounted to 
EUR 3 212.6 million; none of the loans related directly to 
the  environment140.  The  country  ranks  19th  in  terms  of 
total EIB lending. 

In 2020, the EIB provided EUR 24.2 billion to fight climate 
change,  accounting  for  37%  of  its  total  financing,  and 
EUR 1.8 billion (3% of its financing) for the environment141.  

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan  calls for 
EUR 1 trillion in green investments (public and private) by 
2030.  The  MFF  for  2021-2027  and  NextGenerationEU 
programme  will  mobilise  EUR 2.018 trillion  (in  current 
prices) to support COVID-19 recovery and the  EU’s long-
term priorities,  including environmental protection142. In 
line the EU Green Deal’s143 ‘do no harm’ pledge and the 
Interinstitutional  Agreement  on  the  2021-2027  MFF144, 
30% of the EU budget will support climate efforts and 7.5% 

136 European Commission, LIFE Programme. 
137 Ref. to be added. 
138 Source: https://sc5.easme-web.eu/. 
139  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
140 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm. 
141 The EIB Group works with the European Commission to implementing 
several  programmes  that  finance  environmental 
implementation: 
InvestEU,  the  successor  of  EFSI,  Pillar  II  and  III  of  the  Just  Transition 
Mechanism. The EIB Group is as a key implementing partner for InvestEU 
and is responsible for managing 75% of the overall budgetary capacity of 
the mandate. 
142  European  Commission,  2021-2027 
NextGenerationEU. 
143 COM/2019/640 final. 
144 Interinstitutional Agreement, OJ L 433I, 22.12.2020, p. 28-46. 
145 EU taxonomy of sustainable activities. 

long-term  EU  budget  & 

Croatia  35 

(from  2024)  and  10%  (from  2026)  biodiversity.  To  reach 
these targets, more increased financial resources must be 
allocated to biodiversity, specifically under the 2021-2027 
cohesion policy and the 2023-2027  common  agricultural 
policy (CAP).  

increase 

Sustainable  finance  significantly  increases  transparency 
regarding  environmental  sustainability  (a  goal  promoted 
by  the  EU  Taxonomy)145,  strengthens  non-financial 
reporting  requirements  and 
facilitates  green  bond 
issuance (by the EU green bond standard146). Reinforced 
by the Renewed Sustainable Finance Strategy (2020)147, it 
investment  flows  to  climate  and  the 
will 
environment. In support of financing climate adaptation, 
the new strategy on adaptation to climate change148 can 
facilitate  the  closing  of  the  insurance  protection  gap  for 
non-insured  climate-related  events149.  The  EIB  will  align 
50%  of  its  lending  with  climate  and  environment  by 
2025150 with a  EUR 250 billion contribution to the Green 
Deal investment plan by 2027.  

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

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

Instrument 

Country funding allocation  

Cohesion policy 

ERDF 

CF 

ESF 

ETC (ERDF) 

(million EUR) 

Total:8 708.2151 

5 355.7  

1 182.4152 

1 982.6 

187.6153 

146 EU Green Bond Standard - 2021/0191 (COD). 
147 COM (2021) 390 final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
148 COM(2021) 82 final. 
149  The  strategy  would  support  improved  insurance  gap  coverage 
including  through  the  natural  catastrophe  markets,  as  reflected  in  the 
EIOPA  (Association  for  European  Insurance  and  Occupational  Pension 
Authorities)  dashboard  on  the  insurance  protection  gap  for  natural 
catastrophes.  See:  pilot  dashboard  on  insurance  protection  gap  for 
natural catastrophes | Eiopa (europa.eu). 
150 EIB Climate Bank Roadmap 2021-2025, November 2020. 
151  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
152  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is  not 
included. 
153 Interreg initial allocations per MS including ETC transnational and ETC 
cross-border co-operation.  

 Environmental Implementation Review 2022 – Croatia 

 
                                                                 
Just Transition Fund 

185.9154 

Figure 40: Climate expenditure in RRPs, 2021-2026161 

Croatia  36 

EAFRD/rural 
development  

under  CAP  strategic 
plans 
forStrategic 
Plans 2023-2027155 

European  maritime, 
and 
fisheries 
aquaculture 
fund 
(EMFAF) 

Recovery 
and 
resilience facility (RRF)  

2021 – 2026158  

1 486.5156 

243.6157 

6 393.7159 (grants) 

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

Croatia’s  RRP  responds  to  the  urgent  need  to  foster  a 
strong  recovery  and  make  Croatia  future-ready.  The 
reforms and investments will help  Croatia become more 
sustainable  and  resilient  and  better  prepare  it  for  the 
challenges and opportunities presented by the green and 
digital  transitions.  To  this  end,  the  plan  comprises 
146 investments  and  76 reforms.  Croatia  requested 
almost EUR 6.4 billion in grants, and 40.3% of the plan will 
support climate  objectives  (see  Figure 42).  Croatia’s  RRP 
supports  the  green  transition,  through  investments  in: 
energy  efficiency  and post-earthquake  reconstruction of 
sustainable  mobility 
buildings 
(EUR 789 million), 
(EUR 728 million), low-carbon 
transition 
energy 
(EUR 658 million) and assistance for businesses for green 
transition and energy efficiency (EUR 542 million) 160. 

Under NextGenerationEU, the Commission will issue up to 
EUR 250 billion  of  EU  green  bonds 
(one  third  of 
NextGenerationEU  funds)  by  2026.  These  bonds  will 
comply with the general spirit of the DNSH principle, but 
will not be subject to the current delegated acts  relating 
to  the  EU  Taxonomy  and  will  not  fully  align  with  the 
proposed EU green bond standard. 

In  addition  to  the  EU  funds  earmarked  specifically  for 
Croatia in 2021-2027, there are also funding programmes 
that  can  been  accessed  at  EU  level  and  are  open  to  all 
Member  States.  These  include  the  LIFE  programme162 
(EUR 5.4 billion), Horizon Europe (EUR 95.5 billion)163, the 
Connecting Europe Facility164 (EUR 33.7 billion)165 and the 
funds to be mobilised via InvestEU166. These programmes 
will also support the green transition, including research 
and  innovation  activities  for  environmental  protection 
(Horizon  Europe)167,  clean  transport  and  energy  (the 
Connecting 
sustainable 
infrastructure (InvestEU)169. 

Facility)168 

Europe 

or 

154  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
155 European Commission, CAP strategic plans. 
156 Regulation (EU) 2021/2115, Annex XI.   
157 Regulation (EU) 2021/1139, Annex V. 
158  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented by 31 December 2026.  
159 Council Implementing Decision, FIN 592. 
160 European Commission, Croatia’s recovery and resilience plan. 
161 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
162 European Commission, LIFE Programme. 
163  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
164  The  CEF  (Transport)  includes  also  EUR 11.3 billion  transferred  from 
the  cohesion  fund.  Of  the  transferred  amount,  30  %  will  be  made 

available,  on a competitive  basis,  to  all  Member  States eligible  for  the 
cohesion fund, while the remaining 70% will be distributed in line with 
national pre-allocations until 31 December 2023. Any amount of national 
pre-allocation  that  has  not  been  spent  by  that  date  will  be  used  to 
support all cohesion fund-eligible Member States. 
165 Regulation (EU) 2021/1153. 
166  The  InvestEU  Fund  is  expected  to  mobilise  over  EUR 372 billion  in 
investment through an EU budget guarantee of EUR 26.2 billion to back 
investments made by financial partners such as the European Investment 
Bank (EIB) Group and others. 
167 European Commission, Horizon Europe. 
168 European Commission, Connecting Europe Facility. 
169 European Union, InvestEU. 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
 
 
Croatia  37 

institutional  sector,  around  half  of  Croatia’s 
By 
environmental protection investments (CapEx) came from 
the  business  sector,  35%  from  the  general  government 
and  14%  from  specialist  producers  (of  environmental 
protection services, e.g. waste and water companies). At 
EU  level,  37%  comes  from  governments,  33%  from 
specialist producers and 30% from industry (business). 

Figure 42:  EU-27  Member  States’  environmental 
protection  investments  (CapEx)  by  institutional  sector 
(total economy = 100%), 2018172 

National environmental protection 
expenditure 

Total  national  environmental  protection  expenditure 
(including all relevant current and capital expenditure)170 
in the EU-27 was EUR 272.6 billion in 2020. This represents 
2%  of  the  EU’s  GDP  and  has remained  quite  stable  over 
time. While absolute expenditure is concentrated in a few 
countries,  as  a  share  of  GDP,  most  countries  spend 
between 1 and 2%, while Croatia’s expenditure is slightly 
higher (2.3% of GDP).  

Of  the  above  total,  the  EU-27’s  capital  expenditure 
(CapEx)  on  environmental  protection  (i.e.  investment  in 
environmental  protection)  amounted  to  EUR 56.3 billion 
in 2018, falling to EUR 54.5 billion in 2020 (around 0.4% of 
GDP).  While  most  Member  States  invested  0.2-0.5%  of 
their  GDP  in  environmental  protection,  Croatia  invested 
0.6%.  Between  2014  and  2020, 
in 
environmental protection totalled around EUR 376 billion 
for the EU-27 and EUR 1.67 billion for Croatia. 

investment 

Figure 41:  Direct  and indirect  environmental protection 
investments  in  the  EU-27  (EUR  million  and  %  of  GDP), 
2018171 

A partial breakdown of investment by environmental topic 
is  available,  but  only  at  the  level  of  institutional  sectors 
(instead of the entire economy) due to different reporting 
patterns173. Of the environmental protection investments 
made by Croatia’s general government 47% went to waste 
management, 38% to tackling pollution and 15% to waste 
water. Around two-thirds of investments by the country’s 
specialist producers concern waste management and one-
third  wastewater,  while  72%  of  the  business  sector’s 
investments  went  to  waste  water  and  18%  to  the 
protection of air, to name just the most significant items. 

In 2020, total annual green bond issuance174 by European 
countries  was  USD 156 billion  (EUR 137 billion),  up  from 

170  From  the  economy  as  a  whole,  including  final  consumption, 
intermediate  consumption  and  capital  expenditure  of  households, 
corporations  and  governments  relating  to  environmental  protection 
goods  and  services.  This  excludes  EU  funds,  but  may  include  some 
international  expenditure  in  addition  to  domestic  expenditure.  Data 
source:  Environmental  Protection  Expenditure  Accounts  (EPEAs), 
Eurostat.  EPEAs  are  based  on  the  CEPA  2000  classification,  excluding 
climate, energy and circular economy. 
171 Eurostat, Environmental Protection Expenditure Account, 2021. 
172 Eurostat, Environmental Protection Expenditure Accounts (env_epe). 

173 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), while this is less often the 
case  for  general  government  and  industry:  they  often  report  (non-
obligatory)  data  in  merged categories only  (making  it  difficult  to  get  a 
breakdown), if at all.  
174  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  The  majority  of  green  bonds 
issued are green ’use-of-proceeds’ or asset-linked bonds. The very first 
green  bond  was  issued  in  2007  with  the  AAA-rated  issuance  from 

 Environmental Implementation Review 2022 – Croatia 

 
 
 
                                                                 
 
 
Croatia  38 

Figure 44: Environmental taxes in the EU-27, 2020178 

in  2019.  This  figure 
USD 117 billion  (EUR 105 billion) 
includes  bonds 
issued  by  some  non-EU  European 
countries175. The 2020 annual green bond issuance by the 
EU-27  was  EUR 124 billion.  Croatia  did  not  issue  green 
bonds. Between 2014 and 2020, 83% of the green bonds 
issued by European countries served energy, buildings or 
transport objectives, 8% water and waste objectives and 
6% 
links  to  ecosystem 
conservation and restoration176.  

land  use  objectives,  with 

Figure 43: Annual EU green bond issuance in 2020 (EUR 
billion)177 

Green budget tools 

Green taxation and tax reform 

revenue 

in  the  EU 

from  environment-related 

taxes 
Croatia’s 
remained  amongst  the  highest 
in  2020, 
accounting for 3.28% of GDP (EU average: 2.24%). Of this 
revenue, almost 77% was derived from energy tax%, 22% 
from  transport-related  tax  and  1.1%  from  tax  linked  to 
pollution and resources. This last type of tax accounted for 
0.04% of GDP, half of the EU average. 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience and foster a fairer society and a just transition 
by  sending  the  right  price  signals  and  incentives  to 
economic actors. The Green Deal creates the context for 
broad-based  tax  reforms,  removing  fossil  fuel  subsidies, 
shifting  the  tax  burden  from  labour  to  pollution  and 
accounting for social considerations179. The application of 
the ‘polluter pays principle’ (PPP)180, which stipulates that 
polluters  should  bear  the  cost  of  measures  to  prevent, 
control  and  remedy  pollution, 
is  facilitated  by  the 
Commission’s Technical Support Instrument (TSI) flagship 
on greening taxes.  

Environmentally-harmful subsidies 

Addressing  and 
removing  environmentally-harmful 
subsidies is a further step towards wider fiscal reforms181. 

Fossil  fuel  subsidies  are  costly  for  public  budgets  and 
adversely  impact  the  achievement  of  the  Green  Deal 
objectives. In many cases, they also go against incentives 
for  green  investments  as  they  do  not  contribute  to 
levelling  the  playing  field.  Fossil  fuel  subsidies  in  the  EU 
have  stood  at  around  EUR 55 billion  since  2015.  They 
increased by 4% between 2015 and 2019, although some 
countries,  such  as  Latvia,  Lithuania  Sweden,  Greece  and 

Bonds 

Climate 

multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 
175 
Taxonomy: 
https://www.climatebonds.net/standard/taxonomy. The USD value was 
converted using Eurostat’s annual average EUR/USD exchange rates. 
176  Interactive  Data  Platform  at  www.climatebonds.net.  The  Climate 
Bonds Taxonomy is similar to the EU Taxonomy. 
177 Climate Bonds Initiative, 2022. 
178 Eurostat, Environmental taxes accounts (env_eta). 
179  European  Commission,  The  European  Green  Deal,  COM  (2019)  640 
final, p.17. 

180 Article 191(2) of the Treaty on the Functioning of the European Union: 
’Union policy on the environment (…) shall be based on the precautionary 
principle and on the principles that  preventive action should be taken, 
that environmental damage should as a priority be rectified at source and 
that the polluter should pay.’ 
181  European  Commission,  Study  on  assessing  the  environmental  fiscal 
reform 
2016, 
the 
https://ec.europa.eu/environment/integration/green_semester/pdf/Eu
nomia%20EFR%20Final%20Report%20MAIN%20REPORT.pdf  

potential 

January 

EU28, 

for 

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Croatia  39 

climate  end  environmental  objectives).184  Some  EU 
Member states already use green budgeting elements.185 

EU climate proofing and sustainability proofing guidance 
have  also  been  developed.  It  is  intended    as  a  tool  for 
assessing  project  eligibility  and  compliance  with 
environmental  legislation  and  criteria186.  The  European 
Commission  established  a  green  budgeting  reference 
framework187  and  launched  a  technical  support  project 
(supported by the TSI) on green budgeting in 2021 to assist 
Member  States  in  developing  or  further  developing 
national  green  budgeting  frameworks  so  that  they  can 
reap  the  benefits  for  policy  coherence  and  the  green 
transition. Croatia is participating in this technical support 
project. 

Overall financing compared to the needs 

Overall environmental financing for investments in the EU 
is estimated to have been 0.6-0.7% of GDP in 2014-2020, 
taking into account major EU funds and national financing. 
Total  environmental  financing  in  each  Member  State 
ranged  from  0.3%  of  GDP  (Ireland)  to  1.91%  (Bulgaria), 
linked  to  the  level  of  environmental  challenges  in  the 
country.  The  EU’s  environmental  investment  needs  for 
2021-2027 are estimated at 0.9-1.5% of GDP188, suggesting 
a  potential  environmental  financing  gap  of  at  least  0.6-
0.8%  of  GDP  at  EU  level  (previous  financing  levels 
assumed)189. 

Figure 46: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU 27 (% 
of GDP)190  

Ireland, managed to decrease them. In the EU, subsidies 
for petroleum products, in sectors such as transport and 
agriculture, kept growing over the period, while 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 (EU average: 0.4%). For Croatia, 
the  share  was  0.29%  of  GDP,  which  is  below  the  EU 
average. 

In 2020, the EU27’s total fossil fuel subsidies decreased to 
EUR 52 billion (due to falling consumption trends amid the 
-without 
COVID-19-related 
Member  State  action,  they  are  likely  to  rebound  as 
economic activity has picked up from 2020182. 

restrictions).  However, 

Figure 45: Trends in natural gas subsidies in Croatia183 

% GDP 

2015 

2016 

 2017 

2018 

2019 

2020 

Natural gas 

0.18 

0.18 

0.24 

0.21 

0.13 

0.07 

Current green budgeting practices  

Green  budgeting  encompasses  various  climate  and 
environmental tagging and tracking practices in budgets. 
It  helps  identify  and  track  green  expenditure  and  green 
revenues  to  increase  transparency  on  the  environmentl 
implications  of  budgetary  policies, 
improving  policy 
coherence  and  supporting  green  policies  (including 

182 State of the Energy Union report, COM(2021) 950 and Annex. 
183 OECD inventory. 
184  European  Commission,  European  Commission  Green  Budgeting 
Reference  Framework.  European  Commission,  Green  Budgeting  in  the 
EU Key insights from the 2021 Commission survey. 
185 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021. 
186 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
187 European Commission, Green Budgeting Reference Framework, based 
on  the  review  of  the  OECD  Paris  Collaborative  on  Green  Budgeting 
initiative, 2017. 

188 Excluding needs for certain environmental sub-objectives, where the 
detailed breakdown by country was not directly available at the time of 
analysis (e.g. noise, water protection, higher stages of circular economy, 
increased  needs  from  the  2030  Biodiversity  Strategy).  Including  these 
could increase total needs at EU level (by around 50%).  
189  DG  Environment  data  analysis.  EU  financing  sources  covered:  ESIFs 
(ERDF, CF, ESF, YEI, EAFRD, EMFF), Horizon 2020, LIFE, EFSI (EU amount), 
EIB  loans.  National  financing:  total  national  CapEx  on  (investments  in) 
environmental protection – source: Eurostat EPEA data set. Cut-off date 
for data: end 2021. NB Total financing may be higher, in particular as a 
result  of  further  indirect  investments.  Further  analysis  is  therefore 
required in the future.  
190 Eurostat, ESIFs Open Data, 2021. 

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Croatia  40 

0.48%  of  GDP.  The  actual  financing  gap  is  likely  to  be 
greater  be  higher  taking  into  account  needs  that  are 
estimated  at  EU  level  (e.g.  water  protection,  circularity, 
biodiversity  strategy,  etc.).–  This  is  to  be  addressed  by 
mobilising  additional 
for  environmental 
implementation priorities.  

financing 

2022 priority actions  

  The  investment  gap  remains  significant  as  Croatia  is 
still substantially below the EU average for  municipal 
and  packaging  waste  recycling,  sewage  systems  are 
underdeveloped and water supply networks face high 
leakage rates. 
In terms of prioritisation of environmental investments 
in Croatia, waste management and circular economy is 
considered as a main priority, followed by water– that 
provides  an  opportunity  to  potentially  increase  the 
share of private financing as well for the environment 
(which is around one-third overall in Croatia). 

 

  Technical  assistance  could  support  capacity  building 
for management bodies of the Natura sites in line with 
the Environmental Implementation Review (EIR) 2019 
priority action. 

Croatia’s  environmental  financing  for 
investments  is 
estimated to have been 1.32% of GDP (higher than the EU 
average) in 2014-2020. The bulk of this (54%) came from 
EU  funding.  Environmental  investment  needs  for  2021-
2027  (based  on  partial  information  available  at  country 
level)  are  estimated  to  reach  over  1.79%  of  GDP, 
suggesting  an  environmental  financing  gap  of  at  least 

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Croatia  41 

6. Environmental governance  

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention: 
(i) access to information; 
(ii) public participation in decision making; 
(iii) access to justice in environmental matters. 
It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively191.  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  environment192.  It  includes  the  right  to  bring  legal 
challenges (legal standing)193.  

Environmental information 

Croatia’s  implementation  of  the  INSPIRE  Directive  could 
be better. Its performance was reviewed based on its 2021 
country  sheet194.  Progress  on  data  identification  and 
documentation has been slow and implementation levels 
need to improve. More efforts are needed to:  

  make the data more widely accessible; and 
  prioritise environmental data sets in implementation, 
especially  those  identified  as  high-value  spatial  data 
sets for implementing environmental legislation195. 

Table 4:  Country  dashboard  on  the  implementation  of 
the INSPIRE Directive, 2016-2020196 

2016 

2020 

Legend 

Ensure 
coordination  

effective 

■  ■ 

Data sharing without 
obstacles  

■  ■ 

INSPIRE performance indicators 

Conformity 

i. 
metadata  

of 

■  ■ 

ii.  Conformity  of 
spatial data sets197 

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

■  ■ 

■  ■ 

iv.  Conformity  of 
network services 

■  ■ 

(nearly) 
complete. 
are 
Outstanding 
minor and can be addressed 
easily. Percentage: >89% 

issues 

some 

■  Implementation  of  this 
provision  has  started  and 
although 
or 
substantial  progress  has 
been made, it is not yet close 
to  completion.  Percentage: 
31–89%  

is 

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

Public participation 

Extensive  and  useable  information  is  available  to  the 
public  on  environmental  impact  assessment  (EIA)  and 
strategic  environmental  assessment  (SEA)  cases,  both  at 
national  and  regional  level198.  This  includes  links  to 
relevant  documentation  and  details  of  how  members  of 
the public can participate in the process. However, there 
are no centrally collected statistics on public participation 
in  practice  and  it  is  not  possible  to  identify  whether 
participation  is  increasing  or  decreasing  or  assess  how 
participation is contributing to improved decision-making.  

Access to justice  

Effective  coordination  and  data 
sharing 

■  Implementation  of  this 
provision is well advanced or 

Significant  progress  must  be  made  on  informing  the 
general  public  about  the  ways  in  which  individuals  and 
environmental  associations  can  access 
in 
environmental  matters  under  Croatian  and  EU  law.  The 

justice 

191The  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. 
192 These guarantees are explained in the Commission Notice on access 
to justice in environmental matters,  OJ L 275, 18.8.2017, and a related 
Citizen’s Guide. 
193 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. 
194 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/HR. 

195 European Commission, List of high value spatial data sets. 
196 INSPIRE knowledge base.  
197  In  2016,  the  deadlines  for  the  implementation  of  spatial  data 
interoperability were still in the future: 23 November 2017 for Annex I 
data and 21 October 2020 for Annex II and III data. It must be also borne 
in mind that this conformity indicator will never show 100% conformity 
in  many  cases  as  the  majority  of  countries  provide  as-is-data  sets  in 
addition to INSPIRE harmonised data sets. 
198 See https://mingor.gov.hr/o-ministarstvu-1065/djelokrug/uprava-za-
procjenu-utjecaja-na-okolis-i-odrzivo-gospodarenje-otpadom-
1271/procjena-utjecaja-na-okolis-puo-spuo/7370 (in Croatian only). 

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Croatia  42 

information available online does not give a sufficient and 
clear picture on access to justice in environmental matters 
and is focused on cost exposure.  

individuals  and  environmental 
Croatia  allows  both 
associations to bring legal cases in environmental matters 
under  Article 168  of  its  Environmental  Protection  Act 
(Croatian Official Gazette Nos 80/13, 153/13, 78/15, 12/18 
and 118/18). The system is quite liberal.  

However,  plans  and  programmes  for  which  SEAs  are 
conducted are considered general acts. Their legality can 
only be reviewed by the High Administrative Court using a 
sui  generis  review  procedure.  Although  anyone  has  the 
right to bring a case for the review of the legality of general 
acts, this right is limited by the condition that a review can 
only  be  initiated  based  on  the  individual  act  that  was 
passed on the basis the general act, e.g. a location permit 
issued based on the spatial plan in question. 

Under the general rules of judicial review, when a person 
claims  that  a  public  body  has  failed  to  enact  certain 
decision,  that  person  may  initiate  a  judicial  review  in 
respect  of  this  failure  if  they  have  legal  standing  –  for 
instance, if they feel their right to a healthy life has been 
violated. However,  an action for judicial review  can only 
be brought before the Administrative Court if the decision 
at  issue  was  an  individualised  decision.  A  judicial  review 
therefore  cannot  be  initiated  in  respect  of  the  public 
authorities’ failure to enact an act of general application. 
The rules on standing for individuals and NGOs wishing to 
obtain an administrative review and bring a legal challenge 
before  the  national  court  are  limited  in  such  cases.  The 
is  that  decisions  on  such  plans  or 
main  problem 
programmes do not take the form of an administrative act 
(upravni akt). As such, these decisions (odluke) cannot be 
the subject of an administrative review or disputed before 
the Administrative Court. Such decisions do not even have 
information  on  legal  remedies  at  the  end  (uputa  o 
pravnom lijeku). 

In  2019,  priority  actions  were  addressed  to  Croatia  as 
regards access to justice. In particular, Croatia was invited 
to  provide  broader  standing  to  the  public  and  better 
inform them about their rights. It  can be concluded that 
there  has  been  only  limited  or  no  progress  on  both 
aspects. 

2022 priority actions 

199 
https://e-
justice.europa.eu/content_access_to_justice_in_environmental_matter
s-300-en.do 
200 The concept is explained in detail in the Communication on EU actions 
to improve environmental compliance and governance  (COM(2018)10) 
Staff  Working  Document 
the 
and 
(SWD(2018)10).  
201 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation.  

associated  Commission 

 

Improve  access  to  courts  by  the  public  concerned 
when 
it  comes  to  challenging  administrative  or 
regulatory  decisions,  in  particular  under  the  areas  of 
planning related to water, nature and air quality.  
  Better inform the public about their access to justice 
rights,  particularly  by  referring,  on 
judicial  and 
administrative portals, to the Commission eJustice fact 
sheets  on  access 
in  environmental 
matters199. 

justice 

to 

  Take  action  and  carry  out  monitoring  to  ensure  that 
costs are not a hindrance to effective access to justice. 
  Make  spatial  data  more  widely  accessible  and 
the 
prioritise 
implementation  of  the  INSPIRE  Directive,  especially 
those  identified  as  high-value  spatial  data  sets  for 
implementing environmental legislation. 

environmental 

data 

sets 

in 

Compliance assurance 

Environmental compliance assurance covers all the work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air  and nature and  manage  waste200. It includes  support 
measures provided by the authorities, such as: 
(i) compliance promotion201; 
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring202; 
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement203. 
Citizen science and complaints enable authorities to focus 
their efforts better. Environmental liability204 ensures that 
the polluter pays to remedy any damage.  

Compliance promotion and monitoring 

Although there is a wide range of material available online 
about  Natura  2000  sites,  it  is  mainly  concerned  with 
designation and the development of management plans. 
There  does  not  appear  to  be  much  material  focused  on 
communicating  with  farmers  and  land  managers  about 
practical  measures  to  improve  biodiversity  outcomes. 
Similarly,  there  does  not  appear  to  be  online  material 
explaining  to  farmers  how  to  comply  with  the  Nitrates 
Directive, and a guidance document on fertiliser use and 
manure  storage  mentioned  in  the  2019  report  can  no 
longer be found on the relevant website.  

202 This EIR focuses on inspections of major industrial installations.  
203  This  EIR  focuses  on  the  availability  of  enforcement  data  and  co-
ordination between authorities to tackle environmental crime. 
204  The  Environmental  Liability  Directive,  2004/35/EC,  creates  the 
framework. 

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Coordination of inspections under the Industrial Emissions 
Directive has been improved, with the State Inspectorate 
for Environmental Pollution having an enhanced role since 
April 2019. Information on the planning of inspections is 
published regularly, and the state inspectorate publishes 
quarterly reports205 listing the installations inspected and 
the 
inspection  dates  and  providing  a  colour-coded 
summary  of  the  key  aspects  of  the  inspection  report. 
Reasonably  comprehensive  summary  statistics  are 
published, although the latest such report was for 2019206.  

Complaint handling and citizen science 

types  of 

infringements, 

information  on 

The  State  Inspectorate  for  Environmental  Protection 
operates  a  platform  (e-Citizen)  that  provides  the  public 
with 
the 
competent  authorities,  how  to  submit  a  complaint  and 
how  complaints  are  handled.  Any  person  may  submit  a 
complaint  about  a  wide  range  of  environmental 
infringements  on  this  government  platform  using  a 
form207.  The  State 
standardised  online  complaint 
Inspectorate  for  Nature  Protection  has  an  equivalent 
platform where the public may submit complaints about 
nature protection issues208. 

to 

information 
The  authorities  appear  to  actively  use 
provided  by 
investigate  potential 
the  public 
infringements  and  members  of  the  public  are  informed 
about  the  action  taken  in  response  to  their  complaint. 
More broadly, there are active efforts to encourage public 
participation,  with  platforms  enabling  members  of  the 
public  to  report  killings  of  or  accidental  injuries  to 
endangered species and sightings of invasive alien species.  

Enforcement  

There 
is  no  centralised  database  or  statistics  on 
environmental  crimes  and  their  outcomes.  However, 
general  publications  on  crimes  issued  by  the  National 
Statistical  Institute,  the  Prosecutor’s  Office  and  the 
Ministry of the Interior provide some data. For instance,  
the  annual  report  on  police  activity  published  by  the 
Ministry of the Interior includes a  summary of statistical 
data  on  the  chapter  of  the  Criminal  Code  relating  to 
environmental  crimes.  However,  none  of  the  data 
available provide a clear picture of the outcomes relating 
to the prosecution of environmental crimes (convictions, 
penalties, etc.).  

There  appear  to  be  no  formal  systems  for  cooperation 
between  professionals  dealing  with  environmental 
crimes.  There  is  some  concern  among  environmental 
to 
the  police  give 
inspectors 

little  priority 

that 

See 

https://inspektorat.gov.hr/o-drzavnom-inspektoratu-

205 
9/ustrojstvo-77/16-sektor-za-nadzor-zastite-okolisa-zastite-prirode-i-
vodopravni-nadzor/izvjesca/383 (in Croatian only). 
206 Available at the same webpage. 

Croatia  43 

environmental crime, and that national-level priorities are 
not always pursued effectively at regional level. A lack of 
knowledge  sharing  and  training  on  environmental  crime 
and  a  lack  of  information  exchange  between  local  and 
national level are also barriers to improved enforcement.  

Environmental Liability Directive  

information  system, 

There  does  not  appear  to  be  a  central  database  on 
Environmental Liability Directive cases. The Ministry of the 
Economy  and  Sustainable  Development  maintains  an 
environmental  protection 
ISZO, 
which  is  a  series  of  interconnected  databases  and  data 
sources  on  the  state  of  individual  components  of  the 
environment.  While 
focuses  mainly  on  spatial 
characteristics and other data and information important 
for  monitoring  the  state  of  the  environment  at  national 
level209,  the  portal  also  contains  major  accident  reports 
that could lead to environmental liability cases. Only one 
such report has been recorded on the portal. 

it 

Although  Croatia’s  legislation  sets  out  details  of  the 
operator’s  duty  to  ensure,  through  insurance  or  other 
appropriate  means, 
to 
compensate for environmental damage, no specific forms 
of product or insurance are indicated and no information 
has  been  found  on  the  availability  of  relevant  insurance 
products. 

funds  are  available 

that 

2022 priority actions 

  Develop  online  and  other  resources  to  help  farmers 
understand  the  practical  measures  they  can  take  to 
improve  compliance  with  biodiversity  and  nitrates 
legislation. 
Improve and formalise coordination among the bodies 
responsible for enforcing laws on environmental crime 
and  ensure  better  training  and  knowledge  exchange 
on  environmental  issues  for  the  police  and  criminal 
justice systems.  

 

  Collect 

  Further  develop 

and 

publish 

detailed 

statistics 
environmental crime and enforcement activity. 
the 

system  on 
Environmental Liability Directive cases or instances of 
environmental damage. 

information 

on 

  Encourage better availability of insurance products to 
ensure  that  operators  can  meet  the  costs  of  any 
environmental damage for which they are liable.  

207 https://gov.hr/hr/inspekcija-zastite-okolisa/1340. 
208 https://gov.hr/hr/inspekcija-zastite-prirode/1342. 
209 http://envi.azo.hr/?topic=9. 

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Croatia  44 

Effectiveness of environmental 
administrations 

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

Administrative capacity and quality 

At present, the number of complaints and infringements 
relating to the environment can be considered below the 
EU average. 

Overall,  the  implementation  of  EU  environmental  law  in 
the different  sectors has improved over the last decade. 
For  instance,  there  has  been  progress  regarding  the 
implementation  of  the  environmental  assessments. 
Although  some  doubts  were  raised  about  a  recent 
package of legislation aimed at speeding up the licensing 
of projects of national interest, no serious problems were 
identified when it was implemented. 

According  to  the  authorities  responsible  for  their 
detection,  investigation  and  prosecution,  environmental 
crimes  are  currently  one  of  the  most  profitable  and 
fastest-growing  areas  of  criminal  activity.  Statistical 
indicators  show  that  242  environmental  crimes  were 
recorded in Croatia in 2020, an increase of 46 (or 23.5%) 
on the previous year. 

Coordination and integration  

As mentioned in the 2017 EIR report, the transposition of 
the  revised  EIA  Directive210  provides  an  opportunity  to 
streamline  the  regulatory  framework  on  environmental 
assessments. Despite not completing transposition by the 
deadline (May 2017), Croatia has transposed the revised 
Directive.  However,  in  March  2019,  the  Commission 
opened  an  infringement  procedure  concerning  the  non-
conformity  of  Croatian  legislation  with  the  obligations 
arising  from the  EIA Directive  (2011/92/EU) as amended 
by Directive 2014/52/EU.  

the 

The  Commission  encourages 
streamlining  of 
environmental assessments in order to reduce duplication 
and  avoid  overlaps  in  the  environmental  assessments 
applicable  to  projects.  Moreover,  streamlining  helps 
reduce  the  administrative  burden  and  accelerates 
decision-making without compromising the quality of the 

the 

procedure211. 

assessment 

Croatia 
environmental 
introduced 
environmental 
streamlining 
assessments  under  the  EIA  and  Habitats  Directives  even 
before  the  EIA  Directive  was  revised.  Coordinated 
procedures  have  been  established  for  the  EIA  Directive, 
the  Water  Framework  Directive  and  the 
Industrial 
Emissions Directive. 

of 

Croatia’s  single  environmental  permitting  platform  may 
be  highlighted  as  a  good  practice:  it  was  developed  to 
operationalise 
the  single  environmental  permitting 
regime,  which  simplifies,  harmonises  and  links  many 
environmental permits. 

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

The Commission supports environmental implementation 
and  the  green  transition  both  through  the  EU  financing 
programmes and by granting technical assistance through 
mechanisms  such  as  the  Technical  Support  Instrument 
(TSI). 

reorienting 

The  Commission’s  TSI  supported  several  environment-
related  projects  in  Croatia  in  the  reporting  period.  This 
includes  a  2020  project  on  reviewing  expenditure  in  the 
areas of water and waste management and a 2021 project 
aimed  at 
the  Croatian 
development bank (HBOR) towards sustainable financing 
and the green transition in 2021. Two new projects have 
been selected under the 2022 TSI: a project to develop a 
national  loss  reduction  plan  and  build  capacity  among 
water  suppliers,  and  a  project  to  bridge  the  climate 
financing gap with public policy instruments. 

the  work  of 

TAIEX EIR peer to peer projects 

facilitate  peer-to-peer 

The  Commission  launched  the  TAIEX  EIR  peer-to-peer 
tool212  to 
learning  between 
environmental  authorities.  Croatia  benefited  from  two 
expert exchanges in the reporting period: one on the EU 
Eco-Management and Audit Scheme (EMAS) in 2019, and 
one  on  models  of  communication  on  the  value  of  eco-
labels in 2020. Moreover, Croatia has taken part in three 
multi-country workshops on air pollution from household 
technology  and 
heating 
measures (2021), and zero pollution for air, water and soil 
(2022). 

(2019),  ammonia-reducing 

210 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. 
211 The Commission issued a guidance document in 2016 regarding the 
setting  up  of  coordinated  and/or 
that  are 
simultaneously  subject  to  assessments  under  the  EIA  Directive,  the 

joint  procedures 

Habitats  Directive,  the  Water  Framework  Directive,  and  the  Industrial 
Emissions Directive, OJ C 273, 27.7.2016, p. 1.  
212  TAIEX  –  Environmental  Implementation  Review  –  PEER  2  PEER  – 
Environment – European Commission (europa.eu). 

 Environmental Implementation Review 2022 – Croatia