COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - POLAND Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance
Date: 2022-09-08
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, Poland, 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) 269 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022         Country Report - POLAND                     Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions Environmental Implementation Review 2022: Turning the tide through environmental compliance       {COM(2022) 438 final} - {SWD(2022) 252 final} - {SWD(2022) 253 final} - {SWD(2022) 254 final} - {SWD(2022) 255 final} - {SWD(2022) 256 final} - {SWD(2022) 257 final} - {SWD(2022) 258 final} - {SWD(2022) 259 final} - {SWD(2022) 260 final} - {SWD(2022) 261 final} - {SWD(2022) 262 final} - {SWD(2022) 263 final} - {SWD(2022) 264 final} - {SWD(2022) 265 final} - {SWD(2022) 266 final} - {SWD(2022) 267 final} - {SWD(2022) 268 final} - {SWD(2022) 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}  
 
 
Poland  1 

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

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Photographs:  

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

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Poland  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 ............................................................................................................................................. 7 
2. BIODIVERSITY AND NATURAL CAPITAL .................................................................................................................... 10 
Nature protection and restoration ..................................................................................................................... 10 
Marine ecosystems ............................................................................................................................................ 16 
Ecosystem assessment and accounting ............................................................................................................. 18 
3. TOWARDS ZERO POLLUTION ................................................................................................................................ 20 
Clean air ............................................................................................................................................................. 20 
Industrial emissions ........................................................................................................................................... 22 
Major industrial accidents prevention – SEVESO ............................................................................................... 24 
Noise .................................................................................................................................................................. 25 
Water quality and management ........................................................................................................................ 26 
Chemicals ........................................................................................................................................................... 30 
4. CLIMATE ACTION .............................................................................................................................................. 32 
Key national climate policies and strategies ...................................................................................................... 32 
Effort sharing target ........................................................................................................................................... 32 
Key sectoral developments ................................................................................................................................. 33 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 34 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS .............................................................................. 35 

5. FINANCING ...................................................................................................................................................... 35 
Environmental investment needs in the EU ....................................................................................................... 35 
EU environmental funding 2014-2020 ............................................................................................................... 36 
EU environmental funding 2021-2027 ............................................................................................................... 38 
National expenditure on environmental protection ........................................................................................... 40 
Green budget tools ............................................................................................................................................. 41 
Overall financing compared to the needs .......................................................................................................... 43 
6. ENVIRONMENTAL GOVERNANCE ........................................................................................................................... 45 
Information, public participation and access to justice...................................................................................... 45 
Compliance assurance ........................................................................................................................................ 47 
Effectiveness of environmental administrations ................................................................................................ 48 
Reforms through the Commission’s Technical Support Instrument (TSI) ........................................................... 49 
TAIEX EIR peer to peer Projects .......................................................................................................................... 49 

Environmental Implementation Review 2022 – Poland 

 
 
 
 
Poland  3 

Executive summary

Czechia  over  the  prolongation  of  the  mining  concession 
for  the  Turów  coal  mine  ended  with  an  agreement 
between  the  two  countries.  However,  the  dispute  also 
highlighted  Poland’s  refusal  to  comply  with  the  interim 
orders  by  the  Court  of  Justice  of  the  European  Union, 
which led to fines. 

In the field of waste management, there has been some 
progress  in  terms  of  financial  incentives  introduced  by 
new  legislation  to  encourage  better  selective  collection 
of  waste  by  households.  However,  Poland’s  landfill  rate 
of  42%  in  2020  is  still  far  above  the  EU  average  (24%). 
Moreover,  Poland  still  hasn’t  definitely  closed  and 
rehabilitated some municipal landfills that do not comply 
the  Landfill  Directive. 
with 
Furthermore,  Poland  needs  to  increase  investment  in 
recycling  to  meet  the  EU  2020  and  2025  recycling 
targets. 

requirements  of 

the 

Despite  significant  investment,  including  projects  co-
financed  by  the  EU  Funds,  Poland  missed  the  final 
deadlines  for  complying  with  the  Urban  Waste  Water 
Treatment Directive in 2015. Over 1 000 agglomerations 
are  non-compliant  and  require  further  action  and 
investment in infrastructure. 

EU financing continues to provide substantial support for 
implementing environmental measures, as Poland is due 
to  receive  EUR  72  billion  from  the  cohesion  policy 
(European  Fund  for  Regional  Development  –  ERDF,  and 
European  Social  Fund  –  ESF)  in  2021-27.  This  financing 
should  be  used  to  close  the  existing  implementation 
gaps. Poland is strongly encouraged to earmark sufficient 
resources 
support  biodiversity  objectives  and 
especially  to  implement  priority  measures  identified  in 
the Prioritised Action Framework (PAF).  

to 

Poland’s  total  environmental  protection 
investments 
equalled  1.24%%  of  its  GDP  in  2014-2020  (EU  average  
0.7%).  The  overall  environmental  investment  needs  in 
the coming period are estimated to be at least 1.98% of 
Poland’s  GDP  annually  (on  average).  This  suggests  an 
environmental investment gap of over 0.74% of the GDP 
that needs to be addressed by focusing on the country’s 
environmental implementation priorities. 

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

 

to close gaps in the Natura 2000 designation process 
and  improve  the  management  of  Natura  2000  sites 
that overlap with forest districts;  
 

to  improve  air  quality,  especially  to  reduce  
particulate  matter  (PM2.5  and  PM10),  nitrogen 
oxides and benzo(a)pyrene emissions; 
to 
governance: 
environmental 
transparency,  citizen  engagement,  compliance 
and  enforcement,  as  well  as  administrative 
capacity and coordination. 

improve 

 

to 

resources 

As  regards  nature  conservation, 
there  has  been 
substantial  progress  to  draw  up  plans  for  managing 
Natura  2000  sites.  However,  the  designation  of  sites  in 
the  Natura  2000  network  is  not  yet  complete.  Poland 
needs  to  step  up  its  efforts  to  finalise  the  designation 
process,  adopt  management  plans  for  the  remaining 
sites,  and  allocate 
site 
sufficient 
management.  These  are  key  requirements  to  protect 
biodiversity across the EU. The European Green Deal and 
the  European  Biodiversity  Strategy  for  2030  both  stress 
the importance for the EU of halting biodiversity loss by 
preserving  our  natural  sites  and  restoring  damaged 
ecosystems  to  good  ecological  status.  Poland  needs  to 
take  measures  to  improve  knowledge  and  education 
about the Natura 2000 network and benefits from it, and 
to  promote  societal  acceptance.  The  coherence  of  the 
Natura 2000 network continues to be threatened  by the 
fast-developing  infrastructure,  especially  urban  sprawl, 
regulation and maintenance of rivers, road transport, and 
intensive forestry and agriculture. 

There  has  been  some  progress  on  air  quality,  which 
nevertheless continues to give cause for serious concern, 
as Polish cities are amoung the most  polluted in Europe 
due  to  the  exceedances  for  fine  particulate  matter  and 
benzo(a)pyrene.  While  acknowledging  that  Poland  has 
made  progress,  the  Commission  remains  concerned  by 
the pace of changes, particularly with regard to replacing 
outdated solid fuel boilers and measures focusing on the 
transport sector. 

Poland has only made limited progress on environmental 
governance and rule of law. Despite some improvements 
concerning  access  to  justice  under  the  Environmental 
Impact  Assessment  (EIA)  Directive,  access  to  courts  by 
the  concerned  public  still  needs  improving,  and  the 
public  should  be  better  informed  about  their  access  to 
justice rights. The interstate dispute between Poland and 

Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
 
 
Poland  4 

Part I: Thematic areas 

1. Circular economy and waste management  

increased, while its overall material use rate decreased. 
However, according to  the  latest  national data, not  yet 
verified  by  the  Commission,  the  2020  gap  to  the  EU 
average is likely to be reduced. The circular material use 
rate    published  for  2020  is  provisional,  based  on 
estimated data. 

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

Measures towards a circular economy 

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

The circular material use, also known as circularity rate, 
is defined as the ratio of the circular use of materials to 
the  overall  material  use.  The  overall  material  use  is 
measured  by  summing  up  the  aggregate  domestic 
material  consumption  (DMC)  and  the  circular  use  of 
materials.  The  circular  material  use  rate  is  a  good 
indicator  of  an  economy’s  circularity,  as  it  includes  all 
the materials that are fed back into our economy. Large 
differences 
in  the  circularity  rate  exist  between 
countries.  To  help  achieve  the  goal  in  the  EU  circular 
economy  action  plan  goal  of  doubling  the  EU  circular 
material  use  rate  by  2030,  ambitious  measures 
targeting  the  whole  product  life  cycle  are  needed  at 
from 
level.  Such  measures 
Member-State 
sustainable  product  design  that  makes  it  possible  to 
increase  durability,  reparability,  upgradability  and 
recyclability  of  products,  to  other  measures,  like:  (i) 
‘remanufacturing’1;  (ii) 
in 
production  processes;  (iii)  recycling;  (iv)  boosting  eco-
innovation; and (v) increasing the uptake of green public 
procurement. 

increasing  the  circularity 

range 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
negative 
impacts  on  the  environment  and  reduce 
dependency on volatile raw material markets. As shown 
in  Figure  2,  Poland  generated  EUR  0.793  per  kg  of 
material consumed in 2020, which puts the country well 
below  the  EU  average  of  EUR  2.09  per  kg  for  resource 
productivity. 

Poland’s circular (secondary) use of material was 10.2% 
in  2016  and  9.9%  in  2020.  There  has  therefore  been  a 
decline  in  secondary  material  usage  over  the  recent 
years  and  the  gap  between  Poland’s  performance  and 
the EU average of 12.8% has widened. This  is due to the 
fact  that  Poland’s  domestic  material  consumption 

1 A standardized industrial process that takes place within industrial or 
factory  settings,  in  which  cores  are  restored  to  original  as-new 
condition and performance or better. 

2 Eurostat, Circular Economy Monitoring Framework. 
3 https://sdg.gov.pl/en/statistics_nat/12-1-a/  

Environmental Implementation Review 2022 – Poland 

 
                                                                 
 
 
 
                                                                 
Figure 2: Resource productivity, 2010-20204 

Poland  5 

Poland  has  also  set  up  a  working  group  for  research, 
development,  and  innovation  for  the  transition  to  a 
circular  economy,  known  as  the  Working  Group  for 
National Smart Specialisation ‘Circular Economy’. 

Work  is  also  underway  to  develop  a  secondary  raw 
materials  trading  platform. The platform  is intended  to 
operate  on  the  legislative  basis  of  the  end-of-waste 
regulations. Those working on this joint effort include (i) 
the  Working  Group  for  National  Smart  Specialization 
‘Circular Economy’, (ii) the Warsaw Stock Exchange and 
(iii) the National Centre for Climate Change. 

Eco-innovation 

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

innovations, 

creating 

new 

In 2021, Poland ranked 26th on the 2021 Eco-Innovation 
Scoreboard6 with a total score of 63, which indicates the 
country’s  need  to  step  up  its  eco-innovation  activities. 
Poland’s  performance  is  well  below  the  EU  average  on 
all five components of the 2021 eco-innovation index: (i) 
eco-innovation  inputs;  (ii)  eco-innovation  activities;  (iii) 
eco-innovation  outputs; 
resource  efficiency 
outcomes; and (v) socio-economic outcomes.  

(iv) 

However, under the next EU financial perspective 2021-
2027, eco-design will be one of the elements for which 
funding  will  be  available.  Under  the  Cohesion  Policy, 
support  is  planned  for  R&D  and  innovation  in  the 
transformation  of  the  business  sector  towards  circular 
economy  model.  The  measures  envisaged  include  the 
financing  of  eco-design  based  innovation  and  eco-
for 
innovation,  as  well  as 
enterprises  in  their  transition  to  the  circular  economy 
model (through the Green Innovation Hub).  

institutional  support 

Circular economy strategies  

The  Commission  encourages  Member  States  to  adopt 
and 
implement  national/regional  circular  economy 
strategies covering the whole life cycle of products. This 
is because such strategies are one of the most effective 
ways  to  progress  towards  a  more  circular  economy. 
Since  the 
launch  of  the  online  Circular  Economy 
Stakeholder  Platform  in  20175,  national,  regional  or 
local  authorities  have  used  the  platform  to  share  their 
strategies and roadmaps. 

On 10 September 2019, the  Polish Council of Ministers 
adopted  the  ‘Roadmap  for  the  transformation  to  a 
circular economy’. The roadmap contains a set of tools, 
going further than purely legislative tools, which aim to 
create  conditions  for  the  implementation  of  a  new 
economic  model  in  Poland.  Proposed  actions  cover 
mainly  analytical  and  conceptual  measures,  but  also 
informational, promotional and coordination  measures, 
in the areas of competence of particular ministries. The 
roadmap includes a timeline for implementation. 

The roadmap’s aim is to establish sustainable industrial 
production,  a  bioeconomy,  and  new  business  models 
under  the  values  of  circular  economy,  as  well  as  to 
cover  sustainable  consumption.  Poland  does  not  have 
sector-specific  strategies 
textiles  or 
construction,  however  some  measures  included  in  the 
roadmap could impact on those sectors.  

for  plastics, 

4 Eurostat, Resource productivity. 
5 Circular Economy Stakeholder Platform. 

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

 Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
 
 
 
                                                                 
Poland  6 

Figure 3: Eco-innovation performance, 2010-20197 

Green public procurement (GPP) 

Public  procurement  accounts  for  a  large  proportion  of 
European 
consumption,  with  public  authorities’ 
purchasing  power  representing  14%  of  EU  GDP.  Public 
procurement can help drive the demand for sustainable 
products  that  meet  repairability  and  recyclability 
standards.  At present, reporting to monitor the uptake 
of GPP is voluntary. 

Poland adopted its first national action plan on GPP for 
the  period  2007-2009,  followed  by  Sustainable  Public 
Procurement NAP for 2010-2012, 2013-2016, and 2017-
2020.  Currently, 
sustainable  public  procurement 
(encompassing also GPP) is mentioned as one of the top 
priorities  under  the  state  purchasing  policy  for  2022-
2025,  a  strategic  document  adopted  by  the  Council  of 
Ministers in January 2022. The State Purchasing Policy is 
addressed  to  government  administration  units  to 
include  in  particular  green  and  social  aspects  in  their 
tendering  process.  There  are  no  criteria  developed  at 
national  level.  However,  the  Public  Procurement  Office 
promotes the overall application of the EU GPP criteria 
on a voluntary basis. Monitoring is based on the analysis 
of  information  delivered  by  contracting  authorities  in 
their  annual  reports  on  awarded  contracts.  On  that 
basis,  a  report  on  the  functioning  of  the  public 
procurement system is prepared annualy. 

In 
January  2022,  the  Public  Procurement  Office 
published  on  its  website  a  “Guidance  on  the  GPP-

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

related  provisions”8.  The  more  recent  deliverables 
include also a “Guidance on the use of solutions within 
public  contracts  to  counter  impact  on  environment  of 
the 
construction 
components  of 
investment”9. 

individual 

a 

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

The  number  of  EU  ecolabel  products  and  EMAS-
licensed10  organisations  in  a  given  country  provides 
some  indication  of  the  extent  to  which  the  private 
sector  and  national  stakeholders  in  that  country  are 
actively engaged in the transition to a circular economy. 
It  also  shows  how  committed  public  authorities  are  to 
supporting 
instruments  designed  to  promote  the 
circular economy.  

As  of  September  2021,  3 175  out  of  83 590  products, 
and  58  out  of  2 057  licences  in  Poland  were  registered 
under the EU ecolabel scheme, showing a good take-up 
licences 11.  Moreover,  67 
of  these  products  and 
organisations  and  515  sites  from  Poland  are  currently 
registered in the European Commission’s EMAS 12. Since 
the  last  report  in  2019,  there  have  been  615  new  EU 
ecolabel  product  registrations  as  well  as  12  new 
organisations registered with the EU ecolabel in Poland. 
However,  the  number  of  organisations  registered  in 
EMAS has decreased by 2. 

As Poland has adopted a circular economy roadmap, the 
priority  action  from  2019  has  been  fulfilled.  As  the 
circular  material  use  rate  is  well  below  the  EU  average 
the following priority action is proposed. 

2022 priority action 

  Adopt  measures  to 
material use rate. 

increase  the  circular 

8 Przewodnik UZP po obowiazujących przepisach w obszarze zielonych 
zamówien publicznych  
9  Wskazówki  dot.  rozwiązań  przeciwdziałających  oddziaływaniu  na 
środowisko  
10  EMAS  is  the  European  Commission’s  eco-management  and  audit 
scheme,  a  programme  to  encourage  organisations  to  behave  in  a 
more environmentally sustainable way. 
11 European Commission, ecolabel facts and figures. 
12 As of May 2018. European Commission, eco-management and audit 
scheme. 

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
 
 
 
 
                                                                 
Waste management 

Figure 4: Municipal waste by treatment in Poland, 
2010-202015  

Poland  7 

Turning waste into a resource is supported by: 
(i)  fully  implementating  EU  waste  legislation,  which 
includes  the  waste  hierarchy,  the  need  to  ensure 
separate  collection  of  waste,  the 
landfill  diversion 
targets etc.; 
(ii) reducing waste generation and waste generation per 
capita in absolute terms;  
(iii) limiting energy recovery to non-recyclable materials 
and  phasing out  landfilling of  recyclable or  recoverable 
waste. 
This  section  focuses  on  the  management  of  municipal 
waste13,  for  which  EU  law  sets  mandatory  recycling 
targets. 

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

After a downward trend, municipal waste generation in 
Poland has started to increase in recent years, reaching 
336 kg  per  capita  in  2020.  However,  this  value  is  still 
well  below  the  EU  average  of  501 kg  per  capita  (see 
Figure 4). Although a longer period is needed to confirm 
any conclusions on decoupling, Poland might be on the 
track to decouple total waste generation from economic 
growth,  provided  the  decoupling  observed  since  2016 
continues14. 

Figure 4 also shows municipal waste by treatment type, 
in kg per capita. After a decrease in the first half of the 
last  decade,  Poland’s  landfill  rate  has  increased  again 
over the last 3 years, reaching 43% in 2020 (which is far 
above  the  EU  average  of  24%).  This  means  that 
landfilling,  followed  by  incineration  (23%)  remain  the 
predominant forms of waste treatment. 

While  in  the  first  half  of  the  last  decade  Poland  made 
slow  but  steady  progress  in  stepping  up  its  recycling 
rate and diverting municipal waste from landfilling, the 
situation  has  stagnated  over  the  last  3  years.  The  data 
reported by Poland shows that 39% of municipal waste 
is recycled, which is below the EU average of nearly 48% 
(see  Figure  5)  and  shows  no  significant  improvement 
since 2016. 

The Commission called on Poland to comply with the EU 
rules on landfills by  ensuring the definitive closure and 
rehabilitation of five non-compliant municipal landfills16. 

Figure  5  shows  that  Poland  needs  to  increase  its 
investment  in recycling to  meet  the EU 2020 and 2025 
recycling targets. 

13  Municipal  waste  consists  of  (a)  mixed  waste  and  separately 
collected  waste  from  households,  including  paper  and  cardboard, 
glass,  metals,  plastics,  bio-waste,  wood,  textiles,  packaging,  waste 
electrical  and  electronic  equipment,  waste  batteries  and 
accumulators, and bulky waste, including mattresses and furniture; (b) 
mixed  waste  and  separately  collected  waste  from  other  sources, 
where such waste is similar in nature and composition to waste from 
households. (Directive 2008/98/EC, Art. 3 2b). 
14  Poland  Waste  Prevention  Country  Profile  2021  —  European 
Environment Agency (europa.eu) 

15 Eurostat, Municipal waste by waste operation, April 2022. 
16 April infringements package: key decisions (europa.eu) 

 Environmental Implementation Review 2022 – Poland 

 
                                                                 
 
                                                                 
Figure 5: Recycling rate of municipal waste, 2010-
202017 

The  Commission’s  Early  Warning  report18  listed  Poland  
as  one  of  the  countries  at  risk  of  missing  the  EU  2020 
target  of  recycling  50%  of  municipal  waste.  The  report 
listed key priority measures which Poland should take to 
close  the 
is 
currently  finalising  two  progress  analyses,  one  on  the 
recommendations 
the  2018  Early  Warning 
Reports,  the  second  on  achieving  the  2025  waste 
recyling targets. The report will be published at the end 
of 2022 and will assess the progress made to date. 

implementation  gap.  The  Commission 

from 

Implementation of the 2018 waste legislative package 

By  5  July  2020,  EU  Member  States  were  required  to 
bring their national laws into line with changes included 
in 
the 
the  revised  Waste  Framework  Directive, 
Packaging  and  Packaging  Waste  Directive  and  the 
Landfill Directive19. Poland has notified the transposition 
legislative  package20  to  the 
of  the  2018  waste 
Commission.  A 
is  now 
underway. 

conformity  assessment 

and  waste-prevention 
Waste-management  plans 
programmes  are 
in  effectively 
instrumental 
implementing  the  EU’s  waste  legislation.  These  plans 
and  programmes 
set  out  key  provisions  and 
investments  to  ensure  compliance  with  existing  and 

for 

17 Eurostat, Recycling rate of municipal rate, April 2022. 
18  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. 
19  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. 
20  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. 

Poland  8 

new  legal  requirements  (e.g.  on  waste  prevention;  on 
separate  collection  for  a  number  of  specific  waste 
streams;  on  recycling;  and  on  landfill  targets).  The 
Member  States  were  due  to  submit  revised  waste-
management  plans  and  waste-prevention  programmes 
by 5 July 2020. 

In  2016,  Poland  approved 
its  national  waste 
management  plan  2022  (KPGO  2022  –  Krajowy  plan 
gospodarki  odpadami  2022)21,  amended  in  202122.  The 
main  objective  of  the  2022  KPGO  is  to  identify  the 
roadmap  needed  to  meet  the  EU’s  recycling  and  reuse 
target  for  municipal waste. A revised plan with a  more 
forward-looking  perspective  is  still  being  developed 
(expected in 2022). 

2019  brought  significant  legislative  changes  aimed  at 
increasing  recycling  of  waste  and  at  strengthening 
enforcement  of  waste  management 
rules.  Most 
notably, the market for residual waste has been opened 
up to competition by abandoning the obligation to treat 
municipal  waste  in  installations  that  are  classed  as 
regional  installations.  Moreover,  as  from  2021,  mixed 
waste  from  the  municipalities  that  have  not  set  up 
separate  collection  schemes  is  no  longer  accepted  for 
law  on  maintaining 
incineration.  The  amended 
cleanliness and order in communes23 also introduced  a 
major  incentive  for  households  to  collect  recyclables 
separately,  as  costs  of  disposal  of  mixed  waste  can  be 
two  to  four  times  higher  than  for  separated  waste. 
Lastly,  environmental  inspectorates  are  able  to  carry 
out ad hoc inspections without prior notice and impose 
financial 
for  obstructing  controls  and 
investigations. 

sanctions 

Poland  has  not  signed  and  ratified  the  Hong  Kong 
International 
and 
the 
Convention 
Environmentally Sound Recycling of Ships. 

Safe 

for 

In the 2019 EIR, Poland received  five priority actions in 
the  field  of  waste.  There  has  been  no  progress  on  
building  excessive  infrastructure  for  waste  incineration 
and on better enforcement of the waste legislation, for 
example through setting up a system of checks on end-
of-life vehicles. However, Poland made notable progress 
on  financial  incentives  to  encourage  better  selective 
collection  of  waste  by  households.  There  has  been 
improving  the  functioning  of 
limited  progress  on 
extended producer responsibility schemes; legislation is 
currently under discussion. 

Given  the  overall  limited  progress  and  in  light  of  the 
upcoming  2022  Early  Warning  Report,  which  will 
present a detailed  analysis of progress in achieving the 

21 Krajowy plan gospodarki odpadami 2022  
22 Uchwała nr 57 Rady Ministrów z dnia 6 maja 2021 r.  
23 Ustawa o utrzymaniu czystości i porządku w gminach  

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
                                                                 
Poland  9 

2020 targets, similar priority actions as the ones set out 
in the EIR 2019 are proposed below. 

2022 priority actions 

 

Consider introducing incineration fees to more 
effectively divert waste towards the higher end 
of  the  waste  hierarchy  and  to  make  recycling 
and reuse economically attractive, as indicated 
in the national waste management plan. 

  Avoid  building  excessive 

infrastructure  for 
waste  incineration, close and rehabilitate non-
compliant landfills.  
Continue  efforts  to  better  enforce  waste 
legislation;  in  particular,  introduce  effective 
penalties for municipalities or local authorities, 
to  ensure  they  put  more  effort  into  curbing 
illegal  waste  dumping,  and  establish  a  system 
of checks on end-of-life vehicles. 
Improve the functioning of extended producer 
responsibility  (EPR)  schemes,  in  line  with  the 
general minimum requirements on EPR 24. 
Set  up  a  national  project  giving  municipalities 
technical  assistance  with  meeting 
their 
implementation  and  enforcement  obligations, 
regards  separate  collection, 
especially  as 
checks  on  bodies  dealing  with  waste 
management, functioning of EPR, etc. 
Ensure  a  national  waste  management  in  line 
with  revised  Waste  Framework  Directive  is  in 
place.

 

 

 

 

24 Directive (EU) 2018/85 

 Environmental Implementation Review 2022 – Poland 

 
                                                                 
Poland  10 

2. Biodiversity and natural capital

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

The EU’s Habitats and Birds Directives are key legislative 
tools  to  deliver  on  the  targets  in  the  EU’s  biodiversity 
strategy  for  2030,  and  are  the  cornerstone  of  the 
European  legislation  aimed  at  conserving  of  the  EU’s 
wildlife25.  

Poland prepared its first biodiversity strategy in 2003. In 
2015 an updated strategy, ‘a programme of biodiversity 
conservation  and  sustainable  use’,  was  drawn  up  with 
the aim of contributing more to EU biodiversity targets 
(including  achieving  favourable  conservation  status  for 
at least 10% of habitats and 10% of species). A national 
strategy of wetland conservation was drawn up in 2006, 
according to the Ramsar Convention’s requirements. 

Nature protection and restoration  

Natura  200026,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  objectives 
in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats,  and  the 
ecosystems  they  underpin.  Key  milestones  towards 

25  These  should  be  reinforced  by  the  Nature  Restoration  Law, 
according to the new EU Biodiversity Strategy 
26  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 
designated  pursuant  to  the  Habitats  Directive  as  well  as  Special 
Protection  Areas  (SPAs)  classified  pursuant  to  the  Birds  Directive; 
figures of coverage do not add up due to the fact that some SCIs and 
SPAs  overlap.  Special  Areas  of  Conservation  (SACs)  means  a  SCI 
designated by the Member States. 

meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are:  (i)  the  setting  up  of  a  coherent  Natura 
2000 network; (ii) the designation of sites of community 
importance  (SCIs)  as  SACs27;  (iii)  the  setting  of  site-
specific    conservation  objectives  and  measures  for  all 
Natura 2000 sites. 

Setting up a coherent network of Natura 2000 sites 

Poland  hosts  81  habitat  types28  and  176  species29 
covered  by  the  Habitats  Directive.  The  country  also 
hosts  populations  of  105  bird  taxa  listed  in  the  Birds 
Directive Annex I30. 

As shown in the Figure 7, by 2021, 19.6% of the territory 
of  Poland  was  covered  by  Natura  2000  (EU  average 
18.5%),  with  special  protection  areas  (SPAs)  classified 
under  the  Birds  Directive  covering  15.5%  (EU  average 
12.8%)  and  SCIs  under  the  Habitats  Directive  covering 
11% (EU average 14.2%) of Poland’s territory. 

The  assessment  of  the  SCI  part  of  the  Natura  2000 
network  shows  that  there  are  still  some  insufficiencies 
in  designating  SCIs  and  Poland  still  has  to  complete  its 
Natura  2000  network.  The  Commission  has  taken  legal 
action  to  address  these  gaps  and  is  closely  monitoring 
progress in this case. 

Taking  Natura  2000  and  other  nationally  designated 
protected  areas  into  account,  Poland  legally  protects 
39.6% of its terrestrial areas (EU-27 average 26.4%) and 
21.8%  of  its  marine  areas  (EU-27  average  10.7%)31. 
Poland  strictly  protects  approximately  1.5%  of 
its 
territory  (combined  area  of  national  parks  and  natures 
reserves). 

Figure  6  shows  the  EU-level  targets 
in  the  2030 
biodiversity  strategy  and  the  2021  levels  for  terrestrial 
and marine protected area coverage. 

27  Sites  of  community  importance  (SCIs)  are  designated  pursuant  to 
the  Habitats  Directive,  whereas  special  protection  areas  (SPAs)  are 
designated pursuant to the Birds Directive; figures of coverage do not 
add up due to the fact that some SCIs and SPAs overlap. Special areas 
of conservation (SACs) are SCIs designated by the Member States. 
28 EEA, Article 17 dashboard, Annex I total, 2019. 
29  EEA,  Article  17  dashboard,  Annex  II  +  Annex  IV  excluding  those  in 
Annex  II  +  Annex  V  excluding  those  in  Annex  II,  2019.  This  counting 
only takes into account species and habitats for which assessment of 
conservation status was requested. 
30  EEA, Article  12  dashboard,  Annex  I,  2020. This counting  only  takes 
into account birds taxa for which information was requested. 
31  EEA, Protected Areas,  terrestrial  protected area percentage  (2021) 
and marine protected area percentage (2019), March 2022. 

Environmental Implementation Review 2022 – Poland 

 
                                                                 
 
 
                                                                 
Figure 6: Marine & terrestrial protected area coverage, 
202132 

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202133 

Poland  11 

Designating SACs and setting conservation objectives 
and measures 

The  six-year  deadline  set  by  the  Habitats  Directive  to 
designate  SCIs  as  SACs  and  decide  on  appropriate 
conservation  objectives  and  measures  has  expired  for 
849 sites in Poland. 

the  quality  of 

these  objectives 

Nevertheless, 390 SCIs have not yet been designated as 
SACs,  while  conservation  objectives  and  conservation 
measures  have  only  been  established  for  563  SCIs. 
Furthermore, 
is 
insufficient  as  they  are  often  not  related  to  the 
the  conservation 
to  determine 
parameters  used 
condition of the habitat types and species protected on 
the site (e.g. in relation to area, structure and functions 
or  populations).  Due  to  these  shortcomings,  the 
Commission initiated an infringement procedure calling 
on  Poland  to  take the  long  overdue  necessary  steps  to 
protect and manage its Natura 2000 network.  

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

To measure the performance of Member States, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  reuire  reporting  on  the  progress  made 
towards  maintaining 
favourable 
or 
conservation status of species and habitats34. 

restoring 

According  to  the  report  submitted  by  Poland  on  the 
conservation  status  of  habitats  and  species  covered  by 

33  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 
34  Consult  Conservation  status  and  trends  of  habitats  and  species  — 
European Environment Agency (europa.eu) 

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

Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
 
 
 
                                                                 
 
                                                                 
in  2018  showed  habitats 

Article 17 of the Habitats Directive for 2013-2018,  20% 
of  assessments 
in  good 
conservation  status  (the  same  as  under  the  previous 
reporting period, 2007-2012). As  for protected  species, 
37.74%  of  assessments  showed  good  conservation 
status in 2018 (31.99% in 2007-2012). Concerning birds, 
18%  of  the  breeding  species  showed  short-term 
increase,  while  24%  showed  stable  population  trends 
(for wintering species these figures  were 38% and 14% 
respectively). 

However,  the  share  of  habitats 
in  bad  or  poor 
conservation status has increased to 78.26%, while  the 
share  of  assessments  for  species 
in  bad  or  poor 
conservation status has decreased to 46.69%. The main 
pressures  are  natural  processes,  development  of 
infrastructure,  agriculture,  forestry  and  invasive  alien 
species. 

Figure 8: Assessments on conservation status for 
habitats for the 2007-2012 and 2013-2018 reporting 
periods35 

Poland  12 

Figure 9: Assessments on conservation status for 
species for the 2007-2012 and 2013-2018 reporting 
periods36 

In February 2022, Poland submitted to the Commission 
its  2021-2027  prioritised  action  framework  (PAF)  for 
Natura 2000. The document sets out funding needs for 
managing  and  restoring  the  Natura  2000  sites,  the 
green infrastructure necessary to ensure the coherence 
of  the  network,  supporting  protected  species,  and 
administrative and other cross-cutting measures. 

According  to  the  estimates  presented  by  Poland, 
approximately  EUR 689  million  annualy  is  required  to 
effectively  manage  and  restore  the  sites  to  achieve 
favourable  conservation  status  of  habitats  and  species 
interest.  The  highest  costs  are  related  to 
of  EU 
managing  forest  habitats  (EUR 333  milion/year)  and 
grasslands  (EUR 287  million/year).  Filling  knowledge 
gaps was estimated to cost EUR 207 million altogether. 

The LIFE programme has been widely used in Poland for 
nature purposes. Two recent example projects are: 

 

 

Kampinos  WetLIFE  project  on  protection  and 
‘Puszcza 
of  wetlands 
restoration 
Kampinoska’ Natura 2000 site; 
LIFE  Apollo2020  project  on  Conservation  of 
Apollo  butterfly  (Parnassius  apollo)  in  Poland, 
Czechia, and Austria. 

in 

Poland  has  not  signed  and  ratified  the  Agreement  on 
the  Conservation  of  African-Eurasian  Migratory 
Waterbirds (AEWA). 

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

36 Idem 

Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
 
 
 
                                                                 
Bringing nature back to agricultural land and restoring 
soil ecosystems 

renewable  energy  remains  under-used  in  terms  of 
energy per livestock unit. 

Poland  13 

Agricultural land 

in  the  use  of  more  hazardous 

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: 
-  50% reduction in the overall use of – and risk from – 
chemical pesticides; 
-  50%  reduction 
pesticides; 
-  50%  reduction  in  losses  of  nutrients  from  fertilisers 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  20%  reduction  in  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%.  
As shown in Figure 10, with an estimated 3.52% of land 
under  organic  farming 
increase 
compared to 3.49% in 2019, according to Eurostat data), 
Poland is well below the EU average of 9.07% and ranks 
23rd out of 27 EU Member States. 

in  2020  (a  slight 

Figure 10: Share of total utilised agricultural area 
occupied by organic farming per Member State, 202037  

Data  from  recent  years  and  medium-term  projections 
show  an  increasing  trend  for  non-carbon  dioxide  (CO2) 
emissions  from  agriculture.  This  includes  soils  that 
account  for  half  of  the  emissions,  stagnating  CO2 
removal  in  the  land  use,  land-use-change,  and  forestry 
(LULUCF) sectors. The relatively high emissions intensity 
of  the 
livestock  sector  (enteric  fermentation)  and 
significant  energy  consumption  in  the  agricultural  and 
forestry sectors are also areas of concern. Production of 

37 Eurostat, Area under organic farming, February 2022  

Water  availability 
is  a  significant  problem,  caused 
partially  by  the  weak  water  retention  capacity  in  the 
Polish  agriculture  sector,  exacerbated  by  the  changing 
climate.  Water  quality,  regional  surpluses  of  nitrogen, 
and  phosphorus  from  the  use  of  animal  manure  may 
lead to pollution of ground and surface waters and  the 
increasing eutrophication of the Baltic Sea. 

of 

farming  management, 

Intensification 
land 
abandonment,  pollution,  modifications  of  hydrological 
systems  such  as  drainage  and  expansion  of  invasive 
species are main agriculture-related threats responsible 
for the worsening of biodiversity status. 

Soil ecosystems 

Soil  is  a  finite  and  extremely  fragile  resource  and  it  is 
increasingly degrading in the EU.  
The  new  EU  soil  strategy,  adopted  on  17  November 
2021,  stresses  the  importance  of  soil  protection,  of 
sustainable soil management and of restoring degraded 
soils,  to  achieve  the  Green  Deal  objectives  as  well  as 
land degradation neutrality by 2030. This entails: 
(i) preventing further soil degradation; 
(ii)  making  sustainable  soil  management  the  new 
normal; 
(iii) taking action for ecosystem restoration. 

One factor  in the degradation of soil ecosystems  is the 
area of soil that is sealed or atificialised38. The net land 
taken  (land  ‘taken’  means  that 
is  sealed  or 
artificialised)  per  year  in  the  period  2012-2018  (see 
Figure  11)  can  be  seen  as  a  measure  of  one  significant 
pressure  on  nature  and  biodiversity  –  a 
land-use 
change. At the same time, a land-use change constitues 
an environmental pressure on people living in urbanised 
areas.  

land 

land  take 

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

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

Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
                                                                 
Poland  14 

Poland ranks above the EU average39 as regards net land 
take  with  214 m2/km2  (EU-27  average  83.8 m2/km2, 
Eurostat 2018).  

its  reporting  on 

land 
In  2018,  Poland  updated 
degradation  according  to  the  Performance  Review  and 
Implementation  System  (PRAIS3)  reporting  platform40 
with  actions 
intended  to  remedy  the  degradation 
identified. 

Figure 11: Land take and re-cultivation in the EU-27 
(m2/km2), 2012-201841 

Of  the  27%  of  EU  forest  area  protected  under  the 
Habitats Directive, less than 15% of assessments show a 
favourable  conservation  status43.  Bad  conservation 
status increased  in  the EU  from 27%  in 2015  to 31% in 
2018.  

In  Poland,  forests  cover  33.53%  of  the  country’s 
territory44  and  more  than  75%  of  the  assessments  for 
forests  protected  under  the  Habitats  Directive  reveal  a 
bad to poor status45. 

Figure  12:    Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)46 

However,  Poland  has  not  yet  committed  to  set  land 
degradation neutrality targets under UNCCD42. 

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
a 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, 
which 
strengthened 
significantly 
biodiversity and climate ambitions. 
Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050.  

contribute 

to 

The  infringement  procedure  concerning  the  Białowieża 
Forest, launched against Poland in case C-441/17, is still 
not  closed.  The  EU  sent  a  letter  of  formal  notice  to 
Poland,  pursuant  to  Article 260  of  the  Treaty  on  the 
functionning  of  the  European  Union,  concerning  non-
implementation of the Court’s judgment. 

On  17 April 2018,  the  Court  of  Justice 
its 
judgment  in  case  C-441/17  and  ruled  that  Poland  had 
failed to fulfil its obligations under the Habitats and the 
Birds Directive. In particular, Poland had failed to:  

issued 

(i) 

ensure  that  the  forest  management  plan 
for  the  Białowieża  Forest  District  would 
not  adversely  affect  the  integrity  of  the 
Natura 2000 sites;  

39 Land take  in Europe — European Environment Agency (europa.eu) 
fig 6. 
40 All Reports | Prais3 (unccd.int) 
41  European  Environment  Agency,  Land  take  in  Europe,  December 
2021. 
42  The LDN Target Setting Programme | UNCCD 

43  EEA, State of Nature in the EU 
44 EEA, Forest information system for Europe 
45 COM SWD (2021) 652 
46  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 

Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
 
 
 
 
                                                                 
(ii) 

(iii) 

(iv) 

the  necessary 

conservation 
establish 
measures  for  the  protected  species  and 
habitats;  
strict  protection  of 
the 
guarantee 
their 
species 
protected 
disturbance, 
deliberate 
killing 
deterioration  or  destruction  of 
their 
breeding  sites  in  the  Białowieża  Forest 
District;  
guarantee  the  protection  of  bird  species 
regarding 
killing, 
disturbance and protection of their nests. 

regarding 
or 

deliberate 

their 

issued,  the  Commission  has 
Since  the  ruling  was 
continuously  monitored  Poland’s 
implementation 
measures  necessary  to  comply  with  the  Court’s 
judgment. The Polish authorities agreed on a number of 
operational  conclusions  on  this  matter,  covering  short- 
and long-term measures related to the management of 
the forest and specific commitments that logging would 
only  be  possible  under  specific  conditions.  The 
Commission continues to closely monitor this issue. 

(EUTR)47 
The  European  Union  Timber  Regulation 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested  timber.  In  accordance  with  the  EUTR,  EU 
Member  States’  competent  authorities  must  conduct 
regular  checks  on  operators  and  traders,  and  apply 
penalties  for  non-compliance.  With  the  amendment  of 
Article 20 of the EUTR, reporting every 2 years has been 
changed  to  annual  reporting  and  covers  the  calendar 
year as of 2019. 

In  the  period  from  March  2017  to  February  201948, 
Poland  carried  out  43  checks  on  domestic  timber 
operators.  It  also  carried  out  170  checks  on  operators 
importing  timber.  Over  the  reporting  period, 
is 
estimated  that  Poland  had  8 000  operators  placing 
imported timber types onto the single market. 

it 

degradation 

A proposal for a Regulation on making available on the 
EU  market  and  exporting  products  associated  with 
deforestation 
(’the 
forest 
and 
on 
Regulation’)  was 
Deforestation 
17 November  2021.  It  followed  a  request  from  the 
Council in 2019 to table a legislative proposal to address 
the  problem  and  a  European  Parliament  resolution 
recommending  the  Commission  come  forward  with  an 
EU legal framework to halt and reverse EU-driven global 
deforestation.  

adopted 

The  new  Deforestation  Regulation  will  repeal  and 
replace  the  EUTR,  as  it  will  essentially  integrate  and 

47  Regulation  (EC)  No  2173/2005  of  20  December  2005  on  the 
establishment of a FLEGT licensing scheme for imports of timber into 
the European Community. 
48 COM/2020/629 final 

Poland  15 

improve  the  existing  system  to  check  the  legality  of 
timber. 

Invasive alien species (IAS) 

in 

and 

land 

changes 

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

The core of Regulation (EU) 1143/2014 on IAS49 (‘the IAS 
Regulation’) is the list of IAS of Union concern.  

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

According  to  a  2021  report50  on  the  review  of  the 
application of the IAS Regulation, the implementation of 
the  IAS  Regulation  is  already  starting  to  deliver  on  its 
objectives, such as a coherent framework for addressing 
IAS at EU level, and increased awareness of the problem 
identified  some 
of  IAS.  However,  the  report  also 
challenges  and  areas  for  improvement.  Given  that  the 
deadlines  for  complying  with the various obligations of 
the IAS Regulation applied gradually between July 2016 
and  July  2019,  it  is  premature  to  draw  conclusions  on 
specific  aspects  of  the  implementation  of  the  IAS 
Regulation. 

A 2021 report51 on the baseline distribution shows that 
of the 66 species on the EU list, 23 have been observed 

49  Regulation  (EU)  No  1143/2014  of  the  European  Parliament  and  of 
the Council of 22 October 2014 on the prevention and management of 
the introduction and spread of invasive alien species 
50  Report  from  the  Commission  to  the  European  Parliament  and  the 
Council  on  the  review  of  the  application  of  Regulation  (EU)  No 
1143/2014  of  the  European  Parliament  and  of  the  Council  of  22 
October 2014 on the prevention and management of the introduction 
and spread of invasive alien species, COM(2021) 628 final, 13.10.2021. 
51  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D'  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines,  EUR 
30689  EN,  Publications  Office  of  the  European  Union,  Luxembourg, 
2021, ISBN 978-92-76-37420-6, doi:10.2760/11150, JRC123170. 

Environmental Implementation Review 2022 – Poland 

 
                                                                 
                                                                 
in  the  environment  in  the  Poland.  The  spread  can  be 
seen in Figure 13. 

 

Figure 13: Number of IAS of EU concern, based on 
available georeferenced information for Poland, 
202152  

justice. 
Step up action on reducing emissions related to 
fertiliser  use  on  soils  and  avoiding  carbon 
release  from  organic  soil,  on  better  livestock 
management as well as on increasing the area 
under organic farming. 

Poland  16 

  Reduce  the  excessive  area  of  sealed  and 
artificialised soil and remediate degraded areas 
of  soil.  To  this  end,  to  consider  formally 
committing  to 
land  degradation  neutrality 
targets under the relevant UNCCD agreement.  
Step  up  implementation  action  on  the  EU  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 
endangered, 
incidental 
threatened  and  sensitive  species  to  a  level  that  allows 
species recovery and conservation53. 

protected, 

catches 

of 

it  failed  to  draw  up  and 

An  infringement  case  in  relation  to  Poland  is  ongoing 
implement  one 
since 
overarching action plan or a set of action plans fulfilling 
the  requirements  specified  in  Article 13  of  of  the  IAS 
Regulation  by  13 July 2019  and  to  send  it/them  to  the 
Commission without delay. 

2022 priority actions 

 

 

 

Complete the Natura 2000 designation process 
and  put  in  place  site  specific  conservation 
objectives  and  the  necessary  conservation 
measures  for  all  sites  to  maintain/restore 
species  and  habitats  of  Community  interest  to 
a  favourable  conservation  status  across  their 
natural range. 
Ensure  implementation  of  priority  measures 
identified in the PAF. 
forest  management 
Establish  appropriate 
practices  to  ensure  full  compliance  with  the 
Habitats  and  Birds  Directives, 
in 
terms  of  public  participation  in  the  forest 
managment  planning  and  related  access  to 

including 

52  Cardoso  A.C.,  Tsiamis  K.,  Deriu  I.,  D’  Amico  F.,  Gervasini  E.,  EU 
Regulation 1143/2014:  assessment  of  invasive  alien species of  Union 
concern  distribution,  Member  States  reports  vs  JRC  baselines, 
the  European  Union, 
EUR 30689  EN,  Publications  Office  of 
Luxembourg,  2021, 
ISBN  978-92-76-37420-6,  doi:10.2760/11150, 
JRC123170. 

The  Marine  Strategy  Framework  Directive  (MSFD)54 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 
Member  States  must  draw  up  marine  strategies  for 
their marine waters, and cooperate with Member States 
sharing  the  same  marine  region  or  sub-region.  These 
marine  strategies  comprise  different  steps  to  be 
developed and implemented over six-year cycles. 

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

The Commission assessed Poland’s 2018 determinations 
of  GES  for  each  of  the  MSFD’s  11  descriptors55  and 
whether  these  were  appropriate 
‘level  of 
adequacy’  in  relation  to  the  Commission  Decision  on 
criteria and methodological standards for GES in marine 
waters56. A good or very good score in the Commission 
assessment  indicates  that  the  national  determinations 

(their 

53  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
54 Marine Strategy Framework Directive 2008/56/EC 
55 Annex I of Directive 2008/56/EC. 
56  Commission  Decision  (EU)  2017/848  laying  down  criteria  and 
methodological  standards  on  good  environmental  status  of  marine 
waters  and  specifications  and  standardised  methods  for  monitoring 
and assessment, and repealing Decision 2010/477/EU 

Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
                                                                 
Poland  17 

of  GES  are  well  aligned  with  requirements  of  the 
Commission  GES  Decision  and  provide  qualitative  and 
quantitative  national  environmental  objectives  to  be 
achieved for their marine waters.   

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

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

Poland has one marine region: BAL – Baltic Sea.  In this 
marineregion,  8  out  of  11  determinations  of  GES  were 
assessed as good or very good. Poland’s  determination 
of GES is consistent with the requirements set under the 
Commission GES Decision for 7 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  determined  GES.  A 
good  or  very  good  score  indicates  that  the  Member 
State  has  good  capabilities  for  assessing  their  marine 
environment  according  to  the  requirements  set  out  in 
the Commission GES Decision. 

10  descriptors  out  of  11  were  scored  as  good  or  very 
good. Poland’s assessment of its marine environment is 
consistent with requirements set under the Commission 
GES Decision for 10 out of 11 descriptors. 

Eutrophication  and  pollution  of  the  Baltic  Sea  is  a 
serious concern that affects 97% of the Baltic Sea. 

the  MSFD59,  while 

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

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

2022 priority actions 

 

 

Ensure  regional  cooperation  with  Member 
States  sharing  the  same  marine  (sub)region  to 
address predominant pressures. 
Implement the recommendations made by the 

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

58 Idem.  
59 COM(2020)259 

Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
 
                                                                 
Poland  18 

In  2015-2018,  Adam  Mickiewicz  University  participated 
in  the  ESMERALDA  project  (‘Enhancing  ecosystem 
services mapping for policy and decision making’) within 
the  Horizon  2020  programme.  The  project  aimed  to 
deliver  a  flexible  methodology  for  pan-European  and 
regional assessments and sharing experience through a 
process of dialogue and knowledge co-creation. 

the  national  ecosystem 

services 
July  2015, 
In 
partnership  network 
in  Poland  was  created.  The 
Network  webpage62  provides  information  about  recent 
projects,  upcoming  events,  and  other  news  about 
ecosystem assessment progress in Poland. 

Poland has provided updated information, and progress 
has  been  recorded  since  January  2016  (see  Figure  16). 
This  assessment 
implementation 
is  based  on  27 
questions and is updated every six months. 

Figure 16: ESMERALDA MAES barometer, January 2016 
- March 202163 

To assess progress on the implementation of ecosystem 
accounting, the Commission conducts a periodic review 
of Member States by sending out a survey containing 13 
questions (see Figure 17). 

Commission  in  the  staff  working  document60 
accompanying 
on 
recommendations  per  Member  States  and 
region on the 2018 updated reports for Articles 
8, 9 and 10 of the MSFD. 

Communication61 

the 

Ecosystem assessment and accounting  

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

An ecosystem assessment is an analysis of the pressures 
on  –  and  the  condition  of  –  terrestrial,  freshwater  and 
marine  ecosystems  and  their  services.  It  uses  spatially 
explicit  data  and  a  comparable  methodology  based  on 
European data about the functions of  ecosystem assets 
and the ecosystem services they produce.  

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

In  2013-2016,  the  LINKAGE  project  –  linking  systems, 
perspectives  and  disciplines  for  active  biodiversity 
governance  –  was  carried  out.  Its  aim  was  to  improve 
in  Poland  and  Norway  by 
biodiversity  governance 
developing  innovative  protocols  and  technologies  for 
biodiversity governance. 

In  2013-2017,  the  ‘Ecosystem  services  in  young  glacial 
landscapes  –  assessment  of  resources,  threats  and 
utilisation’  project  was  carried  out  at  the  Institute  of 
Geography  and  Spatial  Organisation  in  Warsaw  (Polish 
Academy of Sciences). 

the  Chief 

In  2015,  a  national  mapping  and  assessment  of 
ecosystems  and  their  services  supported  by  the  Polish 
Ministry  of  Environment  was  completed.  Since  January 
2015, 
for  Environmental 
Inspectorate 
Protection  has  worked  on  an  initiative  that  covers 
mapping  and  assessment  of  ecosystem  services  in 
different  types  of  geoecosystems,  as  part  of  the 
environmental monitoring programme. The assessment 
is  performed  for  11  base  stations  (catchments)  within 
integrated environmental monitoring. 

60 SWD(2022)1392. 
61  COM(2022)550. 

62 MAES-related developments in Poland  
63 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem  assessment:  summary  for  policymakers,  page  80,  May 
2021. 

Environmental Implementation Review 2022 – Poland 

 
                                                                 
 
                                                                 
Figure 17: Ecosystem accounting Barometer, 
September 202164 

Poland  19 

2022 priority actions 

 

 

supporting 

the  mapping 

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

64  MAIA  Portal,  Mapping  and  assessment  for  Integrated  Ecosystem 
Accounting (EU Horizon 2020 project), 2022. MAIA uses the System of 
Environmental  Economic  Accounting  –  Experimental  Ecosystem 
Accounting (SEEA-EEA) as the methodological basis for the ecosystem 
accounting. The SEEA EA is an integrated an comprehensive statistical 
framework  that  is  based  on  five  core  accounts:  ecosystem  extent, 
condition, services and monetary ecosystem asset.” 

Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
Poland  20 

3. Towards zero pollution 

Clean air 

its 

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

The EU has developed a comprehensive suite of clean-air 
legislation,  which 
air-quality 
standards65  and  emissions  reduction  commitments66  by 
Member State for a number of air pollutants.  

health-based 

sets 

to 

reach 

its  emission 

Poland  expects 
reduction 
commitments for SO2, NH3 and PM2,5 for the period 2020 
to 2029 and for most pollutants for 2030 onwards. Their 
projections do not, however, indicate they will meet their 
2020-29  emission  reduction  commitments  for  NOX  and 
NMVOC  or  their  2030  onwards  emission  reduction 
commitment  for  PM2.5.  Latest  inventory  data  submitted 
by  Poland,  prior  to  review  by  the  Commission,  indicate 
that Poland is in compliance with the emission reduction 
commitments  for  NOx,  SO2,  NH3  and  PM2.5,  and  in  non-
compliance with the emission reduction commitment for 
NMVOC in 2020. 

its  national  air  pollution  control 
Poland  submitted 
programme 
(NAPCP)  on  27 June 2019.  However, 
according to the latest projections submitted in 2021, it is 
necessary to update the NAPCP and Poland reports that 
the apropriate works have started. 

Figure 18: Emission trends of main pollutants/GDP in 
Poland, 2005-201973 

However, air quality in Poland continues to give cause for 
serious  concern.  The  latest  available  annual  estimates 
(for  2019)  by  the  European  Environment  Agency67 
indicate  about  39 300  premature  deaths  (or  490 300 
years  of  life  lost  –  YLL)  attributable  to  fine  particulate 
matter  concentrations68,  1 370  premature  deaths  (or 
17 800  YLL)  due  to  ozone  concentrations69  and  1 190 
premature  deaths  (14 900  YLL)  due  to  nitrogen  dioxide 
concentrations70 71. 

Emissions  of  several  air  pollutants  have  decreased 
significantly in Poland in recent years, while GDP growth 
latest 
continued  (see  Figure  18).  According  to  the 
projections, submitted under Article 10(2) of the National 
Emission  Reduction  Commitments  Directive  (NECD) 72, 

65 European Commission, 2016. Air Quality Standards. 
66 European Commission, Reduction of National Emissions.  
67 European Environment Agency, Air Quality in Europe –2021 Rapport. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106 
68  Particulate  matter  (PM)  is  a  mixture  of  aerosol  particles  (solid  and 
liquid) covering a wide range of sizes and chemical compositions. PM10 
refers  to  particles  with  a  diameter  of  10  micrometres  or  less.  PM2.5 
refers  to  particles  with  a  diameter  of  2.5  micrometres  or  less.  PM  is 
emitted from many human sources, including combustion. 
69 Low-level ozone is produced by photochemical action on pollution.  
70  NOx  is  emitted  during  fuel  combustion e.g. from  industrial  facilities 
and  the  road  transport  sector.  NOx  is  a  group  of  gases  comprising 
nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
71  Please  note  that  these  figures  refer  to  the  impacts  of  individual 
pollutants, and to avoid double-counting cannot be added up to derive 
a sum  
72 Directive 2016/2284/EU 

73 European Environment Agency. 

Environmental Implementation Review 2022 – Poland 

 
                                                                 
 
 
                                                                 
Figure 19: PM2.5 and NOX emissions by sector in Poland, 
201974 

Poland  21 

with 

Directive 

values  (C-336/16;  COM  vs  Poland),  confirming  Poland’s 
non-compliance 
2008/50/EC. 
Subsequently, the European Commission decided to send 
a  letter  of  formal  notice  to  Poland  for  failing  to  comply 
with  its  obligations  under  the  Directive  on  Ambient  Air 
Quality and with the said ruling. By focusing on Poland’s 
failure to act on  and execute the judgment  of the  CJEU, 
the Commission is seeking to ensure that Poland will take 
decisive  action  to  solve  the  problem.  The  Commission 
acknowledges  that  some  progress  has  been  made. 
However,  it  remains  concerned  by  the  pace  of  changes, 
particularly  with  regard  to  replacing  outdated  solid  fuel 
boilers  used  for  heating  by  individual  households  and 
measures covering the transport sector.  

The  Commission  has  also  taken  legal  action  against 
Poland on NO2, for which the EU AAQD has set air quality 
standards  since  2010.  Full  implementation  of  the  air 
quality  standards  enshrined  in  EU  legislation  is  key  to 
effectively protecting human health and safeguarding the 
natural environment. 

Poland  has  not  yet  ratified  (i)  the  amended  Gothenburg 
Protocol, (ii) the Heavy Metals Protocol, and (iii) the POPs 
Protocol  under  the  UNECE  Air  Convention.    It  has  also 
failed  to  sign  or  ratify  three  agreements  under  the 
Convention  on  Long-range  Transboundary  Air  Pollution: 
(i)  the  Gothenburg  Protocol  to  Abate  Acidification, 
Eutrophication,  and  Ground-level  Ozone; 
the 
Persistent Organic Pollutions Protocol, and (iii) the Heavy 
Metals Protocol. 

(ii) 

In  the  2019  EIR,  Poland  received  priority  actions  calling 
for  specific  actions  to  be  taken  under  the  NAPCP  –  on 
which  there  has  been  some  progress  but  these  are 
reiterated  in  this  report  –  and  to  reduce  particulate 
matter,  benzo(a)pyrene  emissions  and  nitrogen  oxides. 
There  has  been  some  progress  on  these  reductions,  but 
there remains a need to comply with EU standards. 

2022 priority actions 

 

Take, in the context of the national air pollution 
control  programme  (NAPCP),  actions  to  reduce 
emissions  from  the  main  sources  mentioned 
above. 

  Maintain  downward  emissions  trends  for  air 
pollutants,  and  reduse  adverse  air-pollution 
impacts  on  health  and  the  economy,  to  ensure 
future concentrations fall within WHO guideline 
value  and  fully  comply  with  EU  air  quality 
standards, where these are not met. 
Poland  is  strongly  encouraged  to  accelerate  its 
ratification  of 
the  amended  Gothenburg 
Protocol,  the  Heavy  Metals  Protocol  and  the 
POPs Protocol under the UNECE Air Convention. 

 

In  2020,  levels  exceeding  the  limit  values  set  by  the 
Ambient Air Quality Directive (AAQD) were registered for 
nitrogen dioxide (NO2) in two air-quality zones (out of 45)   
and  for  particulate  matter  (PM10  and  PM2.5)  in  16  and  2 
zones  respectively.  Furthermore,  in  3  air  quality  zones 
the  target  values  regarding  ozone concentration  were 
not met 75. 

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 over PM10 and 
NO2 exceedances) covering all Member States concerned, 
including  Poland  for  exceedances  of  PM10  and  NO2  limit 
values.  

The  Court  of  Justice  of  the  European  Union  (CJEU)  has 
delivered  a  judgment  on  exceedances  of  PM10  limit 

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

 Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
 
Industrial emissions 

Figure 20: Number of IED industrial installations per 
sector in Poland, 201880 

Poland  22 

The  main objectives of EU policy on industrial emissions 
are to:  
(i) protect air, water and soil;  
(ii) prevent and manage waste;  
(iii) improve energy and resource efficiency;  
(iv) clean up contaminated sites.  

To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial  Emissions  Directive  (IED)76.  The  Commission 
tabled a proposal  in April  202277. The revision seeks to 
improve the Directive’s contribution to the zero-pollution 
objective, as well as its consistency with climate, energy 
and circular economy policies. 

 The  overview  of  industrial  activities  regulated  by  IED 
below  is  based  on  data  reported  to  the  EU  registry 
(2018)78. 

industrial 

In  Poland,  around  2 000 
installations  are 
required  to  have  a  permit  based  on  the  IED79.  The 
distribution  of  installations  is  shown  in  Figure  20.  This 
represents  a  decrease  of  more  than  1 000  installations 
since the last report, linked mostly to fewer installations: 

(i) 
(ii) 

(iii) 
(iv) 

in intensive rearing of polutry or pigs; 
in  the  waste-management  sector,  including 
landfill; 
in the ceramics sector; and  
in the power generation sector. 

The  industrial  sectors  in  Poland  with  the  most  IED 
installations in 2018 were the intensive rearing of poultry 
or pigs (32%), followed by the waste-management sector, 
including landfill (15%), the energy sector (12%)  and the 
food and drink sector (9%). 

76  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). 
77  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). 
78 European Environment Agency, European Industrial Emissions Portal. 
79  Poland  also  reported  around  2  400  non-IED  installations  to  the  EU 
Registry for the year 2018. 

industrial  sectors 

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

(i) 

(ii) 

(iii) 

(iv) 
(v) 

(vi) 

the  energy  sector  for  sulfur  oxides  (SOx), 
nitrogen oxides (NOx), arsenic (As), mercury 
(Hg), nickel (Ni) and zinc (Zn);  
metal  production  sector  for  emissions  of 
heavy metals such as lead (Pb) or cadmium 
(Cd);  
chemicals production for Pb,  Cd,  chromium 
(Cr) and arsenic (As);  
waste management for dioxins;  
coating  and  printing  activities  for  non 
compounds 
methane 
(NMVOCs); and  
intensive  rearing  of  poultry  or  pigs  for 
ammonia (NH3). 

volatile  organic 

The breakdown is shown in Figure 21. 

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

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
 
 
                                                                 
Figure 21: Emissions to air from IED sectors and the rest 
of national total air emissions in Poland, 201881 

breakdown, based on E-PRTR data, is set out in Figure 22 
below. 

Figure 22: Relative releases to water from industry (%) 
in Poland, 201884 

Poland  23 

Poland  is  one  of  the  Member  States  with  the  highest 
damage  costs  associated  with  emissions  to  air.  Three  of 
the 30 E-PRTR facilities with the highest absolute damage 
costs  from  emissions  of  the  main  air  pollutants  and 
greenhouse gases in 2017 were power stations located in 
Poland.  Poland  was  also  the  Member  State  with  the 
fourth  highest  damage  costs  aggregated  over  all 
pollutant  groups  normalised  against  GDP82.  This  should 
be improved by the implementation of the best available 
techniques  (BATs)  associated  emission  levels  for  large 
combustion  plants83.  The  latter  will  –  on  average  and 
depending on the situation of individual plants  – reduce 
emissions  of  sulfur  dioxide  by  25%,  to  81%,  nitrogen 
oxide by 8%, to 56%, dust by 31%, to 78%, and mercury 
by 19%, to 71% at EU level. 

The  environmental  burdens  for  industrial  emissions  to 
water  mainly  result  from  the  treatment  of  waste  water 
for  nitrogen,  phosphorous,  total  organic  carbon  and 
heavy metals. However, no information is available as to 
the  origin  of  this  waste  water.  The  chemical  sector  also 
contributes  to  emissions  of  heavy  metals  and  total 
organic  carbon  while  the  energy  sector  contributes  to 
emissions of polycyclic aromatic hydrocarbon (PAHs). The 

81  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 
82  EEA  (2021).  Costs  of  air  pollution  from  European  industrial  facilities 
2008–2017. Eionet Report - ETC/ATNI 2020/4. The ranking is based on 
the  approach  accounting  for  the  value  of  a  life  year  (VOLY),  table  41, 
p.124 & table 44, p.136. 
83  Commission  Implementing  Decision  (EU)  2017/1442  of  31  July  2017 
establishing  BAT  Conclusions  for  Large  Combustion  Plants,  OJ  L  212, 
17.8.2017 

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers the 
public and NGOs to ensure that permits are appropriately 
granted  and  that  the  conditions  of  these  permits  are 
complied  with.  As  part  of  environmental  inspection, 
IED 
competent  authorities  undertake  site  visits  at 
installations  to  take  samples  and  to  gather  necessary 
information.  According  to  Article 23(4)  of  the  IED,  site 
visits must be carried out between once a year and once 
every  3  years,  depending  on  the  environmental  risks 
posed by the installations. In 2018, Poland undertook 757 
site visits, most of which were to installations for: (i) the 
intensive rearing of poultry or pigs (27%); (ii) the energy 
sector  (16%);  and  (iii)  the  waste  management  sector 
(15%). 

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

 Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
 
 
 
                                                                 
Figure 23: Number of inspections of IED installations in 
Poland in 201885 

2022 priority action 

Poland  24 

 

Continue  reducing  emissions  from  the  energy 
sector. 

Major industrial accidents prevention – 
SEVESO 

The  main  objectives  of  EU  policy  on  major  industrial 
accident prevention 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 the Directive 2012/18/EU 
(the Seveso-III Directive)88. 

The  below  overview  of  industrial  plants  regulated  by 
Seveso-III Directive (‘Seveso establishments’), is based on 
data  reported  to  the  eSPIRS  database  (2018)89  and  the 
Poland  report  on  the  implementation  of  the  Seveso-III 
Directive for 2015-201890. 

In Poland, among the 439 Seveso establishments, 255 are 
categorised  as  lower-tier  establishments  (LTEs)  and  184 
as  upper-tier  establishments  (UTEs),  based  on  the 
quantity  of  hazardous  substances  likely  to  be  present. 
The  UTEs  are  subject  to  more  stringent  requirements. 
Seveso 
The  development  of 
establishments is set out in Figure 24. 

the  number  of 

88  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances 
89 eSPIRS (Seveso Plants Information Retrieval System) 
90 As provided for by Article 21(2) of the Seveso-III Directive 

The  development  of  BATs  reference  documents  (BREFs) 
and BAT conclusions ensures good collaboration between 
stakeholders  and  enables  better  implementation  of  the 
IED 86. Since the last EIR report, the Commission adopted 
BAT conclusions for Poland for: for (i) waste incineration; 
(ii)  the  food,  drink  and  milk  industries;  and  (iii)  surface 
the 
treatment  using  organic 
preservation of wood and wood products with chemicals. 

including 

solvents, 

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

In  2019,  Poland  received  priority  actions  to  review 
permits  and  to  strengthen  control  and  enforcement  to 
ensure compliance with newly adopted BAT conclusions. 
The  Commission  followed  up  on  these  actions  through 
Poland’s  reporting  to  the  EU  registry.  Currently,  the 
Commission 
is  working  with  Poland  to  verify  the 
information reported about the permits granted for each 
installation in the scope of the IED. 

It is worth mentioning that Poland leads the way amoung 
Member  States  in  containing  emissions  of  fluorinated 
greenhouse gases from refrigeration, air conditioning and 
heat  pump  equipment.  Close  monitoring  of  refrigerant 
leakages  done  through  central  electronic  register  of 
equipment operators established in 2016 has allowed for 
reducing the annual emissions of fluorinated greenhouse 
gases  from  that  equipment  from  ca.  12%  in  2016  to  ca. 
3%  in  2020 87.  Consequently,  energy  efficiency  losses  of 
the  equipment,  due  to  insufficient  refrigerant,  could  be 
avoided. 

85 European Environment Agency, EU Registry, European Industrial 
Emissions Portal (data retrieved on 3 November 2021). 
86 European Commission BAT reference documents 
86  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances 
86 European Commission, Seveso Plants Information Retrieval System 
87 ‘Chłodnictwo i Klimatyzacja’, No. 10, 2020. 

 Environmental Implementation Review 2022 – Poland 

 
 
 
                                                                 
 
 
 
                                                                 
Figure 24: Number of Seveso establishments in Poland, 
2011, 2014, and 201891 

Poland  25 

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

Figure 26: Share of UTEs for which information on safety 
measures and requisite behaviours was actively made 
available to the public in Poland, 2011, 2014 and 201893 

Many  Seveso  establishments  are  required  to  draw  up 
external  emergency  plans 
(EEPs).  These  EEPs  are 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  actions  to  protect  the 
environment  and 
the  population  should  a  major 
industrial  accident  occur  at  them.  In  Poland,  an  EEP  is 
required for 141 UTEs. In 2018, 161 UTEs had an EEP and 
all  of  these  EEPs  had  been  tested  within  the  previous  3 
years. The summary is shown in Figure 25. 

Figure 25: Situation regarding EEPs in Poland, 201892 

The information for the public referred to in Annex V of 
the Seveso-III Directive – especially in relation to how the 
public  will  be  alerted  if  there  is  a  major  accident,  the 
appropriate  behaviour  to  take 
is  a  major 
accident,  and  the  date  of  the  last  site  visit  –  are 
the  Seveso 
permanently  available 
establishments  in  Poland.  This  is  an  important  provision 
in  the  Seveso-III  Directive  as  public  knowledge  of  this 
information  may  reduce  the  consequences  of  a  major 
industrial accident.  

for  99%  of 

if  there 

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

2022 priority action 

 

Strengthen  control  and  enforcement  to  ensure 
compliance  with  Seveso-III  Directive  provisions, 
especially on providing information to the public 
and EEP. 

Noise 

The  Environmental  Noise  Directive94  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 
in  this  respect  are  noise  mapping  and 
instruments 
planning.  A  key  target  under  the  2030  zero-pollution 
action  plan  is  to  reduce  by  30%  the  share  of  people 
disturbed by transport noise compared to 2017. 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 
in  the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted  sleep,  cognitive  impairment,  and  stress95. 
Based  on  the  available  data,  the  number  of  people 
exposed  to  noise  in  Poland  reduced  by  27%  between 
2012 and 2017. 

In Poland, based on a limited set of data, environmental 
is  estimated  to  cause  at  least  around  1 000 
noise 

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

93 Idem. 
94 Directive 2002/49/EC 
95 WHO 2018, Environmental noise guidelines for the European region. 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
 
                                                                 
 
 
 
 
                                                                 
premature  deaths  and  3 000  cases  of  ischaemic  heart 
disease  annually 96.  Moreover,  some  270 000  people 
suffer from disturbed sleep. On the basis of the latest full 
set of information that has been analysed, noise mapping 
remains 
roads  and 
of  agglomerations, 
incomplete.  Poland  also  still  lacks  action  plans  for  some 
roads and railways. 

railways 

In  the  2019  EIR,  Poland  received  one  priority  action  to 
complete  noise  action  plans,  where  there  has  been 
limited progress as detailed above. 

2022 priority action 

 

Complete action plans for noise management of 
roads and railways. 

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  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework  Directive  (WFD)  will  ensure  that  EU  citizens 
benefit  from  good quality and safe  drinking and bathing 
water.  It  will  further  ensure  that  the  nutrient  cycle 
(nitrogen  and  phosphorus) 
in  a  more 
sustainable and resource-efficient way. 

is  managed 

Water Framework Directive 

The  Water  Framework  Directive97  is  the  cornerstone  of 
EU water policy in the 21st century98. The WFD along with 
other  water-related  directives99  set  the  framework  for 
sustainable  and  integrated  water  management,  which 
aims  at  a  high  level  of  protection  of  water  resources, 

for 

under 

health 

reported  by  Member 

Pollution; (iii) the methodology 

96  These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based on: (i) the  data 
States 
on noise exposure  covered  by  Directive  2002/49/EC; (ii) ETC/ATNI, 
2021, Noise indicators 
Environmental Noise Directive 
the 
2021: Methodology  for  estimating  missing  data, ETC/ATNI  Report  No 
2021/06, European Topic Centre on Air Pollution, Transport, Noise and 
Industrial 
impact 
calculations, ETC/ACM,  2018,  Implications  of  environmental noise on 
health  and  wellbeing  in  Europe,  Eionet  Report  ETC/ACM  No  2018/10, 
European Topic Centre on Air Pollution and Climate Change Mitigation.  
97 The Water Framework Directive (2000/60/EC). 
98 The EU Water Policy. 
99  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban  Waste  Water  Treatment  Directive  (91/271/EEC),  the  new 
Drinking  Water  Directive  (2020/2184/EC),  the  Nitrates  Directive 
(91/676/EEC),  the  Marine  Strategy  Framework  Directive  (2008/56/EC), 
the 
(2010/75/EU),  and  the  new 
Regulation on minimum requirements for water reuse (2020/741). 

Industrial  Emissions  Directive 

Poland  26 

prevention  of  further  deterioration  and  restoration  to 
good status. 

By March 2022, Member States are required to report on 
the  third  generation  of  river  basin  management  plans 
(RBMPs) under the WFD. Poland has not yet reported it. 
The Commission  will  assess  the  reported  status  and 
progress,  checking  how  the  findings  identified  in  the 
the  second  RBMPs100  have  been 
assessment  of 
addressed. 

which 

report 

Report 101, 

includes  an  assessment  of: 

In  December  2021,  the  Commission  published  the  6th 
Implementation 
assesses 
implementation  of  the  WFD  and  the  Floods  Directive. 
This 
the 
implementation of the programmes of measures; and (ii) 
the  new  priority  substances.  The  assessment  report  for 
Poland 102  showed  that  new  regulations  are  in  progress 
and  that  Poland  has  implemented  some  basic  and 
complementary  measures  to  improve  or  maintain  good 
water status. General progress was visible, but less than 
expected for all Polish river basins. 

(i) 

Based  on  reporting  in  the  second  RBMPs  and  data 
published in 2020103, 31.2% of all surface water bodies104 
in Poland have good ecological status and only 59% have 
(with  14.7%  unknown).  For 
good  chemical  status 
groundwaters,  7.9%  failed  to  achieve  good  chemical 
status and 7.3% are in poor quantitative status. 

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

100  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, as well as in the 2019 EIR. 
101 See the 6th Implementation Report of the WFD and FD. 
102  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Member  States’  progress  in  Programmes  of  Measures 
during  the  second  planning  cycle  of  the  Water  Framework  Directive. 
Member State: Poland, 2022. 
103 WISE Freshwater (europa.eu) 
104 rivers, lakes, transitional, coastal and territorial waters. 

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
                                                                 
Poland  27 

Hg, Ni, Pbb and in Total Organic Carbon, TOC (13.1%) to 
water107. 

Total  water  abstracted  annually  (corresponding  to  2019 
from  surface  and  groundwater 
baseline) 
sources is 9.078.44 hm3  (EEA,  2021).  The  percentage  for 
water abstraction per sector is: 

in Poland 

(i)  11.13% for agriculture; 
(ii)  22.80% for public water supply; 
(iii)  58.09% for electricity cooling; 
(iv)  5.36% for manufacturing; 
(v)  2.08% for manufacturing cooling; 
(vi)  0.53% for mining and quarrying. 

This  breakdown  is  illustrated  in  Figure  29. Poland uses  a 
register to  control  water  abstractions.  The  register  is 
updated yearly. Small abstractions do not require permits 
in Poland and not all are registered. 

Figure 29: Water abstraction per sector in Poland108 

Figure 27: Proportion of surface water bodies (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District105 

Figure  28  presents  the  percentage of surface  water 
bodies in Poland and other European countries failing to 
achieve good chemical status. For Poland the percentage 
is 26.4%, including water bodies failing due to substances 
behaving  as  ubiquitous  persistent,  bio-accumulative, 
toxic  substances  (uPBTs).  Without  uPBTs,  1%  of  surface 
water bodies fail to have good chemical status (with 15% 
unknown). 

Figure 28: Percentage of surface water bodies not 
achieving good chemical status106 

In  Poland,  the  water  exploitation  index  plus  (WEI+)109  is 
that is 
is  well  below 
6.87%,  which 
generally considered an indication of water scarcity110.  

the  20% 

The  bar  chart  below  presents  the  WEI+  index  in  Poland 
and other European countries. Poland is ranked 9th (with 
1st  indicating  a  country  that  has  a  high  WEI+  and 
therefore  a  country  with  water-scarcity  problems)  at  EU 
level on the WEI+. 

Under  the  IED  framework,  it  should  be  stressed  that 
Poland  showed  over  the 
last  decade  a  significant 
decrease  (53%)  in  releases  of  heavy  metals  such  as  Cd, 

105 European Environment Agency, 2021. 
106 European Environment Agency, December 2019. 

107 European Environment Agency, June 2021. 
108  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
109 The Water Exploitation Index plus (WEI+) is a measure of total fresh 
water  use  as  a  percentage  of  the  renewable  fresh  water  resources 
(groundwater and surface water) at a given time and place. It quantifies 
how  much  water  is  abstracted  and  how  much  water  is  returned  after 
use to the environment. 
110  By  May  2022,  EEA  will  develop  seasonal  WEI+  at  river  basin  and 
NUTS2  level,  which  provide  a  more  complete  picture  of  water  stress 
and water scarcity for each Member State. 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
                                                                 
 
 
                                                                 
Figure 30 : Water exploitation index plus (WEI+) inside 
EU, 2017111 

In 

its  work 

Poland,  in  order  to  overcome  water  shortages  and  to 
cope  with  drought  and  climate  change,  has  begun 
drafting a list to introduce solutions which will encourage 
or  necessitate  increased  retention,  both  in  cities  and  in 
to  achieve  Sustainable 
rural  areas. 
Development  Goals 
(SDGs)  with  an  environmental 
dimension, Poland focuses primarily on SDG 6 (increasing 
available water resources), amoung other SDGs. A boost 
implementing  the  environmental  SDGs  was  the 
to 
agreement  on  and  adoption  of  the  2030  national 
environmental  policy,  the  development  strategy  in  the 
area of the environment and water management, setting 
several environmental priorities112. 

Floods Directive 

In  December  2021,  the  Commission  published  the  6th 
includes  the  review  and 
Implementation  Report.  It 
update of the preliminary flood risk assessments (PFRAs) 
during the second cycle (2016-2021). 

information 

The  assessment  report113  found  that  in  Poland  the  main 
PFRAs  should  ensure  that 
is  presented 
clearly  with  a  distinction  made  between  information  on 
the  methodology  used  and  the  summary  data.  Poland 
should give attention to developing trends – e.g. areas in 
which  flood  risk  seems  to  be  decreasing  and  areas  in 
which  it  seems  to  get  worse  over  time  and  why.  The 
areas  of  most  concern  should  be  highlighted,  alongside 
flood  monitoring, 
highlighting  good  practices  on 
reporting,  and  effective  flood  defence  measures,  which 
could  be  applied  elsewhere.  Further  analysis  and 
modelling  is  needed,  especially  for  pluvial  floods  and 

111 EEA, Water exploitation Index Plus, 2022. 
112  Poland  country  profile  -  SDGs  and  the  environment  —  European 
Environment Agency (europa.eu) 
113  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: Poland, 2022. 

Poland  28 

winter floods due to ice accumulation. The description of 
the  international  information  exchange  could  be  more 
specific regarding flood management  and designation of 
the areas of potential significant flood risk (APSFRs). 

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

Drinking Water Directive 

On  the  Drinking  Water  Directive114,  no  new  assessment 
of the quality of drinking water is available since the 2019 
EIR. The quality of drinking water in Poland has not been 
indicated as an area of concern. 

recast  Directive115  entered 

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

into 

Bathing Water Directive 

Regarding  the  Bathing  Water  Directive,  Figure  31  shows 
that in 2020, out of the 602 Polish bathing waters, 22.1% 
were  of  excellent  quality  and  32.1%  were  of  at  least 
sufficient  quality,  while  66.6%  were  not  classified116. 
Detailed information on Polish bathing waters is available 
via  an 
interactive  map  viewer  from  the  European 
Environment Agency. 

114 OJ L 330, 5.12.1998, p. 32-54. 
115 OJ L 435, 23.12.2020, p. 1-62. 
116  European  Environment  Agency,  2021.  State  of  bathing  water  – 
European Environment Agency (europa.eu) 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
                                                                 
 
 
                                                                 
Figure 31: Bathing water quality in Europe in the 2020 
season117 

them.  Nevertheless,  excessive  fertilisation  remains  a 
problem in many parts of the EU. 

Poland  29 

In Poland, the livestock density is close to the EU average 
and  the  net  nitrogen  and  phosphorus  surplus  slightly 
above the EU average. 

There is a well developed network of monitoring stations. 
The  groundwater  quality  is  generally  good,  with  some 
hotspots having a nitrate concentration > 50 mg/l. A very 
high  number  of  surface  waters  have  been  found  to  be 
eutrophic.  Eutrophication  is  affecting  both  inland  and 
marine waters. 

The action programme was revised in 2018. 

Poland  is  one  of  the  Member  States  facing  the  greatest 
challenges in tackling nutrient pollution from agriculture. 

Figure 32: Poland, bathing water quality 2017-2020118 

Urban Waste Water Treatment Directive 

Poland  has,  over  the  years,  encountered  difficulties  in 
meeting  its  obligations  under  the  Urban  Waste  Water 
Treatment  Directive  (UWWTD).  According  to  the  last 
available  data 121,  the  compliance  rate  in  Poland  is  87%, 
which  is  higher  than  the  EU  average  of  76%  in  2018. 
However,  regarding  the  amount  of  urban  wastewater 
which  still needs to be collected or treated according to 
the  requirements  of  the  UWWTD,  further  efforts  are 
needed to provide:  

(i) 

 collection of additional 0.12 million p.e of urban 
waste water (0.3%); 

(ii)  biological treatment of an additional 0.45 million 

p.e. of urban waste water (1.2%); and 

(iii)  biological 

treatment  with  nitrogen 

and 
phosphorus  removal  of  an  additional  1.31 
million p.e. of urban waste water (4.0%). 

Nitrates Directive 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive 119,  covering  2016-2019120,  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  eutrophication.  Where  national  authorities  and 
farmers  have  cleaned  up  waters,  it  has  had  a  positive 
impact on drinking water supply and biodiversity, and on 
the sectors such as fisheries and tourism that depend on 

117 European Environment Agency, Bathing Water Quality in 2020, 2022. 
118  European  Environment  Agency,  European  Bathing  Water  Quality 
in 2017, 2018, 2019, 2020. 
119 Implementation of the Nitrates Directive in the EU. 
120 Last implementation report 2016-2019 

All  Polish  agglomerations  should  have  been  compliant 
with  the  UWWTD  requirements  by  31 December 2015, 
according to the agreements under the [2003] Accession 
Treaty.    Yet,  to  date,  1 123  agglomerations  still  do  not 
have  a  compliant  collecting  system  for  urban  waste 
water.  Moreover,  in  1 232  agglomerations,  the  urban 
wastewater entering collecting systems is not  subject  to 
appropriate  treatment  before  being  discharged.  Finally, 
in  415  agglomerations,  Poland  has  not  ensured  that 
urban  waste  water,  entering  collecting  systems  and 
discharged 
is  subject  to  more 
stringent  treatment.  Despite  some  progress  and  EU 
financial  support  from  cohesion  policy  funds,  the 
Commission  has  concluded  that  the  authorities  have 
failed to prove compliance for these agglomerations. 

into  sensitive  areas, 

121 WISE – Country profiles on urban water treatment - Poland  

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
                                                                 
 
                                                                 
Figure 33: Proportion of urban waste water that meets 
all requirements of the UWWTD (collection, biological 
treatment, biological treatment with nitrogen and/or 
phosphorus removal) in compliant urban areas of the 
UWWTD (‘compliance rate’) (%), 2018 122 

Poland  30 

effects  on  human  health  and  the  environment.  In 
October 2020,  the  Commission published  its  chemicals 
strategy  for  sustainability  – 
‘Towards  a  Toxic-Free 
Environment’123,  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. 

legislation124 provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the single market. 

collection 

the  Directive’s 

Despite  the  improvement  in  compliance  over  recent 
years, more than 1 000 agglomerations still fail to comply 
treatment 
with 
requirements. In the reasoned opinion sent in May 2020, 
the Commission urged Poland to ensure that urban waste 
water is adequately collected and treated, as required by 
Directive  91/271/EEC.  Should  Poland 
fail  to  take 
appropriate action, the Commission may decide to refer 
the matter to the Court of Justice. 

and 

2022 priority actions 

 

 

 

 

 

Poland  should  asses  new  physical  changes  to 
water bodies in line with Article 4(7) of the WFD 
the  consider  alternative  options  and 
and 
suitable mitigation measures; 
Continue  current  efforts  to  further  reduce 
pollution from water bodies; 
improve 
should 
Poland 
implementation of water and nature policies; 
Complete  implementation  of  the  Urban  Waste 
Water 
all 
agglomerations,  by  building  up  the  necessary 
infrastructure; 
Strengthen  the  action  programme  to  tackle  the 
eutrophication issues for both inland and marine 
waters  for  which  the  agriculture  pressure  is 
significant. 

coordinated 

Treatment 

Directive 

the 

for 

to 

the 

Since 2007, the Commission has gathered information on 
the  enforcement  of  the  Regulation  on  the  Registration, 
Evaluation,  Authorisation  and  Restriction  of  Chemicals 
the  Regulation  on 
(‘the  REACH  Regulation’)  and 
Classification, Labelling and Packaging (‘CLP Regulation’). 
In  December  2020,  the  Commission  assessed  the 
Member  States’  reports  on  the  implementation  and 
enforcement  of  these  Regulations125,  in  line  with  REACH 
Article 117(1)  and  Article 46(2)  of  the  CLP  Regulation. 
According 
latest  available  data,  national 
enforcement structures have not changed significantly in 
recent  years.  However,  it  is  apparent  from  this  report 
that 
the 
implementation  of  the  REACH  and  CLP  Regulations,  and 
notably 
law  enforcement.  Recorded 
compliance  levels  in  Member  States  appear  relatively 
stable over time, but with a slight worsening trend, which 
is  likely  due  to:  (i)  enforcement  authorities  becoming 
detecting 
more 
non-compliant 
effective 
(ii)  more  non-compliant 
products/companies;  and 
products being put on the EU market.  

still  many  disparities 

in  the  area  of 

there 

are 

in 

in 

In August 2021, the Commission published a measurable 
assessment  of  the  enforcement 126  of  the  two  main  EU 
the  CLP 
Regulations 
(the  REACH  Regulation  and 
Regulation)  on  chemicals  using  a  set  of 
indicators 
covering different aspects of enforcement.   

Responsibility  for  checking  compliance  with  REACH  in 
Poland lies with the following authorities127: 

 

 

State 

The 
Sanitary 
enforcement authority). 
Inspectorate of Environmental Protection 

Inspectorate 

(lead 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 

122 European Commission, WISE Freshwater, 2021. 

123 COM(2020) 667 final 
124 REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 
125 European Commission, Final  report  on the operation of REACH and 
CLP 2020. 
126  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 
127  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
                                                                 
                                                                 
Poland  31 

 

administrative  capacities  to  support  a  zero 
tolerance approach to non-compliance; 
Poland 
implement 
invited  to  devise  and 
strategies  to  enforce  the  REACH  and  CLP 
Regulations. 

is 

 
 
 
 

The State Labour Inspectorate 
Trade Inspection 
State Fire Service 
Customs 

Poland  has  not  devised  and  doesn’t  plan  to  devise  any 
strategy  for  the  enforcement  of  REACH  and  CLP 
regulations128. 

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. 

Poland’s report required under Article 117 of the REACH 
Regulation and Article 46 of the CLP Regulation contains 
no  data  about  staff  members  allocated  or  controls 
carried out in the reporting period (2015-2019)129. 

Figure 34: Percentage of non-compliance cases out of 
the total number of REACH and CLP controls in 2019 per 
Member State and compared to the EU average130 

2022 priority actions 

  Upgrade 

implementation  and  enforcement 

128 European Commission, Final  report  on the operation of  REACH and 
CLP 2020, p. 76. 
129 European Commission, Final  report  on the operation of REACH and 
CLP 2020, p. 87-88.  
130 European Commission, Final  report  on the operation of REACH and 
CLP 2020, pp.87-88. 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
                                                                 
 
Poland  32 

4. Climate action 

sustainable 

ensure 
effective 
functioning of the economy and society in the conditions 
of climate change. 

development 

and 

Poland  has  made  limited  progress  over  the  past  2 
decades  in  decarbonising  its  economy.  Compared  to 
1990,  the  country’s  total  emissions  in  2020  were  21% 
lower (see Figure 35). 

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

Effort sharing target 

For emissions not covered by the  EU’s emissions trading 
scheme  (ETS),  Member  States  have  binding  national 
targets  under  the  Effort  Sharing  legislation.  Under  EU 
legislation, Poland has targets of: (i) limiting the increase 
of  greenhouse  gas  emissions  in  the  non-ETS  sectors 
(buildings,  road  and  domestic  maritime  transport, 
agriculture, waste and small industries) to +14% by 2020; 
and  (ii)  reduce  emissions  by  7%  by  2030  compared  to 
2005  levels.  The  country’s  non-ETS  emissions  in  2019 
were very close to its 2020 target. In its  national energy 
and climate plan, Poland intends to implement additional 
measures to achieve non-ETS emissions reductions in line 
with  its  current  non-ETS  emission  reduction  target  for 
2030 of -7% (see Figure 36). 

to 

(NDC) 

The  EU  and  its  Member  States  submitted  updated 
Nationally  Determined  Contribution 
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  2010131  and  sets  binding  GHG  emission 
standards for different vehicle categories132.  
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From  2021,  emissions  and  removals  of  GHGs  from 
LULUCF have been included in the EU emission-reduction 
efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
required 
their  national  adaptation 
policies133,  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. 

report  on 

to 

Key national climate policies and strategies 

In 2019, Poland submitted its integrated national energy 
and  climate  plan  (NECP)  for  2021-2030.  In  2021,  Poland 
adopted  its  national  energy  strategy  looking  ahead  to 
2040. It provides an indicative target of a 30% reduction 
in  total  greenhouse  gas  emissions  by  2030  compared  to 
1990. 

In its recovery and resilience plan (RRP), Poland allocates 
nearly  42.7%  of  the  plan  to  meeting  climate  objectives 
and  outlines  crucial  reforms  and  investments  to  further 
the green transition. 

Poland published its  first  national  adaptation  strategy in 
2013. The 2020 strategic adaptation plan’s main goal is to 

131  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. 
132 Directive 98/70/EC. 
133 Article 29 of Regulation (EU) 2018/1999. 

 Environmental Implementation Review 2022 – Poland 

 
                                                                 
 
 
Figure 36: Emissions and targets under the effort 
sharing decision/ effort sharing regulation in Poland, 
2020 and 2030 as percentage change from 2005 

Poland  33 

alternative  fuels,  including  hydrogen;  and  (iii)  advance 
the development of batteries.  

On  buildings,  the  national  energy  and  climate  plan 
outlines  a  number  of  actions,  with  a  quantitative 
objective  to  increase  the  share  of  thermally  insulated 
residential  buildings  to  70%  in  2030  (compared  with 
58.8%  in  2015).  It  also  aims  to  decrease  the  number  of 
to 
people 
overpopulation,  poor  technical  condition  or  absence  of 
technical facilities to 3.3 million in 2030 (from 5 360 000 
in  2011).  Poland  submitted  its  long  term  renovation 
strategy to the Commission in February 2022. 

in  sub-standard  conditions  due 

living 

On agriculture, the sector is still not structurally on a low-
carbon  pathway.  Non-CO2  greenhouse  gas  emissions, 
such  as  methane  emissions  from  livestock,  continue  to 
stagnate rather than decrease. 

Figure 38 shows GHG emissions by sector. 

Figure 37: Emissions, annual emission allocations (AEAs) 
and accumulated surplus/deficit of AEAs under the 
effort sharing decision in Poland, 2013-2020 

Figure 38: Greenhouse gas emissions by sector in 
Poland134 – historical emissions 1990-2019, projections 
2021-2030135 

Key sectoral developments 

On  road  transport,  the  GHG  intensity  of  vehicle  fuels  in 
Poland decreased by 4.2% between 2010 and 2019.  The 
country needs to act swiftly to meet the current EU-wide 
target  of  a  6%  reduction.  To  meet  this  target,  Member 
States  can,  for  example:  (i)  further  expand  the  use  of 
electricity  in  road  transport;  (ii)  support  the  use  of 
biofuels,  advanced  biofuels  in  particular;  (iii)  incentivise 
the  development  and  deployment  of  renewable  fuels  of 
non-biological origin; and (iv) reduce upstream emissions 
before refining processes. 

Road  transport  represented  16%  of  Poland’s  total  GHG 
emissions  in  2019.  Sectoral  emissions  have  increased  by 
89% compared to 2005. Poland intends to: (i) accelerate 
its electrification of transport, including by expanding the 
the  use  of 
charging 

infrastructure; 

(ii)  promote 

In the LULUCF sector, Poland expects a  further decrease 
of  net  removals  by  2030.  Quantities  reported  under  the 
Kyoto Protocol for the LULUCF sector in Poland show net 
removals  of,  on  average,  34.6  Mt  CO2-eq  for  the  period 
2013  to  2019.  In  this  regard,  Poland  contributes  10%  of 
the annual EU-27 average sink  of  -344.9 Mt  CO2-eq (see 
Figure  39).  Accounting  for  the  same  period  depicts  net 

134  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. 
135 European Environmental Agency, Total GHG trends and projections. 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
 
 
                                                                 
-7.5  Mt  CO2-eq,  which 
credits  of,  on  average, 
corresponds  to  6.5%  of  the  EU-27  accounted  sink  of  -
115.0 Mt  CO2-eq. Reported net  removals and accounted 
net credits decreased between 2013 and 2015, increased 
until 2018 and  sharply dropped in 2019, resulting in net 
debits  for  that  year.  Poland  is  one  of  14  EU  Member 
States  that  show  net  debits  for  at  least  one  year  in  this 
preliminary accounting period. 

Figure 39: Reported and accounted emissions and 
removals from LULUCF in Poland (Mt CO2-eq.)136 

Poland  34 

necessary given the ageing infrastructure. 

  Seize  the  potential  for  onshore  and  offshore  wind 

 

power development. 
Introduce  measures  to 
increase  energy  system 
gas 
integration 
consumption, including by developing the market for 
storage technologies and clean hydrogen. 

the  decarbonisation  of 

and 

in  particular 

  Deploy  zero  emission  transport  or 

low-emission 
zero-emissions  public 
transport, 
transport 
improve  charging 
infrastructure.  Improve  access  to  public  transport 
between cities, towns, and rural areas. 

larger  cities,  and 

in 

  Continue  developing  green  sectors  of  the  economy 
and  creating  new  high-skilled  jobs  by 
increasing 
research and innovation. Between 2014 and 2018, the 
number of green jobs in Poland increased by 20%. 

Use of revenues from the auctioning of EU ETS 
allowances 

The  total  revenues  from  auctioning  emission  allowances 
under the EU ETS over 2012-2021 were EUR 13.6 billion.  
In Poland, revenues are not earmarked, example projects 
have  been  reported  for  around  50%  of  revenues  to 
specific projects funded in relation to climate and energy 
purposes. 

2022 priority actions 

  Continue a just transition for coal mining regions and 
decarbonisation  of  the  energy  mix.  Poland  remains 
highly  dependent  on  coal  and  lignite  and  the  phase-
out  of  coal-fired  generation  poses  a  significant 
challenge.  Investment  in  the  energy  sector  is  also 

136  The  differences  between  reported  and  accounted  emissions  from 
LULUCF under the Kyoto Protocol are described in the ‘explanatory note 
on  LULUCF  –  accounted  and  reported  quantities  under  the  Kyoto 
Protocol’.   

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
                                                                 
Poland  35 

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 gaps. 
Post-2020,  environmental  measures  will  also  be 
supported by the EU’s  COVID-19 Recovery  Fund (via  the 
Recovery  and  Resilience  Facility)  and  the 
‘do  no 
significant  harm’’  principle  across  the  EU  budget.  The 
renewed  commitments  made  at  COP26 
(Glasgow, 
Biodiversity 
October-November 2021), 
Convention  COP15  (April-May  2022)137  will  also  be 
reflected in the EU budget. 

and 

the 

Overall environmental investment gaps (EU-27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  baselines  (i.e.  the  gap  between  what  is 
needed  and  what  is  forecast  to  be  invested  if  no 
additional  action 
is  taken)  for  climate,  energy  and 
transport  were  estimated  at  EUR 390  billion  a  year  (EU-
27)138,  with  further  EUR 130  billion  a  year  to  deliver  the 
EU’s  core  environmental  objectives139.  The  costs  of 
climate-change  adaptation  can  also  be  significant,  and 
are  estimated  to  reach  a  total  of  EUR 35-62  billion 
(narrower  scope)  or  EUR 158-518  billion  (wider  scope) 
per  year140.  Those 
the 
implementation  objectives  to  2020  and  to  2030  (except 
for  climate-change  adaptation,  the  costs  of  which  are 
expected to last over a longer time horizon). 

investment  needs 

reflect 

A  preliminary  update  of  the  EU’s  core  environmental 
investment gap is provided in the Table 1141.  Almost 40% 
of the environmental-investment needs relate to dealing 
with  pollution,  which  accounts  for  over  70%  of  the 
investment gap  combined with water management. The 
investment  gap 
is 
estimated  between  EUR  13-28  billion  a  year,  depending 

in  circular  economy  and  waste 

levels  of  circularity 

on 
implemented.  The  annual 
biodiversity financing gap is estimated  at around EUR 20 
billion. 

Table 1: Estimated breakdown of the EU’s 
environmental investment gaps, by environmental 
objective, 2021-2030 (per year)142 

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

Environmental 
objective 

Pollution  prevention 
& control 

Water  management 
& industries 

Circular  economy  & 
waste 

 EUR billion 

 42.8 

 26.6 

 13.0 

Biodiversity 
ecosystems 143 

& 

 21.5 

R & D & I and other 

Total 

 6.2 

 110.1 

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Environmental-investment needs in Poland  

There  has  been  a  clear  shift  of  investment  priorities  in 
for  climate,  energy,  and 
Poland  towards  support 
transport  policies,  as  seen  in  the  RRP.  An  estimated 
EUR 15.1  billion  will  be  spent  under  the  Recovery  and 
Resilience Fund on investments covering a wide range of 
economic activities, such as: 

 
 

 

offshore wind energy production; 
energy  renovation  of  housing  combined  with 
removing coal-fired heaters; 
hydrogen technologies; 

 Post-2020  Global 

137  The  Convention  on  Biological  Diversity, 
Biodiversity Framework. 
138  SWD(2021)621,  accompanying  proposal  COM(2021) 557  to  amend 
the REDII Directive (EU) 2018/2001. 
139 SWD(2020) 98 final/2. 
140  SWD(2018)292.  Impact  assessment  accompanying  the  Proposal  for 
the LIFE Regulation (COM(2018) 385). 
141 With decreases due to  Brexit and consolidation of some objectives. 
Source: DG ENV ”Study supporting EU green investment needs analysis” 
(ongoing,  2021-2023)  and  DG  ENV  internal  analysis  ”Environmental 
investment needs and financing in the EU’s green transition” July 2020. 

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

Environmental Implementation Review 2022 – Poland 

 
                                                                 
 
 
 
                                                                 
 
 
 

clean urban projects; 
sustainable water management in rural areas; 
and sustainable transport. 

Pollution prevention & control 

The  EU’s  first  Clean-Air  Outlook144  under  the  clean-air 
programme estimated that the total air pollution control 
costs  for  Poland  to  reach  the  NECD  emission  reduction 
requirements  (ERRs)145  by  2030  amount  to  EUR 8 016 
million  per  year.  This  includes  EUR 6 019  million  for 
capital  investment  (assuming  the  achievement  of  the 
2030 climate and energy targets). 

The  second  Clean-Air  Outlook146 suggests  that  the 
EU would  largely  achieve  the  reductions  of  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NEC  Directive  for  2030  if:  (i)  all  relevant  legislation 
adopted  up  to  2018  is  implemented  (including  all  air 
pollution and the 2030 climate and energy targets set in 
2018);  and  (ii)  Member  States  also  implemented  the 
measures  announced  in  their  NAPCPs.  However,  this 
excludes  ammonia  (NH3)  levels  in  15  Member  States, 
including Poland. 

Water management  

and 

groundwater) 

non-conventional 

According  to  the  OECD  study  ‘Financing  a  Water  Secure 
Future’ (2022)147, Poland relies on a  mix of conventional 
(e.g. 
(e.g. 
desalination)  resources  for  its  water  supply.  EU  funding 
has  provided  a  significant  share  of  public  funding  over 
the  past  decade148.  By  2030,  the  cumulative  additional 
investment  need  for  Poland  was  estimated  at  EUR  11.4 
billion  (around  EUR  1.14  billion  per  year)  over  baseline 
levels,  around  88%  of  which  related  to  wastewater149.  
Moreover, the recent 6th Water Framework Directive and 
Implementation  Report150  and  the 
Floods  Directive 

144 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU’s  air  quality  and  emissions 
objectives, 2018. 
145 
Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Source:  Progress  towards  the  achievement  of  the 
EU’s  air  quality  and  emissions  objectives,  IIASA  2018.  (page  29). 
Requirements are based on Directive (EU) 2016/2284. 
146  COM(2021)  3  final.  International  Institute  for  Applied  Systems 
Analysis (IIASA), Support to the development of the  
second Clean Air Outlook, 2020 and Annex. 
147 OECD, Financing a Water Secure Future, 2022. 
148 OECD, Financing a Water Secure Future, 2022. 
149  OECD,  Poland  -  Country  fact  sheet  -  Financing  Water  Supply, 
Sanitation and Flood Protection   
150 WFD and FD Implementation Reports – DG Environment – European 
Commission. 

Poland  36 

financial-economic  study151  accompanying  it,  are  also  a 
relevant source of information in this regard. 

Waste & the circular economy 

According to a Commission study152, in order to meet the 
recycling  targets  for  municipal  waste  and  packaging 
waste, Poland still needs to invest an additional EUR 1.55 
billion  (around  EUR 221.7  million  per  year)  between 
2021-2027 over baselines in: 

(i)  collection; 
(ii)  recycling reprocessors; 
(iii)  biowaste treatment; 
(iv)  waste sorting facilities; and 
(v)  waste registry digitalisation. 

This does not include the investment necessary for other 
key  waste  streams  (plastics,  textile,  furniture)  or  to 
unlock higher uptake of circularity and waste prevention 
across the economy. 

Biodiversity & ecosystems 

The  recently  submitted  prioritised  action  framework 
(PAF)  for  Poland  shows  that  nature  protection  costs 
(including  Natura  2000)  in  2021-27  amount  to  EUR 4.51 
billion  – or around EUR 644.2 million per  year (including 
EUR 188  million  one-off  costs)153.  This  does  not  cover 
additional costs to implement the biodiversity strategy to 
2030, including costs relating to increased protection and 
restoration. 

EU environmental funding 2014-2020 

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

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

152  European  Commision,  Study  on  investment  needs  in  the  waste 
sector and on the financing of municipal waste management in Member 
States, 2019. 
153  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
improving  synergies  with  EU  funding 
instruments  report  to  the 
European Commission, 2021 
154 Council Regulation (EU, Euratom) No 1311/2013. 
155  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
 
 
 
                                                                 
 
MFF  budget  was  subsequently  topped  up  with  over 
EUR 50  billion  (in  current  prices)  from  the  REACT-EU 
programme    for  cohesion-policy  action  against  COVID-
19156. 

Poland received EUR 90.8 billion from the ESI Funds over 
2014-2020 to invest in job creation and a sustainable and 
healthy  economy  and  environment.  Planned  direct 
environmental  investment  accounted  for  nearly  EUR 6 
billion, with a further EUR 7.1 billion identified as indirect 
environmental 
investment  value,  totalling  EUR 13.1 
billion.  Figure  40  shows  an  overview  of  (planned) 
individual  ESI  Funds  financing  earmarked  for  Poland  (EU 
amounts, without national amounts). 

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

concerns 
(EU) 

the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI),  the  European  Agricultural  Fund  for  Rural  Development  (EAFRD) 
and the European Maritime and Fisheries Fund (EMFF). 
156 Regulation (EU) 2020/2221 
157  European  Commission,  DG  Environment  analysis  based  on 
ESI Funds Open Data Portal (cohesiondata.ec.europa.eu), Integration of 
(COWI, 
environmental 
2017), Regulation 
(EU) 
2021/1060 and Implementing  Regulation  (EU)  No  215/2014. Cut-off 
date  for  data:  December  2021.  Environmental  investments  here  are 
captured  via  the  combined  use of  intervention  fields  and  coefficients 
under 
(EU) 
2021/1060  allowing for  a  more  precise  identification  and  valuation  of 
Indirect  environmental 
relevant environmental investments.  N.B. 
investments are valued using the Annex I environmental coefficients of 
the Regulation (EU) 2021/1060 (as opposed to full value). 

Funds 
1303/2013,Regulation 

(EU)  No  1303/2013 and Regulation 

in  Cohesion  Policy 

the Regulation 

No 

Poland  37 

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

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 energy 159 
sustainable transport 
sustainable tourism 
business development, R&I 

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

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

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

Allocations  
for the environment  
(EUR million) 

12 726.6 
5 606.3 
2 779.4 
532.8 
441.4 
516.9 
271.3 
1 064.6 
7 120.3 
482.0 
1 089.4 
295.4 
4 960.7 
61.6 
231.3 

252.5 
252.5 
252.5 

131.6 
122.3 
122.3 

9.3 
9.3 

13 110.7 
5 981.1 
7 129.6 

Funding for the environment from the ESI Funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States  such  as  the  LIFE 
programme,  Horizon  2020,  or  loans  from  the  European 
Investment  Bank  (EIB),  which  add  up  to  an  estimated 
total  of  EUR  13.4  billion  of  EU  environmental  financing 
for Poland in 2014-2020.  

The  LIFE  programme160 
to 
environmental  and  climate  objectives.  It  finances  pilot 

is  entirely  dedicated 

investments 

in 
tracking 

identified  here 
the 
from 

158  European  Commission,  DG  Environment  -  Data analysis. The  values 
the  specific 
of  environmental 
environmental  areas  may  differ 
values 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity due  to 
two factors: the set of environmental coefficients used and the range of 
funds assessed. DG Environment’s analysis here  covered the full range 
of ESI Funds. See also the footnote for the table “ESI Funds allocated to 
Poland, including environmental investments, 2014-2020”. 
159  Intelligent  energy  distribution  systems  (smart  grids)  and  high 
efficiency co-generation and district heating, based on intervention field 
53  and  54  respectively  (with  40%  environmental  coefficients)  of 
REGULATION (EU) 2021/1060, Annex I. 

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                                                        
  
 
 
                                                                 
and  best  practice  actions  for  green  solutions  to  be 
deployed. In 2014-2020, Poland received EU support  for 
13  LIFE  projects  (for  nature  and  the  environment)  with 
EUR 42.7 million from the LIFE programme (out of 1 028 
EU-27  LIFE  projects,  with  a  total  EU  contribution  of 
EUR 1.74 billion)161. 

In  2014-2020,  Horizon  2020  allocated  about  EUR 22.8 
million for Poland, in particular, for the circular economy, 
including  raw  materials,  nature  and  resources,  climate 
action  and  water).  This  is  about  3.1%  of  Poland’s  total 
allocation162.  From  the  European  Fund  for  Strategic 
Investments (EFSI), Poland received EUR 203.9 million for 
direct environmental investments and EUR 30 million for 
indirect  environmental 
to 
EUR 233.9  million)  out  of  its  total  allocation  (EUR 3.3 
billion) 163. Poland received EUR 41.8 million from the EIB 
for  direct  environmental  investments  (specifically,  for 
water  and  sewerage,  and  waste)  out  of  the  total  EIB 
loans  for  Poland  (EUR 33.1  billion)164.  The  country  ranks 
5th in size in total EIB lending. 

investments 

(amounting 

In  2020,  the  EIB  provided  EUR 24.2  billion  in  funding 
across  Europe  to  fight  climate  change,  37%  of  its  total 
financing.  It  also  provided  EUR 1.8  billion  (3%  of  its 
financing) for broader environment lending165 166. 

EU environmental funding 2021-2027 

the 

EU’s 

The 2020 European Green Deal investment plan calls  for 
EUR 1 trillion in green investments (public and private) by 
2030.  The  2021-2027  MFF  and  the  NextGenerationEU 
spending  programme  will  mobilise  EUR 2.018  trillion  (in 
current  prices)  to  support  the  recovery  from  COVID-19 
and 
including 
environmental  protection167.  Following  the  EU  Green 
Deal’s168 pledge to ‘do no harm’ and the Interinstitutional 
Agreement  on  the  2021-2027  MFF169,  30%  of  the  EU 
budget  in  2021-2027  will  support  climate  efforts,  while 
biodiversity will receive 7.5% of the EU budget as of 2024 
and  10%  as  of  2026.  Therefore,  increased  programming 
of  financial  resources  for  biodiversity  is  required  under 

long-term 

priorities, 

several  programs 

160 European Commission, LIFE Programme. 
161 Source: CINEA. 
162 Source: EASME, accessed: 15-12-2021. 
163:Approved and signed EFSI financing - EIB, 2015-2020. 
164 EIB loans in EU countries in 2014-2020: EIB Open Data Portall 
165  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing 
environmental 
implementation: InvestEU,  the  successor  of  EFSI,  Pillar  II  and III  of  the 
Just Transition Mechanism. The EIB Group stands as a key implementing 
partner for InvestEU with responsibility for managing 75% of the overall 
budgetary capacity of the mandate. 
166 EIB 2021 Activity Report 
167  European  Commission,  2021-2027 
NextGenerationEU. 
168 COM/2019/640 final 
169 Interinstitutional Agreement, OJ L 433I 

long-term  EU  budget  & 

finance 

that 

Poland  38 

the 2021-2027 cohesion policy and the 2023-2027 CAP to 
reach those targets. 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  taxonomy)170. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bond  (by  the  EU  green  bond  standard)171.  
Reinforced  by  the  renewed  sustainable  finance  strategy 
(2020)172,  sustainable  finance  will  increase  investment 
flows  to  climate  and  environment.  The  new  strategy  on 
adaptation  to  climate  change173  can  help  to  close  the 
insurance-protection  gap,  which  currently  leaves  many 
risks  from  climate-related  events  uninsured174.  The  EIB 
will  align  50%  of 
lending  with  climate  and 
environmental  objectives  by  2025175  with  a  EUR 250 
billion contribution to the Green Deal investment plan by 
2027. 

its 

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

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

Instrument 

Country funding allocation (million 
EUR) 

Cohesion policy 

Total: 72 180.4 176 

ERDF 

CF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

47 416.7   

9 283.1 177 

14 913.0 

567.6 178 

3 847.4 179 

for  European 

170 EU taxonomy for sustainable activities 
171 EU Green Bond Standard - 2021/0191 (COD). 
172 COM(2021) 390 final – European Commission, Strategy for Financing 
the Transition to a Sustainable Economy. 
173 COM(2021) 82 final 
174  The  strategy  would  support  improved  insurance  gap  coverage, 
including through the natural catastrophe markets as reflected with the 
Insurance  and  Occupational  Pension 
Association 
Authorities (EIOPA) dashboard on insurance protection gap for natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
175 EIB Climate Bank roadmap 2021-2025, November 2020. 
176  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
177  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is  not 
included. 
178  Interreg  initial  allocations  per  MS  including  ETC  transnational  and 
ETC cross-border co-operation.  
179  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 

 Environmental Implementation Review 2022 – Poland 

 
                                                                                                        
 
                                                                 
Figure 41: Climate expenditure in RRP , 2021-2026185  

6 600.0 181 

(Without HU, NL, PL data) 

Poland  39 

512.4 182 

23 858  (grants) 

12 112 (loans) 184  

EAFRD/rural 
development  

under  CAP  Strategic 
Plans 2023-2027180 

European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

Recovery 
and 
Resilience Facility (RRF)  

2021 – 2026183  

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

Poland’s  RRP  has  been  submitted,  but  has  not  yet  been 
approved. 

According to preliminary data, Poland’s  RRP responds to 
the urgent  need to support  a strong recovery and make 
the  country  ready  for  the  future.  The  reforms  and 
investments  in  the  plan  will  help  Poland  become  more 
sustainable,  resilient,  and better  prepared 
the 
challenges  and  opportunities  of  the  green  and  digital 
transitions.  To  this  end,  the  plan  comprises 
five 
components with the overarching objectives of: 

for 

(i) 

increasing 
productivity; 

economic 

development 

and 

(ii)  supporting the digital and green transitions; 
(iii)  and improving the quality of life. 

requested  EUR 23.86  billion 

in  grants. An 
Poland 
estimated  42.7% of  the  plan  will  support climate-related 
objectives  (see  Figure  41),  which  exceeds  the RRF’s 37% 
climate target. In terms of the green transition, the plan 
its  climate  pledge  by  supporting  major 
reflects 
investments directed towards: 

(i)  developing  offshore  wind  energy  in  the  Baltic 

Sea; 

(ii)  the  renovation  of  buildings,  combined  with 

removing coal-fired heaters; 

(iii)  developing  hydrogen  technologies  and  clean 

urban projects; 

(iv)  sustainable water management in rural areas;  
(v)  sustainable public transport. 

180 European Commission, CAP strategic plans.  
181 Regulation (EU) 2021/2115, Annex XI.  
182 Regulation (EU) 2021/1139, Annex V. 
183  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented until 31 December 2026.   
184 Draft NRRP. 

Under  NextGenerationEU,  the  Commission  will  issue  up 
to  EUR  250  billion  of  EU  green  bonds  (one  third  of  the 
NGEU  amount)  until  2026.  The  bonds  will  comply  with 
the  general  spirit  of  the  DNSH  principle,  but  will  not  be 
subject  to  the  currently  developed  Delegated  Acts 
related to the EU Taxonomy and will not fully  align with 
the proposed EU Green Bond Standard. 

(EUR 5.4  billion),  Horizon 

In addition to EU funds earmarked specifically for Poland 
in  the  2021-2027,  there  are  also  funding  programmes 
that  can  been  accessed  at  the  EU  level  and  which  are 
open  to  all  Member  States.  These  include  the  LIFE 
programme186 
Europe 
(EUR 95.5  billion)187,  the  Connecting  Europe  Facility188 
(EUR 33.7 billion)189 or the funds to be mobilised via the 
InvestEU190  programme.  These  other  sources  of  funding 
will also support the green transition, including research 
and  innovation  activities  for  environmental  protection 
(Horizon  Europe)191,  clean  transport  and  energy  (the 

185 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
186 European Commission, LIFE Programme. 
187  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
188  The  CEF  (Transport)  includes  also  EUR 11.3  billion  transferred  from 
the  Cohesion  Fund.  30%  of  the  transferred  amount  will  be  made 
available,  on a competitive  basis,  to  all  Member  States eligible  for  the 
Cohesion Fund. The remaining 70% will respect the national envelopes 
until  31 December  2023.  Any  unspent  amount,  by  that  date,  under 
national envelopes will support all Cohesion Fund Member States. 
189 Regulation (EU) 2021/1153 
190  The  InvestEU  Fund  is  expected  to  mobilise  over  EUR 372  billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to back 
investment by financial partners such as the European Investment Bank 
(EIB) Group and others. 
191 European Commission, Horizon Europe. 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
                                                                 
 
 
                                                                 
Connecting 
infrastructure (InvestEU)193. 

Europe 

Facility)192 

and 

sustainable 

Figure 42: Environmental protection investments in the 
EU-27 (EUR million and % of GDP), 2018195 

Poland  40 

National expenditure on environmental 
protection  

Total  national  expenditure  on  environmental  protection 
(including all relevant current and capital expenditure)194 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2%  of  EU-27  GDP.  This  percentage  has  remained 
relatively stable over time. Although the largest absolute 
amounts  of  expenditure  are  concentrated  in  a  few 
countries, most countries spend between 1-2%, including 
Poland spending 1.9% on environmental expenditure. 

Of  this  spending,  the  EU-27’s  capital  expenditure  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR 56.3  billion  in  2018,  falling  to  EUR 54.5  billion  in 
2020,  representing  around  0.4%  of  EU-27  GDP.  Most 
in 
Member  States 
environmental protection; Poland dedicated 0.5%. During 
2014-2020,  this  totalled  around  EUR 376  billion  of 
environmental  investment  in  the  EU-27,  and  EUR 17.6 
million for Poland. 

invested  0.2-0.5%  of  their  GDP 

protection 

investments 

institutional  sector,  around  46%  of  Poland’s 
By 
environmental 
(capital 
expenditure)  came  from  general  government,  a  further 
21%  came  from  specialist  producers  of  environmental 
protection  services  (e.g.  waste  and  water  companies), 
and 33% from the traditional industry (or business) sector 
that  normally  pursues  environmental  activities  as 
ancillary to their main activities. At EU level, 37% comes 
from  governments,  33%  from  specialist  producers  and 
30% from industry (business). 

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

195 Eurostat, Environmental Protection Expenditure Account, 2021. 

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
 
 
 
                                                                 
Figure 43: EU-27 Member States' environmental 
protection investments (Capex) by institutional sectors 
(Total economy = 100%), 2018196 

A  partial  breakdown  of  investment  by  environmental 
topic is available, at the level of institutional sectors only 
(rather than at economy level), due to different reporting 
the  sectors.  At  Poland’s  general 
patterns  across 
government 
level,  67%  of  environmental  protection 
investments  went  on  wastewater  and  11%  on  air 
protection  in  2018.  When 
looking  at  the  country’s 
specialist  producers,  81%  of  the  relevant  investments 
were  directed  to  wastewater  and  18%  to  waste 
in  the 
involved 
management.  For  businesses  not 
specialist 
environmental-protection 
production 
services, the main focus was on investing in anti-pollution 
measures  (70%),  while  wastewater  received  14%  and 
waste  management  received  6%  of  environmental 
investments.  

of 

issuance197 

The  annual  global  green  bond 
in  2020 
amounted  to  USD 279.8  billion.  Of  this,  the  total  annual 
issuance  of  European  green  bonds  (including  some  non-
EU  countries)  in  2020  was  USD 156  billion  (EUR 137 
billion 198). This has grown from USD 117 billion (EUR 105 
billion)  in  2019.  Looking  only  at  EU-27  Member  States, 
green bond issuance in 2020 was EUR 124 billion. Poland 

196  Eurostat,  Environmental  Protection  Expenditure  Accounts 
(env_epe).  
197  Green  bonds  were  created  to  fund  projects  that  have  positive 
environmental  and/or  climate  benefits.  The  majority  of  green  bonds 
issued are green “use of proceeds” or asset-linked bonds. The very first 
green  bond  was  issued  in  2007  with  the  AAA-rated  issuance  from 
multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 
198 At Eurostat’s annual average EUR/USD exchange rates. 

Poland  41 

did  not  issue  green  bonds.  In  2014-2020,  83%  of  the 
green  bonds 
issued  by  European  countries  served 
objectives  in  energy,  buildings  or  transport,  while  8% 
supported water and waste, and a further 6% supported 
to  ecosystem 
sustainable 
conservation & restoration. This is based on the  climate-
bonds  taxonomy  being  broadly  similar  to  the  EU 
taxonomy199. 

land  use,  with 

links 

Figure 44: Annual EU green bond issuance in 2020 (EUR 
billion)200 

Green budget tools 

Green taxation & environmental tax reform 

Poland’s  revenue  from  environmentally  relevant  taxes 
(2.55%  of  GDP)  is  slightly  higher  than  the  EU  average  in 
2020 (2.24% of GDP), as shown in Figure 45. This is due to 
a  relatively high  proportion of energy taxes, at 2.24% of 
GDP,  against  an  EU  average  of  1.74%.  Transport  taxes 
represented  only  0.18%  of  GDP  (EU  average  of  0.42%). 
However,  taxes  on  pollution  and  resource  represented 
0.13%,  which  is  above  the  EU  average  of  0.08%.  In  the 
same year, the environmental tax accounted for 7.12% of 
security 
total 
contributions  (substantially  above  the  EU  average  of 
5.57%)201. 

taxes  and 

revenues 

social 

from 

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

199 
information 
Bonds 
https://www.climatebonds.net/standard/taxonomy. 
200 Climate Bonds Initiative, 2022. 
201 European Commission, Ensuring that polluters pay – Poland    

Climate 

on 

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
 
 
 
                                                                 
Figure 45: Environmental taxes in the EU-27, 2020202 

Environmentally-harmful subsidies 

Poland  42 

Addressing  and 
removing  environmentally-harmful 
subsidies  (EHS)  is  a  further  step  towards  wider  fiscal 
reforms207.  

Fossil-fuel  subsidies  are  costly  for  public  budgets  and 
make it difficult to achieve the Green Deal  objectives. In 
many  cases,  these  subsidies  also  counteract  incentives 
for  investments.  Annual  fossil-fuel  subsidies  have  been 
around EUR 55 billion in the EU since 2015. They rose by 
4%  between  2015  and  2019,  however  some  countries 
(such  as  Latvia,  Lithuania,  Sweden,  Greece  or  Ireland) 
managed  to  decrease  them  in  this  period.  In  the  EU, 
subsidies  on  petroleum  products,  in  sectors  such  as 
transport  and agriculture  continued to increase in 2015-
2019. However, subsidies  for coal and lignite decreased, 
due  to  the  diminishing  role  of  solid  fuels  in  electricity 
generation. As a share of GDP, fossil fuel subsidies ranged 
from 1.2% in Hungary to less than 0.1% in Malta in 2019 
(with an EU average of 0.4%). In 2019, the total fossil fuel 
in  Poland  amounted  to  EUR 1.7  billion, 
subsidies 
representing 0.3% of the GDP. 

In  2020,  the  EU27’s  total  fossil-fuel  subsidies  decreased 
to EUR 52 billion (due to falling consumption trends amid 
the  COVID-19-related  restrictions).  Without  Member 
State  actions,  these  subsidies  are  likely  to  rebound  as 
economic activity picks up from 2020208. 

207  European  Commission,  Study  on  assessing  the  environmental  fiscal 
reform potential for the EU 28, 2016. 
208  See  table  on  EU  FFS  data  in  2019  which  is  based  on  (for  info) 
COM(2021) 950 and Annex 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society  and  promote  a  just 
transition. Tax reforms can  contribute to this by sending 
the right price signals and incentives to economic actors. 
The  Green  Deal  creates  the  context  for  broad-based  tax 
reforms, the removal of fossil-fuel subsidies, and a shift in 
the  tax  burden  from  labour  to  pollution.  It  achieves  this 
while 
social 
taking 
considerations203. 

simultaneously 

account  of 

The  Green  Deal  promotes  the  ‘polluter  pays  principle’ 
(PPP)204,  which  stipulates  that  polluters  should  bear  the 
cost  of  measures  to  prevent,  control  and  remedy 
pollution.  The  PPP  is  facilitated  by  the  EU  Commission’s 
technical support instrument  (TSI) project205 on greening 
taxes.  

According  to  a  Commission  study  on  green  taxation  and 
instruments  (2021),  Poland  applies 
other  economic 
‘polluter  pays’  economic  instruments  on  water  and 
waste,  such  as  water  consumption  charges  and  pay-as-
you-throw, respectively206. 

202 Eurostat, Environmental taxes accounts (env_eta). 
203 COM (2019/640 final), p. 17. 
204  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’. 
205  European  Commission,  Greening  taxes-  applying  polluter  pays 
principle in practice, green budgeting TSI participation. 
206  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
                                                                 
 
                                                                 
Figure 46: Trends in fossil fuel subsidies (natural gas, 
petroleum products and coal) in Poland (source OECD 
Inventory) 209

% GDP 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Natural gas 

0,03 

0,01 

0,01 

0,06 

0,06 

0,00 

Petroleum  

0,09 

0,09 

0,09 

0,10 

0,09 

0,09 

Coal 

0,15 

0,18 

0,18 

0,21 

0,19 

0,38 

0,00 

0,08 

0,20 

0,0
0 

0,0
8 

0,1
9 

Poland  43 

legislation  and  criteria213.  The  Commission  developed  a 
green-budgeting reference framework214 and launched a 
technical  support  instrument  (TSI)  project  on  green 
budgeting  in  2021  to  assist  Member  States  develop 
national  green  budgeting  frameworks  to  improve  policy 
coherence  and  the  green  transition.  Poland  participates 
in  the  Commission’s  green-budgeting  TSI,  which  started 
in 2021. 

Overall financing compared to the needs 

The EU’s overall environmental financing for investments 
is estimated to have been  0.6-0.7% of GDP in 2014-2020 
comprising  both  major  EU  funds  and  national  financing. 
This  ranged  from  0.3%  (Ireland)  to  1.91%  (Bulgaria), 
depending  on  the  level  of  environmental  challenges  in 
Member States. In 2021-2027 it is estimated that the EU’s 
overall  environmental 
investment  needs  will  range 
between  0.9-1.5%  of  the  projected  GDP  for  the  EU-27 
(2021-2027), suggesting an overall environmental financing 
gap  of    0.6-0.8%  of  GDP  (EU  level),  unchanged  financing 
levels assumed215. 

Poland allocated more than the EU average on fossil-fuel 
subsidies,  and  more 
renewable  energy 
than 
subsidies210. 

to 

Figure  47:  Total  environmental  financing  baseline  (‘14-
20)  and  estimated  needs  (‘20-30)  in  the  EU27  (%  of 
GDP)216 

Current green budgeting practices  

‘Green  budgeting’  encompasses  various  climate  and 
environmental  tagging  and  tracking  practices  in  budgets 
and  some  EU  Member  States  already  use  certain  green 
budgeting  practices211.  Green  budgeting  helps  identify 
and  track  green  expenditure  and  green  revenues  to 
increase  transparency  on  how  green  budgetary  policies 
improving  policy  coherence  and 
are.  This  aims  at 
supporting  green  policies 
(including  climate  end 
environmental objectives)212. 

The Commission has also drawn up climate-proofing and 
sustainability-proofing guidance as tools to assess project 
eligibility and a project’s compliance with environmental 

209 OECD Inventory 
210  European  Court  of  Auditors,  Energy  taxation,  carbon  pricing  and 
energy subsidies. 
211 European Commission, Green Budgeting Practices in the EU: A First 
Review,  2021,  Green  Budgeting  in  the  EU  Key  insights  from  the  2021 
Commission  survey  and  and  OECD,  Public  Governance  Directorate, 
Climate  Change  and  Long-term  Fiscal  Sustainability,  Working  Paper, 
February  2021.  Climate  Change  and  Long-term  Fiscal  Sustainability 
(oecd.org) 
212 OECD Paris Collaborative on Green Budgeting initiative, 2017 

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

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
 
 
 
                                                                 
Poland  44 

environmental  financing  gap  (at  least  0.74%  of  Poland’s 
GDP) if the 2014-2020 environmental financing levels and 
patterns  simply  continued  in  the  new  programming 
period. Nevertheless, the investment gap is likely higher 
if needs that are currently estimated at EU-level only (e.g. 
water  protection,  inreasing  circularity  rate,  biodiversity 
strategy etc.) were to be taken into account . 

financing,  calling 

In the 2019 EIR, Poland had priority actions in the field of 
environmental 
the  necessary 
administrative capacities to be built and investements to 
be  mobilised 
significant 
implementation  gaps.  Despite  some  progress,  there  is 
room for improvement in future years. 

the  most 

close 

for 

to 

2022 priority actions 

for 

  Devise  an  environmental  financing  strategy  to 
maximise 
closing 
opportunities 
environmental  implementation  gaps,  bringing 
together all relevant administrative levels. 
Ensure  an  increased  level  of  financing  for  the 
environment (both from EU and private sources) 
to  cover  the 
investment  needs  across  the 
environmental  objectives  and  to  prevent  likely 
financing gaps from leading to investment gaps. 

 

investments 

is 
Poland’s  environmental  financing  for 
estimated to have  accounted for 1.24% of  GDP in 2014-
2020,  with  a  third  coming  from  EU  sources.  For  2021-
2027,  the  country’s  overall  environmental  investment 
needs  are  estimated  to  be  among  the  highest  in  the  EU 
(1.98% of GDP, covering needs for which a country-level 
breakdown exist), which suggests a potentially significant 

 Environmental Implementation Review 2022 – Poland 

 
 
 
 
 
Poland  45 

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) and access to justice in environmental eatters. 
It  is  of  crucial  importance  to  public  authorities,  the 
public, and businesses that environmental information is 
shared  efficiently  and  effectively217.  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 environment218. It includes the right 
to bring legal challenges (‘legal standing’)219. 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
INSPIRE  Directive.  The  Directive  aims  to  establish  a 
European spatial data infrastructure for: 

(i)  sharing  environmental 

spatial 

information 

between public authorities across Europe; 
(ii)  assisting in policy-making across boundaries; 
(iii)  and 

facilitating 

access 

public 

to 

this 

information. 

Geographic  information  is  needed  for  good  governance 
at  all  levels  and  should  be  readily  and  transparently 
available. 

Poland’s  implementation  of  the  INSPIRE  Directive  could 
be  better.  Its  performance  has  been  reviewed  on  the 
basis of the 2021 country sheet220. There has been good 
progress  on  data  identification  and  documentation,  and 
implementation levels are good. However, more work is 
needed to: 

(ii)  prioritise 

environmental 

in 
implementation,  especially  those  identified  as 
high-value  spatial  datasets  for  implementing 
environmental legislation221. 

datasets 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive, 2016-2020222 

2016 

2020 

Legend 

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

addressed 

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

■ 
this  provision 
significantly 
efforts 
Serious 
necessary 
to 
implementation 
Percentage: <31%  

Implementation  of 
is  falling 
behind. 
are 
close 
gap. 

Effective 
data sharing 

coordination 

and 

Ensure 
effective 
coordination  

Data  sharing 
without 
obstacle  

INSPIRE 
indicators 

■  ■  

■  ■ 

performance 

i.  Conformity 
of metadata  

■  ■ 

ii.  Conformity 
of 
spatial 
data sets 223  

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

iv. 
Conformity  of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

(i)  make the data more widely accessible; 

Public participation 

217  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive,  (Directive 
2007/2/EC)  together  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive’s implementation. 
218 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. 
219  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. 
220 INSPIRE in your country - PL 

Polish  provisions  transposing  the  Environmental  Impact 
Environmental 
Assessment 

Strategic 

(EIA) 

and 

221European Commission, List of high value spatial data sets.  
222 INSPIRE knowledge base, 2021. 
223  The  deadlines  for  implementing  the  spatial  data  interoperability 
were  in  2016  still  in  the  future:  23/11/2017  for  Annex  I  data  and 
21/10/2020 for Annex II and III data. It must be also considered that this 
conformity indicator will in many cases never reach 100% conformity as 
the majority of the countries provide as-is-data sets in addition to  the 
INSPIRE harmonised data sets. 

Environmental Implementation Review 2022 – Poland 

 
                                                                 
  
 
                                                                 
Assessment (SEA) Directives require the general public to 
be  informed,  including  via  electronic  tools,  about  the 
initiation of the public participation procedure within the 
EIA or SEA. They also need to inform the public about the 
practical  arrangements  for  participating  (when  and  how 
to get access to the documentation available; when and 
how to submit comments etc.). After a decision that has 
been preceded by an EIA is made, it must  be published, 
including  online.  No  statistics  on  the  level  of  public 
participation  are  available.  The  situation  in  this  regard 
has not changed since the 2019 EIR. 

The 2019 EIR recommended that Poland facilitates public 
participation 
implementing  EU  environmental 
legislation.  Since  2019,  Poland  has  only  made  limited 
progress on this issue. 

in 

Access to justice  

NGOs do not  have to prove an interest  when they bring 
environmental  court  cases  or 
in  cases  which  have 
significant  effects  on  the  environment.  However,  NGOs 
must meet some conditions in connection with their legal 
status and operation. In Poland, plans, programmes and 
other  strategic  documents, 
including  those  on  the 
environment, are adopted by: 

 

 

of 

self-governmental  authorities;  there  are  three 
levels 
authorities: 
self-governmental 
community  (gmina),  district  or  poviat  (powiat) 
and region (województwo) or 
governmental  authorities:  either  at  the  central 
level  (by  ministers  or  other  central  agencies)  or 
at the regional level.  

Four  specific  Acts  (on  self-governmental  authorities  and 
on  governmental  authorities)  grant  access  to  justice  to 
people  who  have  a  legal  interest  affected  by  the  case, 
and  who  can  prove  that  their  legal  interest  or  right  has 
been 
infringed  (the  mere  threat  or  possibility  of 
infringement is insufficient).  

This means that the group of people entitled to challenge 
a plan or programme is very narrow – narrower than for 
individual decisions, where it is sufficient to demonstrate 
the mere existence of a legal interest in the case and not 
its violation. 

Plans or programmes adopted in the form of a Regulation 
(rozporządzenie) by the Council of Ministers or a Minister 
are not subject to access to justice provisions. There is no 
direct  access  to  the  court  to  challenge  a  normative 
instrument. 

infringement  procedure 

In  response  to  an 
initiated 
against  Poland for  non-conformity  in its transposition of 
access  to  justice  provisions  under  the  EIA  Directive, 
Poland amended its EIA Act on 30 March 2021 rectifying 
the identified breach. 

Poland  46 

The  Polish  EIA  law  entered  into  force  on  13 May 2021. 
The key improvements of the new law are as follows: 

  NGOs  will  be  able  to  request  the  suspension  of 
execution  of  the  environmental  decision  already  at 
the stage of administrative appeal; 

  NGOs will be able to ask for interim measures for the 
environmental  decision  and  development  consent  at 
the stage of judicial review; 

  NGOs  will  be  able  to  challenge  the  development 
consents in cases where they have not had such rights 
until  now  (e.g.  water  permits,  mining  concessions, 
construction  permits  where  a  second  EIA  procedure 
has not been carried out); 

  The limitation of the effects of the administrative and 
judicial review in special acts was corrected (i.e. there 
is  no  limitation  if  the  review  concludes  that  the 
development consent was non-compliant with the EIA 
decision). 

The new EIA law applies to procedures launched as from 
the  day  of  entry  into  force  of  the  law,  i.e.  13 May 2021. 
The  law  includes  transitional  provisions,  according  to 
which  the  new  law  would  also  apply  to  procedures  that 
were initiated before 13 May 2021, but were still pending 
on this date. 

There is some information on access to justice, usually in 
the  official  language  of  the  country  only,  maintained  by 
the  government,  and  it  needs  to  be  searched  for.  No 
official  webpages  concerning  environmental  access  to 
justice have been identified. 

In 2019, there was a priority action addressed to Poland 
on access to justice, namely to provide broader standing 
to the public. Some progress on this has been made. 

2022 priority actions 

  Make  spatial  data  more  widely  accessible  and 
the 
prioritise  environmental  datasets 
implementation  of 
INSPIRE  Directive, 
the 
especially  those  identified  as  high-value  spatial 
datasets 
implementing  environmental 
legislation. 

for 

in 

 

 

  Measure 

the 

level  and  quality  of  public 
participation in EIA and SEA procedures to verify 
how effectively this tool is used in practice.  
Identify  the  levels  of  public  participation  in 
Poland and whether and how feedback provided 
in 
during  public  consultations 
decision making on plans and projects. 
Further 
improve  access  to  courts  by  the 
concerned  public  when  it  comes  to  challenging  
decisions,  acts,  or  omissions  in  particular  under 
the  areas  related  to  water,  nature  and  air 
quality.  

is  considered 

 Environmental Implementation Review 2022 – Poland 

 
 
  Better  inform  the  public  about  their  access  to 
justice rights, in particular by referring to judicial 
and  administrative  portals  to  the  Commission 
eJustice  fact  sheets  on  access  to  justice  in 
environmental matters224. 

Compliance assurance  

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect  water,  air  and  nature,  and  manage  waste225.  It 
includes  support  measures  provided  by  the  authorities 
such as: 
(i) compliance promotion226; 
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring227; 
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remediated,  i.e. 
enforcement228. 
Citizen  science  and  complaints  enable  authorities  to 
liability229 
better  focus  their  efforts.  Environmental 
ensures that the polluter pays to remedy any damage.  

Compliance promotion and monitoring 

There  are  tools  to  distribute  information  relating  to  the 
Nitrates  Directive  to  farmers,  which 
improves  the 
situation  compared  to  the  2019  EIR.  These  include  the 
following: 

  a  programme  of  measures  was  adopted  to  reduce 

 

nitrate pollution from agricultural sources230; 
the  Ministry  of  Agriculture  prepared  guidance  on 
good  agricultural  practices 
to  prevent  nitrate 
pollution231; 

  a government agricultural advisory centre is active in 
the 
providing 
requirements  of  the  Nitrates  Directive232;  it  provides 

information  on 

farmers  with 

224 Access to justice in environmental matters 
225  The  concept  is  explained  in  detail  in  the  Communication  on  ‘EU 
actions  to 
improve  environmental  compliance  and  governance’ 
COM(2018) 10  and  the  related  Commission  staff  working  document, 
SWD(2018)10. 
226 This EIR focuses on the help given to farmers to comply with nature 
and nitrates legislation. 
227 This EIR focuses on inspections of major industrial installations. 
228  This  EIR  focuses  on  the  availability  of  enforcement  data  and 
coordination between authorities to tackle environmental crime. 
229  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 
230 Regulation of 12 February 2020 on the adoption of the ‘programme 
of measures to reduce pollution of waters by nitrates from agricultural 
sources  and  to  prevent  further  pollution’  (Journal  of  Law  2020  item 
243). 
231 Zbiór zaleceń dobrej praktyki rolniczej 
232 Produkcja rolna - program azotanowy - informacje 

Poland  47 

its  website233  and  distributes 
information  on 
leaflets234  listing  the  Directive’s  requirements  for 
farmers. 

Regarding the Nature Directives, no specific new tools to 
actively  promote  compliance  were 
identified.  The 
General  Director  for  Environmental  Protection’s  website 
provides  general  information  about  Natura  2000235  with 
publications  relating  to  Natura  2000  in  various  sectors 
(such  as  water  management,  aquaculture,  forestry);  all 
publications  were  dated  2009.  General  information  on 
location, responsible authorities and standard data about 
existing Natura 2000 sites is also available online, via the 
‘Central  Register  of  Nature  Protection  Forms’  (Centralny 
Rejestr Form Ochrony Przyrody)236. Information about the 
location  of  Natura  2000  sites  can  be  also  found  on  the 
INSPIRE geoportal237. 

Each  on-site  inspection  carried  out  by  the  Inspectorate 
for  Environmental  Protection 
is  documented  by  an 
inspection  report.  The  individual  inspection  reports  are 
not  published  but  must  be  disclosed  on  request 
(according  to  provisions  on  access  to  environmental 
information,  transposing  Directive  2003/4/EC).  Annual 
summary  reports  on  the  inspections  carried  out  by  the 
Inspectorate for  Environmental Protection are published 
online238. These reports are quite extensive and detailed. 
Information  about  the  inspections  actually  carried  out 
within a given year and their results was not found. The 
situation  in  this  regard  has  not  changed  since  the  2019 
EIR. 

Complaint handling and citizen science 

The  Chief  Inspectorate  for  Environmental  Protection 
allows  complaints  to  be  submited  online  using  a 
designated  e-form  on  their  website239.  Some  regional 
inspectorates  refer  to  this  option  on  their  websites,  as 
in  the  2019  EIR.  Some  of  the  Regional 
indicated 
Inspectorates  for  Environmental  Protection  also  provide 
other  information  on  their  websites,  e.g.  on  how  to 
submit  a  complaint,  but  their  level  of  detail  varies  from 
region to region240. 

information  on  complaints  and 
Annual  statistical 
interventions 
for 
Environmental Protection (such as number of complaints 

investigated  by  the 

Inspectorate 

233 Produkcja rolna - program azotanowy - informacje 
234 Program azotanowy - ulotka 
235 Natura 2000 a aktywność człowieka 
236 CRFOP - Centralny rejestr form ochrony przyrody 
237 https://mapy.geoportal.gov.pl/imap/Imgp_2.html?gpmap=gp3 
238  Sprawozdania  z  realizacji  zadań  IOŚ  and  Raporty  -  publikacje  - 
opracowania 
239 Zgłoś interwencję - formularz 
240  See,  for  example,  Zgłaszanie  poważnych  awarii  zagrażających 
środowisku. 

 Environmental Implementation Review 2022 – Poland 

 
                                                                 
                                                                 
tasks  performed  by 

received,  the  outcomes  and  the  follow-up  procedure)  is 
available 
in  the  document  provided  by  the  Chief 
Inspectorate  for  Environmental  Protection:  „Information 
on 
for 
Environmental Protection”241. No specific instruments or 
projects  to  encourage  NGOs  or  individuals  to  submit 
citizen  science  information  to  authorities  have  been 
identified. This has not changed since the 2019 EIR. 

Inspectorate 

the 

The  only  situation  where  scientific  evidence  is  accepted 
or required from individuals is when: 

 

 

 

the  Environmental 

they  ask  the  competent  authorities  to  take 
Liability 
action  under 
Directive (ELD); 
they take part in public participation procedures 
(such as those within an EIA); 
or  –  in  case  of  NGOs  –  when  they  submit  a 
request to the competent authority to carry out 
any 
environmental 
infringement242. 

regarding 

action 

an 

Enforcement 

Statistics on environmental crime in Poland are available 
for  the  number  of  proceedings  initiated,  number  of 
crimes  stated  and  number  of  crimes  for  which  the 
perpetrator  was  found,  via  the  website  of  the  Polish 
police force243. No information could be found in national 
sources  about  the  results  of  the  related  criminal 
proceedings  (such  as 
information  on  convictions  or 
sanctions imposed) and it appears that this information is 
not published. Information is available about the number 
of  convictions  for  particular  environmental  crimes  in 
Poland in 2010-2017244. 

Environmental Liability Directive (ELD) 

Poland has not introduced a mandatory financial security 
system  for  ELD 
is  room  for 
  financial  security  system  for 
improvement  of  the 
liabilities and ELD guidance. 

liabilities  and  there 

While Poland has developed a good practice as the Polish 
legislation 
the 
establishment  of a  Register of ELD incidents245 managed 
by the General Director for Environmental Protection and 

the  ELD  provides 

transposing 

for 

241 Raporty - publikacje - opracowania 
242 On the basis of Art. 31(1) of the Administrative Procedure Code. 
243 Statystyka policyjna - Zniszczenia w świecie roślinnym i zwierzęcym 
244  Commission  staff  working  document  Evaluation  of  the  Directive 
2008/99/EC  of  the  European  Parliament  and  of  the  Council  of 
19 November  2008  on  the  protection  of  the  environment  through 
criminal  law  (Environmental  Crime  Directive),  Part  1/2,  28  October 
2020, Annex 11. 
245 Article 26a of the Act on environmental damage. 

Poland  48 

available  online246.  However,  it  is  only  accessible  to 
environmental  authorities247.  The  general  public  has  no 
access  to  the  Register  but  may  apply  for  information  it 
contains  on  the  basis  of  general  provisions  on  access  to 
environmental information248. 

Operators  who  caused  environmental  damage  or  the 
threat  of  such  damage  are  obliged  to  report  that  to  the 
competent authorities249. Moreover, any person (and not 
only those directly affected), including NGOs, may notify 
the competent authority about environmental damage or 
threat of damage and request  action250. The notification 
may be submitted in a paper form or electronically via e-
PUAP251. 

2022 priority actions 

 

 

 

Provide  and  actively  distribute  information  is 
available to help farmers meet  their obligations 
as regards Natura 2000. 
Provide  more  online  information  on  inspection 
plans, the number of inspection actually carried 
out, and reports on the inspections. 
Poland  can  improve  its  use  of  citizen  science, 
trying  to  encourage  the  public  and  NGOs  to 
work 
and  using 
in 
environmental data. 

collecting 

together 

Effectiveness of environmental 
administrations  

in 

involved 

implementing 

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

Administrative capacity and quality 

There  has  been  progress  on  the  implementation  of  the 
environmental  assessments.  A 
recent  package  of 
legislation aimed at speeding up the licencing of ‘projects 
of national interest’ raised some concerns but no serious 

246 GDOŚ - rejestry  
247  See  instructions  on  how  to  apply  on  the  General  Directorate’s 
website: https://www.gdos.gov.pl/rejestry-gdos 
248 transposing Directive 2003/4. 
249 The Regional Director for Environmental Protection and the Regional 
Inspector  for  Environmental  Protection  ex  Art. 11.1  the  Act  on 
environmental damage. 
250  Art. 24  of  the  Act  on  environmental  damage  which  transposes 
Art. 12 of ELD. 
251 A general platform applicable for all issues, not only environmental 
ones, enabling the public to contact public authorities. 

 Environmental Implementation Review 2022 – Poland 

 
 
                                                                 
 
 
                                                                 
identified  since 

it  has  been 
problems  have  been 
implemented.  Nevertheless,  NGOs  have  recently  drawn 
the  Commission’s  attention  to 
‘negative  screening’ 
decisions that apparently cannot be challenged, which is 
not compliant with the Directive. 

Polish  public  authorities  are  increasingly  adopting  and 
using  electronic  services  to 
interact  with  public  or 
regulated  entities  online.  However,  Poland  only  ranks 
24th of 27 EU Member States in the 2021 edition of the 
Digital Economy and Society Index (DESI), scoring 41.0 as 
compared  to  the  EU-27  average  of  50.7. During  2020, 
Poland made progress on many indicators, but given the 
equally positive developments in other countries this has 
not  translated  into  a  change  in  its  overall  position.  In 
digital  public  services,  Poland  ranks  22nd  with  49%  of 
internet  users 
relying  on  e-government  services, 
compared to 64% in the EU252. 

in  the 

field  of 
An  example  of  a  digital  service 
environment 
(Czyste  Powietrze) 
‘Clean  Air’ 
is  the 
programme  of  subsidies  to  replace  old  stoves  and 
insulation in single-family houses. Another example is the 
‘My  Electricity’  (Mój  Prąd)  programme  dedicated  to 
supporting  the  development  of  prosumer  energy, 
specifically  supporting  the  segment  of  photovoltaic  (PV) 
micro-installations.  The  public  can  apply  for  both 
programmes online, logging in using the ‘trusted profile’ 
(profil zaufany). 

Coordination and integration  

As  mentioned  in  the  2017  EIR,  the  transposition  of  the 
revised  EIA  Directive253  provides  an  opportunity  to 
streamline  the  regulatory  framework  on  environmental 
assessments. Poland enacted the content of the Directive 
by the deadline (May 2017). 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments  to  reduce  duplication  and 
avoid  overlaps  in  environmental  assessments  applicable 
to  projects.  Streamlining  helps  reduce  unnecessary 
administrative  burden  and  accelerates  decision  making, 
provided it is done without  compromising the quality of 
the  environmental  assessment  procedure254.  Poland 
began  streamlining  environmental  assessments  under 
the EIA and Habitats Directives before the revision of the 

252  European  Commission,  Digital  Economy  and  Society  Index  (DESI) 
2021 DESI country profile - Poland 
253 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. 
254 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, Habitats 
Directive,  Water  Framework  Directive,  and  the  Industrial  Emissions 
Directive, OJ C 273, 27.7.2016, p. 1. 

joint  procedures 

Poland  49 

EIA  Directive.  Coordinated  procedures  have  been  set  up 
for the EIA and Industrial Emission Directives. 

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

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

The  Commission’s  TSI  supported  many  environment-
related  projects  in  Poland  during  the  reporting  period. 
Under the TSI 2019, a request was approved for a project 
related  to  the  digitalisation  of  construction  planning. 
Under  the  TSI  2020,  four  requests  were  selected  to 
support: (i) renewable energy solutions in rural areas; (ii) 
capacity  building  for  sustainable  development  goals  and 
sustainable  development;  (iii)  preparing  the  territorial 
just  transition  plans;  and  (iv)  the  state  water  holding 
‘Polish waters’. Then in 2021, TSI supported a project on 
sustainable  development  framework  for  strategy  and 
business  operations  of  Poland’s  Development  Bank. 
Finally,  in  2022,  three  requests  were  approved:  (i)  on 
enhancing 
public 
administration  for  regional  and  local  authorities;  (ii)  on 
developing clean, smart and fair urban mobility; and (iii) 
a  request  related  to  supervisory  capacity  building  in 
sustainable finance. 

cooperation 

quality 

and 

of 

 TAIEX EIR peer to peer Projects 

in  2017255  to 

facilitate  peer-to-peer 

The  Commission  launched  the  TAIEX  EIR  peer-to-peer 
tool 
learning 
between environmental authorities. During the reporting 
period,  Poland  has  participated  in  several  multi-country 
workshop on life cycle approach and circularity in policy 
and  procurement  planning  (2019),  on  green  criteria  in 
public  procurement 
(2019),  on  ammonia-reducing 
technology  and  measures  (2021)  and  on  zero  pollution 
(2021).  Poland  also  benefited  from  a  workshop  on 
combating  trans-boundary  waste  crime  in  the  Polish-
(2019).
German 

border 

region 

255  TAIEX  -  Environmental  Implementation  Review  -  PEER  2  PEER  - 
Environment - European Commission (europa.eu). 

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 Environmental Implementation Review 2022 – Poland