COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review Country Report - THE NETHERLANDS 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, Netherlands, 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) 268 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review     Country Report - THE NETHERLANDS           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) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
The Netherlands  1 

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

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

Photographs:  

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

©European Union, 2022 

Reproduction is authorised provided the source is acknowledged. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Netherlands  2 

Table of Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Measures towards a circular economy ................................................................................................................ 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ............................................................................................................................. 9 
Nature protection and restoration ....................................................................................................................... 9 
Marine ecosystems............................................................................................................................................. 16 
Ecosystem assessment and accounting ............................................................................................................. 17 
3. ZERO POLLUTION ..................................................................................................................................................... 20 
Clean air ............................................................................................................................................................. 20 
Industrial emissions ............................................................................................................................................ 21 
Major industrial accidents prevention – SEVESO ............................................................................................... 24 
Noise .................................................................................................................................................................. 25 
Water quality and management ........................................................................................................................ 25 
Chemicals ........................................................................................................................................................... 29 
4. CLIMATE ACTION ..................................................................................................................................................... 31 
Key national climate policies and strategies ...................................................................................................... 31 
Effort sharing target ........................................................................................................................................... 32 
Key sectoral developments ................................................................................................................................. 32 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 33 

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 environmental financing ..................................................................................................................... 39 
Green budget tools ............................................................................................................................................. 41 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 44 
Information, public participation and access to justice...................................................................................... 44 
Compliance assurance ........................................................................................................................................ 46 
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 – The Netherlands 

 
 
 
 
The Netherlands  3 

Executive summary 

protected under the nature directives is severe, as more 
than half of assessments show a bad conservation status. 

As  regards  water  pollution,  progress  has  been  made, 
although  challenges  remain.   The  Netherlands  need  to 
substantially  reinforce  their  Nitrate  Action  Programme 
with  measures  that  match  the  severity  and  the  urgency 
of  the  situation,  in  line  with  the  obligations  under  the 
Nitrates  Directive,  and  to  ensure    the  objectives  of  the 
Water Framework Directive and the legislation for Natura 
2000 and air quality are met. 

Air  quality  remains  a  cause  of  concern 
in  the 
Netherlands.  While  emissions  of  several  air  pollutants 
have fallen significantly in recent  years, the Netherlands 
is not projected to comply with the 2020-2029 emissions 
reduction  commitments  for  any  pollutant.  Additional 
efforts  are  needed  in  particular  on  ammonia  emissions 
from 
recently 
recommended  that  the  Netherlands  prioritise  ammonia 
reduction measures as part of the new national Common 
Agricultural Policy Strategic Plan.  

Commission 

agriculture. 

The 

On  water  management,  efforts  should  be  made  to 
improve  coordinated  implementation  between  water, 
marine and nature policies. 

Total  environmental  financing  reached  around  0.87%  of 
GDP  in  2014-2020  (almost  exclusively  based  on  national 
sources),  that  needs  to  be 
increased  to  cover  the 
investment  needs  in  the  coming  years  (at  least  1%  of 
GDP) that signals a potential financing gap of over 0.13% 
of GDP.  

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

  optimising  the  contribution  of  the  Natura  2000  and 
to  achieve 
the  national  ecological  networks 
favourable conservation status, and to reduce habitat 
fragmentation  and  biodiversity 
loss,  atmospheric 
nitrogen  deposition,  desiccation  and  acidification, 
while addressing the decline of meadow and farmland 
birds; 
  reducing 

the 
concentrations  of  nitrogen  oxide  levels  (NOx  –  NO2) 
in urban areas and the transport sector, by measures 
such  as  reducing  traffic  emissions,  restrictions  on 
vehicle access or fiscal incentives;  

pollution, 

particular 

air 

in 

  addressing  water  pollution  caused  by  the  nitrogen 
identifying 
surplus  from  agricultural  sources  and 
measures  to  achieve  the  objectives  of  the  Water 
Framework Directive and Nitrates Directive. 

The  Netherlands  continues  to  make  efficient  use  of  EU 
funds and loan opportunities in particular to support the 
circular  economy.  The  country 
is  among  the  best 
performers  in  the  EU  as  regards  resource  productivity, 
secondary  materials  use  and  waste  management. 
However, further progress could be made by introducing 
new  economic  instruments  to  prevent  waste  by  not 
incinerating reusable or  recyclable waste and by making 
the  reuse  and  recycling  of  waste  more  economically 
attractive.  

Protecting  biodiversity  presentsmajor  challenges,  since 
over three quarters of the protected habitats and species 
still  have  unfavourable  conservation  status.  One  main 
reason for the deterioration of habitats is the continued 
significant pressure from agriculture, in particular due to 
nitrogen  deposition  affecting  many  sensitive  habitats 
from  bogs  to  forests  and  the  changes  in  water  regime 
(drainage). Furthermore, the situation for forested areas 

Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
 
 
 
The Netherlands  4 

Part I: Thematic areas 

1. Circular economy and waste management  

Measures towards a circular economy 

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

The  circular  material  use  rate  is  a  good  indicator  of  an 
economy’s circularity, as it includes all the materials that 
are  fed  back  into  our  economy.  Large  differences  in  the 
circularity rate exist across countries. To help achieve the 
EU  Circular  Economy  Action  Plan’s  goal  of  doubling  the 
EU  circular  material  use  rate  by  2030,  ambitious 
measures  targeting  the  whole  product  life  cycle  are 
needed  at  Member  States’  level.  Such  measures  range 
from  sustainable  product  design  able  to 
increase 
durability,  reparability,  upgradability  and  recyclability  of 
like  remanufacturing, 
products,  to  other  measures 
increasing 
in  production  processes, 
recycling,  as  well  as  boosting  eco-innovation  and 
increasing the uptake of green public procurement. 

the  circularity 

(secondary)  use  of  material 

the 
The  circular 
Netherlands  was  26.6%  in  2014  and  was  30.9  in  2020. 
Such  performances  make  the  Netherlands  the  first 
country in the EU for circular materials used, well above 
the EU average of 12.8. 

in 

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

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  minimise 
impacts  on  the  environment  and  reduce 
negative 
dependency on volatile raw  material  markets. As  shown 
in  Figure  2,  with  EUR  4.91  generated  per  kg  of  material 
consumed 
the 
Netherlands is well above the EU average of EUR 2.09 per 
kg.  This  positive  performance  is  further  supported  by  a 
continuous  increase  in  the  resource  productivity  of  the 
Netherlands over the last decade.   

resource  productivity 

in  2020, 

in 

1 Eurostat, Circular Economy Monitoring Framework.  

Environmental Implementation Review 2022 – The Netherlands 

 
 
 
                                                                 
Figure 2: Resource productivity, 2010-20202 

and  food  are  included  in  the  integral  Dutch  Circular 
Economy Strategy as priority sectors or chains. 

The Netherlands  5 

Eco-innovation 

innovation  as 

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

The country ranked 9th in the list of EU countries with a 
total  score  of  124  in  the  Eco-Innovation  Scoreboard  of 
2021, and it performs as an eco-innovation leader. In two 
out  of  five  components  of  the  Eco-innovation  index  of 
2021,  the  Netherlands  perform  below  the  EU  average 
(eco-innovation activities and socio-economic outcomes).  

Figure 3 – Eco-innovation performance, 2010-20204  

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing power representing 14% of EU GDP. This can 
help  drive  the  demand  for  sustainable  (and  circular) 
products  and  business  cases  that  meet  circularity 
standards.  The  Netherlands  has  a 
in 
sustainable  public  procurement  policy.  Evaluation 

long  tradition 

Circular economy strategies  

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

The  country  has  a  circular  economy  strategy,  called  “A 
Circular Economy in the Netherlands by 2050”. The long-
term strategy has been in place since 2016, targeting the 
entire lifecycle of products. The programme’s ambition is 
to achieve an interim objective of a 50% reduction in the 
use  of  primary  raw  materials  (minerals,  fossil-based 
materials and metals) by 2030. In 2019, the government 
adopted a Circular Economy Implementation Programme 
–  covering  the  implementation  measures  for  the  years 
2019-2023. 
the  Netherlands 
Environmental  Assessment  Agency  (PBL)  publishes  a 
progress report on the implementation, and the country 
has  committed  to  update  the  programme  every  five 
years.  A  new  programme  for  2023  and  further  is  in 
preparation. 

Every 

years 

two 

 The  Netherlands  puts  extra  effort  in  policies  regarding 
plastics  and  textiles.  Moreover,  plastics,  construction, 
manufactoring  industry,  consumer  goods,  and  biomass 

2 Eurostat, Resource productivity. 
3  Circular Economy Stakeholder Platform 

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

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
                                                                 
 
 
 
                                                                 
however  has  shown  broad  support  for  GPP,  but  still  too 
little structural uptake.  

To  address  this  and  significantly  boost  the  impact  of 
public  procurement,  a  new  National  Plan  on  SPP  has 
been  adopted  in  2021.  This  plan  aims  to  create  more 
political  commitment,  activate  key  decision  makers  in 
organisations and create more impact in key sectors.  

For  circular  procurement  specifically  a  number  of 
activities are relevant. The Netherlands has so far set up 
around  thirty  so-called  buyer  groups  to 
leverage 
collective  procurement  power  in  a  relevant  sector  and 
provide  a  platform  for  sharing  knowledge  and  learning 
experiences.  Specifically  for 
infrastructure,  extensive 
transition  paths  have  been  worked  out  as  part  of  the 
Climate neutral and Circular Infra Programme. These are 
supported  by  buyer  groups  as  well  for  the  procurement 
angle.  The  national  buyer  group  for  ICT  has  been  linked 
to  the  Circular  and  Fair  ICT  Pact  together  with  seven 
other countries, which the Netherlands has initiated.  

An  increasing  number  of  circular  procurement  best 
practices are shared as part of the free online SPP criteria 
tool SPP criteria tool. The Netherlands promotes the use 
of internal carbon pricing, especially in the infrastructure 
sector.  In  addition,  a  growing  number  of  organisations 
use  the  Dutch  CO2  Performance  Ladder,  which  provides 
both  a  procurement  tool  and  a  plan-do-check-act 
management  system.  This  approach  speeds  up  carbon 
in  companies  and  governments 
emission  reduction 
certified  on  this  Ladder,  including  (on  the  higher  levels) 
emissions  resulting  from  procurement.  This  provides  a 
powerful impetus for circular procurement. 

To  boost  political  support  for  sustainable  (and  circular) 
procurement, a new political Manifest is being drawn up, 
which  focuses on boosting  SPP usage, providing  support 
and creating a stronger foundation for it within signatory 
organisations. 

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

The  number  of  EU  Ecolabel  products  and  EMAS-
licensed5organisations  in  each  country  provides  some 
indication  of  the  extent  to  which  the  private  sector  and 
in  the 
national  stakeholders  are  actively  engaged 
transition to a circular economy.  

As  of  September  2021,  the  Netherlands  had  only  1626 
products  and  86  licenses  registered  in  the  EU  Ecolabel 
scheme out of  83 590 products and 2 057 licences in the 

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

The Netherlands  6 

EU, showing a low take-up of the scheme6. However this 
was  an  improvement  on  thw  2019  figures  of  1100 
products and 83 licences. There is one organisation from 
the  Netherlands  currently  registered 
in  EMAS,  the 
European  Commission's  Eco-Management  and  Audit 
Scheme7. 

In  the  Netherlands  ISO  14001  licensed  organisations 
provides  further  indications  on  the  extent  to  which  the 
private  sector  and  national  stakeholders  are  actively 
engaged  in  the  transition  to  a  circular  economy.  In  the 
Netherlands, 2,650 organizations are ISO 14001 certified 
with 7,700 sites. 

Waste management 

Turning waste into a resource is supported by:  

implementing  EU  waste 

(i)  fully 
legislation,  which 
includes  the  waste  hierarchy,  the  need  to  ensure 
landfill  diversion 
separate  collection  of  waste,  the 
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 management of municipal waste8 
for which EU law sets mandatory recycling targets. 

resource  efficiency  and 

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

reduce 

to 

After  a  downward  trend,  municipal  waste  generation  in 
the Netherlands has started to increase in recent years. It 
came to 508 kg/inhabitant in 2019 and 534 kg/inhabitant 
(505 
in  2020,  remaining  above 

the  EU  average 

6 European Commission, Ecolabel Facts and Figures. 
7  As  of  May  2018.  European  Commission,  Eco-Management  and  Audit 
Scheme. 
8  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). 

 Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
                                                                 
The Netherlands  7 

kg/year/inhabitant),  as  Figure  4  shows.  It  indicates  that 
the Netherlands’s economic growth is not yet decoupled 
from its generation of waste. 

Figure 4: Municipal waste by treatment in the 
Netherlands, 2010-20209 

Figure  4  also  shows  municipal  waste  by  treatment,  in 
terms  of  kilos  per  capita.    Much  of  the  waste  in  the 
Netherlands is incinerated with energy recovery (223 kg per 
capita in 2020, out of the 534 kg treated). 

Netherland’s municipal waste recycling rate is around 57 
%, well above the EU average of around 48 %, and above 
the  2020  and  2025  EU  targets  of  50%  and  55% 
respectively.  Recycling  remains  the  main 
form  of 
treatment of municipal waste, while landfilling, at 3 %, is 
well below the EU average as a result of landfill taxes and 
bans.  This  comparatively  high  value 
illustrates  the 
advanced level of waste management in the Netherlands. 
However, there is  scope to  shift  reusable and recyclable 
through 
incineration, 
waste  away 
economic  instruments,  to  ensure  that  the  post-2020 
recycling  targets,  in  particular  on  plastics,  are  met.  This 
will in particular require action to reduce the incineration 
of municipal waste. Waste prevention and re-use are the 
most preferred options and top the waste hierarchy. 

including 

from 

Figure  5  shows  that  the  Netherlands  needs  to  step  up 
investment  in  recycling  to  meet  the  EU  2020  and  2025 
recycling targets10. 

Figure 5: Recycling rate of municipal waste, 2010-202011 

The Netherlands was not listed in the Commission's Early 
Warning report'12 as being at risk of missing the EU 2020 
target  of  recycling  50 %  of  municipal  waste.  The 
Commission  is  currently  finalising  its  analysis  of  the 
progress  on  the  recommendations  from  the  2018  Early 
Warning  Reports  as  a  well  as  an  analysis  of  progress 
towards achieving the 2025 waste recycling targets. This 
report  will  be  presented  at  the  end  of  2022  and  will 
assess the progress made to date.  

As  mentioned  in  the  2019  report,  the  Netherlands  is 
invited  to  promote  waste  prevention  and  shift  reusable 
and recyclable waste away from incineration.  

Implementation of the 2018 waste legislative package 

The  Netherlands  has  notified  the  transposition  of  the 
2018  waste  package13  to  the  Commission.  A  conformity 
assessment is now ongoing. 

for 

are 

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

legal  requirements 

a 

9  Eurostat, Municipal waste by waste operation, april 2022. 
10 Member States may choose a different method from the one used by 
ESTAT  (and referred to  in this report)  to  calculate  their  recycling  rates 
and track compliance with the 2020 target of 50% recycling of municipal 
waste. 
11 Eurostat, Recycling rate of municipal rate, april 2022. 

12  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. 
13  Directive  (EU)  2018/851,  Directive  (EU)  2018/852,  Directive  (EU) 
2018/850  and  Directive  (EU)  2018/849  amend  the  previous  waste 
legislation and set more ambitious recycling targets for the period up to 
2035. 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
                                                                 
                                                                 
The Netherlands  8 

to 

the  National  Waste 
The  second  amendment 
Management Plan 2017-2029 was adopted on 11 January 
2021 and entered into force on 2 March 202114. It refers 
to  the  years  2017-2023  and  gives  a  preview  to  the 
It  covers  household, 
upcoming  period  2023-2029. 
industrial  and  bulky  waste.  Following 
hazardous, 
clarifications  provided  by 
the  Dutch  authorities, 
Commission  services  have  concluded  that  the  revised 
Waste  Management  Plan  meets  the  requirements  of 
Article 28 of the revised Framework Directive.  

2022 priority actions 

 

new 

policies, 

economic 
Introduce 
instruments,  to  promote  waste  prevention,  make 
reuse and recycling more economically attractive.  
  Shift  reusable  and  recyclable  waste  away  from 

including 

incineration. 

14 https://lap3.nl/ 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
The Netherlands  9 

2. Biodiversity and natural capital

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

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

ensuring  the  long  term  protection,  conservation  and 
survival  of  Europe's  most  valuable  and  threatened 
species and habitats and the ecosystems they underpin. 
Key  milestones  towards  meeting  the  objectives  of  the 
Directives  include  setting  up  a  coherent  Natura  2000 
network,  designating  Sites  of  Community  Importance 
(SCI)  as  Special  Areas  of  Conservation  (SAC)18,  and 
setting  conservation  objectives  and  measures  for  the 
Natura 2000 sites. 

(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 Habitats and the Birds Directives are key legislative 
tools  to  deliver  on  the  Strategy’s  targets  and  are  the 
cornerstone of European legislation on the conservation 
of the EU's wildlife15. 

the 

Program 

The  Netherlands 
of 
launched 
Strengthening Biodiversity in 202016  that builds on the 
2030  Biodiversity  Strategy  and  strives  to  achieve  100% 
of the objectives of the Birds and Habitats Directives by 
2050.  The  new  Strategy  identifies  goals  for  2030    that 
are  reflected  in  more  than  100  measures,  each  with 
corresponding 
deadlines, 
verification means, tools and responsible entities. 

indicators, 

priorities, 

Nature protection and restoration  

Natura  200017,  the  largest  coordinated  network  of 
protected  areas  in  the  world,  is  the  key  instrument  to 
achieve  the  Birds  and  Habitats  Directives'  objectives  of 

15  These  should  be  reinforced  by  the Nature  Restoration  Law, 
according to the new EU Biodiversity Strategy. 
16    Kamerbrief  Programma  versterken  biodiversiteit  |  Kamerstuk  | 
Rijksoverheid.nl 
17  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs) 
designated under the Habitats Directive as well as Special Protection 
Areas (SPAs) classified under the Birds Directive; the coverage figures 
do not add up because some SCIs and SPAs overlap. Special Areas of 
Conservation (SACs) means an SCI designated by Member States. 

Setting up a coherent network of Natura 2000 sites 

The  Netherlands  hosts  52  habitat  types19  and  80 
species20 covered by the Habitats Directive. The country 
also hosts populations of 70 bird taxa listed in the Birds 
Directive Annex I21. 

By  2021,  14.7%  of  the  national  land  area  of  the 
Netherlands  was  covered  by  Natura  2000  (EU  average 
18.5%),  with  Special  Protection  Areas  (SPAs)  classified 
under  the  Birds  Directive  covering  12.8%  (EU  coverage 
12.8%)  and  Sites  of  Community  Importance  (SCIs)    or 
Special Areas of Conservation (SACs) under the Habitats 
Directive covering respectively 8.3% and 9.9% total ling 
10.06% 
(EU  average  14.2%)  of  the  Netherlands’ 
territory. 

The latest assessment of the SCI part of the Natura 2000 
network shows that there are potential insufficiencies in 
designation (even though there is no need to designate 
additional  sites),  as  some  habitats  and  species  do  not 
appear  in  the  designation  decrees  for  some  sites.  The 
adoption  of  a  related  (still  at  draft  stage)  amendment 
decree covering 100 SACs has been pending since 2018. 
Also,  the  coverage  by  the  network  of  three  species 
should be ensured by adding them to the Standard Data 
Forms of the relevant sites. As regards SPAs, while good 
progress  has  been  made  (new  site  designated  on 
8/12/2021),  the  classification  of  one  marine  site  is  still 
pending.  Therefore,  the  Netherlands  still  has  to 
complete  its  Natura  2000  Network,  in  particular  the 
marine network. 

18  Sites  of  Community  Importance  (SCIs)  are  designated  under  the 
Habitats  Directive  whereas  Special  Protection  Areas  (SPAs)  are 
designated under the Birds Directive; the coverage fogures do not add 
up because some SCIs and SPAs overlap. Special Areas of Conservation 
(SACs) are SCIs designated by Member States. 
19 EEA, Article 17 dashboard, Annex I total, 2019. 
20  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. 
21  EEA, Article  12  dashboard,  Annex  I,  2020. This counting  only  takes 
into account birds taxa for which information was requested. 

Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
 
                                                                 
The Netherlands  10 

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202124 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  the  Netherlands  legally 
protects  26,6%  of  its  terrestrial  areas  (EU  27  average 
26,4%)  and  25,6%  of  marine  areas  (EU  27  average 
10,7%).  It strictly protects 1% of terrestrial and marine 
areas.22 

Figure 6: Marine & terrestrial protected area coverage, 
202123 

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

The  6-year  deadline  set  by  the  Habitats  Directive  to 
designate  SCI  as  SAC  and  establish  appropriate 
conservation objectives and measures has expired for 2 
sites in the Netherlands. 

Overall,  3  SCIs  have  not  yet  been  designated  as  SACs. 
Definitive  site  specific  conservation  objectives  have 
been  established  for  all  sites,  except  for  those  where 
designation  is  still  pending.  Two  of  them  already  have 
draft  objectives,  while  for  the  third  site  where  the  6 
year  deadline  has  not  yet  expired  there  are  no 
objectives yet. 

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

The results of reports under Habitats Directive Article 17 
and  Birds  Directive  Article  12  on  progress  towards 
maintaining or restoring favourable conservation status 
of  species  and  habitats  are  key  to  measuring  the 
performance of Member States. 

According  to  the  report  submitted  by  the  Netherlands 
on  the  conservation  status  of  habitats  and  species 
covered  by  the  Article  17  of  the  Habitats  Directive  for 
2013-201825,  the  share  of  assessments  for  habitats  in 
good  conservation  status  in  2018  is  more  than  the 
3.85%  reported  under  the  previous  reporting  period 

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

24  European  Environment  Agency,  Natura  2000  Barometer,  February 
2022. 
25Conservation status and trends of habitats and species — European 
Environment Agency (europa.eu) 

Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
 
                                                                 
  
                                                                 
The Netherlands  11 

Figure 9:  Assessments on conservation status for 
species for the 2007-2012 and 2013-2018 reporting 
periods28 

(2007-2012). As regards protected species, the share of 
assessments  in  good  conservation  status  in  2018  is 
26.25%,  more  than  the  22.78%  reported  under  the 
previous  reporting  period  (2007-2012).  Of  the    forest 
habitats protected under the EU nature directives none 
show a favourable conservation status￼. As far as birds 
are  concerned,  58%  of  the  breeding  species  showed 
short-term  increasing  or  stable  population  trends  (for 
key wintering species this figure was 62%). 

At  the  same  time,  the  share  of  habitats 
in  bad 
conservation  status  has  increased  to  53.85%  and  the 
share  of  assessments  for  species  in  bad  conservation 
status has decreased to 38.75%. The main pressures are 
agriculture,  human-induced  changes  in  water  regime 
and natural succession26. 

Figure 8:  Assessments on conservation status for 
habitats for the 2007-2012 and 2013-2018 reporting 
periods27 

is 

The  Netherlands  made  good  progress  improving  the 
conservation  status  of  an 
increasing  proportion  of 
habitats  and  species  and  as  a  result  the  percentage  of 
habitats  in  favourable  status  tripled  compared  to  the 
previous  reporting  under  Article  17,  though  it  is  still 
below  12%.  At  the  same  time  while  there  was  a 
considerable  fall  in  the  percentage  of  species  in  bad 
status dropping from over 50% to below 39%, the trend 
for habitats was opposite as they increased from 46% in 
  One  main  reason  for  the 
bad  status  to  54%. 
the  continued  very 
deterioration  of  habitats 
significant  pressure  from  agriculture: 
in  particular 
nitrogen  deposition  affecting  many  sensitive  habitats 
from  bogs  to  forests  and  the  changes  in  water  regime 
(drainage).  In  the  case  of  birds,  the  Article  12  report 
indicates  a  minimal  1%  improvement  of  species  with 
increasing population trend, while the population of 5% 
more species is decreasing. This is in particular of major 
concern 
the 
agricultural landscape, and for which the Netherlands is 
a key breeding and wintering area. By 2020, the flagship 
species  blacktailed  godwit  breeding  population  had 
dropped  by  50%    since  2001.  An  EU  Pilot  investigation 
was  launched  in  2017  on  the  decline  of  meadow  birds 
and  the  alleged  insufficiency  of  the  measures  taken. 
According  to  a  2021  report  by  the  Dutch  Court  of 
Auditors,  the  decline  has  still  not  been  halted  despite 
measures put in place29. That Court of Auditors points at 

for  meadow  birds,  dependent  on 

26  NL  indicates  that  the  pressures  under  “natural  processes”  mainly 
are “natural succession”, these are pressures because the succession 
is accelerated due to high nitrogen depositions. NL also indicates that 
invasive species and climate change are not in the top 3 of pressures, 
but also very relevant, because they are hard to deal with. 
27  European  Environment  Agency,  Conservation  status  and  trends  of 
habitats  and  species,  December  2021.  Please  note when  comparing 
the  figures  shown  for  2007-12  and  2013-18  these  may  also  be 
affected by changes of methods or due to better data availability. 

28 Idem. 
29  Partly  as  result  of  the  WFD,  and  related  directives  as  Nitrate 
directive,  the  water  quality 
improved  significantly.  Also  the 
biodiversity  in  the  water.  See  several  recent  publications:  Eindelijk 
goed  nieuws  over  biodiversiteit:  diversiteit  watergebonden  insecten 
neemt toe (h2owaternetwerk.nl) 

Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
                                                                 
 
 
                                                                 
a  major  weakness:  most  measures  are  financial  in 
nature and based on voluntary uptake by farmers. This 
means  that  the  measures 
implemented  are  not 
necessarily  the  best.  The  Dutch  government  has  been 
asked  to  inform  the  Commission  of  the  action  it  will 
take to solve the matter.  

Bringing nature back to agricultural land and restoring 
soil ecosystems 

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 inthe use of more hazardous pesticides;  

-  50%  reduction  in  losses  of  nutrients  from  fertilisers, 
while  ensuring  there  is  no  deterioration  of  soil  fertility 
(which  will  result  in  a  20%  reduction  in  the  use  of 
fertilisers); 

-  bringing  back  at  least  10%  of  agricultural  area  under 
high-diversity landscape features; 

- increasing areas under organic farming to at least 25%. 

Agricultural land  

farming, 

As  shown  in  the  figure  10,  with  an  estimated  3.95%  of 
its  agricultural  area  under  organic 
the 
Netherlands  is  well  below  the  EU  average  of  9,07% 
(2020  data,  Eurostat).  Given  the  benefits  of  organic 
farming,  for  example  in  terms  of  soil  quality  and  its 
positive 
in  reducing  the  use  of  chemical 
pesticides and inorganic fertilisers, extending the Dutch 
areas under organic farming would also contribute to a 
more sustainable food production system. 

impact 

The Netherlands  12 

Figure 10: Share of total utilised agricultural area 
occupied by organic farming, by Member State, 202030 

innovative  and  export-oriented 

The Dutch agricultural sector is characterised as a highly 
productive, 
industry 
with  intensive  agricultural  production  largely  based  on 
lowering  cost  prices  and  encouraging  economies  of 
scale. The transition to a sustainable food system brings 
both  significant  economic  benefits  and  challenges  for 
Dutch farmers. 

The  Netherlands  has  the  highest  greenhouse 
gas  emissions  (CH4  and  N2O)  per  hectare  of 
agricultural  land,  more  than  four  times  higher 
than  the  EU-27  average31.  This  shows  the 
higher intensity of Dutch agricultural activities. 
As  regards  the  Water  Framework  Directive, 
good  status  has  not  yet  been  achieved  for  all 
Dutch  waters,  which  is  largely  due  to  the 
effects of agriculture. In addition, in 2016-2019 
13%  of  groundwater  bodies  were  of  poor 
quality,  with  nitrate  levels  above  the  standard 
of 50  mg/l  laid down in the  Nitrates Directive. 
The nitrogen surplus in the Netherlands is four 
times  higher  than  the  EU  average  at  200  kg  N 
per  hectare  per  year.  Under  the  Farm  to  Fork 
Strategy,  the  Netherlands  should  use  the 
resources provided by the CAP to contribute to 
a  significant  reduction  in  the  use  of  inorganic 
fertilisers  and  manure  (especially  on  sandy 
soils). In addition, the use and risk of pesticides 
(i)  continuing  to 
should  be  reduced  by: 
implement 
non-chemical 
pesticide  and  low  pesticide  input  policies;  and 
(ii)  ensuring  full  implementation  of  integrated 
pesticides management.  

promote 

and 

30 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en (Eurostat, Area under organic farming, February 2022). 
31 Commission SWD (2020) 388 final 

Environmental Implementation Review 2022 – The Netherlands 

 
 
 
                                                                 
This  would  improve  the  status  of  water  bodies  at  the 
end of the programming period and, in addition, reduce 
the air pollution caused by nitrogen and ammonia. 

The  availability  of  agricultural  land  is  under  pressure 
from  urbanisation,  recreation  and  the  need 
for 
renewable energy. The potential for expansion is limited 
by the excess nitrogen/manure and the high density of 
livestock in the Netherlands. Due to the high deposition 
of  nitrogen  (above  critical  deposition  values)  in  Natura 
2000 sites, more effort is needed to protect and restore 
biodiversity  in  nature  reserves  and  on  farmland.  As 
from 
about  40%  of  nitrogen  deposition  comes 
agriculture,  the  agricultural  sector  plays  an  important 
role in addressing this problem. This challenge includes 
reducing ammonia emissions (air pollution contributing 
to nitrogen deposition but also affecting human health), 
which  has  increased  since  2013.  The  Netherlands  is  at 
high  risk  of  non-compliance  with  the  commitments  to 
reduce ammonia emissions. This applies for both 2020-
2029 and from 2030 onwards. 

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 objectives of the Green Deal as well 
as land degradation neutrality by 2030.  

This entails:  

(i) preventing further soil degradation;  

(ii)  making  sustainable  soil  management  the  new 
normal; 

(iii)  taking  action  for  ecosystem  restoration.  As  regards 
the quantitative aspect, land scarcity is a major problem 
in  the  Netherlands,  due  to  the  high  population  density 
(more than four times the EU average of 118/km²). Two 
thirds  of  the  total  area  of  the  Netherlands  is  used  as 
agricultural 
land,  but  due  to  the  high  population 
density,  the  share  of  rural  areas  is  small  (2  %).  The 
decline  in  the  area  of  agricultural  land  is  expected  to 
continue  due  to  increasing  urbanisation  and  the  need 
for space for recreation. 

Soil sealing is also a source of concern; in this respect32, 
degradation  is  influenced  by  the  area  of  soil  that  is 

32 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, 

The Netherlands  13 

sealed  or  artificialised  in  the  Netherlands  (Figure  12). 
The land taken per year in 2012-2018 can be seen as a 
significant  pressure  on  nature  and  biodiversity,  as  well 
as  being  a  change  in  land  use  that  constitutes  an 
environmental  pressure  on  people  living  in  urbanised 
areas. 

The Netherlands ranks  well above the EU average  with 
net  land  take  of  262.5  m2/km2  (EU-27  average:  83.8 
m2/km2). In proportion to its area, the Netherlands was 
one  of  the  two  Member  States  that  saw  the  largest 
amount  of  land  take  between  2000  and  2018.  6.4%  of 
its  soil  was  sealed  or  artificialized  in  2018  (EU-28 
average:  4.2%,  Eurostat)33.  At  the  same  time,  the 
Netherlands  was  among  the  leading  countries  for  the 
increased  re-cultivation  of  land  between  2012  and 
2018.  

In 2018,  the Netherlands updated its reporting on land 
degradation  according  to  the  next  PRAIS3  reporting 
platform34,  including  action  intended  to  achieve  the 
degradation identified. 

Figure 11: Land take and re-cultivation in EU27 
(m2/km2), 2012-201835 

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). 
33 Land take  in Europe — European Environment Agency (europa.eu) 
fig 6 
34 All Reports | Prais3 (unccd.int) 
35  European  Environment  Agency,  Land  Take  in  Europe,  December 
2021. 

Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
 
 
 
                                                                                                      
However,  the  Netherlands  has  not  yet  committed  to 
setting 
land  degradation  neutrality  targets  under 
UNCCD36. 

Contamination  can  severely  reduce  soil  quality  and 
threaten human health and the environment. The latest 
available estimates based on information from Member 
States37 indicate that potentially polluting activities have 
taken  or  are  still  taking  place  on  approximately  2.8 
million  sites  in  the  EU.  At  EU  level,  650  000  of  these 
sites  have  been  registered  in  national  or  regional 
inventories.  65  500  contaminated  sites  have  already 
been  remediated.  The  Netherlands  had  registered  181 
sites  with  either  current  or  past  potentially  polluting 
activities,  and  had  already  remediated  or  applied 
aftercare measures on 83 of these. 

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

As  regards  capacity  building  on  this 
issue,  the 
Netherlands  attended  a  TAIEX-EIR  Peer  to  Peer 
workshop  on  sustainable  urban  development  on  26-27 
March 2019 in Belgium. In addition, a TAIEX-EIR Peer to 
Peer  workshop  on  Maintaining  and  Enhancing 
Ecosystem Services in Urban Regions was carried out on 
4-5 July 2019 in the Netherlands. 

Forests and timber 

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

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

Of  the  27%  of  EU  forest  area  protected  under  the 
Habitats  Directive,  less  than  15%  of  assessments  result 
in  favourable  conservation  status38.  Bad  conservation 
status increased from 27% to 31% in the EU, compared 
to 2015. 

In  the  Netherlands,  forests  cover  8.78%  of  territory39 
and the situation of forest habitats protected under the 
Habitats Directive is particularly worrying as more than 
half  of  the  assessed  protected  forests  have  bad  status 

The Netherlands  14 

and  100%  of  the  assessments  reveal  bad  to  poor 
status40. 

Figure  12:    Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-2018 (% assessments)41 

Under the European Union Timber Regulation (EUTR)42, 
which  prohibits  the  selling  of  illegally  harvested  timber 
in  the  EU,  Member  State  authorities  must  conduct 
regular  checks  on  operators  and  traders,  and  apply 
penalties  in  the  event  of  non-compliance.  With  the 
amendment  of  Article  20  of  the  Regulation,  biennial 
reporting  has  become  annual  and  covers  the  calendar 
year as of 2019. 

Between  March  2017  and  February  2019 
the 
Netherlands  carried  out  83  checks  on  operators 
importing  timber.  It  is  estimated  that  the  Netherlands 
had  100  operators  placing  domestic  timber  and  4  900 
operators placing imported timber on the single market 
during the reporting period. 

The  new  Deforestation  Regulation43  will  repeal  and 
replace  the  EU  Timber  Regulation,  as  the  new 
Deforestation  Regulation  will  essentially  integrate  and 
improve the existing system to check the legality of sold 
and exported timber. 

Invasive alien species (IAS) 

 IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
use, 
sea 
(alongside 
overexploitation, climate change and pollution).  

changes 

land 

and 

in 

36  The LDN Target Setting Programme | UNCCD 
37  Ana  Paya  Perez,  Natalia  Rodriguez  Eugenio  (2018),  Status  of  local 
soil  contamination  in  Europe:  Revision  of  the  indicator  “Progress  in 
the management Contaminated Sites in Europe”. 
38  EEA, State of Nature in the EU 
39 EEA, Forest information system for Europe. 

40 COM SWD (2021) 652 
41  European  Environment  Agency,  Conservation  status  and  trend  in 
conservation status by habitat group - forests, January 2022. 
42 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
43  A  proposal  for  the  Regulation  on  the  making  available  on  the  EU 
market  and  export  of  products  associated  with  deforestation  and 
forest degradation. 

Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
 
                                                                 
Besides  inflicting  major  damage  on  nature  and  the 
economy, many invasive alien species also facilitate the 
outbreak  and  spread  of  infectious  diseases,  posing  a 
threat to humans and wildlife.  

The  implementation  of  the  EU  Invasive  Alien  Species 
Regulation  and  other  relevant 
legislation  must  be 
stepped up.  

The  biodiversity  strategy  for  2030  aims  to  manage 
recognised  invasive  alien  species  and  decrease  the 
number of 'red list' species they threaten by 50%. 

The core of Regulation (EU) 1143/2014 on invasive alien 
species 52  (the  IAS  Regulation)  is  the  list  of  “Invasive 
Alien Species of Union concern”.  

The total number of species) on this list is currently 66, 
of which: 30 animal species and 36 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 report44 on the review of the application 
of  the  IAS  Regulation  for  the  period  2015-2018,  the 
implementation of the IAS Regulation is already starting 
its  objectives  such  as  a  coherent 
to  deliver  on 
framework for addressing IAS at EU level and increased 
awareness  of  the  problem  of  invasive  alien  species, 
including  among  the  public.  At  the  same  time,  the 
above  report  identified  some  challenges  and  areas  for 
for 
improvement.  Given 
deadlines 
that 
implementing  the  various  obligations  of  the 
IAS 
Regulation applied gradually between July 2016 and July 
2019,  it  is  premature  to  draw  conclusions  on  several 
aspects of the implementation of the IAS Regulation. 

the 

According  to  a  2021  report45  on  the  review  of  the 
application of the IAS Regulation, the implementation of 
the  IAS  Regulation  is  already  starting  to  deliver  on  its 
objectives such as a coherent framework for addressing 
IAS at EU level and increased awareness of the problem 
of  invasive  alien  species.  At  the  same  time,  the  above 
for 
report 
for 
improvement.  Given 
deadlines 
implementing  the  various  obligations  of  the 
IAS 
Regulation applied gradually between July 2016 and July 

identified  some  challenges  and  areas 

that 

the 

44  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 
45  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. 

The Netherlands  15 

2019,  it  is  premature  to  draw  conclusions  on  several 
aspects of the implementation of the IAS Regulation.  

A 2021 report  46on the baseline distribution shows that 
of  these  66  species,  37  have  been  observed  in  the 
environment  in  the  Netherlands.  For  their  distribution, 
see Figure 13. 

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

2022 priority actions  

  Ensure  the  completion  of  the  Natura  2000  network 
by the designating the still pending few sites on the 
one  hand,  and  by  adopting  the  overarching  decree 
updating  a  large  number  of  designation  decrees  to 
reflect the more accurate list of species and habitats 
for the sites concerned. This will also ensure that the 
relevant conservation objectives are in place. 
Improve  the  conservation  status  of  habitats  and 
species,  in  particular  by  addressing  the  extremely 
high  pressure  from  agricultural  activities  -  nitrogen 
deposition  being  the  main  cause,    and  from  the 
changes in water regimes.  

 

46  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 – The Netherlands 

 
                                                                 
 
 
 
 
                                                                 
The Netherlands  16 

  Reduce  nutrient  pollution  of  water  and  air,  reduce 
nitrogen deposition in the nitrogen-sensitive Natura 
2000  areas  below  critical  values,  and  contribute  to 
achieving  the  European  Green  Deal  nutrient  loss 
target  in  the  Netherlands  through  well-integrated 
measures  to  support  the  transition  towards  a  more 
sustainable and less intensive agriculture. 

  Contribute  to  the  objective  of  the  European  Green 
Deal  for  organic  farming  by  supporting  conversion 
and conservation schemes.  

the  Commission  GES  Decision, 
requirements  of 
providing  qualitative 
and  quantitative  national 
environmental  objectives  to  be  achieved  for  their 
marine waters. 

Figure 14: Level of adequacy of "good environmental 
status” determination by the Netherlands (ANS region) 
with criteria set under the Commission GES Decision– 
Article 9 (2018 reporting exercise)50 

  Promote 

sustainable 

forest  management  and 
reforestation, while enhancing the multifunctionality 
and  protection  of  forests  and  restoring  forest 
ecosystems. 

Marine ecosystems 

The EU Biodiversity Strategy  2030 aims to substantially 
reduce  the  negative  impacts  on  sensitive  species  and 
habitats  in  marine  ecosystems  and  to  achieve  good 
environmental status as well as eliminate or reduce the 
incidental 
endangered, 
threatened  and  sensitive  species  to  a  level  that  allows 
species recovery and conservation47. 

protected, 

catches 

of 

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

The  Directive  also  required  Member  States  by  15 
October  2018  to  have:  (I)  laid  down  a  set  of  GES 
characteristics  for  each  descriptor  (Article  9);  and  (ii) 
provided  an  initial  assessment  of  their  marine  waters 
(Article 8). The Commission then assesses whether this 
constitutes  an  appropriate  framework  to  meet  the 
requirements of the Directive.  

The  Commission  assessed  the  Netherlands’s  2018 
determinations of GES for each of the 11 descriptors in 
the  Directive48  and  determined 
level  of 
adequacy49. 

their 

A  good  or  very  good  score  indicates  that  the  national 
determinations  of  GES  are  well  aligned  with 

47  The  EU  Common  Fisheries  Policy  (CFP)  aims  to  contribute  to  the 
achievement  of  the  objectives  of  the  environmental  legislation  for 
marine ecosystems. 
48  Annex  I  of  Directive  2008/56/EC  establishing  a  framework  for 
community action in the field of marine environmental policy (Marine 
Strategy Framework Directive), OJ L 164, 25.6.2008, p. 19–40. 
49  This  assessment  was  made  in  relation  to  the  ”Commission  GES 
Decision“, Commission Decision No 2017/848, pp. 43-74. 

The  Netherlands  has  one  marine  sub-region,  ANS-NE 
Atlantic: Greater North Sea. In this marine sub-region, 5 
of  11  determinations  of  GES  were  assessed  as  good  or 
very  good.  The  national  determination  of  GES  by  the 
Netherlands is consistent for 5 out of 11 descriptors. 

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

capabilities 

to  assess 

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

Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
 
 
                                                                 
Figure 15: Level of adequacy of national assessment of 
Netherland’s marine environment (ANS region) with 
criteria set under the Commission GES Decision – 
Article 8 (2018 reporting exercise)51  

considerations  form  the  basis  for  the  2022  priority 
actions. 

2022 priority actions 

The Netherlands  17 

 

  Ensure  regional  cooperation  with  Member  States 
sharing  the  same  marine  (sub)region  to  address 
predominant pressures.  
Implement  the  recommendations  for  each  Member 
State  and  region  made  by  the  Commission53  in  the 
Staff  Working  Documen 
the 
Communication54  on    the  2018  updated  reports  for 
Articles 8, 9 and 10 of the MSFD. 

taccompanying 

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.  

The  Dutch  Atlas  of  Natural  Capital  (ANK)  was  launched 
in  2015.  All  content  has  now  been  translated  into 
English. To improve the quality of data the Netherlands 
Natural  Capital  model  was  developed  based  on  the 
National  Land  Cover  and  Ecosystem  Units  map.  The 
model consists of a set of input maps, a simulation tool 
and output maps which define the relationship between 
the  ecosystems  and  the  services  they  provide.  The 
services are simulated at a 100 and 10 m grid-scale. The 
applicability  of  the  maps  was  tested  in  various  pilots 
studies,  cooperating  with  various  stakeholders.  For 
communication  purposes  a  brochure  on  the  ANK  has 
been developed. 

The  TEEB-city  project  has  delivered  a  tool  which 
calculates  the  monetary  value  of  green  areas  in  cities 
(2016).  This  has  been  further  developed  into  an  high 
resolution  map-based  tool  to  analyse  and  predict  the 
benefits  (and  costs)  of  different  scenario’s  for  green 
infrastructure  in  an  urban  environment:  the  ‘Green 
Benefits  Planner’55,  which  is  being  implemented  in 
green  infrastructure  planning  in  a  growing  number  of 
cities.  The  Netherlands’  Environmental  Assessment 
Agency  (PBL)  conducted  an  extensive  programme  from 
2014-2016  with  conceptual  analysis,  cross-sectoral 
focusing  on  the 
evaluations  and  case-studies  all 
application  of  the  TEEB-model 
  After 
successful  pilots  (phase  I)  in  some  municipalities  and 
provinces,  the  Central  Bureau  for  Statistics  (CBS) 

in  practice. 

A total of 7 descriptors out of 11 were scored as good or 
very  good.  The  Netherlands’s  assessment  of  its  marine 
environment  is consistent  with requirements  set  under 
the Commission GES Decision for 7 of 11 descriptors. 

In the 2019 EIR, the Netherlands received three priority 
actions:  (I)  to  set  targets  for  GES;  (ii)  to  determine 
timelines  for  achieving    GES;  and  (iii)  to  provide  more 
information  about  marine  protection  measures, 
establish  more  measures  that  have  a  direct  impact  on 
level  of 
the  relevant  pressures  and  quantify  the 
pressure 
these 
measures. 

reduction  expected  because  of 

in 

the  Commission’s 

is  needed  to  attain 

As  highlighted 
report  on 
implementing  the  MSFD52,  while  regional  cooperation 
has  improved  since  the  Directive  was  adopted,  more 
cooperation 
full  consistency 
between the regional marine strategies, as required  by 
Directive.  
the 
Furthermore, in March 2022, the 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 
the  Commission  GES  Decision.  The  above 
to 

51  Assessment  carried  out  by  the  European  Commission  of  the  data 
reported by 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.  
52 COM(2020)259 final 

53 SWD(2022)1392. 
54  COM(2022)550. 
55 Groene Baten Planner | Atlas Natuurlijk Kapitaal 

Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
                                                                 
together  with  Wageningen  University  &  Research 
(WUR)  have  developed  a  National  Natural  Capital 
Account,  building  on 
the  SEEA-EEA  and  MAES- 
frameworks.  Eventually  this  led  to  the  first  national 
natural  capital  account  of  the  Netherlands  in  2018, 
which  was  updated  in  2021.  Further  work  is  underway 
to 
improve  and  extend  this  account,  to  test  the 
applicability  in  national  and  regional  planning  and  to 
feed  indicators  in  the  National  Monitor  on  Welbeing 
and performance on the SDG’s. 

In  2016  an  International  conference  on  Natural  Capital 
(“Let’s talk business!”) took place in The Hague. Also the 
WAVES  (Wealth  Accounting  and  the  Valuation  of 
Ecosystem  Services)  policy  forums  in  2016  and  2017 
took place in The Hague. 

In  2018  a  national  guide  was  published  on  accounting 
for  impacts  on  ecosystems  and  ecosystem  services  in 
societal cost-benefit analyses. 

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

Figure 16: ESMERALDA MAES Barometer, January 2016 
- March 202156 

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

The Netherlands  18 

Figure 17: Ecosystem accounting barometer, 
September 202157 

level  of  expertise 

The  Netherlands  has  a  high 
in 
ecosystem  accounting.  This  is  reflected  in  the  high 
number  of  published  accounts.  The  extent  and 
condition  accounts  are  available  on  a  regional  and 
national scale. A wide variety of ecosystem services are 
incorporated  in  their  accounts  on  (I)  ecosystem  assets, 
(ii)  biophysical  and  (iii)  monetary  supply  and  use  for 
ecosystme services. These accounts have been set up in 
2013, 2018 and 2020, thus enabling trend analyses. On 
specific  issues,  accounts  are  published  on  carbon  and 
biodiversity,  and  a  marine  account  at  national  scale  is 
being developed. 

The  Netherlands  has  difficulties  similar  to  the  ones 
often highlighted in international meetings, for example 
during the revision process for the SEEA EA guidelines. It 
is  actively  trying  to  engage  policymakers  and  other 
stakeholders  in  the  accounting  process  and  looking  for 
relevant key indicators and information on the usage of 
the  accounts.  Their  marine  and  biodiversity  accounts 
need  further  development  and  still  have  some  data 
gaps. 

An  important  line  of  action  has  been  to  stimulate 
business and financial institutions to account for natural 
capital 
in  their 
impacts,  dependencies  and  risks 
operations,  in  order  to  fulfill  their  CSR-responsibilities 
and  to  develop 
innovative  and  more  sustainable 
services  and  supplychains.  From  2017  onwards  a 
government 
Capital 
Programme’  was  set  up  and  implemented  by  CSR 
facilitate 
Netherlands 
businesses  in  different  economic  sectors  to  respond  to 
this challenge. Also the development of coöperation on 

‘Societal  Natural 

stimulate  and 

inspire, 

funded 

to 

56 European Commission, Joint Research Centre, Publication Office, EU 
Ecosystem  assessment:  summary  for  policymakers,  page  80,  May 
2021. 

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

Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
 
                                                                 
 
                                                                 
The Netherlands  19 

protocols,  tools  and  data  for  natural  capital  and 
biodiversity-accounting in the financial sector has been 
stronly supported. To this end the Dutch Governement 
also has invested in improving the quality, usability and 
number  of  certified  data  in  the  Ecosystem  Services 
Valuation Database58 (or TEEB-database). 

The  MAIA  project  can  facilitate  exchange  of  methods 
and knowledge between members and the Netherlands 
is eager to support other partners. Other specific needs 
include  developingf  an  improved  viewer  for  interested 
stakeholders who are unable to use the GIS datasets. 

2022 priority actions 

  Support the development of marine account.  
  Expand  the  scale  of  ecosystem  accounting  to  both 
local  and  international  level,  to  cater  the  needs  of 
both local and international stakeholders. 

58  Ecosystem  Services  Valuation  Database  |  Foundation 
Sustainable Development |Environmental Research (esvd.info) 

for 

Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
The Netherlands  20 

3. Zero pollution 

Clean air 

 EU clean air policies and legislation need to significantly 
improve air quality in the EU, moving the EU closer to the 
quality recommended by the WHO and curbing emissions 
of key air pollutants.  

its 

Air  pollution  and 
impacts  on  ecosystems  and 
biodiversity  should  be  further  reduced  with  the  long-
term  aim  of  not  exceeding  critical  loads  and  levels.  This 
requires  strengthening  efforts  to  reach  full  compliance 
with EU clean air legislation and defining strategic targets 
and actions for 2030 and beyond.  

The 2030 zero pollution action plan targets are to reduce 
the health impacts of air pollution by 55% and to reduce 
the EU ecosystems threatened by air pollution by 25%. 

The  EU  has  developed  a  comprehensive  suite  of  air 
quality  legislation,  which  sets  health-based  air  quality 
standards59  and  emissions-reduction  commitments60  by 
Member State for a number of air pollutants. 

Air  quality  in  the  Netherlands  is  generally  good  with 
exceptions.  The  latest  available  annual  estimates  (for 
2019)  by  the  European  Environment  Agency61  point  to 
some 8 900 premature deaths (or 95 200 years of life lost 
(YLL)) 
particulate  matter 
concentrations62, 380 premature deaths (or 4 300 YLL) to 
ozone  concentrations63  and  1  000  premature  death  (10 
700 YLL)  to nitrogen dioxide concentrations64 65. 

attributable 

fine 

to 

commitments    Directive  (NECD)66,  Netherlands  projects 
to  reach  emission  reduction  commitments  for  all  air 
pollutants  covered  by  the  Directive  for  2030  onwards. 
The  projections  however  do  not  demonstrate  reaching  
the  emission  reduction  commitments  for  2020-2029  for 
any  pollutant.    Latest  inventory  data  submitted  by  the 
Netherlands, prior to review by the Commission, indicate 
that  the  Netherlands  is  in  compliance  with  the  emission 
reduction commitments for all pollutants in 2020.   

The Netherlands has submitted its National Air Pollution 
Control  Programme  on  1  April  2019.  In  addition  to  this 
National  Programme,  the  Netherlands  takes  action  to 
permanently improve air quality by means of a Clean Air 
Agreement  (in  Dutch:  Schone  Lucht  Akkoord,  “SLA”), 
January  2020  by  the  national 
which  was  signed 
government  and  a 
large  number  of  provinces  and 
municipalities. The SLA is in effect until 2030, and aims at 
working  towards  the  WHO-recommended 
limits  for 
nitrogen dioxide and fine particulate matter. It also aims 
to  reach  health  gains  of  at  least  50%  from  domestic 
sources relative to 2016. 

Figure 18: Emissions trends for main pollutants/ GDP 
2005-2019 in the Netherlands, 2005-201967 

Emissions  of  several  air  pollutants  have  decreased 
significantly in the Netherlands over the last years, while 
GDP  growth  continued  (see  graph).  According  to  the 
latest  air  pollutant  emission  projections  as  submitted 
under  Article  10(2)  of  the  national  emission  reduction 

59 European Commission, 2016. Air Quality Standards 
60 European Commission, Reduction of National Emissions.  
61  European  Environment  Agency,  Air  Quality  in  Europe  –2021  Raport. 
Please  see  details 
in  this  report  as  regards  the  underpinning 
methodology, p.106 
62  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. Particular 
matter is emitted from many human sources, including combustion. 
63 Low-level ozone is produced by photochemical action on pollution.  
64  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).  
65  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.     

66 Directive 2016/2284/EU. 
67 European Environment Agency. 

Environmental Implementation Review 2022  – The Netherlands 

 
                                                                 
 
 
                                                                 
The Netherlands  21 

Figure 19: PM2.5 and NOx emissions by sector in the 
Netherlands, 201968 

For  2020,  no  exceedances  above  the  limit  values  set  by 
the  ambient  air  quality  Directive  were  registered. 
However,  for  several  air  quality  zones  the  target  values 
regarding ozone concentration have not been met69. 

The  nitrogen  deposition  stems  mainly  from  agriculture 
and  traffic  and  specific  measures  still  need  to  be 
discussed.  The  Netherlands  needs  to  (I)  substantially 
reinforce  its  Nitrate  Action  Programme  with  measures 
that match the severity and the urgency of the situation, 
in line with their obligations under the Nitrates Directive, 
and  (ii)  ensure  they  meet    the  objectives  of  the  Water 
Framework Directive, and Natura 2000 legislation. 

In  the  2019  EIR,  the  Netherlands  received  two  priority 
actions.  The  first  was  related  to  taking  specific  actions 

68 European Environment Agengy. 
69  European Environment Agency, Eionet Central Data Repository. 

under  the  National  Air  Pollution  Control  Programme 
(NAPCP)  to  reduce  the  main  emissions  sources,  with 
particular  attention  to  reducing  PM2.5  and  ammonia. 
The  second  was  to  reduce  nitrogen  oxide  (NOx) 
emissions  and  nitrogen  dioxide  (NO2)  concentrations  by 
(among  other 
transport 
emissions  —  in  particular  in  urban  areas  or  using  fiscal 
incentives.  Only  limited  progress  has  been  achieved  for 
both. 

reducing 

further 

things) 

Ammonia  emissions  are  of  particular  importance  for 
continued  discussion  and  prioritisation  since  they  are 
reported  to  have  remained  almost  stable  since  2010. 
Tackling  ammonia  emissions  is  important  for  the  Dutch 
ambition to reach the WHO guideline levels of particulate 
matter,  as  ammonia 
is  a  precursor  for  secondary 
particulate matter. These emissions are also important to 
address  for  the  sake  of  the  overall  nitrogen  pollution 
situation.  The  Commission  recently  recommended  that 
the  Netherlands  prioritise  ammonia  reduction  measures 
as  part  of  its  new  national  CAP  strategic  plan.  The 
Netherlands has a high share of intensive farming with a 
high density of livestock units as well as energy-intensive 
greenhouse 
livestock 
farming  are  found  to  cause  11%  of  the  health  effects 
attributable  to  national  air  pollution  according  to  the 
Clean Air Agreement analysis70. 

installations.  Emissions 

from 

2022 priority actions 

  Take  action  towards  reducing  the  main  emission 
sources,  as  part  of  the  National  Air  Pollution  Control 
Programme. 

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

Industrial emissions 

 The main objectives of EU policy on industrial emissions 
are to:  

(i) protect air, water and soil;  

(ii) prevent and manage waste;  

(iii) improve energy and resource efficiency;  

(iv) clean up contaminated sites.  

70  Clean  Air  Dialogue  NL 
https://ec.europa.eu/environment/air/pdf/CAD_NLJoint_Conclusions-
17-18Feb2021.pdf 

Joint  Conclusions 

(17-18.2.2021): 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
                                                                 
                                                                 
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  Directive71  (IED).  The  Commission 
tabled  a  proposal  in  April  202272.  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 below of the industrial activities regulated 
by  the  Industrial  Emissions  Directive  is  based  on  data 
reported to the EU Registry (2018)73. 

In  the  Netherlands,  some  4 000  industrial  installations 
are required to have a permit based on the Directive. The 
distribution of installations is shown in the Figure below. 
This  is  an  increase  of  almost  500  installations  since  the 
the  waste 
last 
management  sector and the  intensive rearing of poultry 
or pigs. 

report,  mostly  associated  with 

The  industrial  sectors  in  the  Netherlands  with  most  IED 
installations in 2018 are intensive rearing of poultry and 
pigs (60%), followed by the waste management, including 
landfills (22%), the food and drink industry (5%) and the 
chemicals industry (4%). 

Figure  20:  Number  of  IED  industrial  installations  per 
sector in the Netherlands, 201874 

The Netherlands  22 

industrial  sectors 

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

 

 

 

 

the  metal  sector  for  emissions  of  heavy  metals 
to  air,  such  as  Zinc  (Zn),  Lead  (Pb),  Nickel  (NI), 
Cadmium (Cd) and Arsenic (As);  
coating and other solvents use for non-methane 
volatile organic compounds (NMVOC);  
intensive rearing of poultry or pigs for ammonia 
(NH3) 
the  waste  management  sector  for  emissions  of 
dioxins.  

The breakdown is shown in the following figure. 

71  Directive  2010/75/EU  covers  industrial  activities  carried  out  above 
certain thresholds. It covers energy industry, metal production, mineral 
and chemical industry and waste management, as well as a wide range 
of  industrial  and  agricultural  sectors  (e.g.  intensive  rearing  of  pig  and 
poultry, pulp and paper production, painting and cleaning). 
72  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). 
73  European Environment Agency, European Industrial Emissions Portal. 
74  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal (data retrieved on 3 November 2021). 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
 
 
 
Figure 21: Emissions to air from IED sectors and rest of 
national total air emissions in the Netherlands, 201875 

Figure 22: Relative releases to water from industry in 
the Netherlands, 201878 

The Netherlands  23 

Noted  that  according  to  the  information  reported  into  
the  European  Pollutant  Release  and  Transfer  Register, 
only  3%  of  the  installations  carrying  out  such  activity  in 
the Netherlands report ammonia emissions, whereas this 
ratio  is  40%  inoaverage  at  EU-27  level.  This  suggests 
underreporting. 

In 2017, one facility in the Netherlands was identified in 
the  top  30  of  facilities  in  the  Register  for  absolute 
damage  costs  from  emissions  of  the  main  air  pollutants 
and  greenhouse  gases  in  the  EU76  (Tata  Steel  Ijmuiden 
BV).  The  Dutch  competent  authority  also 
identified 
deposition  of  heavy  metals  and  polycyclic  aromatic 
hydrocarbons  (PAHs) 
in  the  neighbourhood  of  the 
installation77. 

The environmental burdens from industrial  emissions to 
water  mainly  result  from  (I)  waste  management  for 
nitrogen,  phosphorous,  total  organic  carbon  and  heavy 
metals,  and 
for  polycyclic  aromatic 
hydrocarbons (PAHs). The breakdown, based on the  data 
in the Register, is presented in the figure below. 

(ii)  refineries 

inspection, 

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. 
This empowers both the public and NGOs to ensure that 
permits  are  appropriately  granted  and  the  conditions  in 
these  permits  are  complied  with.  As  part  of 
environmental 
authorities 
undertake  site  visits  to  IED  installations  to  take  samples 
and to gather necessary information. According to Article 
23(4) of the IED, site visits must be made between once a 
year  and  once  every  3  years,  depending  on  the 
environmental  risks  posed  by  the  installations.  In  2018 
the  Netherlands  undertook  2 624  site  visits,  mostly  to 
installations  in  the  waste  management  sector  (39%), 
followed by the chemical sector (17%) and the intensive 
rearing of poultry or pigs (15%). 

competent 

75  European  Environment  Agency,  LRTAP,  Air  pollutant  emissions  data 
viewer  (Gothenburg  Protocol,  LRTAP  Convention)  1990-2019  (data 
retrieved on 3 November 2021). 
76   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  42, 
p.129 and table 44, p.139. 
77 
https://www.rivm.nl/publicaties/depositieonderzoek-ijmond-2020-
monstername-analyse-en-risicobeoordeling-van-pak-en 

2021-0110, 

report 

RIVM 

78  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 – The Netherlands 

 
 
 
 
                                                                 
 
 
 
                                                                 
Figure 23: Number of inspections in IED installations in 
the Netherlands in 201879 

Major industrial accidents prevention – 
SEVESO 

The Netherlands  24 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals;  
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment;  
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents.  
The  cornerstone  of  the  policy  is  Directive  2012/18/EU 
(the Seveso-III Directive)81.  

The overview below of industrial plants regulated by the 
Seveso-III  Directive,  (‘Seveso  establishments’),  is  based 
on data reported to the eSPIRS database (2018)82 and the 
Netherlands report on the implementation of the Seveso-
III Directive for 2015-201883. 

the 

396 

(LTE) 

among 

the  Netherlands, 

Seveso 
In 
lower-tier 
establishments,  136  are  categorised  as 
establishments 
upper-tier 
and 
establishments  (UTE)  –  based  on  the  quantity  of 
hazardous  substances  likely  to  be  present.  The  UTE  are 
subject to more stringent requirements. The evolution of 
the  number  of  Seveso  establishments  is  presented  in 
Figure 24. 

260 

as 

Figure 24: Number of Seveso establishments in the 
Netherlands, 2011, 2014 and 201884  

According  to  the  Netherlands,  the  External  Emergency 
Plan (EEP) is required for 256 UTE. In 2018, 236 UTE had a 
plan  and  236  of  these  had  been  tested  over  the  last  3 
years. The summary is shown in Figure 29. Creating EEPs 
is essential for allowing proper preparation and effective 

81  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances. 
82 European Commission, Seveso Plants Information Retrieval System. 
83 As provided for by Article 21(2) of the Seveso-III Directive 
84 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. 

The  development  of  best  available  techniques  (BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  a  good  collaboration  between  stakeholders  and 
enables  a  better  implementation  of  the  IED80.  Since  the 
last EIR report, the Commission adopted BAT conclusions 
for  (i)  waste  Incineration,  (ii)  the  food,  drink  and  milk 
industries  and  (iii)  surface  treatment  using  organic 
solvents including wood and wood products preservation 
with chemicals. 

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

In  2019,  the  Netherlands  received  priority  actions  to 
review  permits  to  ensure  they  comply  with  the  new 
adopted  BAT  conclusions  and  to  strengthen  control  and 
enforcement  to  ensure  compliance  with  the  BAT 
conclusions. These actions have been followed up by the 
Commission through the reporting of the Netherlands to 
the  EU  Registry  and  there  were  no  findings  indicating  a 
systematic  breach  of  EU  law.  The  Netherlands  also 
received  priority  actions  to  address  pollution  (e.g.  dust) 
from  certain  activities,  and  take  actions  to  improve  IED 
and EPRTR reporting, specifically for intensive rearing of 
poultry or pigs.  These two actions are still relevant, the 
first one especially for the metal sector. 

2022 priority actions 

  Address air pollution from the metal sector, especially 

from the Tata Steel plant. 
Improve the reporting to the E-PRTR.  

 

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

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
                                                                 
 
 
                                                                 
implementation  of  the  necessary  action  to  protect  the 
environment and the population, in the event of a major 
industrial accident. 

  Strengthen  control  and  enforcement  to  ensure 
compliance  with  Seveso-III  Directive  provisions, 
especially on EEP. 

The Netherlands  25 

Figure 25: Situation regarding EEPs in the Netherlands, 
201885 

The  information  for  the  public  referred  to  in  annex  V  of 
the Seveso-III Directive is permanently available for 100% 
of  Seveso  establishments  in  Netherlands.  This  applies  – 
especially to how the public concerned will be warned in 
the event of a major accident; the appropriate behaviour 
to take in the event of a major accident; and the date of 
the last site visit. 

The  share  of  UTE  for  which  information  on  safety 
measures  and  requisite  behaviours  were  actively  made 
available  to  the  public  in  recent  years  are  presented  in 
Figure 30. 

Figure 26: Share of UTE for which information on safety 
measures and requisite behaviours were actively made 
available to the public in the Netherlands, 2011, 2014 
and 201886 

2022 priority action 

85 Idem. 
86 Idem. 

Noise 

The  Environmental  Noise  Directive87  provides  for  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  exposure  to  environmental  noise, 
although  it  does  not  set  noise  limits  as  such.  The  main 
instruments  it  uses  in  this  respect  are  strategic  noise 
mapping  and  planning.    A  relevant  2030  zero  pollution 
action  plan  target  is  a  reduction  by  30%  of  the  share  of 
people 
transport  noise 
compared to 2017.  

chronically  disturbed  by 

Excessive noise from aircraft, railways and roads is one of 
the  main  causes  of  environmental  health‐related  issues 
in  the  EU.  It  produces  ischaemic  heart  disease,  strokes, 
interrupted sleep, cognitive impairment and stress88 . 

In  the  Netherlands,  based  on  a  limited  set  of  data89, 
environmental  noise  is  estimated  to  cause  at  least 
around  150  premature  deaths  and  1  200  cases  of 
ischaemic heart disease annually90. Moreover, some 110 
the 
000  people  suffer 
Netherlands,  the  number  of  people  exposed  to  noise 
increased by approximately 5% between 2012 and 2017. 

from  disturbed  sleep. 

In 

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

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  and  fresh  waters 
(including  surface  and  ground  waters)  be  significantly 
reduced.  Achieving,  maintaining  or  enhancing  a  good 
status  of  water  bodies  as  defined  by  the  Water 
Framework Directive  will  ensure that EU citizens benefit 
from good quality and safe drinking and bathing water. It 

: (i) the  data 

87 Directive 2002/49/EC 
88 WHO 2018, Environmental Noise Guidelines for the European Region 
89  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 
90  These  figures  are  an  estimation  by  the  European  Environmental 
Agency  based on 
reported  by  Member  States 
on noise exposure  covered  by  Directive  2002/49/EC; (ii) ETC/ATNI, 
Environmental Noise Directive 
the 
2021, Noise indicators 
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.  

Pollution; (iii) the methodology 

health 

under 

for 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
 
 
 
                                                                 
                                                                 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

Water Framework Directive 

is 

(WFD)91 

The  Water  Framework  Directive 
the 
cornerstone of the EU water policy in the 21st century92. 
The  WFD  and  other  water-related  legislation93  set  the 
framework 
integrated  water 
sustainable  and 
management, which aims at a high level of protection for 
water resources, prevention of further deterioration and 
restoration to good status. 

for 

By March 2022, Member States have to report the third 
generation  of  River  Basin  Management  Plans  (RBMPs) 
under  the  WFD.  The  Netherlands  has  recently  adopted 
and  reported  the  third  RBMPs.  The  Commission  will 
assess  the  reported  status  and  progress,  checking  how 
the  findings  identified  in  the  assessment  of  the  second 
RBMPs94 have been addressed.  

It 

includes  an 

The Commission also published in December 2021 the 6th 
Implementation  Report95. 
interim 
assessment  on  progress  of  the  implementation  of  the 
Programmes of Measures and on monitoring of the new 
priority  substances.  The  assessment  report  for  the 
Netherlands96  showed  that  measures  as  foreseen  in  the 
RBMP  are  being  implemented  and  are  effective  in  the 
sense  that  progress  is  being  made,  but  the  pace  of 
progress is such that much remains to be accomplished in 
the 2021-2027 cycle. Pressures from diffuse sources and 
hydromorphological  pressures  in  the  Rhine  and  Meuse 
basin  in  particular  are  persistent.  Water  abstraction 
pressures,  although  not  very  commonly  identified  as  a 
pressure, are even expected to worsen in the Meuse and 
Rhine basin. 

91 The Water Framework Directive (2000/60/EC). 
92  EU Water Policy. 
93  This 
includes  the  Groundwater  Directive  (2006/118/EC),  the 
Environmental  Quality  Standards  Directive  (2008/105/EC),  the  Floods 
Directive  (2007/60/EC),  the  Bathing  Water  Directive  (2006/7/EC),  the 
Urban  Waste  Water  Treatment  Directive  (91/271/EEC),  the  new 
Drinking  Water  Directive  (2020/2184/EC),  the  Nitrates  Directive 
(91/676/EEC),  the  Marine  Strategy  Framework  Directive  (2008/56/EC), 
the Industrial Emissions Directive (2010/75/EU) and the new Regulation 
on minimum requirements for water reuse (2020/741). 
94  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. 
95 See the 6th Implementation Report of the WFD and FD. 
96  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: The Netherlands, 2022. 

The Netherlands  26 

Based on the 2nd RBMPs reporting and data published in 
202097, 
in the  Netherlands 0.3% of  all  surface  water 
bodies98 reach  good  ecological  status  (with  unknown 
status 0.4%) and only  39.2% have  good  chemical  status 
(with  unknown 9.0%). For  groundwaters,  13%  failed  to 
achieve  good  chemical  status  and  100%  are  in  good 
quantitative status. 

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

Figure 27: Proportion of surface water bodies (rivers, 
lakes, transitional and coastal waters) in less than good 
ecological status per River Basin District, 202199 

The  following  figure  presents  the  percentage of surface 
water  bodies  in the  Netherlands and  other  European 
countries failing to achieve good chemical status.  For the 
Netherlands, the percentage  is 52%, if  we include  water 
bodies  failing  due  to  substances  behaving  as  ubiquitous 
PBTs 
toxic).  Without 
uPBTs,  49%  of  surface  water  bodies  are  failing  good 
chemical status.    

(persistent,  bio-accumulative, 

97 WISE Freshwater (europa.eu) 
98 River, lake, transitional, coastal, territorial 
99 European Environment Agency, 2021. 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
 
 
 
 
                                                                 
Figure 28: Percentage of surface water bodies not 
achieving good chemical status, 2019100 

Figure 29: Water abstraction per sector in the 
Netherlands, 2022102 

The Netherlands  27 

Under the IED framework, it should be stressed that the 
Netherlands  showed  over  the  last  decade  a  significant 
decrease (53.4%) in releases of heavy metals like Cd, Hg, 
Ni,  PL  and  (38%)  in  Total  Organic  Carbon,  TOC  to 
water101. 

Total  water  abstracted  annually  (corresponding  to  the 
2019  baseline)  in the  Netherlands  from  surface  and 
groundwater  sources is 11  600.55 hm3  (EEA,  2022).  The 
percentage for water abstraction per sector is 2.29% for 
agriculture,  10.97%  for  public  water  supply,  45.81%  for 
electricity cooling, 20.97% for manufacturing and 19.95% 
for manufacturing cooling, as illustrated in the following 
Figure.  The  Netherlands uses  a  register to  record  water 
abstractions  that  are  more  than  150.000  m3  per  year. 
Abstractions  for  drinking  water  are  registered  in  the 
Register  of  Protected  Areas. 
groundwater 
abstractions of up to 10 m3 per hour, an exemption from 
the  permit  obligation  may  be  allowed.  For  surface 
waters,  small  abstractions  are  permitted  without 
notification,  as 
is 
available. Mid-sized abstractions have to be notified and 
may  require  a  permit  to  protect  nature  or  buildings. 
Abstractions over 50 m3 per hour require a permit. 

long  as  sufficient  surface  water 

For 

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

In  the  Netherlands, the  water  exploitation  index  plus 
(WEI+)103 is 4.15%, 
20% 
the 
that is generally considered  an 
indication  of  water 
scarcity104. The  Netherlands is  ranked 12rd  (from  high  to 
low score) in the EU level in terms of WEI+. 

below 

well 

Figure 30 : Water exploitation index plus (WEI+) Inside 
EU, 2017105 

Floods Directive 

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

The  assessment  report106  showed  that  the  PFRA  is 
balanced  with  providing  sufficient  information  on  the 

102  European  Environment  Agency,  Water  abstraction  by  source  and 
economic sector in Europe, 2022. 
103 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. 
104  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. 
105 European Environment Agency, Water exploitation Index Plus, 2022. 
106  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
                                                                 
 
 
 
 
                                                                 
 
The Netherlands  28 

Figure 31: Bathing water quality in Europe in the 2020 
season110 

methodology and actual content on the flood risks in the 
different  units  of  management  (UoMs).  The  description 
of past floods is to a large extent based upon quantitative 
information.  A  consistent  national  strategy  to  deal  with 
(future)  flood  risks  has  been  implemented  and  climate 
change  was  taken  into  consideration.  The  assessment 
identified  that  the  methodology  for  evaluating  floods 
could  be  refined  to  reflect  the  differentiation  between 
past and future floods. 

adopted 

Netherlands has recently 

and 
The 
of flood 
reported the second generation 
risk management 
the Floods 
Directive.  The European  Commission will assess  progress 
since  the  adoption  of  the first Plan  and  publish  a  new 
report, as it did in 2019.  

(FRMPs) under 

plans 

Drinking water Directive 

As  regards  the  drinking  water  Directive107,  no  new 
assessment  of  the  quality  of  drinking  water  is  available 
since  the  2019 EIR. The quality of drinking water in  the 
Netherlands  has  not  been  indicated  as  an  area  of 
concern.  

Figure 32: The Netherlands, bathing water quality 2017-
2020111 

The  recast  Directive  108entered  into  force  on  12  January 
2021  and  Member  States  have  until  12  January  2023  to 
transpose 
legal  system.  The 
Netherlands  will  have  to  comply  with  these  reviewed 
quality standards. 

into  their  national 

it 

Bathing water Directive 

Regarding  the  bathing  water  Directive,  Figure  31  shows 
that in 2020, out of the 736 Dutch bathing waters, 73.8%) 
%  were  of  excellent  quality,109.  Detailed  information  on 
Dutch bathing waters is available. 

Nitrates Directive 

The Netherlands has a very high livestock pressure, and a 
high surplus of nitrogen. The phosphorus surplus remains 
limited. There is a well-developed network of monitoring 
stations.  There  are  groundwater  hotspots  with  nitrate 
concentration  >  50  mg/l  or  which  have  an  increasing 
trend,  in  particular  in  the  southern  and  central  sand 
regions and the loess region. A very high  number of the 
surface waters are found to be eutrophic. 

110  European  Environment  Agency,  State  of  bathing  waters  in  2020, 
2022. 
111  European  Environment  Agency,  European  Bathing  Water  Quality  in 
2017, 2018, 2019, 2020. 

Identification  of  Areas  of  Potential  Significant  Flood  Risk  under  the 
Floods Directive : Member State : The Netherlands, 2022 
107 OJ L 330, 5.12.1998, p. 32–54. 
108 OJ L 435, 23.12.2020, p. 1–62. 
109  European  Environment  Agency,  2021.  State  of  bathing  water  — 
European Environment Agency (europa.eu)  , p. 17. 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                                                        
 
 
 
                                                                 
The  Netherlands    recently  adopted  its  seventh  Nitrate 
Action Programme for the period 2022-2025. 

The  Commission  recommends  that  the  Netherlands 
reinforce  its  action  programme  to  (I)  reduce  nitrate 
pollution  in  particular  in  the  ground  waters  of  the  sand 
and loess regions, (ii) tackle eutrophication and (iii) help 
farmers  switch  to  more  sustainable  and  less  intensive 
production.  

According to the last report on the implementation of the 
Nitrates  Directive,  covering  2016-2019112,  groundwater 
quality  has  been  degraded  as  compared  to  the  previous 
reporting  period,  with  the  percentage  of  stations 
reaching  or  exceeding  50  mg  nitrate  per  litre  having 
increased to 14.1%. This can be related to the drought in 
the year in 2018. 

Urban Waste Water Treatment  

The  Netherlands  demonstrates  excellent 
levels  of 
compliance  with  the  Urban  Wastewater  Treatment 
Directive. Overall, in the Netherlands 100 % of the waste 
water 
is  collected  and  undergoes  more  stringent 
treatment. 

Figure 33: Proportion of urban waste water that meets 
all requirements of the urban wastewater treatment 
Directive (collection, biological treatment, biological 
treatment with nitrogen and/or phosphorus removal) in 
compliant urban areas of the Directive (‘compliance 
rate’), 2018113 

2022 priority actions 

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

  Continue  current  efforts  to  further  reduce  nitrates 
pollution from agriculture in groundwater and step up 
efforts  to ensure the implementation of measures to 

112     Commission Report on the implementation of the Nitrates Directive 
for the period 2016-2019 
113 European Commission, WISE Freshwater, 2021.  

The Netherlands  29 

ensure the timely achievement of the objective under 
the water framework Directive. 
Improve  the  coordinated  implementation  between 
water, marine and nature policies. 

 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects  on  human  health  and  the  environment.  In 
October  2020  the  Commission published  its  Chemicals 
Strategy  for  Sustainability  /  Towards  a  Toxic-Free 
environment114,  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. 

legislation115 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.  

of 

and 

the  Member 

In  December  2020, 

Labelling  and  Packaging 

States’ 
enforcement 

Since  2007  the  Commission  has  gathered  information 
on  the  enforcement  of 
  the  Regulation  on  the 
Registration, Evaluation, Authorisation and Restriction of 
Chemicals  (‘the  REACH  Regulation’)  and  the  Regulation 
on  Classification, 
(‘CLP 
the  Commission 
Regulation’). 
the 
reports  on 
assessed 
implementation 
these 
Regulations116, in line with REACH Article 117(1) and CLP 
Article  46(2).  According  to  the  latest  available  data, 
national enforcement structures have not changed much. 
However,  it  is  apparent  from  this  report  that  there  are 
still many disparities in the implementation of the REACH 
and  CLP  Regulations  and  notably  in  the  area  of  the  law 
enforcement.  Recorded  compliance  levels  seem  to  be 
quite stable over time, but with a slight worsening trend 
likely  due  to:  (i)  enforcement  authorities  being  more 
effective in detecting non-compliant products/companies 
and  (ii)  more  non-compliant  products  being  put  on  the 
EU market. 

In August 2021, the Commission published a measurable 
assessment  of  the  enforcement117  of  the  two  main  EU 
Regulations on chemicals (REACH and CLP) using a set of 
indicators on different aspects of enforcement. 

114 COM(2020) 667 final 
115 REACH: OJ L 396, 30.12.2006, p.1. -  CLP: OJ L 252, 31.12.2006, p.1 
116 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu) 
117  European  Commission,  REACH  and  CLP  enforcement:  EU  level 
enforcement indicators 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
                                                                 
                                                                 
The Netherlands  30 

Responsibility for checking compliance with REACH in the 
Netherlands lies with the following authorities118:  

  Dutch  Food  and  Consumer  Product  Safety  Authority 

 

(NVWA) and with the CLP Regulation as well 
Inspectorate  for  Human  Environment  and  Transport 
(ILT) and with the CLP Regulation as well 

is still not sufficient for some specific tasks under REACH, 
namely in relation to risk management and some specific 
areas  of  concern  such  as  nanomaterials  and  endocrine 
disruptors.  The  percentage  of  non-compliance  cases  out 
of the total number of REACH and CLP controls,  is almost 
the EU average121. 

  Labour Inspectorate (ISZW) 
  State Supervision of Mines (SodM) 
  Customs 

The Netherlands has devised and fully implemented both 
REACH and CLP enforcement strategies119.  

The content of the REACH enforcement strategy consists 
of a mixture of general activities and activities focused on 
specific target groups. Its prioritisation is based on:  

 

 
 

The  year  in  which  the  various  REACH  articles 
enter into force;  
the priority these articles have been given;  
information  on  unknown  or  nonorganised 
businesses  in  the  supply  chain  in  specific  target 
groups.  

A  mixture  of  enforcement  tools  to  be  used  is  included, 
ranging  from  information  and  compliance  assistance  to 
enforcement and sanctions.  
The CLP enforcement strategy is based on risk analysis of 
the effect and likelihood of target  groups not  complying 
with 
Its  prioritisation  of  enforcement 
activities is based on the risk analysis, and refined on the 
basis of further target group analysis. 

legislation. 

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

to 

and 

allocated 

In  the  Netherlands  some  20-25  inspectors  were  (partly) 
involved in REACH enforcement. No other quantification 
REACH 
is 
CLP 
enforcement120. Accordingly, 
  REACH  controls  during 
2019  remain  770  and  CLP  controls  93. The  Dutch 
competent authorities did not specify how many of these 
controls  were  proactive  (inspections)  or  reactive/non-
to 
(investigations 
routine 
complaints, accidents and referrals).  Although the actual 
level of expertise has increased since the last reporting, it 

response 

controls 

in 

Figure 34: Percentage of non-compliance cases out of 
the total number of REACH and CLP controls during 
2019 per Member State and compared to the EU 
average122 

2022 priority actions 

  Upgrade 

the 

implementation  and  enforcement 
administrative  capacities,  towards  a  zero  tolerance 
for non-compliance. 

118  European Commission, Final Report, on the operationof REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 70 
119 European Commission, Final Report, on the operationof  REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 76 
120 European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 75. 

121  European Commission, Final Report, on the operation of REACH and 
CLP, Final report_REACH-CLP MS reporting_2020.pdf (europa.eu), p. 88. 
122 European Commission, Final report, on the operation of REACH-CLP, 
p. 87-88, 2022. 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
 
 
 
 
                                                                 
The Netherlands  31 

4. Climate action 

will be required to adopt national strategies, and the 
EU will regularly assess progress as part of its overall 
governance  on  climate  action.  The  updated  EU 
adaptation strategy, published in February 2021, sets 
out  how  the  EU  can  adapt  to  the  unavoidable 
impacts  of  climate  change  and  become  climate 
resilient by 2050. 

Key national climate policies and strategies  

the 

long-term 

The  Netherlands  has  an  integrated  National  Energy 
and Climate Plan (NECP) for 2021-2030. The work is 
consistent  with 
strategy.  The 
Netherlands  is  bound  to  reaching  climate  neutrality 
in  line  with  the  EU  general  target.  The  national 
objective is to reduce emissions by 49 % (compared 
to  1990)  by  2030  and  become  climate  neutral  by 
2050.  The  Netherlands  has  a  national  Climate  Law, 
Supreme  Court  case  law,  and  a  political  consensus 
which binds it to climate policy objectives. 

The Netherlands is expected  to publish its Recovery 
and  Resilience  Plan,  detailing  the  investment  in  the 
climate  and  energy  transition  (more  details 
in 
Chapter 5). 

Monitoring  of  the  National  Climate  Adaptation 
Strategy  started  in  autumn  2021,  based  on  a  plan 
developed  in  2019-2020.  It  entails  monitoring  the 
progress  of 
implementation  programme, 
monitoring  the  extent  to  which  climate  adaptation 
measures are effective reducing risks and monitoring 
the  development  of  climate  change  risks  to  all 
sectors. 

the 

Between 1990 and 2020, economy wide greenhouse 
gas emissions in the Netherlands decreased by  24%. 
The  country’s  greenhouse  gas  emission  intensity  is 
smaller  than  the  EU’s  average,  but  its  per  capita 
emissions remain high. 

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

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

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

climate 

legislation 

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

For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared to 2010123 and sets binding GHG emission 
standards  for  different  vehicle  categories124.  Under 
the F-gas Regulation, the EU’s F-gas emissions will be 
cut  by  two  thirds  by  2030  compared  with  2014 
levels. 

From  2021,  emissions  and  removals  of  GHG  from 
Land  Use  Change  and  Forestry  (LULUCF)  have  been 
included in the EU emission reduction efforts. 

The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States 
are  required  to  report  on  their  national  adaptation 
policies125  as  the  EU  Climate  Law  recognises 
adaptation  as  a  key  component  of  the  long-term 
global  response  to  climate  change.  Member  States 

123  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. 
124 Regulation (EU) 2019/631 
125 Article 29 of Regulation (EU) 2018/1999. 

 Environmental Implementation Review 2022 – The Netherlands 

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

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

The Netherlands  32 

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, the Netherlands has a target to 
reduce  greenhouse  gas  emissions  in  the  non-ETS 
sectors  (buildings,  road  and  domestic  maritime 
transport, agriculture, waste and small industries) by 
16  %  by  2020  and  36%  by  2030  compared  to  2005 
levels.  The  Netherlands  has  largely  overachieved  its 
2020 target. 

In  its  NECP,  the  Netherlands  intends  to  meet  its 
current ESR target for 2030 of -36%. 

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

Key sectoral developments 

On  road  transport  the  greenhouse  gas  intensity  of 
vehicle  fuels  in  the  Netherlands  decreased  by  5.7% 
from  2010  to  2019,  and  the  country  is  close  to 
achieving  the  current  EU-wide  reduction  target  of 
6% by 2020.  

There  are  several  types  of  action  that  Member 
States can take in this regard, for example: (I) further 
expanding the use of electricity in road transport; (ii) 
supporting  the  use  of  biofuels,  and  advanced 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
 
in  particular, 

the 
biofuels 
development and deployment of renewable fuels of 
non-biological  origin  and  (iv)  reducing  upstream 
emissions before refining processes. 

incentivizing 

(iii) 

to  2005.  The  NECP 

Road transport emissions in 2019 in the Netherlands 
represented  15%  of  the  total  greenhouse  gas 
emissions,  and  they  have  decreased  by  12% 
compared 
the 
importance  of  electric  vehicles,  based  on  smarter 
energy 
smart  grids.  The 
Netherlands  has  a 
(non-binding)  objective  of 
reaching  100%  zero  emissions  in  new  car  sales  by 
2030.  

infrastructure  and 

stresses 

Figure 38: Greenhouse gas emissions by sector in 
the Netherlands126 – historical emissions 1990-
2019, projections 2021-2030127 

a 

ongoing 

scale-up 

On buildings, more deep renovations will be needed 
beyond 
efficiency 
of 
improvements.  In  the  NECP,  the  Netherlands  has 
provided information on buildings, such as indicative 
milestones for 2030, 2040 and 2050 in terms of CO2 
emission  reductions,  wider  benefits  and  new 
measures planned for the coming years.  

To reduce emissions in agriculture, the most urgent 
priority is reducing nitrogen emissions, as the limited 
emissions space has led to legal stalling of projects in 
to  support  sustainable 
all  sectors. 

  Policies 

126  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. 
127  European  Environmental  Agency,  Total  GHG  trends  and 
projections. 

The Netherlands  33 

agriculture  in  the  broad  sense,  due  to  the  nitrogen 
issue, might have co-benefits for climate.  

In  the  Land  Use,  Land  Use  Change  and  Forestry 
(LULUCF)  sector,  the  Netherlands  projects  a  further 
in  net  removals  by  2030.  Reported 
increase 
quantities  under  the  Kyoto  Protocol  for  the  LULUCF 
sector  in  the  Netherlands  show  net  removals,  on 
average,  of  -0.5  Mt  CO2-eq  for  the  period  2013  to 
2019. In this regard, the Netherlands contribute with 
0.2% to the annual average sink of -344.9 Mt CO2-eq 
of the EU-27. Accounting for the same period depicts 
net  debits,  on  average,  of  0.5  Mt  CO2-eq,  which 
represents  -0.5%  of  the  EU-27  accounted  sink  of 
115.0  Mt  CO2-eq.  Reported  net  removals  show  a 
declining  trend;  the  same  pattern  is  replicated  for 
accounted  net  debits  with  an  increasing  tendency. 
The Netherlands is one of six EU Member States with 
average net debits and one of 14 EU Member States 
that  show  net  debits  for  at  least  one  year  in  this 
preliminary accounting exercise. 

Figure  39:  Reported  and  accounted  emissions  and 
removals from LULUCF in the Netherlands  

Use of revenues from the auctioning of EU 
ETS allowances 

total 

revenues 

The 
from  auctioning  emission 
allowances  under  the  EU  ETS  over  the  years  2012-
2021 were nearly EUR 3,1 billion. In the Netherlands, 
auctioning  revenues  go  to  the  national  general 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
 
 
 
The Netherlands  34 

budget  which  is  to  finance  climate  and  energy 
projects.  The  Netherlands  spends  more  on  climate 
change and energy than their auctioning revenues. 

2022 priority actions 

 

the  uptake  of 

Increase 
renewables.  The 
Netherlands intends to considerably increase the 
renewable  energy,  with  a 
deployment  of 
particular  focus  on  offshore  wind,  heating  and 
cooling  in  buildings,  and  renewable,  low-carbon 
hydrogen  and  green  gases.  These  efforts  will 
allow  the  Netherlands  to  significantly  contribute 
to the country’s green transition. 

  Accelerate 

sustainable 

transport  based  on 
smarter  energy  infrastructure  and  smart  grids. 
the 
Increase  use  of  electric  vehicles  and 
deployment of charging infrastructure 
Increase energy efficiency and renewable energy 
in 
through  extensive 
sector 
renovation,  which  will  also  address  energy 
poverty and create more green jobs. 

the  building 

 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
The Netherlands  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 gap between countries. 

Post-2020,  environmental  measures  will  also  be 
supported by the  EU’s  COVID-19 Recovery  Fund (via  the 
Recovery  and  Resilience  Facility  (RRF))  and  the  ‘do  no 
significant  harm’  (DNSH)  principle  which  runs  across  the 
EU  budget.  The  renewed  commitments  made  at  COP26 
(Glasgow, Oct-Nov 2021) and the Biodiversity Convention 
(April-May  2022),  will  also  be  reflected 
in  the  EU 
budget128.  

Overall environmental investment gaps (EU-27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed  and  what  is  forecast  to  be  invested  if  no 
additional  action 
is  taken)  for  climate,  energy  and 
transport  were  estimated  in  2021  to  be  EUR  390  billion 
per  year  (EU-27)129130.    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  year  131.  Those 
investment  needs reflect the implementation objectives 
to  2020  and  to  2030    (except  for  climate  adaptation,  the 
costs  of  which  are  expected  to  last  over  a  longer  time 
horizon). 

 A  preliminary  update  of  the  EU’s  core  environmental 
investment gap is provided in the Table 1132. Almost 40% 
of the environmental investment needs relate to dealing 
with  pollution,  which  accounts  for  nearly  two-thirds  of 
the investment gap if combined with water management. 
The  investment  gap  in  circular  economy  and  waste  is 

levels  of  circularity 

estimated  between  EUR  13-28  billion  a  year,  depending 
on 
implemented.  The  annual 
biodiversity financing gap is estimated to be around EUR 
20 billion. 

Table 1: Estimated breakdown of the EU’s 
environmental investment needs, by objective, 2021-
2030 (per year)133 

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 134 

& 

 21.5 

R & D & I and other 

Total 

 6.2 

 110.1 

 % 

 39% 

 24% 

 12% 

 20% 

 6% 

 100% 

Environmental investment needs in the Netherlands 

Climate  is  a  political  priority  in  the  Netherlands  in  line 
with  the  strategic  objectives  of  the  Integrated  National 
Energy and Climate Plan 2021-2030. The INEK’s objective 
is to achieve a 49 % greenhouse gas reduction compared 
to 1990 and to contribute to 32 % renewable energy by 
2030.  In  addition,  NL  introduced  a  “Nitrogen  Reduction 
and  Nature  Improvement  law”  since  1  July  2021.  The 
main elements of this law comprise legally binding target 
values  for  nitrogen  reduction  for  2025,  2030  and  2035, 
the operationalisation and implementation of nature and 
nitrogen  measures  via  a  legal  nitrogen  reduction  and 

128  The  Convention  on  Biological  Diversity  (cbd.int); Post-2020  Global 
Biodiversity Framework | IUCN 
129  SWD(2021)621,  accompanying  proposal  COM(2021)557  to  amend 
the REDII Directive (EU) 2018/2001. 
130 SWD(2020) 98 final/2. 
131  SWD(2018)292.  Impact  assessment  accompanying  the  Proposal  for 
the LIFE Regulation (COM(2018)385). 
132  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  DG  ENV  ”Study  supporting  EU  green  investment  needs 
internal  analysis 
analysis” 
”Environmental  Investment  needs  and  financing  in  the  EU’s  green 
transition“,  July 2020. 

(ongoing,  2021-2023)  and  DG  ENV 

133 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. 
134  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 – The Netherlands 

 
 
 
 
                                                                 
 
                                                                 
nature  improvement  programme  and  12  regional  plans 
to be presented in 2023. 

The  following  environmental  investment  needs  have 
been identified by sector: 

Pollution prevention & control 

The EU’s first Clean Air Outlook135 estimates that for the 
Netherlands  to  reach,  by  2030,  the  emission  reduction 
requirements  (ERRs)136    under  the  Directive  on  national 
emissions reduction commitments, the total air pollution 
costs amount to EUR 3.185 billion per year. This includes 
EUR  1.890  billion  per  year  for  capital 
investment 
(assuming the 2030 climate and energy targets are met).   

the 

second  Clean  Air  Outlook 

suggests137, 
As 
implementing  (i)  all  relevant  legislation  adopted  up  to 
2018138,  (ii)  the  2030  climate/energy  measures  and  (iii) 
the  national  air  pollution  control  programmes  (NAPCP) 
will  largely  allow  the  EU  to  reach  its  2030  climate  and 
2018 energy targets. Furthermore, if the Member States 
implement the measures announced in their NAPCP, the 
EU  would  largely  achieve  the  reductions  of  air  pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NEC Directive for 2030, except for 15 Member States for 
ammonia (NH3), excluding the Netherlands139. 

Water management  

Annual  expenditures 
for  both  water  supply  and 
wastewater  were  approximately  EUR  5.6  billion  for  the 
Netherlands by 2011-2015 (total expenditure)140141. Up to 
2030,  the  additional  cumulative  investment  need  over 
baselines  for  the  Netherlands  was  estimated  to  be  EUR 
4.8 billion (around EUR 480 million per year on average), 
with over 95% of that related to wastewater.  Moreover, 
the  recent  6th  Water  Framework  Directive  and  Floods 
Directive  Implementation  Report142  and  the  financial  - 

135 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 
2018. 
https://ec.europa.eu/environment/air/pdf/clean_air_outlook_overview
_report.pdf 
136  Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Requirements  are  based  on  Directive  (EU) 
2016/2284. 
137 COM(2021) 3 Final and Report Annex.   
138  COM(2021)  3  final.  International  Institute  for  Applied  Systems 
Analysis (IIASA), Support to the development of the   
Second Clean Air Outlook, 2020 and Annex. 
139  COM(2021)  3  final.  International  Institute  for  Applied  Systems 
Analysis (IIASA), Support to the development of the   
Second Clean Air Outlook, 2020 and Annex. 
140 OECD, Financing a Water Secure Future, 2022. 
141  OECD,  Financing  a  Water  Secure  Future,  2022.,  Country  Fact  Sheet 
Netherlands, Page 4 
142 WFD and FD Implementation Reports – DG Environment – European 
Commission. 

The Netherlands  36 

economic  study143  accompanying  it,  are  also  a  relevant 
source of information in this domain. 
Waste & circular economy 

According to a Commission study144 to meet the recycling 
targets  for  municipal  waste  and  packaging  waste,  the 
Netherlands  still  needs  to invest  an  additional  EUR  430 
million  over  baselines  in  2021-2027 (61  million  per  year 
reprocessors, 
on  average) 
biowaste  treatment,  waste  sorting  facilities  and  waste 
registry  digitalisation.  This  does  not 
the 
investment  necessary  for  other  key  waste  streams 
(plastics,  textile,  furniture)  or  to  unlock  a  higher  uptake 
of circularity and waste prevention across the economy. 

in  collection, 

recycling 

include 

Biodiversity & ecosystems 

its 

Prioritised  action  frameworks  (PAFs)  adopted  by  the 
Member  States  according  to  Article  8  of  the  Habitats 
Directive  present  (I)  the  conservation  priorities  for  the 
Natura  2000  network  and 
supporting  green 
infrastructure,  (ii)  their  costs  and  (iii)  planned  funding 
sources  for  the  period  corresponding  to  the  current 
multiannual  financial  framework  (MFF)  (2021-2027).  For 
the  Netherlands,  the  total  identified  needs  amount  to 
EUR  903.1  million  per  year,  including  EUR  739  million 
annual one-off costs  145. This excludes additional costs to 
implement the Biodiversity Strategy to 2030, including on 
increased protection and restoration. 

EU environmental funding 2014-2020 

The MFF for the years 2014-20 allocated almost EUR 960 
billion  (in  commitments,  2011  prices)146  for  the  EU  to 
spend  over  this  period.  The  commitment  to  green 
transition  included  a  20%  climate  spending  target  and 
funding opportunities for the environment, in particular, 
under  the  European  Structural  and  Investment  (ESI) 
Funds147.  The  2014-2020  MFF  budget  was  subsequently 
topped up with over EUR 50 billion (current prices) from 
REACT-EU  (Recovery  Assistance  for  Cohesion  and  the 

143  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. 
144 European Commision, Study on investment needs in the waste sector 
and  on  the  financing  of  municipal  waste  management  in  Member 
States, 2019. 
145  The  N2K  Group,  Strengthening  investments  in  Natura  2000  and 
instruments  report  to  the 
improving  synergies  with  EU  funding 
European Commission, 2021.  
146 Council Regulation (EU, Euratom) No 1311/2013. 
147  The  European  Structural  and  Investment  (ESI)  Funds  include  the 
European Regional Development Fund (ERDF), the Cohesion Fund (CF), 
the  European  Social  Fund  (ESF)  with  the  Youth  Employment  Initiative 
(YEI),  the  European  Agricultural  Fund  for  Rural  Development  (EAFRD) 
and the European Maritime and Fisheries Fund (EMFF).   

 Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
                                                                 
Territories  of  Europe).  This  money  was  spent  on    action 
against COVID-19, under EU cohesion policy148.  

The  Netherlands  received  EUR  2.7  billion  from  the  ESI 
Funds  over  2014-20  to  invest  in  job  creation  and  a 
sustainable  and  healthy  European  economy  and 
environment. 
The  planned  direct  environmental 
investment amounted to EUR 121.9 million with a further 
EUR  47.6  million  identified  as  indirect  environmental 
investment  value,  totalling  EUR  169.6  million.  Figure  41 
shows  an  overview  of  (planned)  individual  ESI  Funds 
earmarked  for  the  Netherlands  (EU  amounts,  without 
national amounts). 

Figure 40: ESI Funds allocated to the Netherlands, 
including environmental investments 2014-2020149 

The Netherlands  37 

Table 2:  Direct  and indirect  environmental investments 
under the ESI Funds in the Netherlands, 2014-2020150 

Instrument 

Under cohesion policy (ERDF) 
Indirect environmental investments 
renewable energy 
energy efficiency 
other energy151 
business development, R&I 

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

Under EMFF 
Direct environmental investments 
environment  protection  &  resource 
efficiency 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

Allocations  
for the environment  
(EUR million) 

47.6 
47.6 
5.0 
21.8 
0.8 
20.1 

46.4 
46.4 
46.4 

75.5 
75.5 
75.5 

169.6 
121.9 
47.6 

supplemented  by  other  EU 

Funding  for  the  environment  from  the  ESI  Funds  has 
been  also 
funding 
programmes available to all Member States, such as, the 
LIFE  programme  or  Horizon  2020  or  EIB  loans,  that  add 
up  to  an  estimated  total  of  EUR  2.3  billion  of  EU 
environmental  financing  for  the  Netherlands  in  2014-
2020.  

is  entirely  dedicated 

The  LIFE  programme152 
to 
environmental  and  climate  objectives. 
finances 
demonstration  and  best-practice  actions  for  green 
solutions  to  be  deployed.  In  the  2014-2020  period,  the 
Netherlands has received EU support for 10 LIFE projects 
with EUR 48.5 million (for nature and environment) from 
the LIFE programme (out of 1 028 EU27 LIFE projects with 
the total EU contribution of EUR 1.74 billion) 153. 

It 

Policy 

Funds 

(COWI, 

2017), Regulation 

148 Regulation (EU) 2020/2221. 
149  European  Commission,  DG  Environment  -  Data  analysis,  DG 
Environment  analysis  based  on  ESI Funds Open  Data  Portal 
(cohesiondata.ec.europa.eu), Integration  of  environmental  concerns  in 
Cohesion 
(EU)  No 
1303/2013,Regulation  (EU)  2021/1060 and Implementing  Regulation 
for  data:  December  2021. 
(EU)  No  215/2014. Cut-off  date 
Environmental investments here are captured via the combined use of 
intervention 
(EU)  No 
1303/2013 and Regulation  (EU)  2021/1060.  This allows for  a  more 
precise 
of 
identification 
Indirect  environmental 
relevant environmental investments.  N.B. 
investments  are  valued  using  the  Annex  I  environmental  coefficients 
in Regulation (EU) 2021/1060 (as opposed to full value). 

fields  and  coefficients  under Regulation 

valuation 

and 

in 

the 

from 

investments 

identified  here 

the 
tracking 

150 European Commission, DG Environment - Data analysis. The values of 
environmental 
specific 
values 
environmental  areas  may  differ 
at cohesiondata.ec.europa.eu, e.g. for clean  air or biodiversity due  to 
two  factors:  (i)  the  set  of  environmental  coefficients used and  (ii)  the 
range  of  funds  assessed.  DG  Environment’s  analysis  here  covered  the 
full  range  of  ESI  Funds.  See  also  the  footnote  of  the  figure  “ESI  Funds 
allocated  to  the  Netherlands,  including  environmental  investments 
2014-20” 
151  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)  in 
Regulation (EU) 2021/1060, Annex I. 
152 European Commission, LIFE Programme. 
153 Source: CINEA 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
 
  
 
                                                                 
In 2014-2020, Horizon 2020 allocated about EUR   175.1 
million for the Netherlands, in particular, for the circular 
economy, including raw materials, climate action, nature 
and  resources,  water  and  earth  observation,  which  is 
about 3.3% of the country’s total allocation.154 From the 
European  Fund  for  Strategic  Investments  (EFSI),  the 
Netherlands  received  EUR  382.9  million  for  direct 
environmental  investment  and  EUR  12.0  million  for 
indirect  environmental  investments  (totalling  to  EUR 
394.9  million)  out  of 
its  total  allocation  (EUR  2.0 
billion).155  From  the  EIB,  the  Netherlands  received  EUR 
1.8  billion 
investment 
for  direct  environmental 
(specifically, for water and sewerage) out of the total EIB 
loans  for  the  Netherlands  (EUR  15.8  billion)156.  The 
country ranks number 6 in size of total EIB lending. 

In 2020, the EIB provided EUR 24.2 billion to fight climate 
change  at  EU  level,  37%  of  its  total  financing.  It  also 
provided EUR 1.8 billion (3% of its financing) for broader 
environmental lending157 158. 

EU environmental funding  2021-2027 

the 

EU's 

long-term 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investment (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  protection.159  Following  the  EU  Green 
Deal’s160 pledge to ‘do no harm’ and the Interinstitutional 
Agreement  on  the  2021-2027  MFF161,  30%  of  the  EU 
budget  in  that  period  will  support  climate  efforts,  while 
biodiversity will receive 7.5% of the EU budget as of 2024 
and  10%  as  of  2026  ,  specifically  under  the  2021-2027 
Cohesion  policy  and  the  2023-2027  CAP  to  reach  those 
targets.  

priorities, 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 

154 Source:EASME, https://sc5.easme-web.eu/. 
155  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
156 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm 
157  The  EIB  Group  jointly  works  with  the  European  Commission  in 
implementing  several  programmes 
finance  environmental 
implementation: InvestEU, the successor of EFSI, and Pillars 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 budget under that mandate. 
158 EIB 2021 Activity Report. 
159  European  Commission,  2021-2027 
NextGenerationEU. 
160 COM/2019/640 final. 
161 Interinstitutional Agreement, OJ L 433I. 

long-term  EU  budget  & 

that 

The Netherlands  38 

(2020)164,  sustainable 

EU  Taxonomy)162. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bond 
(by  developing  the  EU  green-bond 
standard163).  Reinforced  by  the  renewed  sustainable 
finance  will 
finance  strategy 
increase investment flows to climate and environment. In 
support of financing climate adaptation, the new strategy 
on  adaptation  to  climate  change165  can  help  close  the 
insurance  protection  gap,  which  currently  leaves  many 
risks  from  climate-related  events  uninsured166.  The  EIB 
will  align  50%  of 
lending  with  climate  and 
environment projects by 2025167, with an EUR 250 billion 
contribution to the Green Deal investment plan by 2027. 

its 

Table  3  gives  an  overview  of  the  EU  funds  earmarked 
specifically  for  the  Netherlands  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 the Netherlands 
(current prices), 2021-2027 

Instrument 

Country funding allocation  

Cohesion policy 

ERDF 

ESF+ 

ETC (ERDF) 

Just Transition Fund 

EAFRD/rural 
development  

under  CAP  Strategic 
Plans 2023-2027171 

(million EUR) 

Total: 1 298.9168 

506.3 

413.9 

378.7169 

622.9170 

366.3172 

162 

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

finance/sustainable-finance/eu-taxonomy-sustainable-activities_en  
163 EU Green Bond Standard - 2021/0191 (COD). 
164 COM (2021) 390 Final - European Commission, Strategy for Financing 
the Transition to a Sustainable Economy.  
165 COM(2021) 82 final. 
166  The  strategy  would  support  improved  insurance  gap  coverage 
including through the natural catastrophe markets as reflected with the 
EIOPA  (Association  for  European  Insurance  and  Occupational  Pension 
Authorities)  dashboard  on 
insurance  protection  gap  for  natural 
catastrophes. See: The pilot dashboard on insurance protection gap for 
natural catastrophes | Eiopa (europa.eu). 
167 EIB Climate Bank Roadmap 2021-2025, November 2020 
168  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
169  Interreg  initial  allocations  per  MS  including  ETC  transnational  and 
ETC cross-border co-operation.  
170  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
171 European Commission, CAP strategic plans.  
172 Regulation (EU) 2021/2115, Annex XI.  

 Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
 
 
 
                                                                 
European  Maritime, 
and 
Fisheries 
Aquaculture 
Fund 
(EMFAF) 

and 
Recovery 
Resilience Facility (RRF)  

2021 – 2026174  

97.9173 

5.9175 (grants) 

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

To date, the Dutch RRP has not been adopted yet.  

Figure  41:  Climate  expenditure  in  RRPs,  2021-2026176 
(Without data on HU, NL, PL) 

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

In  addition  to  EU  funds  earmarked  specifically  for 
Belgium 
funding 
programmes that can been accessed at the EU level and 
which  are open to all Member States. These include the 

there  are  also 

in  2021-2027, 

173  Regulation (EU) 2021/1139, Annex V. 
174  The  actual  reforms  and  investments  under  the  RRF  have  to  be 
implemented until 31 December 2026.   
175 Regulation (EU) 2021/241, establishing the  Recovery and Resilience 
Facility, Annex IV 
176 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 

The Netherlands  39 

LIFE programme177 (EUR 5.4 billion), Horizon Europe (EUR 
95.5  billion)178,  the  Connecting  Europe  Facility179  (EUR 
33.7  billion)180  or  the  funds  to  be  mobilised  via  the 
InvestEU  programme181.  These  other  sources  of  funding 
will  also  support  the  green  transition,  including  through 
research  and  innovation  activities  for  environmental 
protection  (Horizon  Europe)182,  clean  transport  and 
energy 
and 
sustainable infrastructure (InvestEU)184. 

(the  Connecting  Europe 

Facility)183 

National environmental financing 

Total national expenditure on environmental protection 
(including all relevant current and capital expenditure )185 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2%  of  EU-27  GDP.  This  percentage  has  remained  quite 
stable over time.  Although the largest absolute amounts 
of expenditure are concentrated in a few countries, most 
countries  spend  between  1-2%  of  their  GDP  on 
environmental  protection,  whereas    the  Netherlands 
directs 2.5% of its GDP to this field. 

Of  this  spending,  the  EU-27's  capital  expenditure  on 
environmental protection (i.e. investment) amounted to 
EUR  56.3  billion  in  2018,  lowering  to  EUR  54.5  billion  in 
2020,  representing  around  0.4%  of  GDP.  Most  Member 
States  invested  0.2-0.5%  of  their  GDP  in  environmental 
protection,  the  Netherlands  dedicated  0.5%.  During 
2014-20, this spending totalled around EUR 376 billion of 
environmental  investment  in  the  EU27,  and  EUR  28 
billion for the Netherlands. 

177 European Commission, LIFE Programme. 
178  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
179  The  CEF  (Transport)  also  includes EUR  11.3  billion transferred from 
the  Cohesion  Fund.  30  %  of  the  transferred  amount  will  be  made 
available,  on a competitive  basis,  to  all  Member  States eligible  for  the 
Cohesion Fund. The remaining 70% will follow the nationally earmarked 
amounts  until  31  December  2023.  Any  unspent  national  amount,  by 
that date, will be allocated to support all Member States covered by the 
Cohesion Fund. 
180 Regulation (EU) 2021/1153. 
181  The  InvestEU  Fund  plans  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. 
182 European Commission, Horizon Europe. 
183 European Commission, Connecting Europe Facility. 
184 European Union, InvestEU. 
185  At  economy 
intermediate 
consumption and capital expenditure by households, corporations and 
governments  related  to  goods  and  services  in  the  environmental 
protection  sector.  This  excludes  EU  funds,  bur  may  include  some 
international 
source: 
(beyond 
Environmental Protection Expenditure Accounts (EPEA), Eurostat. EPEA 
accounts are based on the CEPA 2000 classification, excluding climate, 
energy and circular economy. 

including  final  consumption, 

domestic).  Data 

expenditure 

level, 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
 
                                                                 
                                                                 
Figure 42: Direct and indirect environmental protection 
investment in the EU-27 (EUR million and % of GDP), 
2018186 

Figure 43: EU-27 Member States environmental 
protection investment (capital expenditure), by 
institutional sector (Total economy = 100%), 2018187 

The Netherlands  40 

protection 

investments 

By  institutional  sector,  around  74%  of  the  Netherlands’ 
environmental 
(capital 
expenditure)  came  from  the  general  government,  20% 
from  specialist  producers  (of  environmental  protection 
services, e.g. waste and water companies) and 6.5% from 
the  typical  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). 

186 Eurostat, Environmental Protection Expenditure Account, 2021.  

Breakdown  of  investment  by  environmental  issue  is 
partially available, at the level of institutional sectors only 
(rather than at economy level), due to different reporting 
patterns188  At  the  Netherland‘s  general  government 
level, 
in  2018  53%  of  environmental  protection 
investments  went  to  wastewater,  34%  on  waste 
management  and  5%  on  biodiversity 
in  2018.  The 
country’s  specialist  producers  mainly  focused  on  waste 
management,  with  92%  of 
their  environmental 
investment,  with  wastewater  and  water-  and  soil 
protection receiving 4-4%  (each).  For  industry (business) 
the  main  priority  was  the  protection  of  air,  with  60%  of 
relevant  investments,  followed  by  wastewater  (22%)  to 
name the most significant items. 

In  2020,  the  total  annual  issuance  of  European  green 
bonds189 (including some non-EU countries) was USD 156 
billion  (EUR  137  billion),  up  from  USD  117  billion  (EUR 

187  Eurostat,  Environmental  Protection  Expenditure  Accounts 
(env_epe).  
188 Data reporting is different  for the 3 institutional sectors, leading to 
aggregation  difficulties.  Specialist  companies  provide  comprehensive 
data  across  all  environmental  areas  (CEPA  1-9),  while  this  is  less  the 
case for general government and industry, which often report (the non-
obligatory)  data  in  merged  categories  only  (which  are  difficult  to 
separate out), or indeed not at all.  
189  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 
issuance  from 
green  bond  was 
multilateral  institutions,  the  European  Investment  Bank  (EIB)  and  the 
World Bank. 

in  2007  with  AAA-rated 

issued 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
                                                                 
 
 
                                                                 
The Netherlands  41 

Figure 45: Environmental taxes in the EU27, 2020193 

105  billion)  in  2019190.  Looking  only  at  EU-27  Member 
States, green bond issuance in 2020 was EUR 124 billion. 
The  Netherlands  issued  green  bonds  worth  EUR  15.3 
billion  in  2020.  In  2014-2020,  83%  of  the  green  bonds 
issued by European countries served objectives in energy, 
buildings  or  transport,  while  8%  supported  water  and 
waste, with a further 6% supporting land use – with links 
to ecosystem conservation & restoration191. 

Figure 44: Annual EU green bond issuance in 2020 (EUR 
billion)192 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience, foster a fairer society and 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 
simultaneously taking account of social considerations194. 
The  Green  Deal  promotes  the  ‘polluter  pays  principle’ 
(PPP)195  which  stipulates  that  polluters  should  bear  the 
cost  of  measures  to  prevent,  control  and  remedy 
pollution. This principle is facilitated by the Commission’s 
Technical Support Instrument (TSI) project196 on greening 
taxes.  The  Netherlands  applies  economic  instruments 
such  as  water  consumption  charges  and  pay-as-you-
throw schemes197. 

Environmentally-harmful subsidies 

Addressing  and 
removing  environmentally-harmful 
subsidies is a further step towards wider fiscal reforms198. 
Fossil-fuel  subsidies  are  costly  for  public  budgets,  and 
make it difficult to achieve the Green Deal objectives. In 

193 Eurostat, Environmental taxes accounts (env_eta). 
194 COM (2019/640 final), p.17.  
195  Enshrined  in  Article  191(2)  of  the  Treaty  on  the  Functioning  of  the 
European Union: “Union policy on the environment  (…) shall be based 
on  the  precautionary  principle  and  on  the  principles  that  preventive 
action should be taken, that environmental damage should as a priority 
be rectified at source and that the polluter should pay”. 
196  European  Commission,  Greening  taxes-  applying  polluter  pays 
principle in practice,  green budgeting TSI participation. 
197  European  Commission,  Green  taxation  and  other  economic 
instruments, 2021. 
198  European  Commission,  Study  on  assessing  th  environmental  fiscal 
reform potential for the EU 28, 2016.  

Green budget tools 

Green taxation & tax reform 

The  Netherlands’  revenue  from  environmentally-related 
taxes is one of the highest above the EU average in 2020, 
as  shown  in  the  graphic.  Environmental  taxes  stood  at 
3.16%  of  GDP  in  2020  (EU  average:    2.24%).  The  largest 
portion  of  the  environmental  taxes  were  energy  taxes  at 
1.79%  of  GDP,  above  the  EU  average  of  1.74%.  Transport 
taxes,  at  0.92%  of  GDP,  were  well  above  the  EU  average 
(0.42%), as were taxes on pollution and resources at 0.45% 
(the highest among all Member States, while the EU average 
is 0.08%). In the same year, the environmental tax came to 
7.97%  of  total  revenues  from  taxes  and  social  security 
contributions (above the EU average of 5.57%). 

190 

Bonds 

Climate 

Taxonomy 
https://www.climatebonds.net/standard/taxonomy.  USD 
converted via Eurostat’s annual average EUR/USD exchange rates. 
191  Interactive  Data  Platform  at  www.climatebonds.net.  Climate  Bonds 
Taxonomy is similar to the EU Taxonomy. 
192 Climate Bonds Initiative, 2022. 

value 

-  
is 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
 
                                                                 
 
 
                                                                 
many  cases,  these  subsidies  also  counteract  incentives 
for green investments.  

Green budgeting practices  

The Netherlands  42 

Annual  fossil-fuel  subsidies  have  been  around  EUR  55 
billion  in  the  EU  since  2015.  They  rose  by  4%  between 
2015 and 2019, although some countries (such as Latvia, 
Lithuania,  Sweden,  Greece  and  Ireland)  managed  to 
decrease them in this period.  

In  the  EU,  subsidies  for  petroleum  products  in  sectors 
such as transport and agriculture continued to increase in 
2015-2019.  However,  subsidies  for  coal  and 
lignite 
decreased,  due  to  the  diminishing  role  of  solid  fuels  in 
electricity generation. 

As a share of GDP, fossil-fuel subsidies ranged from 1.2% 
in Hungary to less than 0.1% in Malta in 2019  (being an 
EU average of 0.4%). In the Netherlands, they amounted 
to  EUR  0.8  billion  in  2019,  representing  0.09%  of  GDP 
(one-fourth of the EU average). 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 2020199. 

Figure 46: Trends in natural gas, petroleum products, 
electricity and coal subsidies200 

% GDP 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

Electricity 

0.00 

0.01 

0.00 

0.01 

0.01 

0.00 

0.01 

0.00 

Natural 
gas 

0.02 

0.02 

0.02 

0.03 

0.02 

0.02 

0,02 

0.02 

Petroleum   0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

Coal 

0.00 

0.00 

0.00 

0.01 

0.01 

0.01 

0.01 

0.02 

199 State of the Energy Union report, COM(2021) 950 and Annex 
200 OECD, Fossil Fuel Subsidy Tracker. 

Green  budgeting  encompasses  various  climate  and 
environmental tagging and tracking practices in budgets. 
Some  EU  Member  States  already  use  green  budgeting 
practices201.  Green  budgeting  helps  identify  and  track 
green  expenditure  and  green  revenues  to 
increase 
transparency  on  the  environmental 
implications  of 
budgetary  policies.  This  is  aimed  at  improving  policy 
coherence  and  supporting  green  policies  (including 
climate end environmental objectives)202. 

The Commission has also drawn up climate-proofing and 
sustainability-proofing guidance as tools to assess project 
eligibility and a project’s compliance with environmental 
legislation  and  criteria203.  It  has  also  developed  a  green 
budgeting  reference  framework  204  and 
launched  a 
technical  support  project  (TSI)  on  green  budgeting  in 
2021,  to  help  Member  States  develop  (or  further 
develop)  national  green  budgeting  frameworks,  to 
improve  policy  coherence  and  the  green  transition.  The 
Netherlands  did  not  participate  in  the  Commission’s  green 
budgeting TSI, which started in 2021. 

A green budgeting approach has been established in  the 
Netherlands  through  the  2017  Climate  Act,  which 
requires  the  government  to  report  on  progress  towards 
the goals in the climate law on an annual basis, including 
details  of  the  budgetary  impact  of  climate-  and  energy-
related  policies.  The  2019  national  climate  agreement 
comprised  a  set  of  measures  to  reduce  greenhouse  gas 
emissions by 49% by 2030205. The governance framework 
for  meeting  these  targets  is  described  in  the  national 
climate  act.  The  act  also  mandates  the  drafting  of  a 
national  climate  plan  every  5  years  and  tasks  the 
Environmental  Assessment  Agency  with  the  role  of 
”climate  watchdog“, 
the 
government  remains  on  track  to  reach  its  reduction 
for 
targets.  Within 
Economic  Policy  Analysis  (CPB)  has  the  task  of  assessing 
the fiscal and possible  macroeconomic impacts  (through 
the  income  channel)  of  any  climate  policy  measure. 
According  to  their  assessment,  the  measures  related  to 
the  climate  agreement  will  increase  public  expenditure 
on  climate  and  energy  policy  by  EUR  3.9  billion  (around 

the  Netherlands  Bureau 

to  assess  whether 

this, 

i.e., 

201 European Commission, Green Budgeting Practices in the EU: A First 
Review,  2021,  Green  Budgeting  in  the  EU  Key  insights  from  the  2021 
Commission survey  and OECD,  Public  Governance  Directorate,  Climate 
Change  and  Long-term  Fiscal  Sustainability,  Working  Paper,  February 
2021. Climate Change and Long-term Fiscal Sustainability (oecd.org) 
202 OECD Paris Collaborative on Green Budgeting initiative, 2017. 
203 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
204  European  Commission,  European  Commission  Green  Budgeting 
Reference Framework. 
205 Ministry of Economic Affairs and Climate (2019), Integraal Nationaal 
Energie- en Klimaatplan 2021-2030 Nederland. 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
                                                                 
                                                                 
The Netherlands  43 

The 

sources. 

financing 

country’s 

environmental 

The  Netherlands’ 
for 
investments came to  0.87% of GDP (EU average:  0.7%) 
in  2014-20,    overwhelmingly  (over  90%)  relying  on 
national 
environmental 
investment  needs  in  2021-2027  are  estimated  to  reach 
(covering  needs  with  country 
over  1%  of  GDP 
potential 
breakdowns 
environmental  financing  gap  of  at  least    0.13%  of  GDP, 
likely  to  be  higher  when  also  accounting  for  needs 
estimated  currently  at  EU-level  only 
(e.g.  water 
protection, higher circularity, biodiversity strategy etc.).   

suggesting 

available), 

a 

2022 priority actions  

In the 2019 EIR, the Netherlands had a priority action for 
environmental  financing  to  tackle  some  of  the  main 
challenges affecting the country and ensure that the rural 
development  programme  and  greening  measures  boost 
biodiversity  and  contribute  to  achieving  favourable 
conservation  status  for  habitats  and  species.  However, 
there is room for improvement in the coming years: 

 

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, 
in  particular  further  exploring 
private  financing  flows  (currently  around  a 
fourth  of  the  total),  to  cover  the  investment 
needs  across  the  environmental  objectives  and 
closing the investment gaps. 

0.5% of current  GDP) annually by 2030, whereas the tax 
burden  will  increase  by  around  EUR  4.6  billion  (also 
around  0.5%  of  GDP)206.  Therefore,  the  Netherlands 
appears  to  currently  be  implementing  good  practice  in 
green budgeting, which is also in line with its green bond 
issuance207. 

Overall financing compared to the needs 

The EU’s overall financing for environmental  investment 
is  estimated  to  have  been    0.6-0.7%  of  GDP  in  2014-20 
period,  comprising  both  major  EU  funds  and  national 
financing.  This  ranged  from    0.3%  (Ireland)  to    1.91% 
(Bulgaria),  depending  on  the  level  of  environmental 
challenges in different Member States. In 2021-2027, it is 
estimated that the EU’s environmental investment needs 
will  range  between  0.9-1.5%  of  the  projected  total  EU 
GDP(2021-2027),  suggesting  a  potential  environmental 
financing  of  0.6-0.8%  of  GDP  at  EU  level,  compared  to 
previous financing levels208. 

Figure 47: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU27 (% 
of GDP)209 

206  CPB  Netherlands  Bureau  for  Economic  Policy  Analysis  (2019), 
Doorrekening  Klimaatakkoord,  CPB  Netherlands  Bureau  for  Economic 
Policy Analysis, The Hague. 
207  https://ec.europa.eu/info/publications/green-budgeting-practices-
eu-first-review_en  
208 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  capital 
expenditure  (investment)  on  environmental  protection  -  source: 
Eurostat  EPEA  dataset.  Cut-off  date  for  data:  end  2021.  N.B.  The  total 
indirect 
in  particular  through  further 
financing  may  be  higher, 
investment. If so, this would require further analysis in future. 
209Eurostat, Environmental taxes accounts (env_eta). 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
 
                                                                 
 
 
 
The Netherlands  44 

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: 

ii.  prioritise  environmental  datasets  in  implementation, 
especially  those  identified  as  high-value  spatial  datasets 
for implementing environmental legislation213. 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive (2016-2020)214 

2016 

2020 

Legend 

(i) access to information; 

(ii) public participation in decision making 

(iii) access to justice in environmental matters.  

It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively210.  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  and 
administrative procedures to protect the environment211. 
It  includes  the  right  to  bring  legal  challenges  ("legal 
standing")212. 

Environmental information 

for 

spatial  data 

infrastructure 

This section focuses on the Netherland’s implementation 
of  the  Infrastructure  for  Spatial  Information  in  Europe 
(INSPIRE)  Directive.  This  Directive  aims  to  establish  a 
European 
sharing 
information  between  public 
environmental  spatial 
authorities  across  Europe,  assisting 
in  policymaking 
across  boundaries  and  facilitating  public  access  to  this 
information.  Geographic  information  is  needed  for  good 
governance  at  all  levels  and  should  be  readily  and 
transparently 
and 
documentation  have  made  good  progress,  and 
implementation  levels  are  good.  However,  more  efforts 
are needed to:  

available.  Data 

identification 

(i. make the data more widely accessible, and 

for 

legal 

together 

create  a 

foundation 

210  The  Aarhus  Convention,  the  Access  to  Environmental  Information 
Directive  ,  (Directive  2003/4/EC)  and  the  INSPIRE  Directive,  (Directive 
2007/2/EC) 
sharing 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the implementation of the INSPIRE Directive. 
211 These guarantees are explained in the Commission Notice on access 
to  justice  in  environmental  matters,  OJL  275,  18.8.2017  and  a  related 
Citizen's Guide. 
212  This  EIR  report  focuses  on  the  means  implemented  by  Member 
States to  guarantee  rights of  (i)  access  to  justice  and (ii)  to  bring  legal 
challenges  (”legal  standing”)  and  to  overcome  other  major  barriers  to 
bringing cases on nature and air pollution. 

Effective  coordination  and  data 
sharing 

Ensure 
coordination  

effective 

■  ■  

Data sharing without 
obstacle  

■  ■ 

INSPIRE performance indicators 

Conformity 

i. 
metadata  

of 

■  ■ 

ii.  Conformity  of 
spatial data sets215 

■  ■ 

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

■  ■ 

iv.  Conformity  of 
network services 

■  ■ 

is 

or 

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

some 

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

is 

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

The Netherlands received a priority action in 2019 on the 
need  to  improve  access  to  spatial  data  and  services. 
However,  it  is  making  stronger  links  to  the  country 
INSPIRE  portals  and  better  informing  the  public  about 
their  access  to  justice  rights,  notably  in  relation  to  air 
pollution and nature, where some progress can be seen. 
Therefore no priority action is proposed in 2022.  

213  European  Commission,  European  Commission,  List  of  high  value 
spatial data sets.  
214 INSPIRE, knowledge base. 
215  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 
most countries provide as-is-data sets in addition to the INSPIRE-aligned 
data sets. 

Environmental Implementation Report – The Netherlands 

 
                                                                 
 
  
  
 
 
                                                                 
Public participation 

Extensive  information  and  electronic  tools  are  available 
in  the  Netherlands  to  facilitate  public  participation  in 
procedures  for  environmental  impact  assessment  (EIA) 
and  strategic  environmental  assessment  (SEA).  A  Dutch 
government webpage collects all official notifications and 
publications  regarding  initiation  of  plans  and  projects  to 
which  EIA  or  SEA  procedures  apply216.  In  addition,  the 
Ministry  of 
Infrastructure  and  Water  Management 
provides  an  online  participation  platform217  and  quick 
scan  facility218  for  citizens  and  developers  to  determine 
whether  an  EIA  procedure  applies.  Furthermore,  public 
participation  in  EIA  and  SEA  procedures  is  embedded  in 
national  environmental 
for 
law,  providing 
participation 
in  national,  provincial  and  municipal 
planning procedures219 including information obligations, 
obligatory  public  consultation  and  a  duty  to  explain  to 
what extent public feedback was considered. 

rules 

A  new  ‘Environment  and  Planning  Act’  is  expected  to 
enter  into  force  in  the  Netherlands  on  1  January  2023, 
consolidating various areas of environmental law to make 
decision making more effective and efficient and further 
improve  public  participation  in  environmental  decision 
making220.  An  Environment  Platform  is  being  developed 
as part of the digital infrastructure to facilitate the entry 
into  force  of  the  new  Environment  Act  and  stimulate 
participation  by  citizens221. 
  Some  data  on  public 
participation in EIA and SEA procedures and the extent to 
which public views are considered is published, but only 
for procedures in which the Netherlands Commission for 
Environmental  Assessments  is  specifically  requested  to 
take public views into account222. 

Access to justice  

NGOs  do  not  have  to  demonstrate  an  interest  to  have 
standing  in  an  administrative  environmental  court  case 

216  Officielebekendmakingen.nl  Government  website  containing  all 
official publications 
217 
Platform 

Participatie, 

available 

at: 

https://www.platformparticipatie.nl/default.aspx 
218 EIA-scan in the knowledge database of the Ministry of Infrastructure 
and Water 
219  Chapter  7  (SEA  and  EIA)  and  Chapter  4  of  the  Environmental 
Management Act. 
220 More information on the new Environment and Planning Act and its 
entry  into  force  is  available  at  the  dedicated  government  website: 
and 
https://www.rijksoverheid.nl/onderwerpen/omgevingswet 
https://iplo.nl/regelgeving/omgevingswet/english-environment-and-
planning-act/.  
221  More  information  on  the  Digital  System  for  the  Environment  Act 
(DSO)  and the  Environment  Platform  (Omgevingsloket)  is available  on: 
https://aandeslagmetdeomgevingswet.nl/ontwikkelaarsportaal/dso/ds
o/digitaal-stelsel/ 
222 Facts and figures from Annual Report NCEA. 

The Netherlands  45 

in  cases  which  have  significant  effects  on  the 
or 
environment, but they do have to meet some conditions 
regarding  their  legal  status  and  operation.  For  citizens 
the  requirement  is  to  have  a  sufficient  interest  in  the 
in 
decision. 
environmental cases may be more demanding on citizens 
than on NGOs. 

In  practice  meeting 

standard 

that 

the 

(EIA) 
impact  assessment  reports: 
As  regards 
environmental  report  itself  can  only  be  made  subject  to 
review  together  with  the  decision  (such  as  on  the 
application for a permit). If the EIA report is found to be 
flawed,  the  decision  will  be  ruled  to  be  flawed  as  well 
(because not  substantiated by the EIA report) and will  – 
typically - be annulled because of this (Article 3:46 GALA). 

Under  Dutch  administrative  law,  only  final  decisions  can 
be  subject  to  legal  review  and  appeal  to  the  courts. 
Decisions are defined in Article 1:3 of the Dutch General 
Administrative  Law  Act  (Algemene  wet  bestuursrecht). 
Administrative review and judicial review is not available 
against general binding rules or policy rules, only against 
the  decisions  based  on  them.  Article  120  of  the  Dutch 
Constitution  does  not  allow  the  judge  to  check  the 
validity  of 
laws  adopted  by  Parliament  against  the 
Constitution ("The constitutionality of Acts of Parliament 
and  treaties  shall  not  be  reviewed  by  the  courts.").  The 
judge is allowed, though, in a dispute over the (formal or 
material) legality of a decision, to raise arguments calling 
into question the legality of the legal basis on which the 
decision  is  based.  So  it  is  possible  to  check  whether  a 
decision  is  compatible  with  EU  law,  environmental  law 
included. It is also possible for the national judge to check 
whether national law complies with binding international 
law.  Where  it  does  not,  the  judge  can  leave  aside 
international law. 

Plans  and  programmes  (as  defined  in  the  SEA  Directive) 
do  not  constitute  a  decision  as  per  Article  1:3  of  the 
General Administrative Law Act and cannot be challenged 
before  an  administrative  supervisory  forum  or  at  court. 
Action based on civil law may be possible before the civil 
courts if an interest is proven based on the general rules. 

There is easily accessible information on access to justice, 
including  in  the  media  and  social  media,  maintained  by 
the government, in different languages if the country is a 
is  available 
multi-lingual  one.  Advice  and 
online223.  More  specific 
information  about  Dutch 
environmental law and procedures, including information 
on access to justice, can be found on the website of the 
Knowledge Centre InfoMil224. 

legal  aid 

In  2019,  there  was  a  priority  action  addressed  to  the 
Netherlands  on  access  to  justice,  in  particular,  to  better 

223 www.rechtwijzer.nl and www.juridischloket.nlwww.juridischloket.nl 
224 www.infomil.nl 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
                                                                 
inform the public about their rights on access to justice. It 
is  concluded  that  there  has  been  significant  progress 
made. 

2022 priority actions 

environmental 

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

datasets 

in 

  Collect and publish data on public participation in EIA 
and  SEA  processes,  including  information  on  the 
extent to which final decisions are affected by public 
comments. 
Improve  access  to  courts  by  the  groups  concerned, 
it  comes  to  challenging  administrative  or 
when 
regulatory decisions, particularly in areas of planning 
related to water, nature and air quality. 

 

Compliance assurance  

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:  

to  ensure 

(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 
penalties  and  require  damage  to  be  remedied,  i.e. 
enforcement228.  

Citizen  science  and  complaints  enable  authorities  to 
liability229 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

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  co-
ordination between authorities to tackle environmental crime. 
229  The  Environmental  Liability  Directive,  2004/35,  creates  the 
framework. 

The Netherlands  46 

Compliance promotion and monitoring 

Regarding  the  Nature  Directives,  various  compliance 
promotion tools are in place in the Netherlands. Via the 
platform  ‘Bij12’,  information  is  provided  for  use  by 
authorities, stakeholders, farmers and duty-holders alike 
on  nature  management,  species  protection  rules  and 
legislation  regarding  Natura  2000230.    The  Netherlands 
Enterprise  Agency  (RVO)  promotes  compliance  though 
education,  enforcement  communication,  project  visits, 
administrative  controls  and  provides  information  on  its 
website for duty-holders231. In December 2020, the Dutch 
government  announced  a  nature  policy  programme  to 
stimulate  sustainable  nature  management, 
improve 
conservation in protected areas such as Natura 2000 sites 
and  increase  nature  inclusive  agriculture  to  improve  the 
the 
restoration  and  development  of  nature 
Netherlands by 2030232.  

in 

Regarding 
the  Nitrates  Directive,  detailed  online 
information  is  available  to  duty  holders  via  websites  of 
the  Dutch  government233  and  the  Dutch  Enterprise 
Agency234,  giving 
issues  such  as 
information  on 
production  and  usage  control,  leakage  prevention  and 
sustainability projects.  

As  already  indicated  in  the  2019  EIR,  systematic  and 
centralised  inspection  plans  and  inspection  reports  of 
industrial  installations  under  the  industrial  emissions 
directive  (IED)  are  missing  in  the  Netherlands,  although 
information  on  inspections  of  installations  under  the 
Seveso  III  Directive,  including  summaries  of  results,  is 
published  systematically235.  Permitting,  supervision  and 
enforcement  regarding  installations  under  the  IED  is 
mandated  to  all  29  environmental  services,  some  of 
which  have  started publishing enforcement  decisions on 
their  websites236.  The  Ministry  of  Infrastructure  and 
Environment  published  a  report  on  the  performance  of 
the  environmental  services  in  2020,  providing  details 
such  as  number  of 
installations  under  supervision, 
amount  of  employees  and  amount  of  administrative 

230 Bij12 website 
231  See  for  example  RVO  website  on cross-compliance  conditions;  RVO 
POP3 Rural development programme, website  
232 Publication by the national government regarding the agreement on 
a ‘Nature Programme’ for nature restoration and development. 
233  See  for  example  the  Dutch  government  website  on  measures  for 
manure  use;  and  the  Dutch  government  website  on  usage  and 
distribution of manure. 
234  See  for  example  the  Dutch  Enterprise  Agency  (RVO)  webpage  on 
fertilisation  rules  and  policy  in  the  Netherlands;  Dutch  Enterprise 
Agency (RVO), website on manure and related topics. 
235  BRZO+  overview  and 
https://brzoplus.nl/inspectie-resultaten/ 
236  See  for  example,  Environmental  Service  North  Sea  Channel  Area, 
overview  enforcement  decisions  on  website;  DCMR  Environmental 
Service Rijnmond, overview of sanctions 

inspection  results,  available  at: 

list  of 

 Environmental Implementation Review 2022 – The Netherlands 

 
 
                                                                 
                                                                 
sanctions  imposed237.  Annual  activity  reports  regarding 
activities and findings from supervisory authorities under 
Seveso  III  are  published,  but  not  regarding  the  IED. 
However,  the  annual  reports  by  environmental  services 
provide  some  additional  information  on  environmental 
inspections required under the IED. An official report of 4 
March 
LEEFOMGEVING 
Omgevingsdiensten  als  gangmaker  voor  het  bestuur) 
raised  concerns  about  the  functioning  of  the  regional 
inspection  services  (Omgevingsdiensten)  and  suggested 
action  the  Dutch  government  could  take.  Those  actions 
are under preparation.   

("OM 

2021 

DE 

Complaint handling and citizen science 

As  set  out  in  the  2019  EIR,  clear  online  information  on 
how  to  submit  complaints  regarding  environmental 
problems is available in the Netherlands on websites and 
environmental  hotlines  run  by  provinces238  and  regional 
environmental  services239,  aided  by  NGOs  that  direct 
citizens to the right platforms240. Information from public 
complaints 
is  collected  through  the  online  citizen’s 
complaints  platforms  of  the  competent  authorities 
(provinces  and  environmental  services)  and  used  to 
of 
initiate 
environmental  legislation  where  relevant.  The  people 
making the complaints are informed about the follow-up 
to it. 

infringements 

investigations 

into 

The  Netherlands  participates  in  EU-Citizen.Science,  a 
Horizon  2020-funded  project  with  a  number  of  sub-
projects  in  the  Netherlands,  including  the  use  of  citizen 
science to measure water quality241, citizen observatories 
on  environmental  indicators  in  urban  and  rural  areas242 
and  the  use  of  citizen’s  environmental  monitoring  to 
investigate  the  effect  of  climate  change  on  nature243. 
Moreover,  citizen  science  plays  a  role  in  data  collection 
on  biodiversity.  The  National  Flora  and  Fauna 
Database244, the Dutch online species atlas, makes use of 

237Available 
at: 
https://www.rijksoverheid.nl/documenten/kamerstukken/2021/09/17/
voortgang-opvolging-rapport-adviescommissie-vth-aanbieding-
rapporten-kwantitatief-en-juridisch-onderzoek 
238  See  for  example,  the  environmental  complaints  webpages  of  the 
Province of South-Holland, Overijssel, Limburg, and Zeeland.  
239  See,  for  example:  the  environmental  service  of  Middle-Holland, 
providing information on its enforcement power and complaints via its 
FAQ  the  environmental  service  covering  15  municipalities  in  South-
Holland  and  Zeeland,  with  a  webpage  containing  a  central  complaints 
service  and  providing  information  on  which  complaints  to  file  where, 
and  the  environmental  service  covering  the  North  Sea  Channel  area, 
including  the  greater  Amsterdam  area,  which  also  has  a  complaints 
facility specifically dedicated to one particular installation (Tata Steel). 
240 For example, Milieuklachten.nl 
241 See EU-citizen.science webpage on the EyeOnWater project. 
242 See EU-citizen.science webpage on the Ground Truth 2.0 project. 
243 See EU-citizen.science webpage on the GrowApp project.   
244 website of National Flora and Fauna Database. 

The Netherlands  47 

species  observations  submitted  by  citizens  through 
Waarneming.nl245,  which  works  together  with  a  large 
biodiversity  museum 
in  using 
automatic  recognition  software.  This  has  drastically 
increased the number of submitted observations246. 

in  the  Netherlands 

Enforcement  

There is no centralised online publication of statistics on 
non-compliance with environmental legislation, but most 
environmental  services  publish  decisions  on 
their 
websites covering environmental infringements for which 
penalties  have  been  applied247.  Every  four  years,  a 
National  Threat  Assessment  on  Environmental  Crime  is 
carried  out  by  the  Strategic  Environmental  Chamber, 
which  involves  all  parties  involved  in  enforcement  of 
in  the  Netherlands,  both 
environmental 
administrative and criminal enforcement services as well 
as  specialised  inspectorates.  The  most  recent  National 
Threat  Assessment  dates  from  2021  and  provides  an 
overview  of  the  main  trends  in  nine  major  forms  of 
environmental  crime  in  the  Netherlands  and  analyses 
their  impact  on  nature  and  public  health248.  Moreover, 
some  regional  environmental  services  publish  online 
to 
information  on 
environmental law infringements. 

sanctioning  decisions 

legislation 

related 

Cooperation  between  administrative  enforcement  and 
criminal  enforcement  regarding  environmental  crime 
remains a challenge. Despite existing formal cooperation 
structures  and 
information  exchange  agreements, 
however  concrete  action  has  been  taken  since  2019  to 
enhance  cooperation  between  enforcement  authorities. 
Further to reports by the Dutch Justice and Infrastructure 
ministries249 and the Dutch Court of Auditors250 regarding 
enforcement  challenges  in  the  area  of  environmental 
crime,  a  policy  programme  was  enacted,  the  Dutch 

2021, 

2021’, 

available 

‘Image  of  Threats 

245 Website of Waarneming.nl 
246 See the webpage of Naturalis on its cooperation with Waarneming.nl 
247  See  for  example,  Environmental  Service  North  Sea  Channel  Area, 
overview  enforcement  decisions  on  website;  DCMR  Environmental 
Service Rijnmond, overview of sanctions 
248  Openbaar  Ministerie,  Omgevingsdienst  NL,  ILT,  NVWA,  Politie, 
‘Dreigingsbeeld  Milieucriminaliteit 
at 
https://www.om.nl/onderwerpen/milieucriminaliteit/dreigingsbeeld-
milieucriminaliteit;  See  also  the  summary  and  factsheet  on  regarding 
from  Environmental  Crime’ 
the  publication 
(Dreigingsbeeld Milieucriminaliteit 2021). 
249 Een onzichtbaar probleem | Rapport | Algemene Rekenkamer; Dutch 
Court  of  Auditors, 
in  het  duister,  de  aanpak  van 
milieucriminaliteit  en  overtredingen’,  deel  2,  Algemene  Rekenkamer, 
juni 2021, available at: Handhaven in het duister | Rapport | Algemene 
Rekenkamer 
250 https://www.rekenkamer.nl/publicaties/rapporten/2021/01/20/een-
onzichtbaar-probleem;  Dutch  Court  of  Auditors,  ‘Handhaven  in  het 
duister,  de  aanpak  van  milieucriminaliteit  en  overtredingen’,  deel  2, 
at: 
juni 
Algemene 
https://www.rekenkamer.nl/publicaties/rapporten/2021/06/30/handh
aven-in-het-duisteR 

Rekenkamer, 

‘Handhaven 

available 

2021, 

 Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
                                                                 
government  started  an  ‘Action  plan  on  environmental 
crime’  with  the  aim  to  create  a  more  effective  and 
interconnected system of enforcement of environmental 
legislation in the Netherlands251. Further policy measures 
to improve resources, division of tasks, capacity, level of 
expertise  and  information  exchange  of  enforcement 
authorities  involved  in  the  fight  against  environmental 
crime  in  the  Netherlands,  are  being  prepared  by  the 
Ministry of Infrastructure and Water Affairs252. 

Environmental Liability Directive (ELD) 

Infomil  registers  notifications  by  competent  authorities 
of  cases  of  environmental  damage  that  fall  under  the 
Environmental Liability Directive (ELD). However, it is not 
clear  whether  Infomil  keeps  a  register  of  cases  or  only 
provides for a form to be used by competent authorities 
to  notify  the  Ministry  of  any  ELD  cases.  There  is  no 
publicly  available  register  or  central  database  of 
environmental incidents or ELD cases. The Dutch National 
Institute  for  Public  Health  publishes  certain  incidents 
with  hazardous  substances  in  which  the  Environmental 
Accident  Service  was 
involved  for  risk  assessment 
purposes253, however these cases are not necessarily ELD 
cases.  There  is  a  notification  obligation  oncompetent 
authorities 
of 
environmental  damage  or  cases  of  imminent  threat  of 
environmental damage that fall under the Environmental 
Management  Act  which  transposes  ELD  254  which  is 
registered  by  Infomil  but  there  is  no  publicly  available 
database where environmental incidents or ELD cases are 
collected.  The  Netherlands  does  not  have  a  system  of 
mandatory financial security for liability under the ELD255. 
However,  the 
financial 
security  is  currently  under  consideration,  as  a  result  of 
various incidents in which parties causing environmental 
damage  could  not  provide  sufficient  recourse.  A 
legislative  proposal  to  make  the  provision  of  financial 
security  by  certain  high  risk  companies  obligatory  is 
currently  pending  for  advice  by  the  Council  of  State256. 

introduction  of  mandatory 

operators 

regarding 

cases 

and 

2020, 

available 

251  Ministry  of 
‘Rather  a  good 
Infrastructure  and  Environment, 
neighbour  –  a  stronger  permitting,  supervision  and  enforcement 
strategy  and  a  more  effective  approach  to  infringements’  (Dutch), 
November 
at: 
https://www.rijksoverheid.nl/documenten/rapporten/2020/12/03/bijla
ge-1-liever-een-goede-buur-een-sterkere-vth-uitvoering-en-
effectievere-aanpak-van-overtredingen  
252 Information obtained from the Ministry of Infrastructure and Water 
Management  during  consultations  with  national  authorities  for  this 
report. 
253 RIVM webpage with an overview of recent environmental incidents. 
254 Pursuant to Article 17.18 of the Environmental Management Act. 
255 Regarding Seveso companies a decree provides provinces with the 
competence  to  include  financial  secutiry  as  a  permit  condition  (entry 
info force on 1 January 2023). 
256  Ministerie  van  Infrastructuur  en  Waterstaat,  Beslisnota  ‘Wijziging 
omgevingsbesluit  i.v.m.  verplicht  stellen  financiele  zekerheid’,  2  July 

The Netherlands  48 

The obligation would apply to (i) companies to which the 
Major  Hazards  Decree  (implementing  the  EU  Directive 
2012/18/EU)  applies,  (ii)  companies  under  Annex  I, 
category 4 of the Industrial Emissions Directive (chemical 
industry) and (iii) waste processing companies. 

2022 priority actions 

activity 

reports/statistics 

inspection  plans, 

  Publish 
inspection  reports  and 
annual 
to 
environmental  inspections  of  industrial  installations 
under  the  industrial  emissions  Directive,  in  the  same 
manner  as  is  done  for  installations  falling  under 
Seveso III.   

linked 

 

Improve  cooperation  between  enforcing  authorities 
on  environmental  crime,  for  example  by  improving 
information  exchange,  resources,  level  of  expertise 
and  cooperation  systems  of  administrative  and 
criminal authorities involved. 

  Set  up  a  financial  security  system  for  environmental 
liability to meet the costs of environmental damage. 

Effectiveness of environmental 
administrations  

in 

involved 

implementing 

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

Administrative capacity and quality 

Overall,  during  the  last  decade  an  improvement  in  the 
implementation of EU environmental law in the different 
sectors can be observed. In general, the Netherlands take 
early  and  effective  measures  to  deal  with  potential 
breaches of EU environmental law. The Dutch authorities 
approach  is  to  discuss  with  the  Commission  as  soon  as 
they become aware of an issue, hence the relatively low 
number of infringements in this sector. For instance, the 
implementation of the environmental impact assessment 
Directive (EIA) is expected to improve with the Dutch Act 
(Omgevingswet)  expected  to  enter  into  force  on  1f 
January 2023. 

2021, IENW/BSK-2021/193316 and online consultation launched on 24 
November 2020 regarding the proposal; see Overheid.nl for tracking of 
progress of the legislative procedure with regard to the proposal. 

 Environmental Implementation Review 2022 – The Netherlands 

 
                                                                 
 
 
 
 
                                                                                                        
Coordination and integration  

TAIEX EIR peer-to-peer projects 

The Netherlands  49 

it 
the  quality  of 

The  Commission  encourages  the  streamlining  of  the 
environmental  assessments,  to  reduce  duplication  and 
avoid  overlaps  in  environmental  assessments  applicable 
to  projects.  Moreover,  streamlining  helps 
reduce 
unnecessary  administrative  burdens  and  accelerates 
is  done  without 
decision  making,  provided 
the  environmental 
compromising 
The  Netherlands  has 
assessment  procedure257. 
introduced 
environmental 
streamlining 
assessments under the EIA and Habitats Directives before 
the revision of the EIA Directive. It reports annually to the 
Parliament  on  the  progress  made  as  regards  the 
(SDGs).  Coordinated 
sustainable  development  goals 
procedures  have  been  established 
for  EIA,  water 
framework Directive andiIndustrial emissions Directive. 

the 

of 

The TAIEX EIR peer-to-peer tool258 has been launched by 
the  Commission  to 
learning 
between environmental authorities. 

facilitate  peer-to-peer 

During  the  reporting  period,  the  Netherlands  has  taken 
actively  part  in  many  TAIEX  EIR  peer-to-peer  events  on 
various  topics,  including  sustainable  urban  development 
(2019),  green  public  procurement  (2020),  maintaining 
and  enhancing  ecosystem  services 
in  urban  regions 
(2019),  ammonia  reducing  technology  and  measures 
(2021), zero pollution for air, water and soil (2022), etc. 

What can be highlighted as a good practice is the Single 
Environmental  Permitting  Platform,  which  has  been 
developed  to  operationalise  the  Single  Environmental 
Permitting  Regime.  This  regime  simplifies,  aligns  and 
coordinates many environmental permits. 

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 granting technical assistance 
such as the Technical Support Instrument (TSI). 

the 

implementation  of  an 

The  Commission’s  TSI  supported  two  environment-
related  projects  in  the  Netherlands  under  the  TSI  2020: 
one  related  to  the  capacity  building  of  municipalities  to 
support  faster  implementation  of  car  sharing  and  the 
other  on 
integrated 
management  plan  and  socio  economic  data  model.  In 
2021,  two  other  projects  were  selected:  “Use  of 
precaution  in  the  energy  transition  and  extending  the 
knowledge  base  for  risk  regulation  of  new  hydrogen 
applications”  and  “Citizens  participation  and  green 
solutions  in  smart  cities”.  Under  the  TSI  2022,  two  new 
requests  were  considered:  one  to  develop  clean,  smart 
and  fair  urban  mobility  and  one  related  to  the 
digitilisation  of  the  East  Atlantic  Flyway  for  birds  in  the 
Wadden Sea (together with Germany and Denmark).  

257 The Commission issued a guidance document in 2016 about setting 
up coordinated and/or joint procedures that are simultaneously subject 
to  assessments  under  the  EIA  Directive,  habitats  Directive,  water 
framework  Directive,  and  the  industrial  emissions  Directive,  OJ  C  273, 
27.7.2016, p. 1.  

258 http://ec.europa.eu/environment/eir/p2p/index_en.htm 

 Environmental Implementation Review 2022 – The Netherlands