COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022 Country Report - LUXEMBOURG 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, Luxembourg, 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) 267 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2022     Country Report - LUXEMBOURG           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) 268 final} - {SWD(2022) 269 final} - {SWD(2022) 270 final} - {SWD(2022) 271 final} - {SWD(2022) 272 final} - {SWD(2022) 273 final} - {SWD(2022) 274 final} - {SWD(2022) 275 final} - {SWD(2022) 276 final} - {SWD(2022) 277 final} - {SWD(2022) 278 final}  
 
 
Luxembourg  1 

This  report  has  been  written  by  the  staff  of  the  Directorate-General  for  Environment,  European  Commission. 
Any comments are welcome to the following e-mail address: ENV-EIR@ec.europa.eu  

More information on the European Union is available on the internet (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. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Luxembourg  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 
Ecosystem assessment and accounting ............................................................................................................. 15 
3. ZERO POLLUTION ..................................................................................................................................................... 17 
Clean air ............................................................................................................................................................. 17 
Industrial emissions ............................................................................................................................................ 19 
Prevention of major industrial accidents – SEVESO ........................................................................................... 21 
Noise .................................................................................................................................................................. 22 
Water quality and management ........................................................................................................................ 22 
Chemicals ........................................................................................................................................................... 27 
4. CLIMATE ACTION ..................................................................................................................................................... 29 
Key national climate policies and strategies ...................................................................................................... 29 
Effort sharing target ........................................................................................................................................... 30 
Key sectoral developments ................................................................................................................................. 30 
Use of revenues from the auctioning of EU ETS allowances .............................................................................. 31 

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

5. FINANCING ............................................................................................................................................................. 32 
Environmental investment needs in the EU ....................................................................................................... 32 
EU environmental funding in 2014-2020 ........................................................................................................... 34 
EU environmental funding 2021-2027 ............................................................................................................... 35 
National environmental protection expenditure ................................................................................................ 37 
Green budget tools ............................................................................................................................................. 39 
Overall financing compared to the needs .......................................................................................................... 41 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 43 
Information, public participation and access to justice...................................................................................... 43 
Compliance assurance ........................................................................................................................................ 44 
Effectiveness of environmental administrations ................................................................................................ 46 
Reforms through the Commission’s technical support instrument (TSI) ............................................................ 46 
TAIEX EIR peer to peer projects .......................................................................................................................... 47 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
Luxembourg  3 

Executive summary 

The main challenges in Luxembourg’s implementation of 
EU  environmental  policy  and  law  identified  in  past 
environmental implementation reviews (EIRs) were: 

 

 

improve  nitrate  concentrations  in  groundwater  and 
the trophic state of surface water; 
to 
take 
emissions; 

short-term  measures 

reduce  vehicle 

  monitor  the  risk  of 

increased  particulate-matter 
emissions  from  greater  use  of  biomass  to  reduce 
greenhouse-gas emissions; and 

  monitor habitat fragmentation and biodiversity loss. 

On  water management, Luxembourg  achieved sufficient 
levels of collection and treatment of urban waste water. 
Water  pollution  by  heavy  metals  significantly  decreased 
in recent years. However, concerns remain as all surface 
water  bodies  and  a  major  part  of  groundwater  bodies 
failed  to  achieve  a  good  ecological  status  in  2020. 
Nutrient losses from waste  water treatment  plants have 
been  cut  by  half  since  2000.  However,  further  work  is 
needed  to  reduce  nitrate  pollution  where  agriculture 
pressure  is  significant.  77%  of  the  nutrient  flux  comes 
from agriculture. 

On  air  quality,  there  has  been  some  progress.  Key  air 
pollutants  decreased  in  recent  years,  although  in  some 
sensitive  areas,  concerns  on  traffic-induced  air  pollution 
remain.  The  authorities  should  monitor  the  situation 
closely  and  adjust  measures  if  needed,  also  taking  into 
account pollution from private cars. 

On  biodiversity,  there  has  been  progress,  starting  with 
the  full  implementation  of  the  Natura  2000  network 
management  plans.  Although,  Luxembourg  has  one  of 
the highest rates of protected terrestrial areas in the EU, 
the share of habitats and species with a bad conservation 
status  has  increased.  Luxembourgish  authorities  should 
continue  to  take  regulatory  measures  to  stengthen 
integrate 
should  also 
biodiversity.  They 

furhter 

biodiversity  issues  in  other  policies,  in  particular  to 
decrease agriculture pressures on the environment.  

There  has  been  substantial  progress  on  the  circular 
economy, with a significant increase in circular material-
use  rate,  resource  productivity,  and  eco-innovation, 
illustrating Luxembourg’s action.  

On  waste  management,  there  has  been  only  limited 
progress.  Waste  generation  is  stagnating  at  high  levels 
and recycling rates did not progres in recent years. More 
action  will  be  necessary  to  comply  with  the  EU’s  post-
2020 recycling targets. 

Environmental implementation in Luxembourg continues 
to  receive  some  support  from  EU  financing,  but  99%  is 
financed  from  national  sources.  From  the  European 
Structural  and  Investment  Funds,  Luxembourg  received 
EUR  4  million  to  cover  direct  environmental  investment 
in  2014-2020. 
and  climate  and  risk  management 
Luxembourg  is  due  to  receive  over  EUR  93  million 
through  its  national  recovery  and  resilience  plan  (RRP) 
(2021-2026)  and  a  EUR  58.7  million  cohesion-policy 
allocation  (2021-2027).  The  main  funding  to  deal  with 
investment  needs  must  come  from  national  and  private 
sources. Luxembourg’s total financing for environmental 
investment came to 0.49% of GDP in 2014-2020. In 2021-
2027, Luxembourg’s environmental investment needs are 
estimated  to  reach  over  0.77%  of  GDP,  suggesting  an 
environmental  financing  gap  of  at  least  0.27%  of  GDP. 
This  financing  gap  needs  to  be  addressed  by  additional 
raising 
environmental 
financial resources. 

financing  measures  and  by 

Luxembourg’s RRP shows good practice. It contains direct 
investments to support nature and biodiversity, including 
groundwater protection and restoration of watercourses 
to their natural condition. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
Luxembourg  4 

Part I: Thematic areas 

1. Circular economy and waste management  

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

Measures towards a circular economy 

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

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

‘remanufacturing’1;  (ii) 

the  durability, 

increase 

like:  (i) 

to 

Luxembourg’s circular  (secondary) material-use rate was 
11.3%  in  2014  and  13.6%  in  2020,  compared  to  the  EU 
average  of  12.8%.  As  shown  in  Figure  1,  Luxembourg 
performed better than the EU average again in 2020. 

Resource  productivity  expresses  how  efficiently  the 
economy  uses  material  resources  to  produce  wealth. 
Improving  resource  productivity  can  help  to  minimise 
impacts  on  the  environment  and  reduce 
negative 
dependency  on  volatile  raw-material  markets.  As  shown 
in  Figure  2,  with  EUR  4.47  generated  per  kg  of  material 
consumed, resource productivity in Luxembourg was well 
above  the  EU  average  of  EUR  2.09  per  kg  in  2020.  This 
further  supported  by  a 
positive  performance 
continuous 
resource 
increase 
productivity over the last few years. 

Luxembourg’s 

is 
in 

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

2 Eurostat, Circular Economy Monitoring Framework. 

Environmental Implementation Review 2022 – Luxembourg 

 
                                                                 
 
 
 
                                                                 
Luxembourg  5 

for  the 

than 
announced in the strategy separately. 

implementation  of  each  deliverable 

The strategy also includes specific action on construction. 
The  country  has  no  sectoral  strategies  on  plastics  and 
textiles in place. 

Eco-innovation 

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

the  overall  2021  eco-innovation 

On 
scoreboard, 
Luxembourg ranked first of all EU countries, with a total 
score  of  171.  The  country  is  thus  an  eco-innovation 
leader.  In  4  out  of  5  components  of  the  2021  eco-
innovation 
index,  Luxembourg  outperforms  the  EU 
average  (eco-innovation  inputs,  eco-innovation  outputs, 
socio-economic 
resource-efficiency  outcomes, 
outcomes).  It  performs  below  the  EU  average  in  eco-
innovation activities. 

and 

Figure 2: Resource productivity, 2010-20203 

Circular-economy strategies 

The European Commission encourages Member States to 
adopt and implement national/regional circular-economy 
strategies covering the whole  life cycle of products. This 
is  because  such  strategies  are  one  of  the  most  effective 
ways to progress towards a more circular economy. Since 
the  launch  of  the  online  Circular  Economy  Stakeholder 
Platform  in  20174,  national,  regional  or  local  authorities 
have  used  the  platform  to  share  their  strategies  and 
roadmaps. 

In  February  2021,  Luxembourg  adopted  a  new  circular-
economy  strategy  called  Circular  Economy  Strategy 
Luxembourg, to be implemented in 3 years. The strategy 
is  comprehensive  and  targets  products’  entire  life  cycle. 
The strategy was developed jointly by four ministries: the 
Ministry  of  Energy  and  Spatial  Planning,  the  Ministry  of 
the  Economy,  the  Ministry  of  the  Environment,  Climate 
and  Sustainable  Development,  and  the  Ministry  of 
Finance. 

Luxembourg  created  a  new  public  administration  unit, 
It  aims  to 
called  the  National  Coordination  Unit. 
strategy’s 
the  monitoring 
centralise 
the 
implementation. 
an 
The 
implementation  timeline.  However,  this  timetable  sets 
implementation  targets  by  group  of  deliverables  rather 

of 
strategy 

includes 

3 Eurostat, Resource productivity. 
4 https://circulareconomy.europa.eu/platform/en/strategies 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
                                                                 
 
 
Figure 3: Eco-innovation performance, 2010-20195 

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

Luxembourg  6 

The number of EU Ecolabel products and EMAS-licensed6 
organisations in a given country provides some indication 
of  the  extent  to  which  the  private  sector  and  national 
stakeholders  in  that  country  are  actively  engaged  in  the 
transition  to  a  circular  economy.  It  also  shows  how 
supporting 
committed  public  authorities  are 
instruments designed to promote the circular economy. 

to 

In  September  2021,  Luxembourg  had  1  product  and  1 
licence  registered  under  the  EU  Ecolabel  scheme  out  of 
83  590  products  and  2  057  licences  in  the  EU7.  This  is  a 
further  decrease  of  the  already  low  level  in  2019,  when 
Luxembourg  had  9  products  and  2  licences  registered 
under  the  EU  Ecolabel  scheme.  As  regards  EMAS,  there 
in  October  2021, 
was  a  positive  development,  as 
Luxembourg8 had 7 registered organisations, up from 4 in 
2019. 

Waste management 

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

This  section  focuses  on  the  management  of  municipal 
waste9,  for  which  EU  law  sets  mandatory  recycling 
targets. 

Preventing products and materials from becoming waste 
for  as  long  as  possible  is  the  most  efficient  way  to 
the 
improve 
environmental  impact  of  waste.  Waste  prevention  and 
re-use are the most preferred options, and are therefore 

resource  efficiency  and 

reduce 

to 

is  a  European  Commission  programme  to  encourage 

6  EMAS 
organisations to behave in a more environmentally sustainable way. 
7 European Commission, Ecolabel Facts and Figures. 
8 European Commission, EMAS. 
9 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;  and  (b)  mixed  waste  and 
separately  collected  waste  from  other  sources,  where  such  waste  is 
similar in nature and composition to waste from households. (Article 3, 
point (2b), of Directive 2008/98/EC). 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  around  14%  of  EU  GDP. 
Public  procurement  can  help  drive  the  demand  for 
reparability  and 
sustainable  products 
recyclability standards. To date, reporting to monitor the 
uptake of green public procurement is voluntary.  

that  meet 

law 

in  place 

is  currently  not 

A  national  action  plan  or  a  national  strategy  on  green 
in 
public  procurement 
Luxembourg.  Nevertheless, 
public-
Luxembourg’s 
procurement 
formally  encourages  contracting 
authorities  to  use  tender  procedures  to  promote 
sustainable development. The country does not have any 
targets, specific measures or  mandatory criteria in place 
to promote green public procurement. Some guidance on 
criteria  that  can  be  imposed  is  provided  in  the  terms  of 
reference and links to the EU’s green public procurement 
website and toolkit. 

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

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
                                                                 
at  top  of  the  waste  hierarchy.  The  amount  of  municipal 
waste generated is a  good indicator of the effectiveness 
of waste-prevention measures. 

in  2015,  municipal-waste  generation 

Luxembourg generates much more municipal waste than 
the EU average of 505 kg per year per person. However, 
this is partially caused by the very high number of cross-
border commuters. After a continuously decreasing trend 
and having reached its lowest point (607 kg per year per 
person) 
in 
Luxembourg  has  increased  significantly,  reaching  790  kg 
per  year  per  person  in  2020,  as  Figure  4  shows.  This 
increase  can  be  partially  explained  by  a  change  in  the 
definition  of  municipal  waste,  which  induce  a  higher 
share of non-household waste (from 12%  to 35%). Since 
2016, municipal waste generation has slightly decreased, 
which  potentially  indicates  a  decoupling  trend  between 
waste generation and economic growth in Luxembourg. 

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

Figure  5  shows  that  Luxembourg’s  recycling  rate  for 
municipal  waste  has  slightly  increased  in  recent  years, 
in  2017.  Luxembourg’s 
in  2012  to  50% 
from  47% 
performance  then  stagnated 
it 
in  2019  (49%),  but 
improved again in 2020 (53%). 

10 Eurostat, Municipal waste by waste operation, April 2022. 

Luxembourg  7 

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

The  Commission's  early-warning  report12  did  not  list 
Luxembourg as one of the countries at risk of missing the 
EU’s  2020  target  of  recycling  50%  of  municipal  waste. 
However,  Luxembourg  needs  to  do  more  to  reach  the 
post-2020  recycling  targets  (55%  in  2025  and  60%  in 
2030), particularly on total incineration, which remains at 
a  high  level  of  47%  of  municipal  waste  (e.g.  369  kg  per 
person in 2019). The Commission is currently finalising its 
analyses  of  progress  on  the  recommendations  of  the 
2018  early-warning  reports  and  of  progress  towards 
achieving  the  2025  waste-recycling  targets.  A  report 
covering  both  analyses  will  be  presented  at  the  end  of 
2022 and will assess progress made by then. 

Implementation of the 2018 legislative package on 
waste 

By 5 July 2020, Member States had to bring their national 
laws  in  line  with  changes  included  in  the  revised  Waste 
Framework Directive, the Packaging and Packaging Waste 
Directive  and  the  Landfill  Directive13.  Luxembourg  had 
still  not  done  this  for  the  whole  package  by  July  2021. 
Therefore,  the  Commission  sent  four  reasoned  opinions 
urging  Luxembourg  to  fully  transpose  the  new  EU  rules 
on  waste  into  national  legislation.  Otherwise,  the  case 

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  legislation 
on waste and set more ambitious recycling targets for the period up to 
2035. 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
                                                                 
 
 
 
                                                                 
may be referred to the Court of Justice of the European 
Union. 

plans 

Waste-management 
and  waste-prevention 
programmes  are  instrumental  in  properly  implementing 
the  EU 
legislation  on  waste.  They  set  out  key 
requirements and investment to ensure compliance with 
current  and  new 
(e.g.  waste 
prevention,  separate  collection  for  a  number  of  specific 
waste streams, and recycling and landfill targets). Revised 
plans and programmes were due on 5 July 2020. 

requirements 

legal 

In  2018,  Luxembourg  notified  the  Commission  of  its 
updated  waste-management  plan.  The  Commission  is 
currently  carrying  out  a  conformity  assessment  to  verify 
whether the plan meets the requirements of Article 28 of 
the revised Waste Framework Directive. 

Convention 

Luxembourg  has  not  yet  ratified  the  Hong  Kong 
International 
and 
Environmentally  Sound  Recycling  of  Ships  and  the 
International  Convention 
and 
Management of Ships’ Ballast Water and Sediments. 

the  Control 

Safe 

the 

for 

for 

Luxembourg  8 

above. Therefore, this priority action is reiterated. On the 
priority  action  related  to  the 
introduction  of  an 
incineration tax to shift to reusable and recyclable waste, 
there  has  been  no  progress.  In  light  of  the  2022  early-
warning  report,  this  priority  action  is  reiterated.  New 
priority  actions  to  ensure  compliance  with  the  revised 
Waste Framework Directive are added. 

2022 priority actions 

 

new 
to 

economically 

recycling  more 

including 
further 

policies, 
implement 

economic 
Introduce 
the  waste 
instruments, 
hierarchy,  i.e.  promote  prevention,  and  make  reuse 
and 
attractive; 
implement the policies which are already in place. 
  Shift  reusable  and  recyclable  waste  away  from 
incineration  by  gradually  phasing  out  subsidies  to 
incineration  or  by  introducing  an  incineration  tax. 
Channel 
to 
improve  waste  management  in  line  with  the  waste 
hierarchy. 

towards  measures 

revenues 

those 

In  the  2019  EIR,  Luxembourg  received  two  priority 
actions  in  the  field  of  waste  management.  There  has 
limited  progress  on  the  first  priority  action 
been 
(introducing  new  policies  and  economic  instruments  to 
promote waste prevention and make product reuse and 
recycling  more  economically  attractive),  as  detailed 

  Put in place a national waste management plan in line 
with  the  revised  Waste  Framework  Directive  is  in 
place. 

  Ratify  relevant 

international  conventions  on  ship 

recycling and on ballast water and sediments. 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
Luxembourg  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 its sea area and integrate ecological corridors, as 
part of a true trans-European nature network;  
(ii) strictly protect at least a third of the EU’s protected 
areas,  including  all  remaining  EU  primary  and  old-
growth forests;  
(iii)  effectively  manage  all  protected  areas,  defining 
clear  conservation  objectives  and  measures,  and 
monitoring them appropriately.  
The strategy also sets out an EU nature restoration plan 
–  a  series  of  concrete  commitments  and  actions  to 
restore  degraded  ecosystems  across  the  EU  by  2030, 
and  manage  them  sustainably,  addressing  the  key 
drivers of biodiversity loss. 

The EU’s Habitats and Birds Directives are key legislative 
tools  to  deliver  on  the  targets  in  the  EU’s  biodiversity 
strategy for 2030, and are the cornerstone of European 
legislation aimed at conserving the EU’s wildlife14. 

On January 2017, Luxembourg’s national plan on nature 
protection (PNPN)15 was approved by the government16. 

This  new  plan  identifies  goals  for  2030,  reflected  into 
more  than  100  measures,  each  with  corresponding 
indicators,  priorities,  deadlines,  verification  means, 
responsible  entities.  The  Commission 
tools  and 
encourages  Luxembourg  to  update  the  plan  to  make  it 
compliant with the 2030 EU biodiversity strategy. 

Nature protection and restoration  

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

14  According  to  the  new  EU  biodiversity  strategy,  these  should  be 
strengthened by the Nature Restoration Law. 
15  Luxembourgish  Ministry  of  Sustainable  Development  and 
Infrastructure, Environment Department, Plan National concernant la 
Protection de la Nature 2017-2021, Luxembourg, 13 January 2017. 
16 Décision du Gouvernement en Conseil du 13 janvier 2017 relative au 
plan  national  concernant  la  protection  de  la  nature  2017-2021  et 
ayant  trait  à  sa  première  partie  intitulée  «  Stratégie  nationale 
Biodiversité ». 
17 Natura 2000 comprises SCIs designated under the Habitats Directive 
and SPAs classified under  the  Birds  Directive.  Figures of  coverage  do 
not  add  up  because  some  SCIs  and  SPAs  overlap.  SACs  are  SCIs 
designated by Member States. 

Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe's  most 
valuable  and  threatened  species  and  habitats  and 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  to:  (i)  setting  up  of  a  coherent  Natura 
2000  network;  (ii)  designate  sites  of  community 
importance  (SCIs)  as  special  areas  of  conservation 
(SACs);  and 
(iii)  set  conservation  objectives  and 
measures for the Natura 2000 sites. 

Setting up a coherent network of Natura 2000 sites 

Luxembourg  hosts  28  habitat  types18  and  60  species19 
covered  by  the  Habitats  Directive.  The  country  also 
hosts populations of 44 bird taxa listed in Annex I to the 
Birds Directive20. 

By  2021,  27.1%  of  Luxembourg’s  territory  was  covered 
by Natura 2000 (EU average: 18.5%). Special protection 
areas (SPAs) classified under the Birds Directive covered 
16.1% (EU average: 12.8%) and SCIs under the Habitats 
Directive  covered  16%  (EU  average:  14.2%)  of  the 
Member State’s territory. 

The latest assessment of the SCI part of the Natura 2000 
network  was  carried  out  in  2016,  on  the  basis  of  the 
2014 database. At that time, the only insufficiency was 
related  to  Coenagrion  mercuriale.  Luxembourg  has 
designated  a  site  for  this  species  (site  LU0001013, 
Vallée  de  l'Attert  de  la  frontière  à  Useldange).  A  final 
evaluation  of  the  situation  in  the  country  will  be 
sufficient to conclude this procedure. 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas, 
legally 
protects  51.5%  of  its  terrestrial  areas  (EU-27  average: 
26.4%)21. 

Luxembourg 

18 European Environment Agency, Article 17 dashboard, Annex I total, 
2019. 
19  European  Environment  Agency,  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. 
20 European Environment Agency, Article 12 dashboard, Annex I, 2020. 
This counting only takes into account birds taxa for which information 
was requested. 
21  European  Environment  Agency,  Protected  Areas,  terrestrial 
protected area percentage (2021), March 2022. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
                                                                 
 
 
                                                                 
Figure 6: Terrestrial protected area coverage, 202122 

objectives  of  the  management  plans  should  be 
improved to provide quantified objectives. 

Luxembourg  10 

Figure 7: Natura 2000 terrestrial protected area 
coverage, 202123 

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

To measure the performance of Member states, Article 
17  of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  require  reporting  on  the  progress  made 
towards  maintaining  or  restoring 
favourable 
the 
conservation status of species and habitats. 

According  to  Luxembourg’s  report  on  the  conservation 
status  of  habitats  and  species  covered  by  Article  17  of 
the  Habitats  Directive  for  2013-2018,  the  share  of 
habitats with a good conservation status was 32.14% in 
2018  (9  good  assessments).  This  is  more  than  the  25% 
(7  good  assessments)  reported  for  2007-2012.  The 
share  of  protected  species  with  a  good  conservation 
status  was  15%  in  2018  (11  assessments).  This  is  less 
than  the  18.3%  (11  assessments)  reported  for  2007-
2012.  42.86%  of  the  forest  area  protected  under  the 
Birds  and  Habitats  Directives  shows  a  favourable 
conservation  status24  (86.0%  has  a  good  conservation 
status).  For  birds,  65%  of  breeding  species  showed 
short-term  increasing  (15%)  or  stable  (50%)  population 
trends. For wintering species, 50% of species  showed a 
short-term increase. 

At  the  same  time,  the  share  of  habitats  with  a  bad 
conservation status has increased to 50% and the share 
of species with a bad conservation status has increased 
to 45%. The main pressures as reported under Article 17 
of  the  Habitats  Directive  and  Article  12  of  the  Birds 
Directive  are: 
(ii)  development, 
construction  and  use  of  residential,  commercial, 
industrial and recreational infrastructure and areas; and 
(iii) natural processes and changes in land use. 

(i)  agriculture; 

Designating SACs and setting conservation objectives 
and measures 

Luxembourg  has  designated  all  its  48  SACs  within  the 
six-year deadline. For each SAC, conservation measures 
are set out in a comprehensive management plan (some 
management  plans  are  shared  by  several  SACs; 
management  plans  are  available  at  www.emwelt.lu)  or 
in 
the  PNPN.  Grand-ducal  decrees  already  set 
conservation  objectives  that  are  not  repeated  in  the 
Natura  2000  management  plans.  Some  conservation 

22  EU  Biodiversity  Strategy  Dashboard,  indicators  A1.1.1  and  A1.2.1, 
February 2022. 
23 European Environment Agency, 2021. 

24 European Environment Agency, State of Nature Report, 2021. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
                                                                 
 
 
                                                                 
Figure 8: Assessments of habitat conservation status 
for 2007-2012 and 2013-201825 

Figure 9: Assessments of species conservation status 
for 2007-2012 and 2013-201826 

Luxembourg  11 

and  communication  among  stakeholders.  Luxembourg 
is  also  investing  to  improve  biodiversity  monitoring,  in 
particular  to  set  up  species  monitoring.  Luxembourg  is 
also  planning  investment  to  maintain  or  restore  the 
favourable  status  of  grasslands  and  humid  areas,  with 
specific  measures  for  each  habitat  (see  Luxembourgish 
PAF). 

Between 2014 and 2020, Luxembourg has used the LIFE 
programme to co-finance projects such as: 

  LIFE  Bats  &  Birds27, 
endangered species; and 

improving  habitats 

for 

  The Voice for Nature28, raising awareness about the 
environment,  nature  protection  and  the  need  to 
address climate change. 

to 

related 

In  2021,  the  Commission  received  a  complaint  against 
Luxembourg 
the  Habitats  and  Birds 
Directives.  The  complaint  concerned  the  conservation 
status of: (i) the grey partridge (Perdix perdix) and other 
farmland birds; and (ii) semi-natural grasslands (habitat 
codes  6510,  6410,  etc.).  Despite  supporting  measures 
taken  by  Luxembourg,  there  are  only  four  couples  of 
the 
partridges 
in 
conservation  status  of  semi-natural  grasslands 
is 
worsening. The loss and deterioration are mainly caused 
by  harmful  agricultural  practices.  Binding  rules  are 
urgently needed to preserve these species and habitats, 
in  particular  to  protect  and  restore  semi-natural 
grasslands. 

country  and 

remaining 

the 

In  the  2019  EIR,  Luxembourg  received  two  priority 
actions.  The 
first  priority  action  –  effectively 
implementing  Natura  2000  management  plans  –  has 
been 
implemented.  On  the  second  one  – 
integrating  biodiversity  concerns  into  other  policies  – 
there  has  been  some  progress,  as  detailed  above. 
Therefore, it is important to continue this work. 

fully 

Bringing nature back to agricultural land and restoring 
soil ecosystems 

Agricultural land 

The biodiversity strategy works alongside the new farm 
to fork strategy and the new common agricultural policy 
(CAP)  to  support  and  achieve  the  transition  to  fully 
sustainable agriculture. 
The  biodiversity  and  farm  to  fork  strategies  have  set 
four important targets for 2030: 
(i) a 50% reduction in the overall use of – and risk from 

For  habitats,  the  threats  and  risks  induced  by  natural 
processes are on par with those induced by agriculture. 

Luxembourg has completely designated its Natura 2000 
network. Each site has its management  plan describing 
conservation  objectives  and  measures.  The  country  is 
under high pressure due to its high level of urbanisation 
and  agriculture  activities.  The  prioritised  action 
framework  (PAF)  proposed  by  Luxembourg  aims  to 
improve  the  current  situation,  in  particular  by  creating 
eight steering committees to improve site management 

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

27 LIFE Bats & Birds - providing Bed and Breakfast for Bats & Birds. 
28  The  Voice  for  Nature  -  Empowering  Volunteers  to  speak  up  for 
biodiversity and engage in direct action environmental conservation. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
                                                                 
 
                                                                 
in 

– chemical pesticides; 
(ii)  a  50%  reduction  in  the  use  of  more  hazardous 
pesticides; 
(iii)  a  50%  reduction 
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); 
(iv)  bring  back  at  least  10%  of  agricultural  area  under 
high-diversity  landscape  features  and  increase  areas 
under organic farming to at least 25%. 

With  an  estimated  4.63%  of  agricultural  area  under 
organic farming, Luxembourg is far from the EU average 
of  9.07%.  Figure  10  shows  the  situation  in  the  EU  on 
meeting the organic-farming target. 

Figure 10: Share of total utilised agricultural area 
occupied by organic farming per Member State, 202029 

Luxembourg  12 

Soil ecosystem 

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

One factor  in the degradation  of soil ecosystems  is the 
area  of  soil  that  is  sealed  or  artificialised31.  The  land 
taken32 per year in 2012-2018 can be seen as a measure 
of one significant pressure on nature and biodiversity – 
land-use  change.  At  the  same  time,  land-use  change 
constitutes an environmental pressure on people living 
in urbanised areas.  

Luxembourg  ranks  well  above33  the  EU  average,  with 
one of the worst results for net land take: 292.8m2/km2 
(EU-27 average: 83.8m2/km2). 

In  2018,  Luxembourg  updated  its  reporting  on  land 
degradation  according  to  the  third  version  of  the 
Performance  Review  and 
Implementation  System 
(PRAIS3) reporting platform34. In particular, Luxembourg 
expanded its reporting to cover measures to reduce the 
degradation identified. 

According  to  the  Commission  recommendations  for 
Luxembourg’s  CAP  strategic  plan30,  farm  production  in 
Luxembourg’s  rural  areas  is  characterised  by  a  high 
share  of 
livestock,  causing  significant  pressure  on 
natural  resources  and  biodiversity.  Considering  that 
21% of Luxembourg’s Natura 2000 sites are agricultural 
zones,  farming  practices  have  a  significant  impact  on 
nature  conservation  in  the  country.  It  is  of  utmost 
importance  to  further  develop  of  organic  farming  and 
change rural practices (encouraging sustainable soil and 
water  management,  land-use  mitigation  and  reduction 
of the use of pesticides). This will help bring about  the 
climate  and  environmental  transitions  and  counter  the 
degradation of natural sites and the loss of biodiversity. 

29 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en (Eurostat, Area under organic farming, February 2022). 
30 
for 
European  Commission,  Commission  Recomendations 
Luxembourg’s CAP Strategic Plan, 2020. 

31 Artificial  land cover  is defined as the total of roofed built-up areas 
(including  buildings  and  greenhouses),  artificial  non-built-up  areas 
(including sealed-area features, such as yards, farmyards, cemeteries, 
car-parking  areas,  etc.  and  linear  features,  such  as  streets,  roads, 
railways,  runways  and  bridges)  and  other  artificial  areas  (including 
bridges  and  viaducts,  mobile  homes,  solar  panels,  power  plants, 
electrical  substations,  pipelines,  water-sewage  plants,  and  open 
dumpsites). 
32 Land ‘taken’ means land that is sealed or artificialised. 
33 European Environment Agency, Land take in Europe, fig 6. 
34 All Reports | Prais3 (unccd.int). 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
                                                                 
Figure 11: Land take and recultivation in EU-27 
(m2/km2), 2012-201835 

place  and  the  country  had  remediated  or  had  applied 
aftercare measures on 1 060 sites already. 

Luxembourg  13 

transboundary 

Soil  erosion  by  water  is  a  natural  process  that  can  be 
aggravated by climate change and human activities such 
as  inappropriate  agricultural  practices,  deforestation, 
forest  fires  or  construction  works.  High  levels  of  soil 
erosion  can  reduce  productivity  in  agriculture  and  can 
impacts  on 
have  negative  and 
biodiversity  and  ecosystem-service  provision  and  on 
lakes  (increased  volume  of  sediments, 
rivers  and 
transport  of 
the 
RUSLE2015  model38,  Luxembourg  has  an  average  soil-
loss  rate  by  water  of  2.07  tonnes  per  hectare  per  year 
compared  to  a  EU  average  of  2.46  tonnes  per  hectare, 
which  indicates  soil  erosion  is  medium  on  average. 
These  figures  are  the  output  of  a  model  run  at  the  EU 
level.  Therefore,  they  should  not  be  considered  as 
values  measured  in  situ.  The  actual  soil-loss  rate  can 
vary strongly within a Member State depending on local 
conditions. 

contaminants).  According 

to 

The  United  Nations’  Global  Mechanism  and  the 
secretariat of the United Nations Convention to Combat 
Desertification  (UNCCD)  use  the  Land  Degradation 
Neutrality  (LDN)  Taget  Setting  Programme  to  support 
interested countries in their national LDN target-setting 
process. This process includes setting national baselines, 
targets and associated measures to achieve LDN. Target 
15.3  of  the  Sustainable  Development  Goal  states:  ’By 
2030,  combat  desertification,  restore  degraded  land 
and  soil,  including  land  affected  by  desertification, 
drought  and  floods,  and  strive  to  achieve  a 
land 
degradation-neutral  world.’  However,  Luxembourg  has 
not  yet  committed  to  setting  LDN  targets  under  the 
UNCCD36. 

information 

Contamination  can  severely  reduce  soil  quality  and 
threaten  human  health  or  the  environment.  The  latest 
the  Member  States37 
from 
available 
estimated that potentially polluting activities have taken 
or  are  still  taking  place  on  approximately  2.8  million 
sites  in  the  EU.  Of  these  sites,  650  000  have  been 
registered  in  national  or  regional  inventories.  65  500 
contaminated  sites  have  been  remediated  already. 
Luxembourg  had  registered  12  000  sites  where 
potentially polluting activities had taken or were taking 

35  European  Environment  Agency,  Land  take  in  Europe,  December 
2021. 
36 The LDN Target Setting Programme | UNCCD. 
37  Ana  Paya  Perez,  Natalia  Rodriguez  Eugenio, Status  of  local  soil 
contamination  in  Europe:  Revision  of  the  indicator  ‘Progress  in  the 
management contaminated sites in Europe’, 2018. 

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

Forests and timber 

The EU forest strategy for 2030, adopted in July 2021, is 
part  of  the  ‘Fit  for  55’  package.  The  strategy  promotes 
the many services that forests provide. Its key objective 
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 show a 
favourable conservation status39. The  share of  forested 
areas in the EU with a bad conservation status increased 
from 27% in 2015 to 31% in 2018.  

In Luxembourg, forests cover 36.64%40 of the territory41, 
and more than 50% of assessments show a poor to bad 
status. 

38

  Panagos,  P.,  Borrelli,  P.,  Poesen,  J.,  Ballabio,  C.,  Lugato,  E., 
Meusburger, K., Montanarella, L., Alewell, C., ‘The new assessment of 
soil  loss  by  water  erosion  in  Europe’,  Environmental  Science  and 
Policy, Vol. 54, 2015, pp. 438-447. 
39 European Environment Agency, State of Nature in the EU. 
40

  European  Environment  Agency,  Forest  information  system  for 

Europe. 
41

 COM SWD (2021) 652 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
                                                                 
 
                                                                 
Figure  12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  in  EU  Member  States, 
2013-201842 

Luxembourg  14 

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

Invasive alien species (IAS) 

in 

and 

land 

changes 

IAS  are  a  key  cause  of  biodiversity  loss  in  the  EU 
(alongside 
use, 
sea 
overexploitation, climate change and pollution). 
Besides  inflicting  major  damage  on  nature  and  the 
economy,  many  IAS  also  facilitate  the  outbreak  and 
spread of infectious diseases, posing a threat to humans 
and wildlife. 
The implementation of the EU IAS 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%. 

(EUTR)43 
The  European  Union  Timber  Regulation 
prohibits  the  placing  on  the  EU  market  of  illegally 
harvested  timber.  In  accordance  with  the  EUTR,  EU 
Member  States’  competent  authorities  must  conduct 
regular  checks  on  operators  and  traders  and  apply 
penalties  for  non-compliance.  With  the  amendment  of 
Article 20 of the EUTR, reporting every 2 years has been 
changed  to  annual  reporting,  and  covers  the  calendar 
year as of 2019. 

Between March 2017 and February 201944, Luxembourg 
carried  out  16  checks  on  domestic  timber  operators.  It 
also  carried  out  23  checks  on  operators  importing 
timber.  It 
is  estimated  that  Luxembourg  had  400 
operators  placing  domestic  and  484  operators  placing 
imported timber types on the internal market over the 
reporting period. 

A  proposal  for  a  regulation on  the  making  available  on 
the  EU  market  and  export  of  products  associated  with 
deforestation  and  forest  degradation  (Deforestation 
Regulation)  was  adopted  on  17 November 2021.  This 
proposal followed a request from the Council in 2019 to 
table a legislative proposal to address the problem, and 
a  European  Parliament  resolution  recommending  the 
Commission  to  come  forward  with  an  EU 
legal 
framework  to  halt  and  reverse  EU-driven  global 
deforestation.  The  new  Deforestation  Regulation  will 

42  European  Environment  Agency,  Conservation  status  and  trends  of 
habitat and species, January 2022. 
43 Regulation (EU) No 995/2010 of the European Parliament and of the 
Council of 20 October 2010. 
44 COM (2020) 629 final 

The  core  of  Regulation  (EU)  No  1143/2014  on  IAS  (the 
‘IAS  Regulation’45)  is  the  list  of  IAS  of  Union  concern. 
The  total  number  of  -IAS  of  Union  concern  is  currently 
66,  of  which  30  are  animal  species  and  36  are  plant 
species.  Of  all  species,  41  are  primarily  terrestrial 
species;  23  are  primarily  freshwater  species;  1  is  a 
brackish-water species; and 1 is a marine species.  

According  to  a  2021  report46  on  the  review  of  the 
application  of  the  IAS  Regulation,  the  IAS  Regulation  is 
already  starting  to  deliver  on  its  objectives  such  as 
setting  up  a  coherent  framework  for  addressing  IAS  at 
EU level and increasing awareness about the problem of 
IAS. At the same time, the above report identified some 
challenges  and  areas  for  improvement.  The  various 
obligations  of  the  IAS  Regulation  entered  into  force 
gradually between July 2016 and July 2019. Therefore, it 
is  too  early  to  draw  conclusions  on  several  aspects  of 
the IAS Regulation’s implementation.  

A 2021 report47 on the baseline distribution shows that 
of  the  66  species  on  the  Union  list,  14  have  been 
observed in the environment  in Luxembourg. Figure 13 
shows the spread of these species in the country 

45  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. 
46  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. 
47  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 – Luxembourg 

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

In  the  2019  EIR,  no  priority  action  was  proposed  for 
Luxembourg in the fields of agriculture, soil, forest  and 
IAS. 

2022 priority actions 

addressing 

  Complete the Natura 2000 site designation process, 
including 
Special  Areas  of 
the 
Conservation  (SACs),  and  defining  the  conservation 
objectives  and  measures  to  achieve  the  favourable 
conservation  status  of  protected  habitats  and 
species in the framework of site management plans 
or equivalent instruments. 

  Continue  the  integration  of  biodiversity  concerns 
into  other  policies  (in  particular  in  agriculture,  but 
also  in  fisheries,  urban  and  infrastructure  planning 
and 
promote 
communication  between  actors.  Where  relevant, 
fragmentation  and  take 
further  habitat 
avoid 
measures to restore connectivity. 

sustainable 

tourism) 

and 

  Urgently  adopt  binding  and  regulatory  measures  to 
address  root  causes,  for  example  to  stop  harmful 
effective 
agricultural 
enforcement  to  protect  and  restore  the  habitat  of 
the grey partridge and other farmland birds. 

practices 

ensure 

and 

  Achieve  the  2030  target  of  increasing  land  under 

organic farming to at least 25%. 

  Step 

up 

action 

the 
on 
recommendations  set  out  in  Luxembourg’s  CAP 
strategic plan, especially on improving rural areas. 

implementing 

Luxembourg  15 

  Reduce the excessive area of sealed and artificialised 
soil  and  remediate  degraded  soils.  To  this  end, 
consider  formally  committing  to  LDN  targets  under 
the UNCCD. 

  Step up the implementation of the IAS Regulation. 
  Ensure  regional  cooperation  with  neighbouring 
Member States to address predominant pressures. 

Ecosystem assessment and accounting  

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

At the end of 2013, the Environment Department of the 
Ministry of Sustainable Development and Infrastructure 
launched  the  development  of  a  methodological  guide 
for  the  implementation  of  ecosystem  assessment  in 
Luxembourg. Based on this guide, the minister in charge 
prioritised  13  ecosystem  services  to  be  mapped  by  the 
end of 2014. At the beginning of 2014, a  meeting  with 
relevant  stakeholders  was  arranged  to:  (i)  present  and 
discuss 
for 
the  various 
(ii)  ensure 
Luxembourg;  and 
departments  (agriculture,  environment  (nature,  forest, 
air, noise and climate) and tourism) and public research 
institutes  involved  would  provide  all  relevant  data  for 
the  ecosystem  assessment.  In  2015,  habitat-quality 
mapping 
a 
methodology developed for  restoring ecosystems using 
national  fine-scale  datasets)  and  ecosystem-services 
mapping were finalised48. 

the  ecosystem-assessment  approach 

assessment  with 

ecosystem 

that 

(i.e. 

Luxembourg 
in  several 
is  developing  or  engaged 
projects  related  to  ecosystem  services,  such  as  the 
Values  Project49  or  Nature4cities50.  Some  departments 
plan to integrate ecosystem  services  in the planning of 
their  management  action  more  systematically.  For 
example, 
the  Water  Management  Administration 
envisages  to  use  the  River  Ecosystem  Service  Index51. 
These  recent  developments  have  not  yet  been 
integrated  in  the  reporting  on  the  progress  made 
is  based  on  27 
reporting 
(Figure  14).  This 

48 Mapping and assessing ecosystems and their services in Luxembourg 
– Assessment results, December 2015. 
49 www.lifecycle-values.lu/ 
50 www.nature4cities.eu 
51 www.resi-project.info 

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Luxembourg  16 

implementation  questions  and  updated  every  six 
months. 

Figure 14: ESMERALDA MAES Barometer, January 2016 
to March 202152 

Progress  on  implementing  ecosystem  accounting  is 
assessed at a national scale based on 13 questions. 

2022 priority actions 

indicators 

development, 

  Continue  to  support  the  mapping  and  assessment 
of:  (i)  ecosystems  and  their  services;  and  (ii) 
ecosystem-accounting 
using 
appropriate 
integrate  ecosystem 
to 
extent,  condition  and  services  (including  some 
monetary  values)  in  national  accounts  and  the 
planning of management and restoration action. 
  Continue  to  support  the  development  of  national 
business  and  biodiversity  platforms, 
including 
systems  for  natural-capital  accounting,  to  monitor 
and value the impact of business on biodiversity. 

52 European Commission, Joint Research Centre, Publication Office, EU 
ecosystem assessment – Summary for policymakers, May 2021, p. 80. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
 
 
 
                                                                 
Luxembourg  17 

3. Zero pollution

commitments  for  most  air  pollutants  covered  by  the 
Directive for 2020-2029 and for 2030 onwards. However, 
it  does  not  expect  to  achieve  its  emission-reduction 
commitments  for  2020-2029  and  2030  onwards  for 
ammonia  (NH3).  The  latest  inventory  data  submitted  by 
Luxembourg  (which  the  Commission  has  not  reviewed 
yet) indicate that in 2020, Luxembourg complied with the 
emission-reduction commitments for NOx, non-methane 
volatile  organic  compounds  (NMVOC),  sulfur  dioxide 
(SO2)  and  PM2.5,  and  did  not  comply  with  the  emission-
reduction commitment for NH3. 

Luxembourg  has  submitted  its  national  air  pollution 
control programme (NAPCP) on 8 February 2021. 

Figure 15: Trends of emissions of main pollutants and 
GDP in Luxembourg, 2005-201961 

Clean air 

its 

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

The  EU  has  developed  a  comprehensive  suite  of  air-
quality  legislation,  which  sets  health-based  standards53 
and emissions-reduction commitments54 for a number of 
air pollutants. 

Air  quality  in  Luxembourg  is  generally  good,  with  some 
exceptions.  The  latest  available  annual  estimates  (for 
2019)  by  the  European  Environment  Agency55  point  to 
about  200  premature  deaths  (or  2  100  years  of  life  lost 
(YLL))  that  can  be  attributed  to  fine  particulate  matter 
concentrations56,  10  (100  YLL)  that  can  be  attributed  to 
ozone  concentrations57  and  20  (300  YLL)  that  can  be 
attributed to nitrogen dioxide concentrations5859. 

Over the last years, the emissions of key air pollutants in 
Luxembourg  have  decreased  significantly,  while  GDP 
growth  continued 
latest 
projections of air-pollutant emissions as submitted under 
reduction 
Article  10(2)  of 
‘NEC  Directive’)60, 
Commitments  Directive 
Luxembourg  expects  to  achieve  its  emission-reduction 

the  National  Emission 

(see  Figure  15). 

In  the 

((the 

53 European Commission, Air Quality Standards, 2016. 
54 European Commission, Reduction of National Emissions. 
55 European Environment Agency, Air Quality in Europe – 2021 Report. 
See the details in this report on the underpinning methodology, p. 106. 
56  Particulate  matter  (PM)  is  a  mixture  of  (solid  and  liquid)  aerosol 
particles  covering  a  wide  range  of  sizes  and  chemical  compositions. 
PM10 refers to particles with a diameter of 10 micrometres or less. PM2.5 
refers  to  particles  with  a  diameter  of  2.5  micrometres  or  less.  PM  is 
emitted from many human sources, including combustion. 
57 Low-level ozone is produced by photochemical action on pollution.  
58 Nitrogen oxides (NOx) are emitted during fuel combustion, e.g. from 
industrial  facilities  and  the  road-transport  sector.  NOx  are  a  group  of 
gases comprising nitrogen monoxide (NO) and nitrogen dioxide (NO2). 
59  These  figures  refer  to  the  impacts  of  individual  pollutants.  To  avoid 
double-counting, they cannot be added up to derive a sum. 
60 Directive 2016/2284/EU. 

61 European Environment Agency. 

Environmental Implementation Review 2022 – Luxembourg 

 
                                                                 
 
 
 
                                                                 
Figure 16: PM2.5 and NOx emissions by sector in 
Luxembourg, 201962 

In  2020,  no  exceedances  of  the  limit  values  set  by  the 
Ambient  Air Quality Directive  were registered. However, 
for several  air-quality zones,  the target  values  for ozone 
concentration have not been met63. 

The Commission is following up on persistent breaches of 
air-quality  requirements,  which  have  severe  negative 
effects  on  health  and  environment. 
launched 
infringement  procedures  (mainly  over  PM10  and  NO2 
exceedances)  covering  all  Member  States  concerned, 
including  Luxembourg  for  exceedances  of  NO2  limit 
values  in  several  air-quality  zones.  The  aim  is  that 
appropriate  measures  are  put  in  place  to  make  all  air-
quality zones compliant with the requirements. 

It 

Luxembourg  18 

In  July  2017,  the  Commission  sent  a  letter  of  formal 
notice  to  Luxembourg  for  failing  to  put  an  end  to  the 
repeated  exceedances  of  NO2  limit  values  in  the  city  of 
Luxembourg. The city is not amongst the worst offenders 
and  measures  have  been  taken  already  (for  example,  a 
tramway  has  replaced  buses,  public  transport  has  been 
made free, and an evaluation of the monitoring network 
has  led  to  new  locations  of  stations).  Nevertheless, 
Luxembourg  still  fails  to  ensure  full  compliance.  This  is 
mainly due to traffic volumes (also linked with diesel cars, 
older  buses  and  a  large  share  of  commuting).  A  2018 
monitoring  campaign  suggested  the  exceedance  of  NO2 
limit values in the two other air-quality zones (near busy 
streets). 

On  16  November  2021,  Luxembourg  participated  in  an 
EIR peer to peer event on ammonia-reducing technology 
and  measures.  On  9  February  2022,  Luxembourg 
participated  in  an  EIR  peer-to-peer  event  to  present  the 
EU action plan ’Towards Zero Pollution for Air, Water and 
Soil‘ and  to provide advice and guidance, particularly on 
implementation  and  compliance  aspects  of  the  action 
plan64. 

In  the  2019  EIR,  Luxembourg  received  four  priority 
actions in the field of clean air. On the first action, related 
to  the  reduction  of  main  emission  sources,  there  has 
been  limited  progress.  On  the  reduction  of  NMVOC 
emissions,  there  has  been  limited  progress.  On  the 
reduction  of  NOx  emissions  and  NO2  concentrations, 
there  has  been  limited  progress,  as  detailed  above.  On 
the  upgrade  and 
improvement  of  the  air-quality 
monitoring  network,  there  has  been  some  progress  as 
Luxembourg 
in  the  zones 
is  monitoring  air  quality 
covered by the infringement procedures. However,  work 
should continue. 

2022 priority actions 

 

In  the  context  of  the  NAPCP,  take  actions  towards 
reducing  emissions  from  the  main  emission  sources 
mentioned above. 

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

62 Idem. 
63 European Environment Agency, Eionet Central Data Repository. 

64 TAIEX-EIR PEER 2 PEER. 

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Industrial emissions 

Figure 17: Number of IED industrial installations per 
sector in Luxembourg, 201868 

Luxembourg  19 

The  main objectives of EU policy on industrial emissions 
are to: 
(i) protect air, water and soil; 
(ii) prevent and manage waste; 
(iii) improve energy and resource efficiency; 
(iv) clean up contaminated sites. 
To  achieve  this,  the  EU  takes  an  integrated  approach  to 
the  prevention  and  control  of  routine  and  accidental 
industrial emissions. The cornerstone of the policy is the 
Industrial Emissions Directive (IED)65. 
The  Commission  tabled  a  proposal  in  April  202266.  The 
revision seeks to improve the Directive’s contribution to 
the  zero-pollution  objective,  as  well  as  its  consistency 
with climate, energy and circular-economy policies. 

The  below  overview  of  industrial  activities  regulated  by 
the  IED  is  based  on  data  reported  to  the  EU  Registry 
(2018)67. 

In  Luxembourg,  around  40  industrial  installations  are 
required under the IED to have a permit. The distribution 
of installations is shown in Figure 17. 

In  2018,  Luxembourg’s  industrial  sector  with  the  most 
IED installations was intensive rearing of poultry and pigs 
(27%),  followed  by  the  production  and  processing  of 
metals  (24%),  the  waste-management  sector  (including 
landfills)  (15%),  the  mineral  industries  (7%)  and  the 
chemicals sector (7%). 

The  industrial  sectors  identified  as  placing  the  largest 
burden  on  the  environment  in  terms  of  emissions  to  air 
were: 

 

the  mineral  industries  (cement,  glass  and  others)  for 
sulfur oxides (SOx), NOx, lead (Pb) and cadmium (Cd); 
the metals sector for mercury (Hg) and Pb; 
intensive rearing of poultry and pigs for NH3; 

treatment  using  organic 

solvents 

for 

 
 
  surface 

NMVOCs; and 
the waste-management sector for PM2.5 and dioxins.  

 

The breakdown is shown in Figure 18. 

65  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). 
66  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). 
67  European  Environment  Agency,  EU  Registry,  European  Industrial 
Emissions Portal. 

68 Idem (data retrieved on 3 November 2021). 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
                                                                 
 
 
 
 
                                                                 
Figure 18: Emissions to air from IED sectors and rest of 
national total air emissions in Luxembourg, 201869 

Figure 19: Number of inspections at IED installations in 
Luxembourg, 201870 

Luxembourg  20 

In  Luxembourg,  the  ferrous-metals  processing  industry 
(particularly  the  processing  of  heavy  metals)  places  the 
largest burden on the environment in terms of industrial 
emissions to water (based on E-PRTR data). 

The  EU  approach  to  enforcement  under  the  IED  creates 
strong  rights  for  the  public  to  have  access  to  relevant 
information  and  to  participate  in  the  permitting  process 
for potentially polluting installations. This empowers the 
public and non-gouvernemental organisations (NGOs), to 
ensure  that  permits  are  appropriately  granted  and  that 
the conditions of these permit are complied with. As part 
of  environmental 
inspection,  competent  authorities 
undertake  site  visits  at  IED  installations  to  take  samples 
and to gather necessary information. According to Article 
23(4) of the IED,  site visits  must  be carried  out between 
once  a  year  and  once  every  3  years,  depending  on  the 
environmental  risks  posed  by  the  installations.  In  2018, 
Luxembourg  undertook  17  site  visits,  most  of  which  to 
installations for the production and processing of metals 
(29%),  installations  for  the  intensive  rearing  of  poultry 
and  pigs  (29%),  waste-management  sites  (including 
landfills)  (12%),  and  mineral-industry  site  (12%)  (see 
Figure 19). 

The  development  of  best  available  technique  (BAT) 
reference  documents  (BREFs)  and  BAT  conclusions 
ensures  good  collaboration  between  stakeholders  and 
enables better implementation of the IED71. Since the last 
EIR report, the Commission adopted BAT conclusions for 
Luxembourg for: (i) waste incineration; (ii) the food, drink 
and  milk  industries;  and  (iii)  surface  treatment  using 
organic solvents  including  the preservation of  wood and 
wood products with chemicals. 

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

In  2019,  Luxembourg  received  priority  actions  to  review 
permits  to  comply  with  newly  adopted  BAT  conclusions 
and  to  strengthen  checks  and  enforcement  to  ensure 
compliance  with  BAT  conclusions.  The  Commission 
followed  Luxembourg’s  progress  on  these  actions  using 
the  country’s  reporting  to  the  EU  Registry.  The 
Commission  is  currently  verifying  with  Luxembourg  the 
reported  information  on  the  permits  granted  for  each 
installation in the scope of the IED. 

On addressing air-pollutant emissions from iron and steel 
plants, the ferrous-metal industry is still one of the main 
polluting sectors. 

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

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

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
                                                                 
 
 
 
                                                                 
2022 priority action 

  Address  the  pollution  from  metal  production  and 

processing.  

Figure 20: Number of Seveso establishments in 
Luxembourg, 2011, 2014 and 201875 

Luxembourg  21 

Prevention of major industrial accidents – 
SEVESO 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major  accident  hazards  involving  dangerous 
substances, especially chemicals; 
(ii)  limit  the  consequences  of  such  accidents  for  human 
health and the environment; 
(iii)  continuously  improve  prevention,  preparedness  and 
response to major accidents. 
The  cornerstone  of  the  policy  is  Directive  2012/18/EU 
(the Seveso-III Directive)72. 

The below overview of industrial plants regulated by  the 
Seveso-III Directive (‘Seveso establishments’) is based on 
data  reported  to  the  eSPIRS  database  (2018)73  and 
Luxembourg’s  report  on  the  implementation  of  the 
Seveso-III Directive for 2015-201874. 

In  Luxembourg,  among  the  18  Seveso  establishments,  9 
are categorised as lower-tier establishments (LTEs) and 9 
as  upper-tier  establishments  (UTEs)  –  based  on  the 
quantity  of  hazardous  substances  likely  to  be  present. 
UTEs  are  subject  to  more  stringent  requirements.  The 
trend  of  the  number  of  Seveso  establishments 
is 
presented in Figure 20.  

Many  Seveso  establishments  are  required  to  draw  up 
external  emergency  plans 
(EEPs).  These  EEPs  are 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  actions  to  protect  the 
environment  and  the  population  should  a  major 
industrial  accident  occur  at 
to 
Luxembourg,  an  EEP  is  required  for  8  UTEs.  In  2018,  8 
UTEs  had  an  EEP  all  of  which  had  been  tested  over  the 
last 3 years. The summary is shown in Figure 21. 

them.  According 

Figure 21: Situation regarding EEPs in Luxembourg, 
201876 

The  information  to  the  public  referred  to  in  Annex  V  to 
Seveso-III Directive is permanently available for the 100% 
of  the  SEVESO  establishments 
in  Luxembourg.  This 
information is mainly about: (i) how the public concerned 
will  be  warned  in  the  event  of  a  major  accident;  (ii)  the 

72  Directive  2012/18/EU  on  the  control  of  major-accident  hazards 
involving dangerous substances (OJ L 197, 24.7.2012, p. 1). 
73 European Commission, Seveso Plants Information Retrieval System. 
74 As required under Article 21(2) of the Seveso-III Directive. 

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

for 

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appropriate  behaviour  in  the  event  of  a  major  accident; 
and (iii) the date of the last site visit. 

The  share  of  UTEs  for  which  information  on  safety 
measures  and  required  behaviour  was  actively  made 
available to the public over the last years is presented in 
Figure  22.  This  is  an  important  requirement  of  the 
Seveso-III  Directive  because  if  the  public  knows  this 
information,  this  may  reduce  the  consequences  of  a 
major industrial accident. 

Figure 22: Share of UTEs for which information on safety 
measures and required behaviour was actively made 
available to the public in Luxembourg, 2011, 2014 and 
201877 

Luxembourg  22 

and  60  cases  of  ischaemic  heart  disease  in  Luxembourg 
annually81.  Moreover,  some  20 000  people  suffer  from 
disturbed sleep. Overall, 305 000 people were exposed to 
environmental  noise  in  Luxembourg  in  2017,  the  latest 
year  with  complete  data.  Based  on  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 
will  further  ensure  that  the  nutrient  cycle  (nitrogen  and 
phosphorus)  is  managed  in  a  more  sustainable  and 
resource-efficient way. 

Water Framework Directive 

Noise 

The  Environmental  Noise  Directive78  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 
transport  noise 
people 
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  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress79. 

Based  on  a  limited  set  of  data80,  environmental  noise  is 
estimated to cause at least around 20 premature deaths 

77 Idem. 
78 Directive 2002/49/EC 
79 WHO, Environmental Noise Guidelines for the European Region, 2018. 
80  For  further  information:  European  Environment  Agency,  Noise  Fact 
Sheets 2021. 

is 

(WFD)82 

The  Water  Framework  Directive 
the 
cornerstone of EU water policy in the 21st century83. The 
legal  acts84  set  the 
WFD  and  other  water-related 
framework 
integrated  water 
sustainable  and 
management, which aims at a high level of protection of 
water resources, prevention of further deterioration and 
restoration to good status. 

for 

By  March  2022,  Member  States  had  to  report  the  third 
generation  of  river  basin  management  plans  (RBMPs) 
under the WFD. The Commission will assess the reported 
status  and  progress,  checking  how  the  findings  of  the 

81  These  figures are  an  estimate  by  the  European  Environment  Agency 
based  on:  (i)  the  data  reported  by  the  Member  States  on  noise 
exposure  covered  by  Directive  2002/49/EC;  (ii)  ETC/ATNI,  ‘Noise 
indicators under the Environmental Noise Directive 2021: Methodology 
for  estimating  missing  data,  ETC/ATNI  Report  No  2021/06,  European 
Topic Centre on Air Pollution, Transport, Noise and Industrial Pollution, 
2021;  and  (iii)  the  methodology  for  health 
impact  calculations, 
ETC/ACM, ‘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, 2018. 
82 Directive 2000/60/EC. 
83 https://ec.europa.eu/environment/water/index_en.htm 
84  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 ((EU) 2020/741). 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
 
                                                                 
                                                                 
second  RBMPs85  have  been  addressed.  Luxembourg  has 
not yet reported the third RBMP86.  

In  December  2021,  the  Commission  published  the  6th 
Implementation  Report,  which  assesses  implementation 
of  the  WFD  and  the  Floods  Directive87.  This  report 
includes an interim assessment of: (i) the implementation 
of the  programmes  of  measures; and (ii) the  monitoring 
of  new  priority  substances.  The  assessment  report  for 
Luxembourg88  showed  that  the  information  and  data 
provided  by  Luxembourg  are  incomplete  and  have  only 
allowed  the  Commission  to  assess  a  limited  number  of 
indicators  and  measures,  making  any  interpretation  of 
the  pace  of  progress  impossible.  Based  on  information 
reported  electronically,  no  new  regulation  or  legislation 
should  be 
implemented  under  this  programme  of 
measures. It has been reported that no further rules are 
needed for the Rhine and Meuse river-basin districts, and 
the  programme  of  measures  has  reached  the  status 
‘some measures are completed’. 

Based  on  data  reported  in  the  2nd  RBMPs  and  data 
published  in  202089,  only  2.7%  of  all  surface  water 
bodies90 in Luxembourg reached a good ecological status, 
and  all  surface  water  bodies  (100%)  failed  to  achieve  a 
good  chemical  status.  For  groundwater  bodies,  50% 
failed to achieve a good chemical status, and 100% had a 
good quantitative status. 

Figure  23  illustrates  the  proportion  of  surface  water 
bodies in Luxembourg and other European countries that 
failed to achieve a good ecological status so far. 

Luxembourg  23 

Figure 23: Proportion of surface water bodies (rivers, 
lakes, and transitional and coastal waters) with a less 
than good ecological status per river basin district91 

Figure  24  presents  the  percentage  of  surface  water 
bodies  in  Luxembourg  and  other  European  countries 
to  achieve  a  good  chemical  status.  For 
failing 
Luxembourg,  the  percentage  is  100%,  including  water 
bodies  failing  due  to  substances  behaving  as  ubiquitous 
persistent, bio-accumulative and toxic substances (PBTs). 
Without  PBTs,  the  percentage  of  surface  water  bodies 
failing  to  achieve  a  good  chemical  status  remains  the 
same (100%). 

85  Detailed  information  can  be  found  in  the  5th  Report  from  the 
Commission on the implementation of the Water Framework Directive 
and the Floods Directive, and in the 2019 EIR. 
86  Based on  information provided  by  the  Luxembourgish  authorities  in 
April 2022. 
87  See  the  6th  implementation  report  of  the  WFD  and  the  Floods 
Directive. 
88  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: Luxembourg, 2022. 
89 https://water.europa.eu/freshwater 
90  Rivers,  lakes,  transitional  waters,  coastal  waters,  and  territorial 
waters. 

91 European Environment Agency, 2021. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
                                                                 
 
 
 
                                                                 
Figure 24: Percentage of surface water bodies not 
achieving a good chemical status92 

Figure 25: Water abstraction per sector in Luxembourg95 

Luxembourg  24 

On the IED, it should be stressed that in the last decade, 
Luxembourg showed a significant decrease in releases to 
water of heavy metals (44.4%) like Cd, Hg, nickel (Ni) and 
Pb,  and  of  total  organic  carbon  (70.7%)93.  Total  water 
abstracted  from  surface  and  ground  water  sources  in 
Luxembourg  is  166.35 hm3  a  year  (corresponding  to  the 
2019  baseline)  (European  Environment  Agency,  2022). 
The distribution of water abstraction  by sector is: 0.28% 
for  agriculture,  25.02%  for  public  water  supply,  71.89% 
for  electricity  cooling94,  2.45%  for  manufacturing,  0.25% 
for  manufacturing  cooling,  and  0.11%  for  mining  and 
quarrying.  This  is  illustrated  in  Figure  25.  Luxembourg 
uses  a  register  to  check  groundwater  abstractions.  A 
second register is kept for all authorised points in surface 
waters. 

Index  plus 
In  Luxembourg,  the  Water-Exploitation 
(WEI+)96 is 2.92%. This is below the 20% threshold, which 
is  generally  considered  as  an 
indication  of  water 
scarcity97. 

Figure  26  presents  the  WEI+  index  in  Luxembourg  and 
the  EU-27  average.  Luxembourg  is  ranked 15th  (from 
high to low score) in the EU-27. 

Figure 26: WEI+ in Luxembourg and the EU, 201798 

Luxembourg’s  RRP  directs  EUR  6  million  to  conclude  a 
‘Naturpakt’  with  municipalities  to  provide  financial 
support  for  measures  to  protect  nature  and  prevent 
biodiversity  loss,  including  groundwater  protection  and 

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

92 European Environment Agency, December 2019. 
93 European Environment Agency, 2021. 
94  The  percentage  for  electricity  cooling  was  calculated  by  using  data-
gap  filling  (which  corresponds  to  the  119.59  hm3  reported  in  2017).  If 
electricity  cooling  is  disregarded,  public  water  supply  takes  the  lion’s 
share as regards water abstraction in Luxembourg. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
                                                                 
 
 
 
 
 
                                                                 
Luxembourg  25 

restoration  of  watercourses  to  their  natural  condition99. 
Moreover, to make information on drinking-water quality 
more  accessible, 
the  Luxembourgish  government, 
together with the drinking-water providers, has launched 
a  new  website100  with  information  about  tap  water  and 
safeguard 
for  drinking-water  catchments.  Further 
information  on  general  water  quality  is  also  available 
online101. 

Bathing Water Directive 

In  2020,  out  of  the  17  Luxembourgish  bathing  waters, 
82.4% were of excellent quality103. 

Figure 27: Bathing-water quality in Europe in the 2020 
season104 

Floods Directive 

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

in  December  2021, 

The  Commission’s  assessment  report102  showed  that 
Luxembourg’s preliminary flood-risk assessment includes 
clear basic information. However, there is little detail on 
methods  and  very  little  background  information.  The 
assessment 
further 
improvements, 
long-term 
developments,  the  effectiveness  of  current  artificial 
flood-defence  infrastructure,  and  the  impact  of  climate 
change. 

identified 
such 

factoring 

some 

areas 

for 

as 

in 

The  Commission  will  assess  progress  since  the  adoption 
of  the  first  flood-risk  management  plans  and  publish  a 
new report, like it did in 2019. 

Drinking Water Directive 

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

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

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

99 
coronavirus/recovery-and-resilience-facility/luxembourgs-recovery-
and-resilience-plan_en 
100 https://drenkwaasser.lu 
101 https://geoportail.lu; https://waasser.lu 
102  European  Commission,  Directorate-General 
for  Environment, 
Assessment  of  Second  Cycle  Preliminary  Flood  Risk  Assessments  and 
Identification  of  Areas  of  Potential  Significant  Flood  Risk  under  the 
Floods Directive – Member State : Luxembourg, 2022. 

Figure 28: Bathing-water quality, Luxembourg and EU 
average, 2017-2020105 

103 European Environment Agency, State of bathing water, 2021, p. 17. 
104 European Environment Agency, Bathing Water Quality in 2020, 2022. 
105  European  Environment  Agency,  European  Bathing  Water  Quality  in 
2017, 2018, 2019, 2020. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
                                                                 
 
 
 
 
                                                                 
Luxembourg  26 

requirements 

Figure 29: Proportion of urban waste water that  meets 
all  UWWTD 
(collection,  biological 
treatment,  biological  treatment  with  nitrogen  and/or 
phosphorus  removal)  in  compliant  urban  areas  of  the 
UWWTD (‘compliance rate’), 2018108 

Nitrates Directive 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive106,  covering  2016-2019107,  warns 
that  nitrates  are  still  causing  harmful  pollution  to  water 
in the EU. Excessive nitrates in water are harmful to both 
human health and ecosystems, causing oxygen depletion 
and  eutrophication.  Where  national  authorities  and 
farmers  have  cleaned  up  waters,  it  has  had  a  positive 
impact on drinking-water supply and biodiversity, and on 
sectors  that  depend  on  them,  such  as  fisheries  and 
tourism.  Nevertheless,  excessive  fertilisation  remains  a 
problem in many parts of the EU. 

According to the lastest report on the implementation of 
the Nitrates Directive, Luxembourg has a high number of 
groundwater-monitoring 
nitrate 
concentrations  above  50  mg/l,  and  a  high  number  of 
monitoring stations have an increasing trend. A very high 
number of surface waters are found to be eutrophic. 

stations 

with 

in  Luxembourg  is  above  the  EU 
Livestock  pressure 
average.  For  2016-2019,  Luxembourg  assessed  that  the 
annual  nitrogen  discharge  was  3 893  tonnes,  76%  of 
which  of  agricultural  origin.  Luxembourg  is  among  the 
Member States facing the greatest challenges in tackling 
nutrient pollution from agriculture. 

Luxembourg updated its action programme in 2018. 

Urban Waste Water Treatment Directive 

Regarding  the  Urban  Waste  Water  Treatment  Directive 
(UWWTD),  Luxembourg  has  a  compliance  rate  of  100%, 
well above the EU average in 2018. 

In  the  2019  EIR,  Luxembourg  received  three  priority 
actions.  The  first  action,  on  the  compliance  of  new 
projects with the WFD, has been fully implemented. The 
levels  of  collection  and 
action  to  ensure  correct 
treatment  of  urban  waste  water  has  been 
fully 
implemented  as  well.  There  is  no  information  available 
on  the  action  on  clarifying  the  method  used  by 
Luxembourg for the prioritisation of measures, including 
the  assessment  of  costs  and  benefits  in  relation  to  the 
flood-risk management plan. 

2022 priority actions 

  Assess new physical modifications of water bodies in 
In  these 
consider  alternative  options  and 

line  with  Article  4(7)  of  the  WFD. 
assessments, 
appropriate mitigation measures. 

  Facilitate 

implementation  of  measures  to  help 
achieve  the  WFD  objectives  and  step  up  efforts  to 
counteract pollution in water bodies. 

  Strengthen  Luxembourg’s  action  programme  under 
the  Nitrates  Directive  to  further  reduce  nitrate 
pollution  and  better  address  polluted  hotspots  of 
groundwater  and  eutrophication  of  surface  water 
where agriculture pressure is significant. 

  Better  coordinate  the  implementation  of  water  and 

nature policies. 

106 
nitrates/index_en.html 
107 SWD(2021) 1001 final. 

https://ec.europa.eu/environment/water/water-

108 European Commission, WISE Freshwater, 2021. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
 
 
 
 
                                                                 
Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
In 
effects  on  human  health  and  the  environment. 
October  2020,  the  Commission published  its  chemicals 
strategy  for  sustainability  - 
'Towards  a  Toxic-Free 
Environment'109,  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. 

legislation110  provides  baseline 
The  EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating within the internal market. 

of 

and 

the  Member 

In  December  2020, 

Labelling  and  Packaging 

‘REACH  Regulation’)  and 

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  Regulation  on 
(the 
‘CLP 
(the 
Classification, 
the  Commission 
Regulation’). 
the 
assessed 
reports  on 
implementation 
these 
Regulations111,  in  line  with  Article  117(1)  of  the  REACH 
Regulation  and  Article  46(2)  of  the  CLP  Regulation. 
According 
latest  available  data,  national 
enforcement structures have not changed much in recent 
years. However, it is apparent from this report that there 
are  still  many  disparities  in  the  implementation  of  the 
REACH  and  CLP  Regulations,  and  notably  in  the  area  of 
law enforcement. Recorded compliance levels in Member 
States,  but  with  a  slight  worsening  trend,  which  is  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.  

the 

to 

Luxembourg  27 

In  Luxembourg,  responsibility  for  checking  compliance 
with  the  REACH  and  CLP  Regulations  rests  with  the 
following authorities113:  

 
 
 
 
 

 

the Customs and Excise Administration; 
the Labour and mining inspection; 
the Health Directorate; 
the Water Management Administration; 
for  Standardisation, 
the 
Accreditation,  Safety  and  Quality  of  Products  and 
Services; and 
the Environmental Administration. 

Luxembourg 

Institute 

implemented 
Luxembourg  has  devised  and 
enforcement strategies for both REACH and CLP114. Their 
main aspects are: 

fully 

  risk-based  prioritisation:  focus  on  the  areas  where 

instances of non-compliance occur; and 

  annual publication of the results. 

In Luxembourg, two full-time equivalents are allocated to 
REACH  and  CLP  enforcement115. In  the  reporting  period, 
they  carried  out  37  REACH  checks.  The  number  of 
instances  of  non-compliance  out  of  the  total  number  of 
REACH checks is almost the average116. 

respectively. 

In  2019,  Luxembourgish  helpdesks  received  58  and  45 
enquiries  on  REACH  and  CLP, 
In 
Luxembourg, the main topics of enquiries on REACH were 
registration,  chemical-safety  reports  and  safety  data 
sheets.  On  CLP,  the  main  topics  of  enquiries  were 
labelling  and  classification.  To 
the  public’s 
awareness,  the  Luxembourgish  competent  authority 
mainly  used  articles,  leaflets  and  newsletters,  social 
media posts, and glossaries on specific substances. 

raise 

The  2019  EIR  did  not  provide  priority  actions  for 
Luxembourg on chemicals. 

In August 2021, the Commission published a  measurable 
assessment  of  the  enforcement112  of  the  two  main  EU 
Regulations on chemicals (the REACH Regulation and the 
CLP  Regulation)  using  a  set  of  indicators  on  different 
aspects of enforcement. 

109 COM(2020) 667 final 
110  Principally  for  chemicals:  REACH  (OJ  L  396,  30.12.2006,  p.  1);  for 
Classification,  Labelling  and  Packaging:  the  CLP  Regulation  (OJ  L  252, 
31.12.2006,  p.  1);  together  with  legislation  on  biocidal  products  and 
plant protection products. 
111  European  Commission, Technical  assistance  to  review  the  existing 
Member States reporting questionnaire under articles 117(1) of  REACH 
and 46(2) of CLP – Final report. 
112  European  Commission,  REACH  and  CLP  enforcement  –  EU  level 
enforcement indicators. 

113  European  Commission, Technical  assistance  to  review  the  existing 
Member States reporting questionnaire under articles 117(1) of  REACH 
and 46(2) of CLP – Final report, p. 70. 
114  European  Commission, Technical  assistance  to  review  the  existing 
Member States reporting questionnaire under articles 117(1) of  REACH 
and 46(2) of CLP – Final report, p. 76. 
115  European  Commission, Technical  assistance  to  review  the  existing 
Member States reporting questionnaire under articles 117(1) of  REACH 
and 46(2) of CLP – Final report, p. 75. 
116  European  Commission, Technical  assistance  to  review  the  existing 
Member States reporting questionnaire under articles 117(1) of  REACH 
and 46(2) of CLP – Final report, pp. 87-88. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
                                                                 
 
                                                                 
Figure 30: Percentage of instances of non-compliance in 
total  REACH  and  CLP  checks  per  Member  State  and 
compared to the EU average, 2019117 

Luxembourg  28 

2022 priority action 

  Upgrade 

the 

in 
administrative 
implementation and enforcement towards a policy of 
zero tolerance to instances of non-compliance. 

capacities 

117  European  Commission,  Technical  assistance  to  review  the  existing 
Member States reporting questionnaire under articles 117(1) of  REACH 
and 46(2) of CLP – Final report, pp.87-88, 2022. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
 
                                                                 
Luxembourg  29 

4. Climate action

consistent  with  the  EU’s  Long-term  Strategy  2050121. 
its  Climate  Law,  Luxembourg  aims  to 
According  to 
achieve climate neutrality by 2050. In line with its NECP, 
Luxembourg  also  has  the  objective  to  reduce 
its 
greenhouse-gas emissions by 55% by 2030 (compared to 
the  2005  level)  for  sectors  not  covered  by  the  EU’s 
emissions trading system (ETS)122. This is more ambitious 
than  the  country’s  current  EU  2030  reduction  target  of 
40%. 

In its RRP, Luxembourg allocates nearly 61% of resources 
to climate objectives. It also outlines crucial reforms and 
investment to further the green transition. 

Luxembourg  adopted  a  national  adaptation  strategy  in 
2012 and has updated it frequently. The National Climate 
Law  is  the  legal  basis  of  the  strategy.  The  Climate  Law 
requires  the  government  to  draw  up  an  adaptation 
strategy every 10 years. 

The  country’s  greenhouse  gas  emissions  decreased  by 
18%  between  1990  and  2020.  Although  the  emission 
intensity  of  Luxembourg’s  economy  is  under  the  EU 
average,  emissions  per  person  are  more  than  twice  the 
EU average. 

Figure 31: Total greenhouse-gas emissions (incl. 
international aviation) in Luxembourg, 1990-2020 

to 

(NDC) 

law  also 

In  line  with  the  Paris  Agreement  and  as  part  of  the 
European Green Deal, the European Climate Law sets the 
EU  target  of  reaching  climate  neutrality  by  2050  and 
reducing  greenhouse  gas  (GHG)  emissions  by  55%  by 
2030  compared  to  1990.  The 
limits  the 
contribution  that  carbon  removals  can  make  towards 
emission  reductions 
in  2030  to  ensure  a  sufficient 
mitigation effort.  
The  EU  and  its  Member  States  submitted  updated 
the 
Nationally  Determined  Contribution 
UNFCCC in December 2020.  
The  EU  is  working  across  all  sectors  and  policies  to  cut 
GHG  emissions  and  make  the  transition  to  a  climate-
neutral  and  sustainable  economy,  as  well  as  addressing 
the unavoidable consequences of climate change.  
EU  climate  legislation  incentivises  emissions  reductions 
from power generation, industry, transport, the maritime 
sector and fluorinated gases (F-gases) used in products.  
For  road  transport,  EU  legislation  requires  the  GHG 
intensity  of  vehicle  fuels  to  be  cut  by  6%  by  2020 
compared  to  2010118  and  sets  binding  GHG  emission 
standards for different vehicle categories119.  
Under the F-gas Regulation, the EU’s F-gas emissions will 
be cut by two thirds by 2030 compared with 2014 levels. 
From  2021,  emissions  and  removals  of  GHGs  from 
LULUCF have been included in the EU emission-reduction 
efforts.  
The  EU  adaptation  policy  is  an  integral  part  of  the 
European  Green  Deal.  From  2021,  Member  States  are 
their  national  adaptation 
required 
policies120,  as  the  EU  Climate  Law  recognises  adaptation 
as a key component of the long-term global response to 
climate change. Member States will be required to adopt 
national  strategies,  and  the  EU  will  regularly  assess 
progress  as  part  of  its  overall  governance  on  climate 
action. The updated EU adaptation strategy, published in 
February  2021,  sets  out  how  the  EU  can  adapt  to  the 
unavoidable  impacts  of  climate  change  and  become 
climate resilient by 2050. 

report  on 

to 

Key national climate policies and strategies 

Luxembourg  has  an 
(NECP) 
climate  plan 

integrated  national  energy  and 
is 
for  2021-2030.  The  work 

118  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. 
119 Directive 98/70/EC. 
120 Article 29 of Regulation (EU) 2018/1999. 

121 2050 long-term strategy (europa.eu) 
122  Sectors  currently  outside  of  the  ETS  include  buildings,  road  and 
domestic  maritime  transport,  agriculture,  waste  and  small  industries, 
and F-gases. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
                                                                 
 
 
                                                                 
Effort sharing target  

For  emissions  not  covered  by  the  ETS,  Member  States 
have  binding  national  targets  under  the  Effort  Sharing 
legislation123  124.  The  country’s  target  under  the  EU 
legislation is to reduce emissions not covered by the ETS 
(such  as  buildings,  road  transport,  agriculture,  small 
industry  and  waste)  by  20%  by  2020  and  40%  by  2030 
compared to 2005. Luxembourg exceeded its 2020 effort 
sharing  emissions  reduction  target,  but  emissions  are 
expected to increase again if no additional measures are 
implemented. 

In  its  NECP,  Luxembourg  intends  to  achieve  a  greater 
reduction  than  its  current  non-ETS  target  of  -40%  by 
2030. 

Figure 32: Emissions and targets under the Effort 
Sharing Decision/ Effort Sharing Regulation in 
Luxembourg, 2020 and 2030 as a percentage change 
from 2005 

Luxembourg  30 

Figure 33: Emissions, annual emission allocations (AEAs) 
and accumulated surplus/deficit of AEAs under the 
Effort Sharing Decision in Luxembourg, 2013-2020 

Key sectoral developments 

In  road  transport,  the  GHG  intensity  of  vehicle  fuels  in 
Luxembourg decreased  by 3.4% from 2010 to 2019. The 
country needs to act swiftly to meet its reduction target. 
There are several types of action that Member States can 
take  in  this  regard,  for  example:  (i)  further  improving 
public transport, expanding the use of electricity in road 
transport;  (ii)  supporting  the  use  of  biofuels,  and 
advanced  biofuels  in  particular;  (iii)  incentivising  the 
development and deployment of renewable fuels of non-
biological  origin;  and  (iv)  reducing  upstream  emissions 
before refining processes. 

Road-transport  emissions,  which  represented  48%  of 
total  greenhouse-gas  emissions  in  Luxembourg  in  2019, 
have  decreased  by  15%  compared  to  2005.  Transport  is 
the  biggest  emitting  sector,  notably  driven  by  a  high 
demand 
from 
transiting  road  transport.  There  is  a  strong  reliance  on 
increased  traffic 
individual  transport  that  has  also 
congestion. 

transportation 

including 

fuels, 

for 

123 Regulation (EU) 2018/842 
124 Effort sharing 2021-2030: targets and flexibilities (europa.eu) 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
 
Figure 34: Greenhouse-gas emissions by sector in 
Luxembourg125 (historical emissions for 1990-2020, 
projections for 2021-2030126) 

Figure 35: Reported and accounted emissions and 
removals by the LULUCF sector in Luxembourg127 

Luxembourg  31 

Luxembourg’s  NECP  provides  many  measures  to  further 
reduce  emissions  of  buildings.  Luxembourg  aims  to 
renovate  all  existing  houses 
to  net-zero-emission 
buildings by 2050.  

Emissions in agriculture have increased since 2005. 

In  the  LULUCF  sector,  Luxembourg  projects  a  small 
increase  in  net  removals  by  2030.  Reporting  under  the 
Kyoto  Protocol  for  the  LULUCF  sector  in  Luxembourg 
shows average net removals of -0.4 Mt CO2-eq for 2013-
2019.  Luxembourg  contributes  0.1%  to  the  EU-27’s 
annual average sink of -344.9 Mt CO2-eq. Accounting for 
the  same  period  depicts  average  net  credits  of  -0.2  Mt 
CO2-eq,  which  corresponds  to  0.2%  of  the  EU-27 
accounted  sink  of  -115.0  Mt  CO2-eq.  Reported  net 
removals  and  accounted  net  credits  show  a  declining 
trend with moderate fluctuations; for 2018, the accounts 
show very small net debits. Luxembourg is one of 14 EU 
Member States that show net debits for at least one year 
in this preliminary accounting procedure. 

in 

the 

figure  correspond 

125  The  sectors 
following 
Intergovernmental  Panel  on  Climate  Change  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. 
126 European Environment Agency, Total GHG trends and projections. 

the 

to 

Use of revenues from the auctioning of EU ETS 
allowances 

from 

revenues 

Total 
the  auctioning  of  emission 
allowances  under  the  EU  ETS  in  2012-2021  were  EUR 
90.1  million. 
revenues  are  not 
earmarked;  example  projects  have  been  reported  up  to 
100% of revenues each year. 

In  Luxembourg, 

2022 priority actions 

  Tackle  growing  traffic  congestion,  that  is  a  major 
in  Luxembourg  with  economic,  social, 

challenge 
climate and environmental consequences 

Further  invest  in  public  transport  networks  and 
infrastructures  

  Take  national  measures  to  support  road-transport 
electrification,  incentivise  the  purchase  of  electric 
the  deployment  of 
vehicles 
recharging/refuelling 
infrastructure. 
Reducing sales of fuel for traniting road transport and 

(hydrogen) 

accelerate 

and 

127  The  differences  between  reported  and  accounted  emissions  by  the 
LULUCF  sector  under  the  Kyoto  Protocol  are  described  in  LULUCF  – 
the  Kyoto  protocol: 
accounted  and  reported  quantities  under 
explanatory note for country fact sheets. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
 
 
                                                                 
Luxembourg  32 

shifting  towards  electrification  of  the  transport 
system  could  have  a  significant  budgetary  impact  on 

Luxembourg. 

Part II: Enabling framework: implementation tools 

5. Financing

Environmental investment needs in the EU 

Financing  environmental  measures  is  essential  for  their 
success.  Although  most  financing  comes  from  national 
sources, various EU funds contribute significantly, helping 
to close the financing gaps. 
Post-2020,  environmental  implementation  will  also  be 
supported by the EU’s  COVID-19 Recovery Fund (via the 
RRF) and the ‘do no significant harm’ principle which runs 
across the EU budget. The renewed commitments made 
at  COP26  (Glasgow,  October-November  2021)  and  the 
Biodiversity  Convention  (April-May  2022)128  will  also  be 
reflected in the EU budget. 

Overall environmental investment gaps (EU-27) 

The EU’s investment needs for the green transition cover 
a  range  of  interlinked  areas.  The  additional  investment 
needs  over  the  baselines  (i.e.  the  gap  between  what  is 
needed  and  what  is  forecast  to  be  invested  if  no 
additional  action 
is  taken)  for  climate,  energy  and 
transport  were  estimated  at  EUR  390  billion  a  year  (EU-
27)129 with a further EUR 130 billion a year to deliver the 
EU's  core  environmental  objectives130.  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  year131.  Those 
the 
implementation  objectives  to  2020  and  to  2030  (except 
for  climate-change  adaptation,  the  costs  of  which  are 
expected to last over a longer time horizon). 

investment  needs 

reflect 

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 
estimated  to  be  between  EUR  13  billion  and  EUR  28 
billion  a  year,  depending  on  the  level  of  circularity 
implemented.  The  annual  biodiversity  financing  gap  is 
estimated at around EUR 20 billion. 

Table 1: Estimated breakdown of the EU-27’s 
environmental investment gaps, by environmental 
objective, 2021-2030133 

Estimated investment gap (EU-27, 
per year)  

Environmental 
objective 

Pollution  prevention 
and control 

Water  management 
and industries 

Circular economy and 
waste 

EUR million 

42.8 

26.6 

13.0 

Biodiversity 
ecosystems134 

and 

21.5 

Research, 
development, 
innovation and other 

6.2 

% 

39% 

24% 

12% 

20% 

6% 

A  preliminary  update  of  the  EU’s  core  environmental 
investment  gap  is  provided  in  Table  1132.  Almost  40%  of 

Total 

110.1 

100% 

https://www.cbd.int/convention/; 

128 
https://www.iucn.org/theme/global-policy/our-work/convention-
biological-diversity-cbd/post-2020-global-biodiversity-framework 
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 final). 
132  With  decreases  due  to  Brexit  and  some  reconciliation  among  the 
objectives.  Source:  European  Commission,  Directorate-General  for 
Environment,  Study  supporting  EU  green  investment  needs  analysis, 
ongoing  (2021-2023),  and  European  Commission,  Directorate-General 

and 

European 

European 

Commission,  Directorate-General 

for Environment, internal analysis Environmental investment needs and 
financing in the EU’s green transition, July 2020. 
133 
Environment, 
Commission,  Directorate-General 
Study supporting  EU  green  investment  needs  analysis,  ongoing  (2021-
2023), 
for 
Environment,  internal analysis  Environmental Investment  needs  and 
financing in the EU’s green transition, July 2020.  
134  To  meet  the  needs  of  the  biodiversity  strategy  for  2030  (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 – Luxembourg 

 
 
                                                                 
 
 
 
                                                                                                        
Environmental investment needs in Luxembourg 

is  a  clear  shift  of 

investment  priorities 

in 
There 
Luxembourg  towards  support  for  climate  policies,  as 
shown  in  the  RRP135.  The  country  focuses  on  reducing 
greenhouse-gas  emissions  in  the  transport  and  building 
sectors.  Under  the  RRP,  EUR  57  million  will  be  spent  on 
climate  investment  priorities  to  address  the  needs  or 
investment  gaps  in  a  wide  set  of  economic  sectors  such 
as  energy  renovation  of  housing,  sustainable  transport, 
and ‘Naturpakt’ (providing financial support for measures 
to protect nature and prevent biodiversity loss). 

Below are the environmental investment needs that have 
been identified for each of the below sectors. 

Pollution prevention and control 

The  EU’s  first  Clean  Air  Outlook136  under  the  clean  air 
programme estimated that the total air-pollution-control 
costs  for  Luxembourg  to  reach  the  NEC  Directive’s 
emission-reduction  requirements137  by  2030  amount  to 
EUR  259  million  per  year.  This  includes  EUR  118  million 
for  capital  investment  (assuming  that  the  2030  climate 
and energy targets are achieved).  

The  EU’s  second  Clean  Air  Outlook138  suggests  that  the 
EU  would  largely  achieve  the  reductions  of  air-pollutant 
emissions  that  correspond  to  the  obligations  under  the 
NEC  Directive  for  2030  if:  (i)  all  relevant  legislation 
adopted  up  to  2018  delivered  its  full  benefits  (including 
all  air-pollution  legislation  and  the  2030  climate  and 
energy targets set in 2018) ; and (ii) Member States also 
implemented  the  measures  announced  in  their  national 
air-pollution-control  programmes.  The  only  exception  is 
including 
for  ammonia 
Luxembourg.  

for  15  Member  States, 

Water management 

According to the Organisation for Economic Co-operation 
and  Development  (OECD)  study  ‘Financing  a  Water 

135 Luxembourg’s recovery and resilience plan, 2021. 
136 International Institute for Applied Systems Analysis (IIASA), Progress 
towards  the  achievement  of  the  EU's  air  quality  and  emissions 
objectives, 2018. 
137  Covering  the  reductions  of  and  the  emission  ceilings  for  5 
atmospheric  pollutants,  SOx,  NOx,  PM2.5,  NH3  and  VOC  by  2030, 
compared  to  2005.  Source:  Progress  towards  the  achievement  of  the 
EU’s  air  quality  and  emissions  objectives,  IIASA  2018.  (page  29). 
Requirements are based on Directive (EU) 2016/2284. 
138 COM(2021) 3 final. Support to the development of the Second Clean 
Air Outlook, 2020 and Annex.  

Luxembourg  33 

Secure  Future’  (2022)139,  water  coverage  and  treatment 
compliance remain high in Luxembourg. However, future 
flood  events  present  a  serious  risk.  In  Luxembourg,  a 
distinctive feature is the large share of the workforce that 
lives in neighbouring countries and commutes daily. This 
non-resident  population  uses  significant  volumes  of 
water  and  generates  waste  water,  affecting  per-person 
ratios  in  Luxembourg.  The  value  of  assets  at  risk  is 
projected  to  grow  substantially.  EU  funding  provided  a 
significant  share  of  public  funding  over  the  past 
decade140.  It  is  estimated  that  Luxembourg  will  need  to 
invest  a  cumulative  additional  EUR  218  million  over 
baselines  in  drinking  water  and  sanitation  by  2030.  This 
corresponds to an investment need (capital expenditure) 
of around EUR 22 million per year, with over 90% of that 
related to waste water141. Moreover, the recent 6th WFD 
and  Floods  Directive  Implementation  Report142  and  the 
financial - economic study143 accompanying it, are also a 
relevant source of information in this domain. 

Waste and circular economy 

According  to  a  Commission  study144,  to  meet  the 
recycling  targets  for  municipal  waste  and  packaging 
waste, Luxembourg still needs to invest an additional EUR 
32 million (around EUR 4.6 million per year) over baselines 
in collection, recycling reprocessors, biowaste treatment, 
waste sorting facilities and waste registry digitalisation in 
2021-2027.  This  does  not 
investment 
necessary  for  other  key  waste  streams  (plastics,  textile, 
furniture) or to unlock a higher uptake of circularity and 
waste prevention across the economy. 

include  the 

Biodiversity and ecosystems 

The  recently  submitted  prioritised  action  framework 
(PAF) for Luxembourg shows that nature-protection costs 
(including Natura 2000) are  EUR 59.4  million  per  year in 
2021-2027,  including  EUR  43.8  million  of  annual  one-off 
costs145.  The  cost 
site-related 

for  Natura  2000 

139 OECD, Financing a Water Secure Future, 2022. 
140 OECD, Financing a Water Secure Future, 2022. 
141  OECD, Luxembourg-  Country  fact  sheet-  Financing  Water  Supply, 
Sanitation and Flood Protection. 
142 WFD and FD Implementation Reports – DG Environment – European 
Commission. 
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 
improving  synergies  with  EU  funding 
instruments  report  to  the 
European Commission, 2021. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
 
                                                                 
maintenance  and  restoration  measures  for  species  and 
habitats amounts to EUR 31 589 408 per year. The three 
main areas (representing 88% of the total investment  in 
Natura  2000  sites)  are  freshwater  habitats  (EUR  14  379 
100 per year), woodlands and forest (EUR 6 835 698 per 
year)  and  grasslands  (EUR  6  806  105  per  year).  This 
excludes  additional  costs 
the  EU 
biodiversity  strategy  for  2030,  including  on  increased 
protection and restoration. 

implement 

to 

The  four  freshwater  habitats  of  Annex  I  to  the  Habitats 
Directive  have  an  unfavourable  status,  as  well  as  the 
amphibians.  Measures  aim  to  create  additional  water 
bodies  to  protect  current  ones  by  creating  buffer  areas 
large  enough  to  significantly  reduce  the 
impact  of 
fertilisers, pesticides, and vegetation clearing followed by 
mud removal from ponds. 

In addition to measures put in place under the WFD (e.g. 
installing or modernising water-treatment plants), action 
taken  included  installing  buffer  zones,  renaturing  river 
streams and installing fish passages. 

Luxembourg hosts seven forest habitats of Annex I to the 
Habitats  Directive,  of  which  three  have  a  favourable 
status, three have an unfavourable status and one has a 
very unfavourable status. Although many species hosted 
in  these  forests  show  more  or  less  positive  or  stable 
trends,  some  are  showing  unfavourable  or  bad 
conservation  status.  Restoration  measures  concern 
improvement  of  forest  edges,  conversion  of  conifer 
plantations 
into  Annex-I  habitats,  and  reduction  of 
pressure 
from  game.  Restoration  of  hydrological 
conditions relies on: (i) creating buffer zones for wooded 
bogs to reduce the supply of nutrients; and (ii) removing 
unsuitable/exotic  tree  species.  Substantial  work  on  river 
banks  will  be  needed  to  increase  the  surface  area  of 
alluvial 
(for  example  converting  coniferous 
plantations  and  enabling  rivers’  natural  dynamic). 
Securing suitable surfaces by purchasing them is another 
measure considered important. 

forest 

Luxembourg  hosts  six  grasslands  of  Annex  I  to  the 
Habitats  Directive,  One  has  a  favourable  conservation 
status  (6110),  the  five  others  have  bad  conservation 
status U2 (6210, 6230, 6410, 6430 and 6510). Improving 
megaphlorbiae  will  require:  (i)  the  creation  of  closed 
bands  alongwatercourses  with  suitable  mowing;  and  (ii) 
the management of IAS. To halt the decrease of lowland 
6510, it will be important to conclude more contracts  to 
develop  extensive  grasslands.  This  also  applies  to  the 
Molinia  meadows,  to  improve  their  quality  by  adapting 
management and to avoid falling. For species-rich Nardus 
grasslands 6230, the measures in place will be continued 
to extend the total area and improve its quality. Clearing 
of semi-natural dry grassland  6210 to remove  scrub and 
brushwood  will  be  followed  by  suitable  management, 
such as itinerant grazing. 

Luxembourg  34 

EU environmental funding in 2014-2020 

The  multiannual  financial  framework  (MFF)  for  2014-
2020 allocated almost  EUR 960 billion (in commitments, 
2011 prices)146 for the EU to spend over this period. The 
commitment 
in  this  2014-2020  MFF  to  the  green 
transition  included  a  target  to  spend  at  least  20%  on 
climate action. It also included  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  (in  current  prices)  from  the  REACT-EU 
programme  for  cohesion-policy  action  to  support  the 
recovery from COVID-19148. 

Luxembourg  received  EUR  313.8  million  from  the  ESI 
Funds  in  2014-2020  to  invest  in  job  creation  and  a 
sustainable  and  healthy  EU  economy  and  environment. 
The planned direct environmental investment amounted 
to  EUR  0.5  million,  with  a  further  EUR  3.5  million 
identified  as  indirect  environmental  investment  value, 
totalling EUR 4.0 million. Figure 37 shows an overview of 
for 
ESI 
(planned) 
Luxembourg (EU amounts, without national amounts). 

earmarked 

individual 

Funds 

146  Council  Regulation  (EU,  Euratom)  No  1311/2013  (OJ  L  347, 
20.12.2013, p. 884). 
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). 
148 Regulation (EU) 2020/2221 (OJ L 437, 28.12.2020, p. 30). 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
                                                                 
Figure 36: ESI Funds allocated to Luxembourg, including 
environmental investments, 2014-2020149 

Under EMFF 

Under ESI Funds total  
Direct environmental investments 
Indirect environmental investments 

0 

4.0 
0.5 
3.5 

Luxembourg  35 

Funding for the environment from the ESI Funds has also 
been  supplemented  by  other  EU  funding  programmes 
available  to  all  Member  States  such  as  the  LIFE 
programme  or  Horizon  2020.  For  Luxembourg,  this 
additional  EU  environmental  financinf  added  up  to 
around EUR 11 million in 2014-2020. 

is  entirely  dedicated 

The  LIFE  programme151 
to 
environmental  and  climate  objectives. 
finances 
demonstration  and  best-practice  actions  for  green 
solutions  to  be  deployed.  In  2014-2020,  Luxembourg 
received  EUR  3.6  million  from  the  LIFE  programme  for 
one nature project (out of 1 028 EU-27 LIFE projects with 
a total EU contribution of EUR 1.74 billion)152. 

It 

In  2014-2020,  Horizon  2020  allocated  about  EUR  2.9 
million (about 1.5% of its total allocation) to Luxembourg, 
in  particular  for  the  circular  economy,  including  raw 
materials  and  climate  action153.  Luxembourg’s  allocation 
under the European Fund for Strategic Investments (EFSI) 
of  EUR  20  million  did  not  include  any  environmental 
funding154.  Luxembourg’s  European  Investment  Bank 
(EIB)  loans  (EUR  684.3  million)  did  not  include  any 
environmental support  either155. The country ranks  26th 
in size in total EIB lending. 

In  2020,  the  EIB  provided  EUR  24.2  billion  in  funding 
across  Europe  to  fight  climate  change,  37%  of  its  total 
financing.  It  also  provided  EUR  1.8  billion  (3%  of  its 
financing) for broader environmental lending156 157. 

EU environmental funding 2021-2027 

The 2020 European Green Deal investment plan calls for 
EUR 1 trillion in green investments (public and private) to 
be made across the EU by 2030. The 2021-2027 MFF and 

151 European Commission, LIFE Programme. 
152 Source: CINEA 
153 Source: EASME, https://sc5.easme-web.eu/, accessed: 15-12-2021. 
154  Approved  and  signed  EFSI  financing  -  EIB,  2015-2020:  Source: 
https://www.eib.org/en/products/mandates-
partnerships/efsi/index.htm. 
155 EIB loans in EU countries in 2014-2020. Source: EIB Open Data Portal: 
https://www.eib.org/en/infocentre/eib-open-data.htm 
156  The  EIB  Group  works  together  with  the  Commission  to  implement 
several  programmes  that  finance  environmental 
implementation: 
InvestEU,  the  successor  of  EFSI,  Pillars  II  and  III  of  the  Just  Transition 
Mechanism. The EIB Group is a key implementing partner for InvestEU. 
It is responsible for managing 75% of the overall budgetary capacity of 
the mandate. 
157 EIB 2021 Activity Report. 

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

Instrument 

Under cohesion policy (ERDF) 
Indirect environmental investments 
renewable energy 
energy efficiency 
sustainable transport 
business  development, 
and innovation 

research 

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

Allocations  
for the environment  
(EUR million) 

3.5 
3.5 
0.7 
1.4 
1.2 
0.1 

0.5 
0.5 
0.5 

on 

ESI 

Data 

Open 

based 

Funds 

is  calculated  by  combining 

149  European  Commission,  Directorate-General  for  Environment,  data 
analysis;  European  Commission,  Directorate-General  for  Environment, 
Portal 
analysis 
(cohesiondata.ec.europa.eu); COWI, 
Integration  of  environmental 
concerns in Cohesion Policy Funds, 2017; Regulation (EU) No 1303/2013; 
Regulation  (EU)  2021/1060; and Implementing  Regulation  (EU)  No 
215/2014. Cut-off  date  for  data:  December  2021.  Environmental 
fields  and 
investment 
coefficients  under  Regulation  (EU)  No  1303/2013 and Regulation  (EU) 
2021/1060 enabling  a  more  precise  identification  and  valuation  of 
relevant environmental investment.  Indirect  environmental  investment 
is  valued  using  environmental  coefficients  from  Annex  I  to  Regulation 
(EU) 2021/1060 (as opposed to full value). 
150  European  Commission,  Directorate-General  for  Environment,  data 
analysis.  The  values  of  environmental  investment  identified  in  specific 
environmental  areas  may  differ 
tracking  values  at 
cohesiondata.ec.europa.eu, e.g. for clean air or biodiversity. This is due 
to two factors: the set of environmental coefficients used and the range 
of  funds  assessed.  The  Directorate-General  for  Environment’s  analysis 
covered the full range of ESI Funds. See also the previous footnote. 

intervention 

from  the 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
  
                                                                 
 
 
                                                                 
including 

environmental 

the NextGenerationEU spending programme will provide 
EUR  2.018  trillion  (in  current  prices)  to  support  the 
long-term 
recovery 
from  COVID-19  and  the  EU’s 
priorities, 
protection158. 
Following the EU Green Deal’s159 pledge to ‘do no harm’ 
and  the  Interinstitutional  Agreement  on  the  2021-2027 
MFF160, 30% of the EU budget  in 2021-2027  will support 
climate efforts, while biodiversity will receive 7.5% of the 
EU budget as of 2024 and 10% as of 2026. To reach these 
targets,  more  financial  resources  will  need  to  be 
allocated  to  biodiversity,  specifically  under  2021-2027 
cohesion policy and 2023-2027 CAP. 

Sustainable  finance  significantly  increases  transparency 
on environmental sustainability (a goal promoted by the 
EU  Taxonomy)161. 
It  also  strengthens  non-financial 
reporting  requirements  and  facilitates  the  issuance  of 
green  bonds 
(by  developing  the  EU  green  bond 
standard162).  Reinforced  by  the  renewed  sustainable 
finance  will 
finance  strategy 
increase 
the 
flows 
environment. The new strategy on adaptation to climate 
change164 can help tp close the insurance-protection gap, 
which  currently  leaves  many  risks  from  climate-related 
events uninsured165. The EIB will align 50% of its lending 
for  climate  and  environment  projects  by  2025166,  with  a 
EUR  250  billion  contribution  to  the  Green  Deal 
investment plan by 2027. 

(2020)163,  sustainable 

climate  and 

investment 

to 

Table  3  gives  an  overview  of  EU  funding  earmarked 
specifically for Luxembourg for 2021-2027. This funding is 
supplemented  by  other  EU 
funding  programmes 
available to all Member States. 

Table  3:  Key  2021-2027  EU  funding  allocated  to 
Luxembourg (current prices) 

Instrument 

Country funding 
allocation (EUR million) 

158  European  Commission,  2021-2027 
NextGenerationEU. 
159 COM/2019/640 final. 
160 Interinstitutional Agreement, OJ L 433I. 
161 

long-term  EU  budget  & 

Luxembourg  36 

Cohesion policy 

Total: 58.7167 

ERDF 

European Social Fund Plus 

European 
Territorial 
Cooperation  (ETC)  (under 
the ERDF) 

Just Transition Fund 

EAFRD/rural development  

under 
strategic plans170 

2020-2027  CAP 

European 
Maritime, 
Fisheries and Aquaculture 
Fund 

Recovery  and  Resilience 
Facility (RRF) 

2021 – 2026172  

14.9 

14.8 

29168 

9.3169 

61.6171 

none 

93.4173 (grants) 

In  Luxembourg,  programming  of  most  EU 
funds 
(cohesion-policy  funds  and EAFRD)  is  ongoing.  However, 
the negotiations under the RRF have been concluded. 

investments 

Luxembourg’s  RRP  (which 
is  needed  to  access  RRF 
funding)  responds  to  the  urgent  need  to  foster  a  strong 
future-ready.  The 
recovery  and  make  Luxembourg 
the  plan  will  help 
reforms  and 
in 
Luxembourg  become  more 
resilient 
sustainable, 
and better prepared for the challenges and opportunities 
of the green and digital transitions. To this end, the plan 
consists  of  12  investments  and  8  reforms.  Luxembourg 
requested  EUR  93 million in  grants.  Out  of  the  RRP  total 
amount,  60.95%  will  will  support climate  objectives  (see 
Figure 38). This exceeds the RRF’s 37% climate target and 
puts  Luxembourg  among  the  top  Member  States  as 
regards  climate  commitment. 
terms  of  green 
transition, the plan reflects Luxembourg’s climate pledge 
by  supporting  the electrification  of  road  transport, 
including: 

In 

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

finance/sustainable-finance/eu-taxonomy-sustainable-activities_en 
162 EU Green Bond Standard - 2021/0191 (COD). 
163  European  Commission,  Strategy  for  Financing  the  Transition  to  a 
Sustainable Economy, COM(2021) 390 final.  
164 COM(2021) 82 final. 
165  The  strategy  would  support  improved  insurance-gap  coverage 
including  through  the  natural  catastrophe  markets  as  reflected  in  the 
dashboard on insurance protection gap for natural catastrophes of the 
Insurance  and  Occupational  Pension 
Association 
Authorities. 
https://www.eiopa.europa.eu/document-
library/feedback-request/pilot-dashboard-insurance-protection-gap-
natural-catastrophes_en. 
166 EIB Climate Bank Roadmap 2021-2025, November 2020. 

for  European 
See 

167  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
168  Interreg  initial  allocations  per  MS  including  ETC  transnational  and 
ETC cross-border co-operation.  
169  The  transfer  to  the  Connecting  Europe  Facility  (Transport)  is  not 
included. 
170 European Commission, CAP strategic plans.  
171  European  Commission,  2021-2027  Cohesion  policy  EU  budget 
allocations. 
172 The reforms and investments under the RRF have to be implemented 
by 31 December 2026. 
173 Council Implementing Decision on the approval of the assessment of 
the recovery and resilience plan for Luxembourg. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
                                                                 
 
 
                                                                 
 

 

 

investment  to  promote  charging  points  (EUR  30.5 
million); 
investment  to  build  a  new  housing  district  with  heat 
and  electricity  produced  from  renewable  energy 
sources (EUR 24 million); and 
’Naturpakt’  with 
concude 
investment 
to 
municipalities 
for 
to  provide 
measures  to  protect  nature  and  prevent  biodiversity 
loss174. 

a 
financial  support 

Figure 37: Climate expenditure in RRPs, 2021-2026175 

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 
Luxembourg 
in  2021-2027,  there  are  also  funding 
programmes  that  can  be  accessed  at  the  EU  level  and 
which are open to all Member States. These include the 
LIFE  programme  176  (EUR  5.4  billion),  Horizon  Europe 
(EUR  95.5  billion)177,  the  Connecting  Europe  Facility178 

174 European Commission, Luxembourg’s recovery and resilience plan. 
175 European Commission. The contributions to climate objectives have 
been calculated using Annex VI of the RRF Regulation (EU) 2021/241. 
176 European Commission, LIFE Programme. 
177  European  Commission,  Multiannual  financial  framework  2021-2027 
(in commitments) - Current prices. 
178  The  Connecting  Europe  Facility  (Transport)  includes  also  EUR  11.3 
billion  transferred  from  the  Cohesion  Fund.  30%  of  the  transferred 
amount  will  be  made  available,  on a  competitive  basis,  to  all  Member 
States eligible for the Cohesion Fund. The remaining 70% will be made 
available  respecting  national  allocations  until  31  December  2023. 
National  allocations  that  are  not  spent  by  this  date  will  support  all 
Member States eligible for the Cohesion Fund. 

Luxembourg  37 

(EUR  33.7  billion)179  or  the  funds  to  be  provided  via  the 
InvestEU180  programme.  These  other  sources  of  funding 
will  also  support  the  green  transition,  including  through 
research  and  innovation  activities  for  environmental 
protection  (Horizon  Europe)181,  clean  transport  and 
energy (the Connecting Europe Facility)182 or sustainable 
infrastructure (InvestEU)183. 

National environmental protection 
expenditure 

Total  national  expenditure  environmental  protection 
(including all relevant current and capital expenditure)184 
in the EU-27 was EUR 272.6 billion in 2020, representing 
2%  of  EU-27  GDP.  This  percentage  has  remained  quite 
stable over time. Although the largest absolute amounts 
of expenditure are concentrated in a few countries, most 
countries  spend  1-2%  of  their  GDP  on  environmental 
protection, with Luxembourg dedicating 1%. 

Of  this  spending,  the  EU-27’s  capital  expenditure  on 
environmental  protection  (i.e.  investment)  amounted  to 
EUR  56.3  billion  in  2018,  falling  to  EUR  54.5  billion  in 
2020,  representing  around  0.4%  of  EU-27  GDP.  Most 
Member  States 
in 
environmental  protection,  including  Luxembourg  (0.4%). 
In  2014-2020,  this  totalled  around  EUR  376  billion  of 
environmental  investment  in  the  EU-27,  and  EUR  1.18 
billion in Luxembourg. 

invested  0.2-0.5%  of  their  GDP 

179 Regulation (EU) 2021/1153. 
180  The  InvestEU  Fund  is  expected  to  provide  over  EUR  372  billion  of 
investment  using  an  EU  budget  guarantee  of  EUR  26.2  billion  to  back 
the investment of financial partners such as the EIB Group. 
181 European Commission, Horizon Europe. 
182 European Commission, Connecting Europe Facility. 
183 European Union, InvestEU. 
184  At  economy 
intermediate 
consumption and  capital  expenditure  of  households,  corporations  and 
governments related to environmental-protection goods and services. It 
excludes  EU  funds,  but  may  include  some  international  expenditure 
(beyond  domestic).  Source:  Environmental  Protection  Expenditure 
Accounts (EPEA), Eurostat. EPEA accounts are based on the CEPA 2000 
classification, excluding climate, energy and circular economy. 

including  final  consumption, 

level, 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
 
                                                                 
Figure 38: Direct and indirect environmental protection 
investment in the EU-27, 2018185 

Figure 39: Environmental protection investments in the 
EU-27 (capital expenditure) by institutional sector (total 
economy = 100%), 2018186 

Luxembourg  38 

protection 

investment 

By  institutional  sector,  only  around  7%  of  Luxembourg’s 
environmental 
(capital 
expenditure)  came  from  the  general  government.  Most 
of  it  (93%)  was  incurred  by  specialist  producers  (of 
environmental protection services, e.g. waste and water 
companies).  At 
from 
governments,  33%  from  specialist  producers  and  30% 
from industry (businesses). 

level,  37%  comes 

the  EU 

A  breakdown  of  investment  by  environmental  topic  is 
partially available, at the level of institutional sectors only 
(rather than at economy level), due to different reporting 
patterns. At Luxembourg’s general-government level, the 
priorities  were  biodiversity  (43%),  waste  management 
(31%)  and  air  protection  (23%)  in  2018.  The  country’s 
specialist producers focused on waste water, with 94% of 
environmental  investments.  On  industry  (businesses), 
there was no official data available.  

In  2020,  the  total  annual  issuance  of  European  green 
bonds (including some non-EU countries)187 was USD 156 
billion (EUR 137 billion188), up from USD 117 billion (EUR 
105  billion)  in  2019.  Looking  only  at  EU-27  Member 
States, green-bond issuance in 2020 was EUR 124 billion. 
In  2014-2020,  83%  of  the  green  bonds 
issued  by 
European countries served objectives in energy, buildings 
or transport, while 8% supported water and waste, with a 
further 6% supporting sustainable land use, with links to 
ecosystem  conservation  and  restoration.  These  data  are 
based  on  the  climate  bonds  taxonomy,  which  is  broadly 
similar  to  the  EU  Taxonomy189.  Of  this  2020  annual 

186 Eurostat, Environmental Protection Expenditure Accounts. 
187 Green bonds were created to fund projects that have environmental 
and/or  climate  benefits.  Most  green  bonds  issued  are  green  ‘use  of 
proceeds’ or asset-linked bonds. The very first green bond was issued in 
2007.  It  was  an  AAA-rated  issuance  from  multilateral  institutions,  the 
EIB and the World Bank. 
188 At Eurostat’s annual average EUR/USD exchange rates. 
189 
information 
https://www.climatebonds.net/standard/taxonomy  

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

climate-bonds 

on 

185 Eurostat, Environmental Protection Expenditure Accounts, 2021. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
                                                                 
 
 
                                                                 
Luxembourg  39 

issuance  of  EU  green  bonds,  Luxembourg’s  issuance 
amounted to around EUR 1 billion (data  available for 16 
EU Member States, see Figure 41). 

Figure 41: Environmental taxes in the EU-27, 2020191 

Figure 40: Annual issuance of EU green bonds, 2020 
(EUR billion)190 

The  2019  European  Green  Deal  underlines  that  well-
designed  tax  reforms  can  boost  economic  growth  and 
resilience,  foster  a  fairer  society,  and  promote  a  just 
transition. Tax reforms can contribute 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 
considerations192.  The  Green  Deal  promotes 
the 
‘polluter-pays principle’193, which stipulates that polluters 
should bear the cost of measures to prevent, control and 
remedy  pollution.  The  polluter-pays  principle 
is 
facilitated  by  the  Commission’s  Technical  Support 
Instrument (TSI) flagship project194 on greening taxes. 

According  to  a  Commission  study  on  green  taxation  and 
other economic instruments (2021),  Luxembourg applies 
polluter-pays  economic  instruments  on  waste  (with  a 
municipal  waste  management  tax)  and  on  nature  and 
natural-resource  protection  (with  biodiversity  offsetting 
and an eco-points regime)195. 

There is no measure on green taxes in the Luxembourgish 
RRP.  There 
increase  environmental 
taxation in Luxembourg. For instance, the introduction of 

is  potential  to 

191 Eurostat, Environmental taxes accounts. 
192  European  Commission,  The  European  Green  Deal,  COM  (2019/640 
final), p.17. 
193  Article  191(2)  of  the  Treaty  on  the  Functioning  of  the  European 
Union states: ‘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’. 
194  European  Commission,  Greening  taxes  -  applying  polluter  pays 
principle in practice, green budgeting TSI participation. 
195  European  Commission, Green 
instruments, 2021. 

taxation  and  other  economic 

Green budget tools 

Green taxation and reform 

With  environmental  taxes  standing  at  1.39%  of  GDP  in 
2020,  Luxembourg’s  revenue  from  these  taxes  is  among 
the  lowest  of  all  Member  States,  well  below  the  EU-27 
average:  of  2.24%,  as  shown  in  Figure  42.  Energy  taxes 
have the highest share in this with 1.27% of GDP (below 
the  EU  average  of  1.74%).  Transport 
taxation 
represented 0.11% in 2020 (well below the EU average of 
0.42%),  while  pollution  and  resource  taxes  are  almost 
negligible 
taxes 
represented  to  3.62%  of  total  revenues  from  taxes  and 
social-security  contributions  (below  the  EU  average  of 
5.57%). 

In  2020,  environmental 

(0.01%). 

190 Climate Bonds Initiative, 2022. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
                                                                 
 
 
                                                                 
a  pesticide  tax  could  improve  water  quality.  Modelling 
suggests that much higher rates based on  pesticide-load 
indicators  could  strongly  reduce  the  pesticide  load  in 
Luxembourg  without  impact  on  GDP  or  employment196. 
Also,  as  highlighted  in  the  2019  European  Semester 
Country Report, there is potential to increase taxation in 
the transport sector. Luxembourg’s tax rates on transport 
fuels  are  considerably 
in  neighbouring 
countries,  inducing  cross-border  fuel  purchasing.  This 
enables  the  country  to  raise  sizeable  tax  revenues 
despite very low rates197. 

lower  than 

Environmentally-harmful subsidies 

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

Fossil-fuel  subsidies  are  costly  for  public  budgets,  and 
make it difficult to achieve the Green Deal objectives (on 
climate  neutrality,  air  quality,  zero  pollution  and  health 
impacts). In  many cases, these subsidies also  counteract 
incentives  for  investment  in  green  technologies.  Annual 
fossil-fuel  subsidies  have  been  around  EUR  55  billion  in 
the  EU  since  2015.  They  rose  by  4%  between  2015  and 
2019, although some countries (such as Latvia, Lithuania, 
Sweden, Greece 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, largely owing 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  0.03%  in  Malta  in  2019  (with  an  EU  average  of 
0.4%). 
subsidies 
represented 0.05% of GDP in 2019. In 2020, the  EU-27’s 
total fossil-fuel subsidies decreased to EUR 52 billion (due 
to falling consumption trends amid the COVID-19-related 
restrictions).  Without  Member  State  actions,  these 
subsidies  are  likely  to  rebound  as  economic  activity 
picked up from 2020198. 

In  Luxembourg, 

fossil-fuel 

total 

Luxembourg  40 

Figure 42: Trends in petroleum-product subsidies in 
Luxembourg199 

In  terms  of  bad  practices,  Luxembourg  does  not  have  a 
duty  on  air  travel.  There  is  no  fuel  tax  and  value  added 
tax on aviation (while road transport, such tax is levied). 
Therefore,  airlines  do  not  pay  fuel  tax  when  they  fill  up 
indirect 
their  planes.  This 
environmentally harmful subsidy that damages air quality 
and  the  climate  by  encouraging  air  transport,  which  is 
very  carbon  intensive  and  causes  a  large  amount  of  air 
pollution. 

is  an  example  of  an 

Current green-budgeting practices 

‘Green  budgeting’  encompasses  various  climate  and 
environmental  tagging200  and  tracking  practices 
in 
budgets.  Some  EU  Member  States  already  use  certain 
green-budgeting  practices201.  Green  budgeting  helps 
identify and track green expenditure and green revenues 
to 
increase  transparency  on  how  green  budgetary 
policies are. This is aimed at  improving policy coherence 
and  supporting  green  policies  (including  climate  and 
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 

196 European Commission, Ensuring that polluters pay - Luxembourg. 
197 European Commission, Country report Luxembourg 2019, SWD(2019) 
1015 final, p. 22. 
198  See  table  on  EU  FFS  data  in  2019  which  is  based  on  (for  info) 
COM(2021) 950 and Annex. 

199 OECD, Fossil Fuel Subsidy Tracker. 
200  Tagging  is  explained  in  European  Commission,  Green  budgeting 
practices in the EU: a first review , 2021 (p.7). 
201 European Commission, Green Budgeting Practices in the EU: A First 
Review, 2021, Green Budgeting Reference Framework and OECD, Public 
Governance  Directorate,  Climate  Change  and  Long-term  Fiscal 
Sustainability - Scoping Paper, February 2021. 
202 OECD Paris Collaborative on Green Budgeting initiative, 2017. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
                                                                 
 
 
 
                                                                 
Luxembourg  41 

Figure 43: Total environmental financing baseline (2014-
2020) and estimated needs (2020-2030) in the EU-27 (% 
of GDP)206 

legislation  and  criteria203.  The  Commission  developed  a 
green-budgeting reference framework204 and launched a 
TSI flagship projects  on green budgeting in 2021 to  help 
Member  States  develop  national  green-budgeting 
frameworks to improve policy coherence and support the 
green transition. Luxembourg participates in this project. 

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  a  year  in 
2014-2020, comprising both major EU funds and national 
financing.  This  ranged  from  0.3%  (Ireland)  to  1.91% 
(Bulgaria),  depending  on  the  level  of  environmental 
challenges  in  different  Member  States.  In  2021-2027 
period,  it  is  estimated  that  the  EU’s  environmental 
investment  needs  will  range  between  0.9%  and  1.5%  of 
forecast  GDP,  suggesting  a  potential  environmental 
financing gap of 0.6-0.8% of  GDP,  compared to  previous 
financing levels205. 

the 

the 

financing. 

In  2021-2027, 

Luxembourg’s  financing  for  environmental  investment 
amounted  to  0.49%  of  GDP  in  2014-2020  (under  the  EU 
average). The country relied on national sources for 99% 
of 
country’s 
environmental investment  needs are estimated to reach 
over  0.77%  of  GDP,  suggesting  an  environmental 
financing gap of at least 0.27% of GDP. This  gap is likely 
to  be  larger  when  factoring  in  needs  that  are  currently 
only  estimated  at  EU 
level  (e.g.  water  protection, 
circularity,  biodiversity  strategy,  etc.).  This  needs  to  be 
financing 
addressed  by  additional  environmental 
measures and by raising financial resources. 

In the 2019 EIR, Luxembourg received one priority action, 
namely  to  provide  adequate  funding  to  tackle  the  main 
environmental challenges affecting the country, including 
through  the  mobilisation  of  investments  and  the  use  of 
EU  funds.  There  has  been  some  progress  on  this  (for 
example the issuance of a green bond worth EUR 1 billion 
in  2020),  while  for  other  areas,  the  recommendation  is 
reiterated. 

2022 priority actions 

  Draw  up  an  environmental  financing  strategy  to 
maximise  opportunities  for  closing  environmental 
increasing 
implementation  gaps, 
environmental taxes.  

including  by 

206 Eurostat, ESI Funds Open Data, 2021. 

203 European Commission, Technical guidance on sustainability proofing 
for the InvestEU Fund. 
204  European  Commission,  European  Commission  Green  Budgeting 
Reference Framework.  
205 Source: European Commission, Directorate-General for Environment, 
data  analysis.  EU  financing  sources  covered:  ESI  Funds  (ERDF,  CF,  ESF, 
YEI,  EAFRD,  EMFF),  Horizon  2020,  LIFE,  EFSI  (EU  amount),  EIB  loans. 
National  financing:  total  national  environmental-protection  capital 
expenditure (investment) – source: Eurostat EPEA dataset. Cut-off date 
for data: end-2021. Total financing may be higher, in particular because 
of  further  indirect  investments.  This  requires  further  analysis  in  the 
future. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
                                                                 
 
 
 
                                                                 
  Tackle  the  country’s  main  environmental  challenges 
by providing appropriate funding, including by raising 

investment and using EU funds. 

Luxembourg  42 

Environmental Implementation Review 2022 – Luxembourg 

 
 
 
Luxembourg  43 

6. Environmental governance 

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they  can  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention: 
(i) access to information; 
(ii) public participation in decision making; 
(iii) access to justice in environmental matters. 
It is of crucial importance to public authorities, the public 
and businesses that environmental information is shared 
efficiently  and  effectively207.  Public  participation  allows 
authorities  to  make  decisions  that  take  public  concerns 
into account. Access to justice is a set of guarantees that 
allows  citizens  and  NGOs  to  use  national  courts  to 
protect the environment208. It includes the right to bring 
legal challenges (‘legal standing’)209. 

Environmental information 

This section focuses on Luxembourg’s implementation of 
the  INSPIRE  Directive.  The  INSPIRE  Directive  aims  to  set 
up  a  European  spatial  data  infrastructure  for:  (i)  sharing 
environmental  spatial 
information  between  public 
authorities  across  the  EU;  (ii)  assisting  in  policy-making 
across  boundaries;  and  (iii)  facilitating  public  access  to 
this  information.  Geographic  information  is  needed  for 
good  governance  at  all  levels  and  should  be  readily  and 
transparently available. 

Luxembourg’s implementation of the INSPIRE Directive is 
good.  Luxembourg’s  performance  has  been  reviewed 
based on its 2021 country fiche210. Data identification and 
documentation  have  made  good  progress,  and 
implementation levels are good. 

207  Together,  the  Aarhus  Convention,  the  Access  to  Environmental 
Information  Directive  (Directive  2003/4/EC)  and  the  INSPIRE  Directive 
(Directive  2007/2/EC)  create  a  legal  foundation  for  the  sharing  of 
environmental  information  between  public  authorities  and  with  the 
public. This EIR focuses on the INSPIRE Directive’s implementation. 
208 These guarantees are explained in the Commission Notice on access 
to  justice  in  environmental  matters  (OJ L  275,  18.8.2017)  and  in  a 
related citizen’s guide.  
209  This  EIR  focuses  on  the  means  implemented  by  Member  States  to 
guarantee rights of access to justice and legal standing and to overcome 
other major barriers to bringing cases on nature and air pollution. 
210 https://inspire.ec.europa.eu/INSPIRE-in-your-Country/LU 

Table 4: Country dashboard on the implementation of 
the INSPIRE Directive, 2016-2020211 

2016 

2020 

Legend 

Effective coordination and data 
sharing 

Ensure effective 
coordination  

■  ■ 

sharing 

Data 
without 
obstacle  

INSPIRE 
indicators 

■  ■ 

performance 

i. Conformity of 
metadata  

■  ■ 

ii.  Conformity 
of  spatial  data 
sets212 

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

iv.  Conformity 
of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

advanced 

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

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

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

Public participation 

Environmental  impact  assessments  (EIAs)  are  published 
in  daily  newspapers,  referring  to  the  website  on  which 
detailed  information  is  available  and  mentioning  the 
deadline  for  submissions  of  observations  by  the  public. 
Projects that are subject to ongoing or finalised EIAs are 
available  on  the  environmental  portal.  Observations  can 
be  submitted  electronically  either  via  the  online  form 
available  on  the  webpage  of  the  specific  project  or  via 
email. 

For  strategic  environmental  assessments  (SEAs),  the 
publication  procedure  is  the  same  as  the  onefor  EIAs. 
However,  contrary  to  the  EIA,  a  centralised  database 

211 INSPIRE knowledge base 
212 In 2016, the deadlines for implementing spatial-data interoperability 
were still in the future: 23.11.2017 for Annex-I data and 21.10.2020 for 
Annex-II and -III data. In many cases, this conformity indicator will never 
reach 100% as most countries provide as-is data sets in addition to the 
INSPIRE harmonised data sets. 

Environmental Implementation Review 2022 – Luxembourg 

 
 
                                                                 
 
 
                                                                 
to 

search  by 

gathering all the ongoing and finalised SEAs could not be 
found.  Access  to  ongoing  SEAs  is  possible  via  the  portal 
on public consultations that was set up recently, but it is 
difficult 
type  of  procedure.  The 
Luxembourgish  portal  on  public  consultations  set  up  in 
January  2021  shows  relatively 
levels  of  public 
participation  in  decision-making.  Luxembourg  is  invited: 
(i)  to  continue  the  good  practice  of  providing  accessible 
information  on  EIA  and  SEA  procedures,  to 
online 
facilitate public participation; and (ii) to consider making 
the  information  on  public  consultations  on  the  online 
portal searchable by type of procedure. 

low 

Access to justice 

Standing rules are consistent before all courts. However, 
Article  63  of  the  Law  on  the  protection  of  nature  and 
natural resources has set specific rules for environmental 
associations. 
litigants’ 
standing.  Standing  rules  are  applicable  throughout  the 
environmental procedure, from administrative appeal to 
judicial review. 

In  Luxembourg,  courts  assess 

judicial  review  against 

Generally,  standing  is  subject  to  a  prior-participation 
requirement in all kinds of environmental matters for all 
kinds  of  participants,  and  this  requirement  seems  to  be 
difficult  to  fulfil.  The  requirements  for  standing  do  not 
change  according  to  the  type  of  remedy  sought.  The 
Council  of  State  has  confirmed  that  case-law  allowing 
NGOs  to  bring  a 
individual 
administrative decisions did not need to be included in a 
new  law  on  nature  and  natural-resources  protection  as 
judges  must  be  able  to  use  their  discretionary  power. 
There  are  no  difficulties  in  challenging  SEA  decisions 
(either  the  plan  or  programme  or  the  environmental 
report,  or  both).  The  administrative  tribunal  judges  the 
procedural and substantive legality of the administrative 
decision  as  it  judges  the  merits  of  the  case.  Judges  will 
verify  factual  and  technical  criteria  and  all  relevant 
documents. There is a system of regular and substantive 
oversight of legally binding acts, and it is accessible to the 
members of the public and NGOs. 

Information  on  access  to 
matters is accessible via government sites213. 

justice 

in  environmental 

In  the  2019  EIR,  Luxembourg  received  three  priority 
actions.  There  is  no  information  available  on  the  first 
action,  on  improving  access  to  spatial  data  and  services 
linkages  between  the  country 
by  making  stronger 
INSPIRE  portals.  The  action  on 
legal  standing  for 
legal  challenges  on 
environmental  NGOs  to  bring 

213 
infrastructures.public.lu/fr/index.html 

www.emwelt.lu; 

www.developpement-durable-

Luxembourg  44 

environmental  issues,  where  relevant  without  facing 
prohibitive  costs,  has  been  fullly 
implemented,  as 
detailed  above.  On  better  informing  the  public  about 
their  access  to  justice  rights,  it  can  be  concluded  that 
limited progress has been made. 

2022 priority actions 

  Ensure  that  standing  is  not  conditional  on  prior 

participation in environmental cases. 

  Better  inform  the  public  about  public  consultations 
and  access  to  justice  rights,  in  particular  by  referring 
to  judicial  and  administrative  portals  and  to  the 
Commission’s eJustice fact sheets on access to justice 
in environmental matters214. 

Compliance assurance  

to  ensure 

Environmental compliance assurance covers all the work 
undertaken  by  public  authorities 
that 
industries,  farmers  and  others  fulfil  their  obligations  to 
protect water, air and nature, and manage waste215. 
It includes support measures provided by the authorities 
such as: 
(i) compliance promotion216; 
(ii) inspections and other checks that they carry out, i.e. 
compliance monitoring217; 
(iii)  the  steps  that  they  take  to  stop  breaches,  impose 
sanctions  and  require  damage  to  be  remedied,  i.e. 
enforcement218. 
Citizen  science  and  complaints  enable  authorities  to 
liability219 
focus  their  efforts  better.  Environmental 
ensures that the polluter pays to remedy any damage. 

Compliance promotion and monitoring 

Full  and  detailed 
is  provided  on 
information 
Luxembourg’s  national  environmental  portal  on  the 
Natura 2000 sites and species. Furthermore, the national 
environmental  portal  includes  national  and  European 

214 
https://e-
justice.europa.eu/content_access_to_justice_in_environmental_matter
s-300-en.do 
215 The concept is explained in detail in the Commission Communication 
on  EU  actions  to  improve  environmental  compliance  and  governance 
(COM(2018) 10)  and  the  related  Commission  Staff  Working  Document 
(SWD(2018) 10).  
216 This EIR focuses on the help given to farmers to comply with nature 
legislation and nitrates legislation.  
217 This EIR focuses on inspections of major industrial installations.  
218  This  EIR  focuses  on  the  availability  of  enforcement  data  and  on 
coordination between authorities to tackle environmental crime. 
219 The Environmental Liability Directive (Directive 2004/35/CE) creates 
the framework . 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
                                                                 
 
 
                                                                 
action  plans  in  favour  of  certain  species  and  habitats. 
Finally, the same website provides biodiversity guides for 
farmers  containing  information  on  the  protection  of 
nature through sustainable agricultural practices. 

Information  on  the 
implementation  of  the  Nitrates 
Directive  is  available  on  the  website  of  the  Ministry  of 
Agriculture. This website has contains a dedicated section 
providing  assistance  and  advice  to  farmers  on  fertiliser 
application  limits  based  on  the  size,  the  type  of  crop  or 
the  period  during  which  the  application  of  fertilisers  is 
not  allowed.  Luxembourg  has  also  set  up  agricultural 
advisory centres. 

Detailed  information  on  the  planning  of  inspections  of 
industrial  installations  is  provided  in  the  national  law 
implementing  the  IED220.  After  each  inspection  (planned 
or unplanned), the Environmental Administration drafts a 
report  setting  out  the  findings  on  the  conformity  of  the 
installation  and  the  action  to  be  taken.  The  report  is 
notified  to  the  operator  within  2  months  and  is  made 
the  public  within  4  months.  No 
available 
environmental statistics or annual activity reports linked 
to environmental inspections are available. 

to 

Complaint handling and citizen science 

Detailed  information  on  the  way  the  public  can  file 
environmental  complaints  with  one  of  the  three 
competent  authorities is available on the website of the 
Luxembourgish  government.  Standardised  complaint 
forms for each competent authority are also available on 
the  website  of  the  Luxembourgish  government.  This 
facilitates the submission of environmental complaints. 

Complaints  on  the  management  of  the  administration 
can  be  filed  with  the  ombudsman.  Information  on  the 
conditions  for  filing  such  a  complaint  and  applicable 
procedure is available on the websites of the government 
and the ombudsman. 

submitting  environmental 

complaints  are 
Poeple 
informed  about  the  receipt  of  their  request  and  can 
decide  to  be  informed  about  the  outcome  of  their 
leads  to  an 
complaint.  Reception  of  a  complaint 
the 
investigation  of 
competent authority, and the applicants must be granted 
the right to be heard on the observations  submitted. No 
information is available on the number of environmental 
complaints received by the authorities or their outcomes. 

infringement  by 

the  alleged 

Luxembourg  45 

Enforcement 

No  centralised  database  or  statistics  on  environmental 
crimes and their outcomes are available.  The  website of 
the  national  police  provides  some  statistics  on  crimes 
against  the  environment.  However,  it  does  not  specify 
the  type  of  crimes.  A  specialised  police  investigation 
team  carries  out 
into  environmental 
investigations 
against 
crimes. 
environmental  crime  has  been  criticised  for  lacking  a 
strategic approach221. 

Luxembourg’s 

However, 

fight 

Various  authorities  are  authorised  to  confirm  the 
existence  of  environmental  damage  and  adopt 
temporary safeguard measures before such measures are 
validated by the prosecutor. 

The Environment Agency, the police and the customs and 
the  Excise  Agency  cooperate  formally  and  exchange 
information  on  waste  transport  and  trade  inspections. 
Enforcement  authorities  also  cooperate  on  hazardous-
waste management. 

Environmental Liability Directive  

Ministerial  redress  measures  on  environmental  damage 
are published electronically, but there does not appear to 
be  a  central  database  recording  such  Environmental 
serious 
Liability  Directive 
environmental damage. 

cases  or  other 

(ELD) 

In  the  2019  EIR,  Luxembourg  received  four  priority 
actions.  There  are  reiterated  below  as  there  has  only 
been limited progress. 

2022 priority actions 

  Better 

inform 

the  public  about 

compliance 

promotion, monitoring and enforcement. 

  Ensure  more 

information  on  how  professionals 

 

dealing with environmental crime work together. 
Improve financial security for environmental liabilities 
and/or  ELD  guidance  and/or  the  collection  and 
publication of information on environmental damage. 
  Publish information on the outcomes of enforcement 
action  and  on  the  follow-up  to  detected  cross-
compliance breaches on nitrates and nature. 

No  initiatives  to  raise  the  public’s  awareness  of  the 
possibility to alert or inform authorities about facts likely 
to cause environmental damage have been identified. 

220 Directive 2010/75/EU (OJ L 334, 17.12.2010, p. 17). 

221 Council of the European Union,  Eighth round  of mutual evaluations 
on the practical implementation and operation of European policies on 
preventing  and  combating  environmental  crime  –  Report  on 
Luxembourg, 7947/1/19, p. 16. 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
                                                                 
 
 
 
                                                                 
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 

implementation  of  EU  environmental 

Overall, 
law 
improved  across  sectors  during  the  last  decade.  For 
instance,  implementation  of  environmental  assessments 
progressed. A recent  legislative  package aimed  to  speed 
up  licencing  of  projects  of  national  interest  raised  some 
doubts,  but  no  serious  problems  have  been  identified 
after its implementation. 

performance 

Luxembourg  ranks  second  out  of  180  in  the  2020 
Environmental  Performance  Index222.  Yet,  Luxembourg 
scores  below  the  EU  average  when  it  comes  to  overall 
environmental-governance 
(2019 
governance  study  ot  the  Commission’s  Directorate-
General  for  Environment).  In  terms  of  transparency, 
some  environmental  information  is  either  not  publicly 
available  or  difficult  to  access.  On  e-governance, 
Luxembourg  has  attempted  to  develop  tools  to  improve 
public access to information, and some success has been 
justice,  all  environmental 
achieved.  On  access  to 
associations  have  a  “sufficient 
interest”  to  request 
administrative jurisdictions to take actions under the ELD. 
However,  no  different  rules  exist  in  Luxembourg  for 
environmental procedures against the state compared to 
other  areas.  Environmental  claims  against  the  state  are 
treated  the  same  way  as  other  administrative  claims. 
There  is  no  distinction  between  various  environmental 
issues.  Lastly,  impact  assessments  are  required  when 
new  laws  or  programmes  are  developed,  but  these 
impact assessments do not require environmental issues 
to  be  addressed  directly  and  are  linked  primarily  to 
administrative burden and enforcement costs. 

this  area,  namely 

In the 2019 EIR, Luxembourg received one priority action 
in 
improve  environmental 
to 
governance  (such  as  transparency,  citizen  engagement, 
compliance  and  enforcement,  as  well  as  administrative 
capacity  and  coordination).  There  has  been 
limited 
progress. Therefore, the action is reiterated. 

222 https://epi.yale.edu/epi-results/2020/component/epi 

Luxembourg  46 

2022 priority action 

  Continue  to  improve  environmental  governance,  in 
particular administrative capacity and coordination at 
the national level. 

Coordination and integration 

As  mentioned  in  the  2019  EIR,  the  transposition  of  the 
revised  EIA  Directive223  provides  an  opportunity  to 
streamline  the  regulatory  framework  on  environmental 
assessments. Luxembourg has transposed the revised EIA 
Directive. 

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  burden  and  accelerates 
decision-making without compromising the quality of the 
environmental-assessment  procedure224.  Luxembourg 
already  streamlined  the  environmental  assessments 
under the EIA and Habitats Directives before the revision 
of  the  EIA  Directive.  Joint  procedures  have  been 
developed for the EIA Directive, the WFD and the IED. 

Reforms through the Commission’s technical 
support instrument (TSI) 

The  Commission  has  provided  expertise  to  help  design 
more  than  1  200  reform  projects  in  27  Member  States 
since  2017,  first  through  the  Structural  Reform  Support 
Programme, and since 2021 through the TSI, its successor 
programme. 

is  to  promote  the  EU’s 
The  TSI’s  main  objective 
economic,  social  and  territorial  cohesion  by  supporting 
Member  States’  action  on  implementing  the  necessary 
reforms  to  achieve  economic  and  social  recovery, 
social 
and 
resilience 
convergence225. 

economic 

upward 

and 

223 Directive 2014/52/EU of the European Parliament and of the Council 
of 16 April 2014 amending Directive 2011/92/EU on the assessment of 
the effects of certain public and private projects on the environment. 
224 The Commission issued a guidance document in 2016 regarding the 
setting  up  of  coordinated  and/or 
that  are 
simultaneously subject to assessments under the EIA Directive, Habitats 
Directive,  Water  Framework  Directive,  and  the  Industrial  Emissions 
Directive, OJ C 273, 27.7.2016, p. 1.  
225  European  Commission,  Technical  Support  Instrument:  2021  country 
factsheet. 

joint  procedures 

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Luxembourg  47 

the  environmental 

However, Luxembourg has not yet submitted TSI projects 
sector226.  The  Commission 
in 
encourages  Luxembourg  to  use  this  tool  in  the  coming 
years. 

TAIEX EIR peer to peer projects 

facilitate 

peer-to-peer 

The Commission launched the Taiex EIR peer-to-peer tool 
to 
between 
environmental  authorities.  During  the  reporting  period, 
on 
Luxembourg 
ammonia-reducing technology and measures  (November 
2021) and on zero pollution (February 2022). 

participated 

workshops 

learning 

in 

226 European Commission, Supporting reforms in Luxembourg, 2021. 

 Environmental Implementation Review 2022 – Luxembourg