COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Directive of the European Parliament and of the Council on ambient air quality and cleaner air for Europe (recast)
Date: 2022-10-26
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, air quality, environmental cooperation, environmental impact, environmental monitoring, environmental standard, pollution control, prevention of pollution, quality of the environment

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   EUROPEAN COMMISSION  Brussels, 26.10.2022  SWD(2022) 345 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council on ambient air quality and cleaner air for Europe (recast)       {COM(2022) 542 final} - {SEC(2022) 542 final} - {SWD(2022) 542 final} - {SWD(2022) 545 final}  
 
 
EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT 

Despite significant reductions of harmful air pollutant emissions over the past three decades in the 
EU, around 300 000 premature deaths per year (compared to up to 1 million per year back in the 
early  1990s)  and  a  significant  number  of  non-communicable  diseases  are  still  attributed  to  air 
pollution across the EU (and especially related to particulate matter, nitrogen dioxide and ozone).  

The European Commission committed, in the European Green Deal and in the subsequent Zero 
Pollution Action Plan, to further improve air quality and to align EU air quality standards more 
closely  with  the  recommendations  of  the  World  Health  Organization  (WHO),  most  recently 
revised in September 2021.  

The Ambient Air Quality Directives (Directives 2004/107/EC and 2008/50/EC) set standards for 
the concentration levels of 12 ambient air pollutants to be attained by all Member States across 
their territories against specific timelines. The fitness check of these directives concluded that they 
have been partially effective in improving air quality and achieving air quality standards, but that 
not all their objectives have been met to date. The Directives have led to the establishment of a 
representative high-quality monitoring of air quality, and contributed to a downward trend in air 
pollution across the EU.  

Nevertheless, four types of significant shortcomings in air quality policy remain and point to scope 
for improvements to the existing framework. Firstly, EU air quality standards are not as protective 
as  those  recommended  by  the  WHO.  Secondly,  the  fact  that  air  quality  plans  required  by  the 
Ambient Air Quality Directives are often insufficient to prevent exceedances or minimise their 
duration,  points  to  implementation  challenges  and  related  governance  and  enforcement 
shortcomings.  Thirdly,  reliability  and  comparability  of  air  quality  monitoring,  modelling  and 
assessments could be improved. Finally, further harmonisation of the way air quality information 
is presented, especially at Member State level, would provide further EU added value, and help 
ensure even higher comparability of information.  

This impact assessment considers merging the two directives and a total of 68 potential specific 
policy measures, combined in 19 potential policy options, to address the identified shortcomings. 
Most of them are complementary and somewhat independent from each other. Some co-benefits 
across  options  are  considered.  This  impact  assessment  suggests  to  retain  15  policy  options  - 
including  16  measures  to  improve  the  governance  and  enforcement  of  air  quality  plans,  15 
measures  to  further  improve  the  reliability  and  comparability  of  air  quality  monitoring  and 
modelling, 4 measures to improve access to air quality data and information with a particular focus 
on enhancing the use of digital tools, as well as 5 measures to strengthen the use of the average 
exposure indicator and keep EU air quality standards under regular review. 

Three policy options, namely those contrasting different levels of alignment with the WHO Air 
Quality  Guidelines  (i.e.  ‘full  alignment’  (I-1),  ‘closer  alignment’  (I-2)  and  ‘partial  alignment’ 
(I-3)), will require a political choice. The impact of these three policy options have been assessed 

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in a quantitative manner and would each render significant health and environment benefits – albeit 
to varying degrees. 

Stakeholder  feedback  pointed  to  a  preference  for  a  high  level  of  ambition.  In  the  public 
consultation, 73 % percent of all respondents, mainly representatives of civil society and NGOs 
and EU citizens, expressed a clear preference to align with the 2021 WHO Air Quality Guidelines. 
However, this assessment shows that, by the year 2030, reaching air pollutant concentration levels 
that fully  correspond to  the latest  Guidelines (equivalent  to  5 µg/m3 for fine particulate matter, 
PM2.5) may not be possible at all for large parts of sampling points in the EU (71 % in the case of 
PM2.5), even as virtually all technology options are explored.  

This assessment takes into account that air quality is also affected by sectors and activities, e.g. 
transport,  industry,  energy  and  agriculture,  and  includes  assumptions  on  the  effect  of  major 
initiatives under the European Green Deal such as the European Climate Law and the Fit for 55 
package,  the  Methane  Strategy,  the  Sustainable  and  Smart  Mobility  Strategy,  EURO-7  vehicle 
emission standards, the Biodiversity and the Farm to Fork Strategies as well as the very recent 
RePowerEU initiative. It however does not consider (given their very limited predictability, at this 
stage) other potential abatement options, such as much accelerated changes of behaviours across 
society or shifts to cleaner fuels.  

This resulting analysis shows that policy option I-3 (‘partial alignment’ with the 2021 WHO Air 
Quality Guidelines by 2030) has the highest benefit-to-cost ratio (between 10:1 and 28:1). Most 
air  quality  sampling  points  in  the  EU  might  be  expected  to  meet  the  corresponding  air  quality 
standards with little additional effort. The net benefits amount to more than 29 billion EUR. For 
policy option I-2 (‘closer alignment’ with the 2021 WHO Air Quality Guidelines by 2030) the 
benefit-to-cost  ratio  is  expected  to  be  slightly  lower  (between  7.5:1  and  21:1).  Some  6%  of 
sampling points would not be expected to meet the corresponding air quality standards without 
additional  effort  at  local  level  (or  may  need  time  extensions  or  exceptions).  The  net  benefits 
amount to more than 36 billion EUR, i.e. 25% more than policy option I-3. Under policy option 
I-1 (‘full alignment’ with the 2021 WHO Air Quality Guidelines by 2030) the benefit-to-cost ratio 
remains  significantly  positive  also  (between  6:1  and  18:1).  However,  71%  of  sampling  points 
would not be expected to meet the corresponding air quality standards without additional effort at 
local level (and in many of these instances would not be able to meet these standards at all with 
technical feasible reductions only). The net benefits amount to more than 38 billion EUR, i.e. 5% 
more than policy option I-2. 

As regards impacts on the environment, notably on the share of ecosystem areas exceeding critical 
loads for eutrophication from deposition of nitrogen, closer alignment would, without prejudice of 
further co-benefits a sound implementation of the Biodiversity Strategy and of the planned Nature 
Restoration Law may render, all three options reduce the share of ecosystem areas suffering from 
critically  high  loads  of  nitrogen.  When  it  comes  to  social  impacts,  sensitive  population  groups 
(including  children,  pregnant  women,  elderly  citizens  and  those  suffering  from  pre-existing 
conditions) are the most affected by air pollution today. Therefore, they will in  most instances 
benefit the most from reduced air pollution impacts on their health. Net gross domestic product 

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(GDP)  gains  by  2030  are  expected  for  all  policy  options,  in  the  range  of  0.26 %  to  0.44 %. 
Improving air quality is also expected to bring economic gains related to reduction of negative air 
pollution impacts such as healthcare expenditures, crop yield losses, absence from work due to 
illness (including of dependent children) and lower productivity at work.  

The total administrative burden ranges from EUR 76 to 106 million. All these are costs borne by 
public authorities since the Ambient Air Quality Directives do not impose direct administrative 
costs on consumers and businesses. However, these sectors do bear important adjustment costs, 
notably  due  to  measures  needed  to  achieve  EU  air  quality  standards.  Annual  adjustment  (or 
mitigation) costs have been estimated to be substantial in absolute terms: EUR 7.0 billion for full 
alignment (I-1), EUR 5.6 billion for closer alignment (I-2), EUR 3.3 billion for partial alignment 
(I-3) for the year 2030. Costs are expected to be higher (relatively speaking) for those Member 
States that either see persistent air pollution challenges today, or where specific measures would 
be required. In particular, for the residential heating sector additional costs would occur as well as, 
to a lesser degree, for the industry and agriculture sectors. Still, for all options considered, overall 
net benefits of the initiative outweigh costs considerably (between 29 and 38 billion EUR). 

For all three policy options (i.e. independent of the political choice made) there is a clear case for 
embracing  a  staged  approach  towards  setting  current  and  future  EU  air  quality  standards:  (1) 
establish clear EU air quality standards for the mid-term, i.e. the year 2030 (with a limited number 
of temporary exceptions where these are clearly warranted); (2) develop a long-term, post-2030 
perspective for  a full  alignment with  the 2021  WHO Air Quality  Guidelines, whilst  getting  on 
track towards alignment also with future WHO Guidelines to achieve the zero pollution vision by 
the year 2050; (3) a regular review mechanism to assure that the latest scientific understanding of 
air quality guides future decisions, and retains flexibility elements  given potential (future) geo-
political challenges. 

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