REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the 8th Environment Action Programme Mid-Term Review
Date: 2024-03-13
Institutions: Directorate-General for Environment, European Commission
Subjects: EU environmental policy, EU programme, biodiversity, carbon neutrality, circular economy, environmental impact, environmental protection, green economy, greenhouse gas, pollution control measures, sustainable development

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 13.3.2024  COM(2024) 123 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS on the 8th Environment Action Programme Mid-Term Review  {SWD(2024) 60 final}  
 
 
1. 

INTRODUCTION .......................................................................................................................... 2 

2.  PROGRESS TOWARDS PRIORITY OBJECTIVES .................................................................... 3 

2.1 

2.2 

2.3 

2.4 

2.5 

2.6 

Swift and predictable reduction of greenhouse gas emissions and enhancement of natural 
carbon sinks ............................................................................................................................ 3 

Strengthening and mainstreaming climate adaptation, including ecosystem approaches ....... 6 

A clean circular economy ....................................................................................................... 7 

Zero pollution for a toxic-free environment.......................................................................... 10 

Protecting, maintaining and restoring biodiversity ............................................................... 12 

Reducing environmental and climate pressure from production and consumption .............. 14 

3.  PROGRESS ON SELECTED ENABLING CONDITIONS ........................................................ 16 

3.1 

3.2 

3.3 

3.4 

3.5 

3.6 

3.7 

3.8 

Implementation, enforcement and environmental rule of law .............................................. 17 

Financing the transition ......................................................................................................... 17 

Governance for integrated policymaking .............................................................................. 19 

Sustainable business models for a resilient economy ........................................................... 19 

Just transition and environmental fairness ............................................................................ 20 

The link between the environment and health ...................................................................... 21 

Digitalisation ......................................................................................................................... 22 

Global uptake ........................................................................................................................ 22 

4.  MEASURING PROGRESS .......................................................................................................... 23 

5.  CONCLUSIONS ........................................................................................................................... 24 

1 

 
 
 
 
 
 
1.  INTRODUCTION 

The  European  Green  Deal  recognises  the  severity  of  the  generational  challenge  of  climate 
change and environmental degradation, which scientists and increasingly economists warn may 
hit the point of no return1. It has set the EU on a path to become the world’s first ‘climate-
neutral  continent  by  2050,  which  is  resource-efficient  and  leaves  no  person  and  no  space 
behind’2. It sets out a transformative agenda for the EU to become a modern and competitive 
economy that is resilient to external shocks and that enables people to live a fair and prosperous 
life in a healthy environment. 

Building on the Green Deal, the 8th environment action programme3 establishes a framework 
for action on environment and climate policy until 2030 with six thematic priority objectives 
for 2030 and a long-term 2050 priority objective of living well, within planetary boundaries. It 
identifies the enabling conditions for all sectors to meet these objectives in a coherent manner. 
The  implementation  of  this  programme  is  fundamental  to  achieving  the  environmental  and 
climate objectives under the UN 2030 Agenda, its sustainable development goals (SDGs) and 
multilateral environmental and climate agreements. 

In line with Article 5(1) of the 8th environment action programme, this report presents a mid-
term review4 of progress in meeting the programme’s thematic priority objectives. It looks at 
the status of the enabling conditions, and the progress made to monitor and assess systemic 
change. It is accompanied by a staff working document  providing deeper insights into each 
priority objective, the enabling framework and monitoring, as well as the programme’s vision 
for 2050. 

This mid-term review draws on the European Environmental Agency (EEA)’s monitoring 
report  on  progress  towards  the  objectives  of  the  programme5,  which  is  based  on  the  8th 
environment action programme monitoring framework6. It also considers the discussions with 
Member  State  experts  and  stakeholders,  the  feedback  received  in  response  to  the  call  for 
evidence7 and other related findings. 

Overall, the ambitious measures taken by the EU have led to progress, in particular in reducing 
greenhouse  gas  emissions,  improving  air  quality  and  mobilising  financing  for  the  green 
transition. Achieving the 2030 objectives is  within reach if the Member  States meet their 
commitments to implement policies and laws.  

However,  additional  efforts  are  needed  to  shift  towards  sustainable  production  and 
consumption. This would require, among other things, exploring with the relevant stakeholders 
suitable alternatives across key economic sectors, which could ensure, at the same time, EU 

1  https://www3.weforum.org/docs/WEF_The_Global_Risks_Report_2024.pdf.  The  2024  Global  Risk  Report 
from the World Economic Forum points to climate change and environmental degradation risks as the top short 
and long-term risks. 
2 COM(2019) 640 final. 
3 Decision (EU) 2022/591. 
4 Article 4 of Decision (EU) 2022/591. 
5 https://www.eea.europa.eu/publications/european-union-8th-environment-action-programme. 
6 COM(2022) 357 final. 
7 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14080-8th-Environment-Action-
Programme-Mid-term-Review_en. 

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competitiveness.  The  EU  consumption  leads  to  impacts  which  are  still  crossing  certain 
planetary boundaries.  In addition, while considerable achievements have been realised over 
the last few years, including major uptake of renewable energy and less dependency on fossil 
fuels,  EU  could  further  reduce  the  use  of  raw  materials  and  fossil  resources.  This  would 
contribute to the reduction of levels of air, water and soil pollution, biodiversity loss, and, in 
so doing, would alleviate the pressure on ecosystems and on the value chains.  

It is therefore crucial to adopt and fully implement the ambitious actions taken under the 
European Green Deal as reflected in the 8th environment action programme to achieve 
real impacts on the ground and the long-term resilience of the EU economy and society. 

2.  PROGRESS TOWARDS PRIORITY OBJECTIVES 

2.1 Swift and predictable reduction of greenhouse gas emissions and enhancement of 

natural carbon sinks 

Climate  change  is  accelerating  and  it  is  having  aggravating  impacts  on  people,  nature  and 
economies, both in the EU and across the world. 

The EU has made good progress towards the target of reducing net GHG emissions. But 
it needs to do more to reach the target for net GHG removals by carbon sinks from the 
land  use,  land  use  change  and  forestry  (LULUCF)  sector.  Trends  from  this  sector  are 
negative in the EU, which is losing carbon sinks, with some Member States' land-use sector 
producing emissions instead of removals. 

Overall,  2022  data  show  that  the  EU’s  domestic  greenhouse  net  emissions  (excluding 
international  aviation)  are  falling  steadily,  down  by  32.5%  (compared  to  1990)  in  20228. 
However, to meet the EU’s 2030 greenhouse gas reduction target (at least –55% compared to 
1990)  and  to  achieve  climate  neutrality  by  2050,  the  pace  of  emission  reduction  needs  to 
accelerate to reach almost triple the average annual reduction rate achieved over the last 
decade. Relative to past mitigation efforts, the most significant cuts in emissions are needed in 
buildings and transport, where the pace of decarbonisation is sluggish or even moving in the 
opposite direction. 

To  reach  the  target  for  net  GHG  removals  by  carbon  sinks  from  the  LULUCF,  a 
significant boost of carbon removals is essential. 

The EU set itself a legally binding objective to achieve economy-wide climate neutrality and 
resilience by 2050 in the European Climate Law9, which it adopted in 2021. The European 
Climate Law also sets an interim target of a domestic reduction in net greenhouse gas emissions 
(emissions after deducting removals) of at least 55% by 2030 compared to 1990 levels. 

The ‘Fit for 55’ package10 of measures sets the EU on a path to reach its climate targets in a 
fair, cost-effective and competitive way. The EU has adopted most of the key proposals in the 

8 COM(2023) 653 final. 
9 Regulation (EU) 2021/1119. 
10 COM(2021) 550 final. 

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package11 which, if fully implemented, will ensure that the EU meets its updated 2030 net GHG 
target.  The  revised  EU  Emission  Trading  System  is  now  more  ambitious  and  will  cut 
emissions  by  62%  in  2030  compared  to  2005  levels  and  is  extended  to  cover  international 
maritime  transport.  A  new,  separate  emissions  trading  system  will  apply  to  greenhouse  gas 
emissions  from  fuel  combustion  in  road  transport  and  buildings  and  small-emitting  sectors 
(ETS2)12 with a 42% emission reduction in 2030 compared to 2005.  

The EU decided to raise the overall emissions reduction target set under the Effort Sharing 
Regulation (ESR)13, which covers GHG emissions from domestic transport (excluding CO2 
from  aviation), buildings, agriculture, small  industry and waste, from  29% to  40% by 2030 
compared to 2005, with revised 2030 targets for each Member State. 

The new Regulation on LULUCF14 sets an overall EU-level objective to achieve 310 Mt CO2 
equivalent of land-based net removals in 2030. 

In 2022 and 2023, the Commission made additional proposals to speed up the fair and inclusive 
transition to climate neutrality. For example, Parliament and Council reached agreement on the 
revised  Fluorinated  greenhouse  gases  (F-gases)  Regulation,15  which  will  further  reduce 
emissions  from  those  highly  potent  greenhouse  gases.  The  Commission  proposed  more 
ambitious  emissions  reductions  targets  for  heavy-duty  vehicles16.  It  also  put  forward  the 
REPowerEU plan17 with specific measures to reduce the EU’s energy dependence on Russian 
fossil fuels, and to speed up implementation of the European Green Deal with new actions, 
building  on  the  ‘Fit  for  55’  package.  To  enhance  the  EU’s  open  strategic  autonomy  and 
competitiveness and boost innovation, in particular in green technologies, and ensure a smooth 
climate transition,  the Commission  put forward  a Green  Deal  industrial  plan. The  Net-Zero 
Industry Act and the Critical Raw Materials Act18 are the main pieces of legislation to achieve 
these objectives. 

Carbon removals will be needed for the EU to reach climate neutrality in 2050 and move to 
negative emissions thereafter, in  order to  minimise the EU’s cumulative  GHG  budget19. To 
ensure  high-quality  EU-certified  carbon  removals,  the  Commission  proposed  a  regulatory 
framework for the certification of carbon removals20. The aim is to establish a transparent 
and  credible  governance  framework,  including  for  the  development  of  certification 

11 This includes the revised EU ETS Directive, a new ETS for buildings, road transport and fuels, the Market 
Stability Reserve, the Effort Sharing Regulation, CO₂ standards for cars and vans, the Land Use, Land Use Change 
and  Forestry  Regulation,  the  Carbon  Border  Adjustment  Mechanism,  the  establishment  of  the  Social  Climate 
Fund, FuelEU Maritime, the Alternative Fuel Infrastructure Regulation (AFIR), ReFuel EU Aviation, the Energy 
Efficiency Directive and the Renewable Energy Directive. Only the proposed revised energy taxation directive is 
still pending agreement. 
12 Directive (EU) 2023/959 amending Directive 2003/87/EC. 
13 Regulation (EU) 2023/857. 
14 Regulation (EU) 2023/839. 
15 COM/2022/150 final. 
16 COM(2023) 88 final. 
17 COM(2022) 230 final. 
18 For more information, see the 2023 Climate Action Progress Report. 
19 ESABCC (2023), Scientific advice for the determination of an EU-wide 2040 climate target and a greenhouse 
gas budget for 2030-2050, DOI: 10.2800/609405. 
20 COM(2022) 672 final. 

4 

 
 
 
methodologies, encouraging further investments in carbon removal activities and increasing 
their deployment. The Commission issued a communication on industrial carbon management 
in  February  2024  to  support  EU  action  to  reach  climate  neutrality  by  2050  and  negative 
emissions thereafter. 

With  the  biodiversity,  soil  and  forest  strategies,  the  EU  set  ambitious  targets  to  protect 
ecosystems,  especially  carbon-rich  ecosystems.  The  Nature  Restoration  Law21  will  help 
restore  degraded  ecosystems,  in  particular  those  with  a  high  potential  to  capture  and 
store carbon, such as forests, peatlands and wetlands. The EU's commitment to plant at least 
3 billion additional trees by 2030 will also support climate mitigation action. By ensuring that 
EU’s  consumption  and  production  do  not  contribute  to  deforestation,  the  Regulation  on 
deforestation-free products22 is another important tool in the fight against climate change and 
halt biodiversity loss. 

Full implementation of the ‘Fit for 55’ package and mobilising adequate investments (see 
Section  3.2)  are  key.  For  some  Member  States,  progress  is  not  consistent  with  the  level  of 
action required to meet the long-term climate targets. 

Based on the information provided in the draft updated national energy and climate plans 
(NECPs), by 2030, net GHG emissions in 2030 are estimated to be 51% lower than in 199023, 
4 percentage points short of the 55% target set in the Climate Law. This estimate uses the cap 
imposed on the contribution of the LULUCF sector to the Fit-for-55 objective, set at 225 Mt 
CO2-eq. Adding the contribution of the LULUCF sector above this cap would lead to a total 
reduction of emissions of 51.7%. The trajectory identified in the draft updated NECPs forecasts 
the EU to fall short of reaching  climate neutrality in 205024. Although emissions in the EU 
have fallen by 32.5%25 since 1990, the analysis of projected  emissions in  the draft updated 
NECPs highlights the need to step up the pace.  The draft updated NECPs bring us closer to 
meeting  the  EU's  2030  targets,  however  there  is  a  clear  need  for  extra  efforts  to  speed  up 
implementation of the agreed Fit for 55 legislation. Member States are now in the process of 
updating their plans by June 2024 and are considering how to enhance policies and investments 
to deliver on the 2030 target of net GHG emission reductions of at least 55%. 

In February 2024, as called for under the European Climate Law, the Commission published a 
communication  and  detailed  impact  assessment  on  the  EU’s  climate  target  for  2040,  to 
establish the path from the agreed, intermediate 2030 target  to net-zero emissions by 2050. 
The 2040 target will provide predictability for decision-makers and investors to keep the EU 
on track to climate neutrality and support the implementation of the 2030 targets. It will also 
send a strong signal to the EU’s partners around the world on the need to step up global climate 
action.  

21 COM(2022) 304 final. 
22 Regulation (EU) 2023/1115. 
23 Net total GHG emissions, including the LULUCF sector and excluding international transport. 
24 The 2023 climate action progress report estimates that EU Member States still need to take additional mitigation 
measures  to  achieve  climate  neutrality  by  2050  to  cut  around  1 600  million  tonnes  of  CO2  equivalent  (or  34 
percentage points). Data provided in the NECPs is in line with this finding. 
25 Climate Action Progress Report 2023, COM(2023) 653 final. 

5 

 
 
 
The  Commission  communication  launches  a  dialogue  with  stakeholders  on  the  pathway  to 
2040. A legislative proposal to amend the European Climate Law to include this target, as well 
as the post-2030 policy framework, will be in the hands of the next Commission. The agreed 
target will be the basis for the EU’s new nationally determined contribution, which all parties 
to the Paris Agreement must submit in 2025. 

2.2 Strengthening  and  mainstreaming  climate  adaptation,  including  ecosystem 

approaches 

The latest Intergovernmental Panel on Climate Change assessment reports project that weather- 
and climate-related extreme events such as floods, droughts and heatwaves will become more 
frequent and severe. This will happen even in the best-case scenario of a rapid and steep global 
cut in greenhouse gas emissions to meet the Paris Agreement goals. 

The effects of climate change  on ecosystems,  socio-economic sectors and people’s health 
and well-being are already being felt.  

Weather-  and  climate-related  events  in  Europe  have  caused  a  high  number  of  human 
fatalities, estimated between 85 000 and 145 000 between 1980 and 202026, mostly due to 
heatwaves. In 2022, heatwaves were estimated to have caused over 60 000 excess deaths, a 
figure that was only superseded by the heatwaves of 2003, which caused 70 00027. All regions 
and socio-economic categories are affected by the effects  of climate change, but not in the 
same way, vulnerable households being disproportionately exposed to the above threats. 

Economic  losses  due  to  weather  and  climate-related  extremes  are  increasing,  reaching 
EUR 52.3 billion in 2022, with floods having the highest impacts (40%).  

The extent of drought-impacted areas has increased in the EU between 2000 and 202228. 
The area where vegetation productivity suffered increased five-fold in 2022 compared to the 
average over this period. For example, over 50% of vegetated area was affected by drought in 
Belgium, Luxembourg and Slovenia that year, against the long-term average of less than 10%. 
At  the  other  extreme,  Ireland  saw  no  detectable  impact  at  all.  Drought  stress  hampers 
ecosystems’ ability to store carbon, manage the impact of subsequent floods, to contribute to 
food  production  and  provide  a  wide  range  of  other  benefits.  Heatwaves  are  projected  to 
increase  in  the  future  and  continental  and  Mediterranean  regions  are  expected  to  see  less 
summer  rainfall.  This  makes  it  increasingly  urgent  to  build  resilience  through  land 
management practices. 

The EU's 2021 strategy on adaptation to climate change29 sets out the vision to achieve a 
climate-resilient EU by 2050, fully prepared to  manage the unavoidable and already visible 
impacts of climate change. 

26 Depending on the data sources (NatCatSERVICE and CATDAT). See 
https://www.eea.europa.eu/publications/economic-losses-and-fatalities-from. 
27 Heat-related mortality in Europe during the summer of 2022 | Nature Medicine 
28 EEA, 04-Drought impact on ecosystems in Europe-indicator — European Environment Agency (europa.eu) 
29 COM(2021) 82 final. 

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The EU Climate Law sets an obligation for the EU and its Member States to make continuous 
progress  on  reducing  vulnerability  to  climate  impacts,  increasing  resilience  and  building 
adaptive  capacity.  The  Commission  issued  an  assessment  under  the  EU  Climate  Law  in 
December  2023.  Almost  all  EU  Member  States  have  conducted  climate  risk  assessments, 
although only a few provide robust comprehensive climate risk assessments across more than 
five  sectors.  Health,  agriculture,  forestry,  biodiversity,  energy  and  water  management  are 
reported to be the policy areas/sectors most affected by climate threats in Europe. All Member 
States have national adaptation strategies and/or plans in place. The Commission has issued 
a new set of guidelines to assist Member States in updating and implementing them. 

Eight  Member  States  have  embedded  elements  of  their  adaptation  policy  in  their  domestic 
legal frameworks. Monitoring, reporting and evaluation mechanisms are  lacking in several 
Member States. Nature-based solutions are included only to a limited extent at strategic level 
and through the policy documents, especially in sectoral strategies and plans. Assessing the 
costs of adaptation remains a challenge for many Member States and their plans and strategies 
often lack dedicated budgets or financing streams to implement the plans. 

In parallel, wide-ranging action is underway to implement the EU’s 2021 adaptation strategy. 
Policy coherence has improved by work to mainstream adaptation into other EU policies, 
for example health  policies. More  broadly,  progress  has been made in  raising awareness  of 
climate impacts and of the need to prepare for them30. 

In March 2024, the Commission issued a communication on managing EU climate risks, 
following evidence provided in a scientific European Climate Risk Assessment report and other 
sources. The communication put forward areas of action where a step-change is needed in order 
to effectively protect citizens and our economies. It also highlighted the European added value 
of supporting action at national and private levels of competence and risk ownership. 

2.3 A clean circular economy 

Circular economy has the potential to reduce carbon emissions, pressure on natural resources 
and biodiversity, and reduce pollution. It can help Europe boost resource productivity by up to 
3% annually and reach the 2050 goal of climate neutrality. Circular economic models can also 
drive the long-term competitiveness of the EU economy, increase its resilience and safeguard 
security of supply31. 

The EU now has a sound legislative framework to accelerate the shift to a circular economy. 
However,  legislation  takes  time  to  take  effect.  Concerted  action  is  needed  to  roll  out  this 
framework  to  tackle  the  negative  environmental  impacts  of  material  consumption  and 
unsustainable trends in waste generation observed over the last decade in the EU. Stepping up 
action  at  all  levels  and  in  all  sectors  will  be  essential  to  decouple  growth  from  the  use  of 

30 See, for example, the European Drought Risk Atlas and the European Drought Impact Database, the Floods 
viewer  and 
review  2023,  at: 
the  Sendai 
https://data.europa.eu/doi/10.2795/151300. 
31 Growth Within: A Circular Economy Vision for a Competitive Europe; McKinsey Centre for Business and 
Environment & Ellen Macarthur Foundation; June 2015. According to the Long-term competitiveness of the EU: 
looking beyond 2030, COM(2023) 168 final. 

reduction  –  Midterm 

for  disaster 

framework 

risk 

7 

 
 
 
 
natural resources, ensure a sustainable use of materials and boost resilience and the security 
of supply. 

The EU’s material footprint was 14.8 tonnes per capita in 2022, a 6% increase over the last 
decade. Most materials  are non-metallic minerals,  driven by  construction activities, which 
saw the highest increase in material use (+22%)32. 

Total EU waste generation by all economic activities and households fell by almost 3% over 
the last decade to reach 4.8 tonnes per capita in 2020, showing a slight decoupling from GDP. 
However, waste from packaging, in particular plastic packaging, has increased by more than 
20%  in  the  last  decade  in  the  EU  to  reach  36  kg  of  plastic  packaging  waste  per  person  in 
202133. More waste is recycled and recovered in the EU, but only a limited volume of materials 
(around 11.5%) re-enter the economy as recycled materials in 202234. 

Thanks to an increase in resource productivity of about 35% since 200035, EU greenhouse 
gas  emissions  from  production  fell  by  around  25%  from  2008-2021,  showing  that  the 
transition to a circular economy plays an important role in the path to climate neutrality36. 

The 2020 circular economy action plan37 aims to decouple economic growth from resource 
use,  reduce  our  consumption  footprint,  double  the  circular  material  use  rate,  significantly 
reduce overall volumes of waste and halve the volume of residual (non-recycled) municipal 
waste. 

The Commission has put forward all 35 measures announced in the action plan. A ground-
breaking  product  policy  initiative  building  on  the  lifecycle  approach  of  the  Ecodesign 
Directive, the Ecodesign for Sustainable Products Regulation38, expands the framework for 
setting performance and information requirements, including a digital product passport for a 
wide range of products. It will be essential to implement this Regulation over the coming years 
to  ensure  that  circular  and  sustainable  products  become  the  norm.  The  Empowering 
Consumers Directive39 and the proposal for a green claims directive40 will help consumer 
choice  by  enabling  consumers  to  identify  sustainable  products  for  purchase  without  being 
misled. 

New  initiatives  have  also  been  launched  to  tackle  environmental  concerns  linked  to  the 
production  and  consumption  of  textiles,  guided  by  the  EU  strategy  for  sustainable  and 
circular  textiles.  The  new  Batteries  Regulation41  and  the  proposals  for  a  Regulation  on 

32 Eurostat dataset (cei_pc020) 
33 Eurostat dataset (cei_pc050) 
34 Eurostat dataset (cei_srm030) 
35 Eurostat dataset (cei_pc030) 
36 Eurostat dataset (cei_gsr011) 
37 COM(2020) 98 final. 
38 COM(2022) 142 final. 
39 COM(2022) 143 final. 
40 COM(2023) 166 final. 
41 Regulation (EU) 2023/1542. 

8 

 
 
 
packaging  and  packaging  waste42  and  on  the  design  and  end-of-life  management  of 
vehicles43 are other game-changing initiatives. 

The  Commission  has  revised  key  pieces  of  legislation  on  waste,  including  the  Waste 
Shipments Regulation44 and an update of limits for Persistent Organic Pollutants in waste45. 
The Commission has also proposed a targeted revision of the Waste Framework Directive to 
tackle  food  and  textile  waste46,  with  a  particular  emphasis  on  preventing  waste  and  on 
extending the scope of extended producer responsibility. 

The  Commission  launched  initiatives  to  reduce  plastics  pollution,  including  measures  to 
prevent  the  release  of  microplastics47  into  the  environment,  notably  a  proposal  to  tackle 
pollution from pellet loss and a restriction on intentionally added microplastics. It also put 
forward a new policy framework for biobased, biodegradable and compostable plastic48 and 
made  progress  on  implementing  measures  to  reduce  single  use  plastics.  Internationally, 
negotiations on a new global treaty on plastic pollution are ongoing. 

Circularity principles are mainstreamed across EU policies such as the European social action 
plan, the Renovation Wave, research and innovation. Circularity is also a cornerstone of the 
Critical Raw Materials Act49, contributing to the European Green Deal industrial plan. It is also 
at the core of sector-specific transition pathways to decarbonise European industry, and a key 
driver to achieve the objectives of other priority objectives under the 8th environment action 
programme. 

Policy makers, businesses, public authorities and members of the public  have engaged 
with initiatives on the circular economy over the last 10 years, via the European Circular 
Economy Stakeholders’ Platform. So far, 23 Member States have adopted circular economy 
strategies, action plans or roadmaps. 

The  EU  launched  and  supported  the  Global  Alliance  on  Circular  Economy  and  Resource 
Efficiency to accelerate the global transition. 

Actions such as more efficient resource use in production, extending the lifetime of products, 
or  substituting  primary  raw  materials  with  less  carbon-intensive  recyclates  are  estimated  to 
potentially contribute with 20-25% to the EU's climate goals by 2050. Action is also ongoing 
to explore the synergies between the circular economy and a sustainable bioeconomy. 

Optimising material use significantly reduces dependency on imported materials. In the EU, 
around  23%  of  materials  are  imported50,  mostly  fossil-energy  materials,  including  plastics 

42 COM(2022) 677 final. 
43 COM(2023) 451 final. 
44 COM(2021)709 final 
45 Regulation (EU) 2022/2400 on Persistent Organic Pollutants 
46 COM(2023) 420 final. 
47 COM(2023) 645 final and Commission act C(2023) 6419. 
48 COM(2022) 682 final. 
49 COM(2023) 160. 
50 Eurostat dataset (cei_gsr030) 

9 

 
 
 
(71% of imports), and critical raw materials (like cobalt and silicon) needed for the green and 
digital transition51. 

Financing the green transition requires strong partnerships with Member States and businesses, 
driven by EU benchmarks and well-targeted investments, with the EU Taxonomy an essential 
reference  point  to  mobilise  and  guide  sustainable  finance.  Further  use  of  market-based 
instruments  and  green  public  procurement  at  EU  and  national  levels  could  help  make 
sustainable products the norm. 

A globally shared understanding and agenda on circular economy is gradually emerging. 
As a multilateral mechanism would speed up the global transition, the EU will continue to 
support the UN Sustainable Consumption and Production holistic approach. 

2.4 Zero pollution for a toxic-free environment 

Pollution  is  among  the  main  causes  of  mental  and  physical  diseases  and  it  also  leads  to 
premature deaths. Pollution threatens people’s well-being wellbeing and health and generates 
economic costs to society. It is also one of the five main drivers of biodiversity loss, reducing 
the ability of ecosystems to provide services such as carbon sequestration and decontamination. 

The grounds have been laid to reach the 2030 targets of zero pollution, but achieving the 
objectives  requires  steady  progress  in  a  wide  range  of  areas,  from  air  pollution,  where 
progress is encouraging, to water, marine and soil pollution, where further action is needed. 
The latest projections by the EEA52 indicate that the EU is on track to reach its 2030 target 
to reduce premature deaths due to fine particulate matters by 55%, but not the 2030 target 
to reduce transport noise exposure by 30%. It will be very challenging to meet the target to 
reduce nutrient losses into groundwater by at least 50%. Plastic litter at sea also remains a 
major, multi-faceted problem. 

In 2021, 253 000 premature deaths in the EU were attributable to fine particulate matter, a 
41% drop since 200553. Over the period 2016-201954, 14.1% of groundwater stations in the 
EU were polluted by nitrates, with annual average concentration exceeding the threshold of 
50mg NO/l, almost one percentage point more than the previous period.  

Around two thirds of agricultural soils in the EU area are affected by erosion, loss of organic 
carbon,  nutrient  (nitrogen)  balance  exceedances,  compaction  or  secondary  salinisation55. 
Overall, while the sales of pesticides are not decreasing, the risk associated with their use is 

51 Eurostat dataset (cei_gsr020) 
52 EEA 07-Premature deaths due to exposure to fine particulate matter in Europe-indicator — European 
Environment Agency (europa.eu) and COM(2022) 674. 
53 EEA: 07-Premature deaths due to exposure to fine particulate matter in Europe-indicator — European 
Environment Agency (europa.eu) 
54 COM(2021) 1000 final.  
55 COM(2023)416 final. 

10 

 
 
 
 
decreasing and the sales of the more hazardous pesticides (candidates for substitution) are 
reducing over time56. 

The goal to reach zero pollution for a non-toxic environment has moved from tackling point 
sources of pollution to a systemic approach on environmental pressure, with clear links to 
industry and other sectors of the economy.  

For the first time, the EU has an integrated and comprehensive zero pollution action plan57 
to reduce pollution in air, water and soil to levels that are no longer harmful to health and 
natural ecosystems. 

By now, most of the flagship initiatives and actions (over 75%) announced in the zero pollution 
action plan have been  completed or are at an advanced stage of implementation58. EU laws 
were  revised  to  raise  the  ambition  by  extending  their  scope  to  cover  more  polluting 
activities, such as the revised legislation governing industrial emissions59 and urban waste 
water treatment60, or to adapt EU rules on air quality61 and water pollutants62 to the levels 
prescribed by science. For the first time ever, soils 63 will have a similar level of protection as 
other ecosystems, through the Commission proposal for a soil monitoring law. 

Complementing  the  zero  pollution  action  plan,  the  chemicals  strategy  for  sustainability64 
establishes a clear hierarchy that states that preventing pollution should always be the priority. 
To  this  end,  a  recommendation  was  adopted  to  make  chemicals  safe  and  sustainable  by 
design,  and  the  revised  Classification  Labelling  and  Packaging  Regulation65  will  make 
labelling of hazardous chemicals clearer, including for online sales. The Commission proposed 
to  simplify  the  processes  for  dealing  with  chemicals  to  implement  the  one-substance-one-
assessment commitment made under the Green Deal66. It also proposed revising the Mercury 
Regulation67 to  further restrict the remaining  uses of mercury in  the EU: in February 2023 
Council and European Parliament reached a provisional political agreement68. 

Policy coherence has improved by including action to prevent and reduce pollution in other 
Green Deal strategies and improving the enabling framework. The latest additions to the EU 
Taxonomy, applicable since the beginning of 2024, include activities for pollution prevention, 
control and reduction through sustainable water investments, along with other activities for the 
environmental  objectives  of  the  Taxonomy  Regulation69.  The  EU  financing  instruments 

56  Source: Statistics | Eurostat (europa.eu);  trends eu - European Commission (europa.eu) 
57 COM(2021) 400 final. 
58 Zero Pollution action tracker 
59 COM/2022/156 final/3. 
60 COM(2022) 541 final. 
61 COM/2022/542 final. 
62 COM(2022) 540. 
63 COM(2023) 416 final. 
64 COM(2020) 667 final. 
65 COM(2022) 748 final. 
66 This entailed three legislative proposals on chemicals data flows (COM(2023) 779), on reallocating work on 
chemicals across EU agencies (COM(2023) 783), and amending the Directive on the Restriction of Hazardous 
Substances in electric and electronic equipment (COM(2023) 781). 
67 COM(2023)  395 final. 
68 Press release 
69 Commission Delegated Regulation (EU) 2023/2486. 

11 

 
 
 
support  zero  pollution  actions  in  many  areas. The  climate  mainstreaming  under  the  EU's 
multiannual  budget  and  the  recovery  and  resilience  plans  helped  increasing  support  for 
measures to improve air quality. To improve the knowledge base, the Commission presented 
the first Zero Pollution Monitoring and Outlook Report and related research and innovation 
activities under Horizon Europe. 

Swift implementation of existing or proposed measures at local, national, cross-border and 
global  levels  is  key  to  achieving  the  2030  objectives.  The  zero-pollution  goal  can  only  be 
achieved in conjunction with the EU's goals to reach climate neutrality, to protect biodiversity 
and to transition to a clean, circular economy. Mainstreaming zero pollution into other policy 
areas is also important. Exposing the links between pollution, human health and inequalities 
are crucial to forge public support for policy responses to tackle the causes of pollution. It is 
essential to apply the polluter pays principle across other sector-specific policies for fair and 
effective  policies,  building  on  experience  with  measures  that  work  well,  such  as  the  recent 
change to include extended producer responsibility in the revised Urban Wastewater Treatment 
Directive70. 

Effective  implementation  of  laws  requires  further  integration  of  data  analytics  between 
environment and public health data, and integrated and geo-localised visualisation of pollution 
impacts71. These should be coupled with enabling action, notably investments and price signals, 
and action to promote skills, research, innovation and digitalisation focusing on zero-pollution 
solutions. The flagship initiatives in the zero pollution action plan, in particular those related 
to urban and regional policies, have already started to integrate data analytics and can be further 
developed. The Commission, together with the EEA, will work on better sharing and using the 
latest available data in the next Zero Pollution Monitoring and the Outlook Report, which is 
expected to be published by the end of 2024. 

2.5 Protecting, maintaining and restoring biodiversity 

The continuing loss of nature and biodiversity poses major risks to the ecosystem services that 
we  all  depend  on.  Nature  provides  food,  clean  water,  helps  prevent  floods,  purify  the  air, 
pollinate crops, store carbon dioxide and helps us adapt to a changing climate. 

The  first  EU  ecosystem  assessment72  revealed  that  Europe’s  ecosystems  suffer  from 
unrelenting  pressure  from  intensive  land  and  sea  use,  climate  change,  pollution, 
overexploitation  and  invasive  alien  species.  Some  progress  has  been  made  to  designate 
protected areas for land and marine areas. The level of forest connectivity has not increased, 
and populations of common birds continue to decline in the EU. Although populations of 
forest birds has increased, farmland bird populations continue to be in sharp decline. 

70 COM(2022) 541 final. 
71 Including Copernicus services. 
72 https://publications.jrc.ec.europa.eu/repository/handle/JRC123783 

12 

 
 
 
 
The  EU  biodiversity  strategy  for  203073  sets  ambitious  targets  for  2030  to  protect  and 
restore nature. It calls for action to tackle the five main drivers of biodiversity loss: changes 
in land and sea use, overexploitation, climate change, pollution and invasive alien species. 

The  nature  restoration  law  sets  targets  to  restore  degraded  ecosystems  and  reverse 
biodiversity  loss.  The  EU  has  adopted  strategies  on  soil  and  forests,  and  two  legislative 
proposals to boost the resilience of these key ecosystems are under negotiation74. Additional 
measures were launched to protect pollinators75. The Commission has taken action to reduce 
pollution pressures on biodiversity, notably in the framework of the EU chemicals strategy for 
sustainability  and  the  zero  pollution  action  plan,  with  new  initiatives  on  urban  waste  water 
treatment and industrial emissions76.  

Progress  has  also  been  made  in  mainstreaming  biodiversity  objectives  into  related  EU 
policies, notably in forestry and agriculture policy, through the climate adaptation strategy, 
the EU organic action plan77 and the farm to fork strategy, in fisheries policy through the 
marine action plan78 and in the energy sector (e.g. through environmental impact assessments 
for  energy  infrastructures  and  increased  renewable  energy  targets).  Mainstreaming  has  also 
improved on trade, international cooperation, consumption and production, pollution reduction 
(in particular nutrients) and health. 

Nature-based  solutions  are  increasingly  integrated  in  other  policies  and  deployed  on  the 
ground, such as carbon removal measures (see Section 2.1) and flood risk reduction. As climate 
change and air pollution are two of the main drivers of biodiversity loss, the replacement of 
energy  production  from  fossil  fuels  by  renewable  sources  can  contribute  to  biodiversity 
protection overall.  

Full  and  swift  implementation  of  the  EU  legal  framework  is  a  priority,  including  current 
legislation on  birds,  habitats,  invasive alien  species, water, the  Marine Strategy  Framework 
Directive  and  the  law  on  nature  restoration.  The  proposed  new  laws  on  soil  or  forests 
monitoring  will,  once  they  become  EU  law,  contribute  to  reversing  the  negative  trends. 
Adoption  and  effective  implementation  of  national,  cross-cutting  biodiversity  strategies  or 
action plans by all Member States is a crucial step towards meeting the biodiversity objectives. 

The recently launched strategic dialogue on the future of agriculture will feed into the reflection 
on  how  to  support  viable  livelihoods,  reducing  burdens  and  ensuring  competitive  and 
sustainable  food  production  in  the  future79.  Businesses  and  the  financial  sector  continue  to 
increasingly factor in the economy’s dependence and its impacts on nature and biodiversity, 
and the associated business and financial risks from biodiversity loss. The European Central 
Bank and national central banks now consider nature degradation and biodiversity loss-related 
risk  assessment  as  falling  squarely  under  their  mandate  since  most  companies  are  highly 

73 COM(2020) 380 final. 
74 COM(2023) 416 final and  COM(2023) 728 final. 
75 COM(2023) 35 final. 
76 COM(2022) 156 final/2 , COM(2022) 541 final. 
77 COM(2021) 141 final/2. 
78 COM(2023) 102 final. 
79 Strategic Dialogue on the future of EU agriculture - European Commission (europa.eu) 

13 

 
 
 
dependent  on  ecosystem  services80,  such  as  clean  water,  pollination  and  climate  regulation. 
Further advances in natural capital accounting should improve the process of integrating the 
multiple values that nature provides into policy and investment decisions. 

The EU's multiannual budget for 2021-27 includes for the first-time biodiversity financing 
targets (see Section 3.2). Estimates of national commitments indicate that the EU is well on 
track  to  reach  the  7.5%  biodiversity  financing  target  ser  for  2024.  However,  the  10% 
biodiversity  financing  target  set  for  2026  and  2027  might  be  missed.  More  investment  in 
nature is needed, both from public and private-sector sources, including incentives for nature-
positive impacts such as nature restoration, nature-based solutions and sustainable management 
practices in – inter alia - land, forestry, freshwater and marine ecosystems. 

At  international  level,  the  Kunming-Montreal  Global  Biodiversity  Framework  (GBF) 
brings in a comprehensive set of ambitious targets and actions to stem biodiversity loss. The 
Commission is preparing the submission of EU targets to implement the GBF, which will cover 
the commitments laid down in existing and proposed legislation and policies. The submission 
will also indicate the degree of alignment between EU and GBF targets.  

The Commission’s assessment of the degree of EU alignment with the Global Biodiversity 
Framework indicates that current policy initiatives and recently proposed legislation (pending 
their adoption) cover most of the targets. Work is also ongoing to finalise a robust monitoring 
framework to track progress on all targets, improve existing dataflows and develop models and 
scenarios to underpin the work to develop policy options and measures for after 2030. 

The EU’s international ocean governance agenda embodies the commitment to an ambitious 
set  of  marine  biodiversity  targets.  The  successful  conclusion  of  the  agreement  on  the 
conservation and sustainable use of marine biological diversity of areas beyond national 
jurisdiction is a major accomplishment for the depollution of the high seas and the restoration 
of marine life in the global ocean. The Commission pledged to double international financing 
for biodiversity as a contribution towards the target of USD 20 billion by 2025. The target of 
USD 30 billion by 2030 will require more resources and efforts, also at global level. 

2.6  Reducing environmental and climate pressure from production and consumption 

The EU has embarked on a deep transformation of its consumption and production patterns, 
building a climate-neutral and resource-efficient  circular economy that is resilient to supply 
shocks, thereby strengthening the EU competitiveness and strategic autonomy.  

The EU’s consumption footprint has transgressed the planetary boundaries and went up by 
4% between 2010 and 2021. This is driven mostly by current consumption patterns in the areas 
of food, housing and transport81. Water scarcity82 affects almost one third of areas in the 

80  The Network for Greening the Financial System (NGFS)  acknowledges that nature-related risks could have 
significant macroeconomic and financial implications;  COM(2023) 376 final. 
81 https://eplca.jrc.ec.europa.eu/ConsumptionFootprintPlatform.html  
82 Source: EEA, https://www.eea.europa.eu/publications/european-union-8th-environment-action-
programme/indicators/24-water-scarcity-conditions-in/view 

14 

 
 
 
 
EU and is one of the most dangerous threats to society. The pressure on land take83 has not 
abated. 

Energy consumption has fallen thanks to energy efficiency84, and renewable energy sources 
have  more  than  doubled  over  the  last  17  years85.  Industry  has  slightly  increased  the  use  of 
secondary  materials  and  slightly  reduced  GHG  emissions.  Agriculture  is  slowly  shifting 
towards  organic  farming,  but  the  sector  still  emits  significant  volumes  of  GHG  and  air 
pollutant emissions. EU sales of antimicrobials for farmed animals have fallen but the volume 
of food waste is not falling. In transport, the share of public transport (buses and trains) fell 
in 2020 due to the COVID-19 pandemic but is now recovering and the share of zero-emissions 
vehicles has increased considerably over the last 5 years. 

The EU now has integrated strategies for key production systems to boost systemic change: 
the Energy Union, the Green Deal industrial plan, the smart and sustainable mobility strategy, 
the renovation wave, the bioeconomy strategy and the farm to fork strategy (see accompanying 
staff working document for details). The EU's long-term competitiveness strategy86 underlines 
that we are at  a make-or-break point to succeed in the twin green and digital transition and 
remain an attractive place for business. 

The EU's climate and environmental strategies, such as the action plans on zero pollution and 
circular economy, include measures in key sectors to reach the targets. So does the ‘Fit for 
55’ package, which also tackles land-use change. The EU initiatives on nature restoration and 
soil include ambitious measures to reverse land take and improve the capacity of the land to 
carry out valuable ecological functions (e.g. storing carbon and protecting land from flooding, 
flood prevention, pollination). The EU Taxonomy provides the incentives to allocate private 
capital  to  the  achievement  of  these  objectives.  The  European  Semester  further  provides 
guidance on the reforms and investments that Member States should undertake to deliver on 
the EU’s environmental sustainability goals. 

Water is a vital resource that is already under pressure in many parts of Europe due to 
structural  mismanagement,  unsustainable  land  use,  hydro-morphological  changes,  and 
pollution. Climate change is exacerbating these pressures and increasing water-related risks in 
the form of prolonged or more frequent droughts or extreme precipitation as highlighted in the 
Communication on Climate Risks. Protecting and restoring the water cycle, promoting a water-
smart EU economy and safeguarding access to clean freshwater to all is crucial to ensure we 
have a water-resilient Europe. 

Fully applying circular economy approaches to additional industrial sectors, in particular 
steel, cement, plastics and aluminium, could reduce global greenhouse gas emissions from key 
industry  materials  by  40%  by  2050,  according  to  estimates.  It  is  particularly  important  to 
increase  carbon  removals,  including  natural  carbon  sinks,  in  these  hard-to-abate  sectors  to 
reach climate neutrality. The EU ETS Innovation Fund and update of the Industrial Emissions 

83 Source: EEA, https://www.eea.europa.eu/publications/european-union-8th-environment-action-
programme/indicators/23-land-take-net-land/view  
84 Including Council Regulation (EU) 2022/1369 on coordinated demand reduction measures for gas. 
85 Eurostat dataset (nrg_cb) 
86 COM(2023) 168 final. 

15 

 
 
 
Emissions  Directive  (IED)87  will  help  the  green  transformation  of  EU  industry  and  support 
innovation. While the revised Renewable Energy Directive88 tightened up the sustainability 
criteria of bioenergy, including no-go areas for forest biomass. 

Construction, buildings and infrastructure are still the most energy and material-intensive 
sector in the EU and a driver for land take and soil sealing. The 2023 State of the Energy Report 
concluded  that  the  building  sector  must  significantly  accelerate  the  shift  to  sustainable 
practices. Material use for buildings could potentially decrease by 30% if used more efficiently, 
in particular by extending the lifespan of existing buildings and reducing demand for new 
buildings. The Social Climate Fund89 supports housing renovations, which provide win-win 
opportunities  for  climate,  social  and  energy  objectives,  with  particular  regard  to  the  most 
vulnerable groups. 

In the food sector, it will be key to support farmers, fishers and foresters to collectively 
achieve the ambitious objectives. Innovative financing tools, such as carbon and biodiversity 
farming approaches, can provide win-win solutions by rewarding farmers for preserving or 
increasing soil quality and its fertility, as well as water quality and availability. The proposed 
legally binding 2030 food waste targets90 are designed to help reduce the environmental and 
climate impacts. The EU's research and innovation policy framework substantially supports the 
transition towards sustainable, healthy and inclusive food systems. 

The EU needs to better monitor and minimise the potentially negative environmental impacts 
associated with trade. In 2021, the EU brought in rules on the export, import and intra-EU 
shipment of plastic waste, based on the Basel Convention. Exports of plastic waste to non-
OECD countries from the EU have fallen from around 1 million tonnes in 2020 to around 0.5 
million tonnes in 2022. With the recently adopted Waste Shipment Regulation91, the EU took 
another  key  step  in  this  direction.  An  ongoing  evaluation  of  the  Prior  Informed  Consent 
Regulation92  will  help  design  measures  to  ensure  that  hazardous  chemicals  banned  in  the 
European Union are not produced for export. 

3.  PROGRESS ON SELECTED ENABLING CONDITIONS 

As part of the mid-term review, the Commission analysed progress in using enabling conditions 
clustered around the key challenges. The accompanying staff working document provides more 
details on the other enabling conditions referred to in the 8th environment action programme. 

87 Directive (EU) 2010/75. 
88 Directive (EU) 2023/2413. 
89 Regulation (EU) 2023/955. 
90 COM(2023) 420 final. 
91 https://www.europarl.europa.eu/doceo/document/TA-9-2024-0087_EN.html   
92 Regulation (EU) No 649/2012, L 201/60. 

16 

 
 
 
 
 
3.1 Implementation, enforcement and environmental rule of law 

 Effective implementation of existing legislation is the key to generate impact on the ground, 
in particular for the ambitious measures adopted under the Green Deal legislative framework. 
Fully  implementing  EU  environmental  laws  could  save  the  EU  economy  around  EUR  55 
billion every year in health costs and direct costs to the environment93. The 2022 Environmental 
Implementation Review confirmed that there has been good progress in some areas, but it is 
still not sufficient. 20% of all infringement cases handled dealt with by the Commission still 
relate to environment policy. The compliance with the rule of law is also a matter of public 
confidence  in  the  political  process.  The  revised  Aarhus  Regulation  on  Access  to  Justice94 
improves public strengthens civil society scrutiny of EU acts. The newly agreed Environmental 
Crime Directive95 provides the basis for prosecution of new environmental crime offences and 
for issuing harmonised penalties, based on common criteria.  

Closing  the  implementation  gap  will  require  significant  efforts  by  building  greater 
administrative capacity and stronger governance mechanisms. The level of enforcement of 
individual and collective rights related to environmental matters is uneven across the EU. 

Working with Member States will remain crucial to improve the effectiveness and efficiency 
of  implementation  work96.The  Commission  will  continue  to  provide  technical  support  to 
Member States, including on the design and implementation of reforms through the Technical 
Support Instrument. 

3.2 Financing the transition 

The Green Deal has built momentum to mobilise public97 and private-sector financing for 
the transition. 

The  EU's  multiannual  budget  for  2021-2027  underpins  the  objectives  of  the  Green  Deal, 
notably  by  setting  an  ambitious  climate  target  of  30%,  which  at  this  stage  is  likely  to  be 
exceeded (projected 32.6%). A 37% climate target also exists for the Recovery and Resilience 
Facility, the headline instrument under the NextGenerationEU, mobilising additional funding 
of over 42% of the total investments allocated to climate and environmental investments. This 
created  significant  synergies  from  investing  in  the  circular  economy  for  climate  and 
biodiversity, and in biodiversity investments in climate adaptation or zero pollution.  

The ‘do no significant harm’ principle is instrumental to ensure that EU investments are future 
proof. The Commission issued guidance on how to apply this principle to the Recovery and 
Resilience Facility and is currently working on a coherent approach to applying it to other EU 

93 Study The costs of not implementing EU environmental law study - Publications Office of the EU (europa.eu)  
94 Regulation (EU) 2021/1767. 
95 COM(2021) 851 final. 
96 See SWD(2023) 254 final on how the Commission monitors the application of EU law. 
97 Public funding by Member States must be in line with State Aid rules which also apply to EU funds under 
shared management. 

17 

 
 
 
 
financing instruments (such as the Social Climate Fund, Cohesion policy, InvestEU) and the 
revised Financial Regulation98, and to make this principle applicable across the EU budget. 

The transparency created by the EU sustainable finance framework including the EU taxonomy 
has helped reallocating private capital flows and drive down capital costs for sustainable 
activities and investments. Further mainstreaming awareness of the opportunities as well as the 
financial risks of climate change and nature degradation23 will enable financial markets to play 
their full role in helping to fund the transition. The most recent evidence of the impacts of the 
EU sustainable finance framework is broadly encouraging99, also confirmed for example by 
the strong increase in green bonds: from 0.6% in 2014 to 8.9% in 2022 of all EU bonds. 
However, further action as set out in the Communication on the 2040 target is still needed100. 

There is potential to take further action to make polluters pay. For example, the Commission 
proposed  including  the  principle  of  extended  producer  responsibility  in  the  revision  of  the 
Urban Wastewater Treatment Directive. There are also new commitments made and interest in 
market-based  instruments  especially  at  national  level  to  direct  investments  to  green  and 
climate objectives. 

This could help reverse the fall in the share of environmental taxes in total tax revenues 
(from 6.0% in 2010 to 5.5% in 2021), due to political difficulties to implement changes in the 
tax  system  and  associated  social  and  economic  challenges101.  Less  than  4%  of  all 
environmental taxes are linked to pollution and the use of virgin resources, while more than 
96% are related to energy and transport. 

The Green Deal fosters a greater use of green budgeting tools to redirect public investment, 
consumption and taxation to green priorities and away from harmful subsidies. Green public 
procurement rules are becoming increasingly mandatory (e.g. under the recent initiatives on 
batteries,  energy  performance  of  buildings102,  construction  products103  and  sustainable 
products). Despite this work, fossil fuel subsidies remained more or less unchanged at around 
EUR 56 billion (2022 prices) over the 2015-2021 period, almost half used to subsidise oil and 
over a quarter to subsidise natural gas. 

Fossil fuel subsidies increased by almost 120% between 2021 and 2022 in response to the 
energy price crisis. Under the Governance Regulation104, Member States report on all energy 
subsidies.  The  Commission  is  also  developing  a  methodology  for  reporting  non-energy 
environmentally harmful subsidies. 

Carbon pricing, such as the EU ETS, is reducing emissions. It generates revenues for Member 
States to tackle climate change and to support industrial innovation and households for a fair 

98 Regulation (EU) 2022/2434. 
99 See e.g. the Platform on Sustainable Finance report on a compendium of market practices - European 
Commission (europa.eu) 
100 COM(2024) 63 final 
101 Eurostat dataset (ten00141) 
102 COM(2021) 802 final. 
103 COM(2022) 144 final. 
104 Regulation (EU) 2018/1999. 

18 

 
 
 
transition. In the first three rounds, the EU ETS Innovation Fund allocated EUR 6.5 billion to 
around 100 pilot projects and demonstration plants for innovative low-carbon technologies. 

Though the level of public and private-sector green investments has increased considerably, 
there is still a substantial EU-wide environmental investment gap which stands at between 
EUR 95 and 145 billion per year until 2030105. 

3.3 Governance for integrated policymaking 

A  broad  range  of  ambitious  EU  governance  initiatives  promote  integrated  solutions  for 
societal,  environmental  and  climate  challenges  in  Member  States.  For  example,  integrating 
circularity in national energy and climate plans and the EU competitiveness strategy, ensuring 
the uptake of nature-based solutions in national climate adaptation strategies, urban greening 
plans, including built environment, green infrastructure and land use strategies/plans. 

The EU's annual cycle of macroeconomic governance framework, the European Semester, 
now  embeds  the  Sustainable  Development  Goals  and  the  EU  Resilience  Dashboard.  It  is 
structured around the competitive sustainability framework, which covers the transitions of 
key industries (energy,  mobility,  agri-food, built  environment) to  circular economic models 
and to carbon neutrality. It also covers nature protection, water resilience, the environmental 
investment gap, social and employment aspects of a fair and inclusive transition, the phase-out 
of environmentally harmful subsidies and the polluter pays principle, including taxes. This is 
reflected in the 2023 country-specific recommendations, which put a strong focus on the green 
transition,  especially  energy  transition  and  green  skills  and  the  industrial  and  the  built 
environment for most Member States. The focus on other environmental priorities may also 
sharpen further. 

3.4 Sustainable business models for a resilient economy 

Healthy ecosystems form the very bedrock of our economy. Businesses are highly dependent 
on natural resources: 72% of the 4.2 million companies in the euro area are highly dependent 
on at least one nature-related service such as pollination, clean water, healthy soil, or timber106. 

The  roll-out  of  the  Green  Deal  legislation  is  expected  to  increase  employment  and  gross 
added value in green economy sectors, thereby boosting EU competitiveness. These sectors 
showed a considerable resilience during successive crises, outperforming the wider economy. 
However, the green economy still accounts for less than 3% of the economy in the EU107. 

The contribution and value of nature still tends to be overlooked in too many business 
and investment decisions. To remedy this, strong partnerships will be needed with business, 
underpinned by the key benchmarks set under EU rules. The recent initiative on ‘green claims’ 
tackles the risk of greenwashing, which can be overcome by using standardised methodologies. 

105 Provided that the relevant baseline investments, i.e. energy, transport, industry or agriculture, are implemented 
and deliver the necessary co-benefits for the environment. 
106 COM(2023) 376 final. 
107 Eurostat dataset (env_ac_egss2) 

19 

 
 
 
 
 
The  Corporate  Sustainable  Reporting  Directive  (CSRD)108  and  the  proposed  Corporate 
Sustainability  Due  Diligence  Directive109  support  responsible  corporate  behaviour  across 
value chains and prevent, mitigate, and address the adverse social, climate and environmental 
impacts  of  business  activities  by  both  EU  and  non-EU  companies  operating  in  the  EU. 
Increased uptake of new corporate natural capital management accounting methodologies 
would  provide  valuable  data  for  company  disclosures,  for  example  under  the  CSRD.  More 
action is needed to help companies meet their reporting obligations. 

Improving  access  to  finance  for  EU  start-ups  and  scale-ups,  promoting  research  and 
innovation, developing skills and providing the critical raw materials needed are equally 
important to support sustainable businesses models. 

3.5 Just transition and environmental fairness 

The  impacts  of  environmental  degradation  and  pollution  on  EU  citizens  are  not  evenly 
distributed within and among EU Member States. Vulnerable groups – whether vulnerable 
for socio-economic reasons, health, age, gender or because they belong to a minority  – are 
disproportionally affected by climate change, environmental hazards and related health risks 
and  changes  in  the  labour  market.  This  weakens  social  cohesion,  undermining  trust  in 
governments and thus the viability of the transition. 

The  EU  Just  Transition  agenda  aims  to  achieve  a  shift  that  benefits  everyone.  The  Just 
Transition Mechanism is a fund to support workers and citizens living in the regions that are 
most  affected  by  the  transition  (the  fund  is  endowed  with  at  least  EUR  100  billion).  The 
Emissions Trading System (ETS) reduces emissions and generates revenues for Member States 
to tackle climate change. The ETS-funded Social Climate Fund will mobilise EUR 87 billion 
to support vulnerable households, transport users and micro-enterprises. The first assessment110 
of the implementation of the Council Recommendation on ensuring a fair transition towards 
climate neutrality111 showed that Member States are starting to implement measures for a fair 
transition, with significant differences across countries and room for improvement.  

The EU Gender Equality Strategy 2020-2025 and the Recovery and Resilience Facility tackle 
gender and intersecting inequalities in this process112. The EU Skills Agenda supports learners 
of all ages and workers to access education, training and lifelong learning. 

The evidence base for the environment-social nexus is still largely underdeveloped, with a few 
exceptions.  Air  pollution  inequalities  have  not  improved  from  2007  to  2020.  The  poorest 
regions (with the lowest 20% of GDP per person) have levels of PM2.5 that are consistently 

108 Directive (EU) 2022/2464. 
109 COM(2022) 71 final. 
110 Key messages from EMCO and SPC on the implementation of the Council Recommendation on ensuring a 
fair transition towards climate neutrality pdf (europa.eu). 
111 Council Recommendation of 16 June 2022 on ensuring a fair transition towards climate neutrality 2022/C 
243/04. 
112 See EIGE Gender Equality Index 2023 for links between gender and the environment. 

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around one third higher than the average, with low prospects for swift improvement. People at 
risk of poverty or social exclusion have less access to quality drinking water and sanitation113. 

Greater awareness of the potential of the green economy to create jobs could increase public 
support.  In  2021,  4.3  million  people  had  jobs  in  the  circular  economy,  a  11%  increase  on 
2015114, while the related added value increased by 27% to reach around EUR 299 billion115. 
The  clean  water,  waste  and  remediation  sector  alone  employs  about  1  million  people  and 
investments in clean technologies are driving further job creation. 

There has been a rise in awareness of the need to protect vulnerable groups (for example, 
under  the  proposed  air  quality  directive  and  the  Urban  Waste  Water  Directive)  and  the 
implementation of the European Social Pillar of Rights on water access. These changes are 
an  opportunity  to  step  up  action  on  environmental  fairness.  At  global  level,  the  EU  has 
pioneered Just Transition Energy Partnerships with South Africa, Indonesia, Vietnam, Senegal 
and India. The Just Transition Work Programme established at COP28 will enable exchanges 
on just transition pathways. 

3.6 The link between the environment and health  

There is increased awareness about the role of nature and biodiversity for human health and 
well-being. Since 2021, the European Climate and Health Observatory supports cooperation 
on how climate change has an impact on human health and the EEA’s Health and Environment 
Atlas provides maps to visualise the environmental impacts. 

One in ten premature deaths in Europe can be linked to pollution, which affects more the 
disadvantaged  and  vulnerable  population  groups.  Environmental  causes  are  thought  to  be 
behind over a quarter of a million cancer deaths in Europe every year and pollution has a 
particularly  harmful  effect  on  young  children116.  The  Communication  on  a  comprehensive 
approach to mental health117 underlines the mental health impacts of public exposure to air 
pollution or toxic chemicals, and the positive effect of a clean environment on both physical 
and mental health.  

Scientists are increasingly concerned about the potential impact of  microplastics on human 
health,  and  warn  that  exposure  to  chemicals  can  lead  to  reproductive  and  developmental 
health  problems  including  infertility,  miscarriage,  abnormal  foetal  development  and  early 
puberty. 

The ‘One Health approach’ recognises that public health and the health of domestic and wild 
animals, plants, and the wider environment are interdependent. This approach is included in 
EU initiatives such as the farm-to-fork and pharmaceutical strategies, which include action to 

113 See: European Commission, Access to Essential Services (European Pillar of Social rights): Evidence from 
EU Member States, Final Synthesis Report, 2023. 
114 Eurostat dataset (cei_cie011) 
115 Eurostat dataset (cei_cie012) 
116 COM(2021) 44 final. 
117 COM(2023) 398 final. 

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reduce the overall use of antimicrobials, including in animal farming, to prevent antimicrobial 
resistance. 

At  global  level,  the  EU  has  been  an  early  supporter  of  the  One  Health  approach  under  the 
Convention on Biological Diversity and the Quadripartite Alliance (FAO, UNEP, WHO and 
WOAH).  The  COP28  Declaration  on  Climate  and  Health118  commits  parties  to  tackling 
climate-related health impacts and to promote collaboration on One Health. 

3.7 Digitalisation 

The 8th environment action programme emphasises that digitalisation holds untapped potential 
to accelerate the transition. 

Implementing  the  Green  Data  space  initiative  and  reviewing  the  rules  on  environmental 
geospatial data sharing (‘GreenData4All’) seek to make relevant environmental data available 
to strengthen evidence-based policy making and implementation. 

One specific example is the new Digital Product Passport, which is a deliverable under the 
EU strategy ‘A Europe Fit for the Digital  Age'. The product passport will help using fewer 
materials  and 
less  energy,  reduce  emissions,  minimise  waste  and  even  promote 
dematerialisation. 

Further  action  on  digitalisation  is  needed  to  facilitate  Member  States  and  businesses  in 
reporting on climate and environmental performance. 

Action  on  digitalisation  can  not  only  help  governments  but  also  empower  members  of  the 
public to help monitor the state of the environment. Tapping the full potential of modern data 
collection  and  analysis  (including  through  Copernicus  satellites)  will  strengthen  the 
monitoring  and  reporting  framework  under  the  8th  environment  action  programme.  Using 
citizens science methods can raise awareness, put public pressure on governments and feed 
into environmental foresight. 

As the environmental impacts of digitalisation are growing rapidly, it will be pivotal to tackle 
the  potential  environmental  downsides  (due  to  the  related  rise  in  energy  use  and  the 
production, consumption and disposal of electronic devices). 

3.8 Global uptake 

The drivers of climate change and biodiversity loss are global, and many forms of pollution 
are  transboundary.  The  EU  cannot  achieve  its  climate  and  environmental  objectives 
acting alone. 

The Green Deal has given a new impetus to the EU’s global green and climate action. Green 
Deal  diplomacy  has  promoted  the  global  uptake  of  climate,  energy  and  environmental 
objectives and, in the wake of the COVID-19 pandemic, sustainability in the global economic 
recovery.  The  EU  launched  Green  Alliances  with  Japan,  Norway  and  Canada,  and  Green 

118 Focus on Health at COP 28 (who.int) 

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Partnerships with Korea and Morocco. . The EU has also stepped up its collaboration with 
like-minded donors, and launched   Just Energy Transition Partnerships with South Africa, Viet 
Nam, Indonesia and Senegal, while strengthening engagement with several other countries and 
regional  groupings.  At  multilateral  level,  the  adoption  of  the  Kunming-Montreal  Global 
Biodiversity Framework at the 15th Conference of the Parties (COP15) of the Convention for 
Biological  Diversity  and  the  adoption  of  the  Biodiversity  of  Areas  Beyond  National 
Jurisdiction Treaty were key milestones in international cooperation. Progress was made at 
the  UN  climate  conferences  COP27  and  COP28,  including  the  Global  Stocktake 
commitments  to  double  energy  efficiency  and  triple  renewable  energy  capacity  and  Global 
Methane Pledge covering energy, waste and agriculture sectors. The UN Global Framework 
on  Chemicals,  the  2023  UN  Water  Conference  and  the  launch  of  negotiations  on  an 
intergovernmental mechanism to end plastic pollution were further important achievements. 
The Green Deal has also resulted in new EU legislation (on deforestation, CBAM etc.) aimed 
at  more  sustainable  supply  chains  and  leading  to  stronger  engagement  internationally  on 
specific issues, including in the context of the EU trade policy. The first 2023 EU voluntary 
review  of  the  progress  in  the  implementation  of  the  2030  Agenda  for  Sustainable 
Development  shows  that  the  EU  is  fully  committed  to  delivering  the  17  Sustainable 
Development Goals (SDGs and has made progress towards them119. 

Given the current challenges to multilateralism due to deteriorating geopolitical relations, it 
is  key to mobilise third countries  to  achieve shared climate and environmental  objectives. 
The  EU  must  build  on  its  diplomatic  networks,  political  influence,  technological  expertise, 
training provisions and financial resources to engage with governments and businesses and 
help build global resilience to prevent instability, food insecurity, population displacement 
and forced migration, and to promote global sustainable development in all its dimensions. It 
is also imperative to co-finance the just transition at global level.  

4.  MEASURING PROGRESS 

To assess progress and facilitate high-level strategic political communication, the Commission 
presented the 8th environment action plan monitoring framework, following consultations 
with stakeholders120. It includes 28 headline indicators, providing a strategic approach to track 
systemic change on the ground, fully  in line with sector-specific climate and environmental 
monitoring  tools.  Based  on  the  selected  headline  indicators,  the  EEA  will  publish  annual 
monitoring reports. 

As required under the 8th environment action programme, the monitoring framework should 
stay  stable  to  ensure  accountability.  It  was  adopted  in  2022  and  the  headline  indicators  it 
contains are still fit for purpose. Nonetheless, work is ongoing to improve the current indicators 
and  develop  new  ones  (see  accompanying  staff  working  document),  and  an  update  of  the 
monitoring framework could be considered in the future. 

119 COM(2023) 700 final. 
120  COM(2019) 640 final. 

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Over the last few years, the Commission has developed several new cross-cutting monitoring 
frameworks to measure progress on systemic change, including progress on the SDGs and on 
resilience.  In  developing  these  frameworks,  the  Commission  has  used  climate  and 
environmental  indicators  from  current  thematic  monitoring  frameworks,  including  the  8th 
environment action programme monitoring framework. These indicators are also used in the 
European Semester. Work is ongoing to develop a framework to measure progress ‘beyond 
GDP’, towards a sustainable and inclusive well-being dashboard. 

5.  CONCLUSIONS 

The EU has put in place ambitious long-term targets, initiatives and framework laws under the 
Green Deal and in line with the 8th environment action programme. This has put the EU on 
the right trajectory to reach a net-zero, clean, nature-positive and circular economy. It now 
has a solid legal framework setting climate and environmental objectives  and cross-sectoral 
legislation to accelerate the transition in key sectors of the economy such as energy, industry 
and transport. Most initiatives still have to be fully implemented. It is therefore too early to 
assess their full impact on the environment. 

The Green Deal charts the EU's path to a sustainable future in a way that avoids reaching social, 
climate and environmental tipping points, which would damage the economy and society. It is 
a  systemic  strategy,  delivered  in  full  coherence  with  the  priority  objectives  and  enabling 
conditions of the 8th environment action programme. It builds on synergies between climate, 
environmental,  social,  industrial  and  competitiveness  objectives,  with  progress  in  one  area 
creating a leverage effect in others.  

The circular economy and zero-pollution initiatives will trigger positive changes that will help 
mitigate climate change and safeguard biodiversity. Safeguarding nature generates co-benefits 
for  climate  mitigation  and  adaptation.  A  resource-efficient  economy  reduces  pressure  on 
ecosystems, helps maintain long-term competitiveness and build resilience to external shocks. 
The vision for 2050 of the 8th environment action programme is at the heart of a just and fair 
green transition in the EU and beyond, guided by inter-generational responsibility.  

Efforts from authorities at all levels and the private sector will be needed to ensure that the 
laws have effects on the ground, and accelerate the pace of emission reductions, biodiversity 
protection  and  restoration,  and  the  uptake  of  clean  and  circular  solutions.  Simplification, 
modernisation, and digitalisation, and adequate funding will be key to successfully implement 
the  policy  and  regulatory  framework.  It  is  also  essential  to  understand  and  overcome  the 
challenges of implementation for the legal framework to take root, produce effects and create 
buy-in from everyone concerned. All sectors and groups need to see the benefit that the green 
transition brings for them.  

To  this  end,  the  Commission  will  continue  working  closely  with  Member  States  and  all 
stakeholders.  Dialogues  with  economic  actors  and  the  social  partners  as  well  as  citizen 
panels121  are  examples  of  this  work  to  support  key  groups  in  understanding  climate  and 

121 Citizens' Engagement Platform - European Commission (europa.eu) 

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environment risks, and increasing their support for the measures needed to build resilience and 
long-term sustainability in every segment of the socio-economic spectrum.  

Substantial investment is needed to power the green transition in the EU and to reach the goal 
of climate neutrality.  Financing the green transition is essential to  avoid the cost of climate 
change and environmental degradation, which destroys the ecosystem services that nourish the 
economy and society. To bridge the financing gap, public and private-sector investments are 
needed and fossil fuel and other environmentally harmful subsidies should be phased out.  

Investors and the industry are increasingly getting on board, understanding what sustainability 
means for the future of their business models and what strategic decisions they need to take for 
the long term. For the green transition to happen, it will need to be better integrated in economic 
coordination mechanisms such as macroeconomic coordination and the European Semester. 

Lastly, global action on climate change and environmental objectives is key. The EU has led 
the way by putting climate change, biodiversity loss and more recently plastic pollution and 
water  resilience  at  the  core  of  the  international  agenda.  It  is  mobilising  the  international 
community to achieve the 8th environment action programme vision of living well within the 
planetary boundaries. 

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