REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the progress made on the implementation of Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants
Date: 2024-07-30
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, air quality, atmospheric pollutant, environmental impact, national implementing measure, pollution control measures, reduction of gas emissions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.7.2024  COM(2024) 348 final  REPORT FROM THE COMMISSION TO THE COUNCIL AND THE EUROPEAN PARLIAMENT on the progress made on the implementation of Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants  
 
 
1. 

INTRODUCTION  

Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric 
pollutants (the Directive) is one of the legislative instruments that contribute to reaching 
the  2030  air  pollution  objectives  of  the  Zero  Pollution  Action  Plan (1).  It  sets  national 
emission  reduction  commitments  for  each  EU  Member  State  for  2020-2029  and  more 
ambitious ones as of 2030. It  targets five air pollutants responsible for significant negative 
impacts on human health and the environment, namely: sulphur dioxide (SO2); nitrogen 
oxides (NOx); non-methane volatile organic compounds (NMVOC); ammonia (NH3); and 
fine particulate matter (PM2.5).  

The Directive entered into force on 31 December 2016, repealing Directive 2001/81/EC (2) 
on  national  emission  ceilings  for  certain  atmospheric  pollutants  with  effect  from 
1 July 2018.  The  Directive  sets  national  reduction  obligations  for  pollutant  emissions, 
expressed  as a percentage of the emissions of each pollutant in  the baseline year 2005. 
These obligations have applied since 2020, with emissions data reported for the first time 
in 2022.  

The  Directive’s  emission  reduction  commitments  for  2020  to  2029  correspond  to  the 
emission reduction commitments for 2020 onwards taken by the EU and its Member States 
under  the  revised  Gothenburg  Protocol (3)  to  the  UNECE  Air  Convention (4).  The 
Directive transposes those international obligations into EU law, and sets more ambitious 
commitments for 2030 onwards.  

The Directive addresses overall national emissions. It is part of the EU legal framework 
on  clean  air,  alongside  the  EU  Ambient  Air  Quality  Directive(s) (5)  and  EU  legislation 
regulating air pollution at source (6). The effective implementation of clean air legislation 
is essential for achieving the two air-related 2030 targets of the Zero Pollution Action Plan, 
i.e.:  (i)  reducing  by  more  than  55%  the  health  impacts  of  air  pollution  (expressed  as 
premature  deaths  due  to  PM2.5  pollution)  in  the  EU;  and  (ii)  reducing  by  25%  the 
ecosystems area where air pollution threatens biodiversity (compared to 2005 levels).  

Member States were required to fully transpose (i.e. integrate into national law) Directive 
(EU) 2016/2284 by 1 July 2018.  

(1)   COM/2021/400 final  
(2)   Directive 2001/81/EC of the European Parliament and of the Council of 23 October 2001 on national 

emission ceilings for certain atmospheric pollutants, OJ L 309, 27.11.2001, p. 22.  

(3)   1999  Protocol  to  Abate  Acidification,  Eutrophication  and Ground-level  Ozone  to  the  Convention on 
Lang-range Transboundary Air Pollution, as amended on 4 May 2012 (amended Gothenburg Protocol). 
http://www.unece.org/env/lrtap/status/lrtap_s.html 

(4)   1979  Convention 

on  Long-Range  Transboundary  Air  Pollution 

(Air  Convention). 

https://www.unece.org/environmental-policy/conventions/envlrtapwelcome/the-air-convention-and-
its-protocols/the-convention-and-its-achievements.html 

(5)   Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on ambient air 
quality and cleaner air for Europe (OJ L 152, 11.6.2008) and Directive 2004/107/EC of the European 
Parliament and of the Council of 15 December 2004 relating to arsenic, cadmium, mercury, nickel and 
polycyclic aromatic hydrocarbons in ambient air (OJ L 23, 26.1.2005). The Commission proposed to 
revise these Directives on 26 October 2022 (COM(2022) 542 final/2). Council and Parliament reached 
2024 
early 
a 
a 
(https://www.consilium.europa.eu/en/press/press-releases/2024/02/20/air-quality-council-and-
parliament-strike-deal-to-strengthen-standards-in-the-eu/) 

agreement 

Directive 

political 

revised 

on 

in 

(6)   An overview is available at: https://environment.ec.europa.eu/topics/air/air-pollution-key-sectors_en  

1 

 
 
 
The  Commission  followed  up  on  the  eight  instances  of  late  communication  of  the 
transposition of the Directive with letters of formal notice, in line with Article 258 of the 
Treaty on the Functioning of the European Union (TFEU). All eight cases have since been 
closed.  

The  Commission  has  checked  the  conformity  of  the  notified  national  measures,  and 
initiated nine infringement procedures due to national legislation not being in line with the 
requirements of the Directive. All but one (7) of those procedures have since been closed.  

According to Article 11(1) of the Directive, the European Commission has an obligation 
to inform the European Parliament and the Council on the implementation progress made.  

A first implementation report was presented in 2020 (8). This second report comes 4 years 
after the previous one, as required by Article 11 of the Directive. It presents the progress 
made to date in implementing the Directive, and includes an assessment of its contribution 
to  achieving  the  objectives  set  out  in  Article  1.  More  precisely,  Article  11(1)  of  the 
Directive requires the Commission to report on progress towards:    

− 

the indicative emission levels and emission reduction commitments referred to in 
Article 4 and, where applicable, the reasons for any non-achievement;  

−  ambient air quality levels in line with the air quality guidelines published by the 

− 

World Health Organization;  
the EU's biodiversity and ecosystem objectives set out in the seventh environment 
action programme. 

Article 11(1) also requires the Commission to: 

− 

identify further measures required at EU and Member State level to achieve these 
objectives;  

−  report on the uptake of EU funds to support the measures taken to comply with the 

Directive’s objectives;  

−  present the results of the Commission’s examination of the national air pollution 
control programmes and their updates in line with the third subparagraph of Article 
10(1);  

−  evaluate the health, environmental and socio-economic impacts of this Directive.  

Article 11(2) further requires the Commission to investigate the need for further action, 
including possible legislative measures, where the report indicates that a non-achievement 
of the indicative emission levels and emission reduction commitments could be the result 
of ineffective EU source legislation, including its implementation at Member State level.  

The fourth Clean Air Outlook, planned for the end of 2024, which follows on from the 
previous  editions (9),  will  complement  this  report  by  providing  information  on  the 
trajectory to  compliance. More specifically, the 2024 Clean Air Outlook  will provide a 
detailed analytical assessment of the extent to which Member States and the EU as a whole 
are on track to meet the Directive’s emission reduction requirements and to improve air 
quality, thus reducing impacts on human health and on the environment, as well as of the 
costs and benefits of the needed measures and expected impacts.  

(7)  The still open procedure is against Poland 

(https://ec.europa.eu/commission/presscorner/detail/en/INF_21_2743)  

(8)  COM(2020) 266 final. 
(9)   All available at: https://environment.ec.europa.eu/topics/air/clean-air-outlook_en  

2 

 
 
 
 
 
2.  PAST AND PROJECTED ACHIEVEMENT OF THE EMISSION REDUCTION COMMITMENTS  

2.1.  Emission reduction achieved so far and compliance checks  

The central obligation for Member States, as set out in the Directive, is to reduce emissions 
for the air pollutants SO2, NOx, NMVOC, NH3 and PM2.5 for the years 2020-2029 and from 
2030 onwards. Member States’ reduction commitments are expressed as a percentage of 
2005 emission levels.  Figure 1  presents  changes  in  emissions  of these pollutants  at  EU 
level, showing that emissions of all pollutants but ammonia have substantially decreased 
over  time.  This,  however,  hides  discrepancies  between  Member  States,  whose  changes 
over time are detailed in European Environmental Agency (EEA) publications (10).   

160%

140%

120%

100%

80%

60%

40%

20%

0%

5
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2

6
0
0
2

7
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0
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1
2
0
2

NH₃

NMVOC

NOₓ

PM₂.₅

SO₂

GDP

Figure  1:  2005-2021  trends  in  EU  emissions  of  NH3,  PM2.5,  NMVOC,  NOX  and  SO2,  as 
percentages of 2005 levels, set against EU Member States’ GDP as a percentage of the 2005 
GDP 
https://www.eea.europa.eu/publications/national-emission-reduction-
(source: 
commitments-directive-2023) 

Based  on  the  emission  inventories  reported  every  year  by  Member  States  under  the 
Directive, the Commission checks compliance with the emission reduction commitments. 
Inventories contain emissions data with a 2-year time lag. The latest inventories reported 
by  Member  States  in  February  2024  include  emissions  data  from  2022.  In  2022,  the 
Comission  therefore  checked,  for  the  first  time,  Member  States’  compliance  with  the 
emission reduction commitments, on the basis of reviewed 2020 emissions data.  

As  shown  in  Table  1,  overall  compliance  is  relatively  good  for  all  pollutants  except 
ammonia.  In 2022, the  Commission found 19 cases  of non-compliance, spread over 14 
Member States (11). While all five pollutants are concerned, most non-compliance cases 
relate to ammonia. As a consequence, the Commission issued letters of formal notice to 
these 14 Member States (12).  

(10)  For  pollutant  trends  per  country,  see:  https://www.eea.europa.eu/data-and-maps/dashboards/necd-
directive-data-viewer-7. For the latest state-of-play on distance to compliance per Member State and an 
overall  assessment  of  progress,  see:  https://www.eea.europa.eu/publications/national-emission-
reduction-commitments-directive-2023 

(11)  Bulgaria, Denmark, Ireland, Spain, Cyprus, Latvia, Lithuania, Luxembourg, Hungary, Austria, Poland, 

Portugal, Romania and Sweden. 

(12)  https://ec.europa.eu/commission/presscorner/detail/EN/inf_23_142  

3 

 
 
 
The 2023 compliance assessment, based on reviewed 2021 data, showed that most non-
compliance  cases  have  not  been  resolved,  and  that  there  were  a  few  additional 
breaches (13).  The  Commission  has  followed  up  accordingly,  with  three (14)  additional 
letters of formal notice and nine (15) reasoned opinions issued in November 2023 (16).   

Table 1: Overview of non-compliance with emission reduction commitments based 
on 2020 and 2021 data 

Pollutant  Member  States  non-compliant  in 

2020*  

Member  States  non-compliant  in 
2021†  

NH3  

11 MS:  AT, BG, DK, ES, HU, IE, 
LT, LU, LV, PT, SE  

10 MS: AT, BG, DK, HU, IE, LT, 
LU, LV, PT, SE  

PM2.5 

3 MS: HU, LT, RO  

NMVOC 

2 MS: LT, PL 

NOx 

2 MS: LT, RO 

3 MS: HU, PL, RO  

3 MS: LT, LU, PL 

2 MS: LT, RO 

1 MS: CY 

SO2 
*According to inventories reported by Member States in 2022 (on which the letters of formal notice issued 
in January 2023 were based). 
†According to inventories reported by Member States in 2023 (on which the letters of formal notice and 
reasoned opinions issued in November 2023 were based). 

1 MS: CY 

Inventories  need  to  be  of  good  quality  for  a  reliable  assessment  of  compliance.  The 
Commission  closely  monitors  the    quality  of  inventories  and  supports  Member  States’ 
efforts  to  improve  them  (see  Section  5.1  of  this  report),  including  by  conducting  and 
publishing reviews of national inventories (17) and providing capacity building support.  

When reviewing national inventories, the Commission verifies the transparency, accuracy, 
consistency, comparability and completeness of information provided.  

According to the 2023 review (18), the quality of inventories was good for most Member 
States, but that there was some variation between countries, with a few inventories being 
of notably poorer quality. Significant areas for improvement exist across all sectors and 
pollutants, and include: 

− 
− 

− 

over- or underestimated emissions and inconsistencies within data time series; 
lack of transparency on methodologies and recalculations compared to previous 
inventories;  
a need for more sophisticated methods to estimate emissions for key emission 
sources as well as for uncertainty analysis. 

(13)  Croatia failed to submit its emissions inventory in 2023 and therefore received a letter of formal notice. 

It therefore does not appear in the compliance assessment for 2021 emissions.  

(14)  Luxembourg, Poland and Romania. 
(15)  Bulgaria, Cyprus, Ireland, Hungary, Latvia, Lithuania, Austria, Portugal and Sweden.  
(16)  November infringement package (https://ec.europa.eu/commission/presscorner/detail/en/inf_23_5380). 
(17)  See: 
https://environment.ec.europa.eu/topics/air/reducing-emissions-air-pollutants/emissions-

inventories_en#review-of-national-emission-inventories  

(18)  See 

the 

EU-wide 

assessment 

in 

the 

horizontal 

review 

report: 

https://circabc.europa.eu/ui/group/cd69a4b9-1a68-4d6c-9c48-77c0399f225d/library/a43a894a-191f-
42c1-bb45-5dfc696ebdb3/details?download=true  

4 

 
 
 
 
 
The inventory reviews assess not only the quality of the inventory data but also whether  a 
Member State’s application for a flexibility according to Article 5 of the Directive can be 
accepted. Article 5(1) sets out the conditions under which Member States can adjust their 
inventories.  An  adjustment  can  notably  be  made  when  a  Member  State  is  applying 
improved inventory methods updated in line with scientific knowledge since the emission 
reduction commitments were first drawn up.  

In 2021, one Member State submitted new adjustment applications, while several others  
resubmitted applications for previously approved adjustments. As of the 2022 inventory 
submission, the number of flexibility applications has fallen considerably. This is due to 
the  introduction  of  emission  reduction  commitments  expressed  in  percentages,  while  
previously  approved  adjustments  related  to  emission  ceilings  (still  applicable  from 
Directive 2001/81/EC as laid down in the transitional provision under Article 21(2) of the 
Directive)  and  are  therefore  no  longer  valid.  Since  this  change,  only  one  Article  5(1) 
adjustment application was received in 2022 and subsequently approved, and resubmitted 
in  2023  as  a  previously  approved  one.  To  date,  the  Commission  has  not  received 
applications for any of the other flexibilities set out in Article 5 of the Directive.  

2.2. 

Projected  achievement  of  the  2020-2029  and  2030  onwards  emission 
reduction commitments 

Article 10(2) of the Directive requires Member States to submit, every 2 years, projections 
of air pollutant emissions for the years 2020, 2025 and 2030 (19), to assess the extent to 
which they are on track to meet their emission reduction commitments for 2020-2029 and 
for 2030 onwards.  Projected emission levels  for 2025 are also  assessed against a linear 
trajectory  between  the  2020-2029  and  2030  emission  reduction  commitments  (as  per 
Article 4(2) of the Directive). Projections must cover a ‘with measures’ scenario (existing 
measures  only)  and,  where  relevant,  a  ‘with  additional  measures’  scenario  (existing 
measures  and  planned  additional  measures) (20).  If  a  Member  State  projects  that  it  will 
meet  all  of  its  emission  reduction  commitments  under  existing  measures,  no  ‘with 
additional  measures’  scenario  is  required.  The  Commission  also  conducts  its  own 
modelling  exercise  to  complement  Member  State  projections  to  assess  compliance 
prospects  under  different  scenarios.  The  Third  Clean  Air  Outlook (21)  summarises  the 
results of this modelling. 

The latest reporting by Member States took place in 2023. 22 Member States (22) submitted 
projections  in  time to  be reviewed in  detail (23). For the ‘with  measures’ scenario, non-
compliance is most frequently projected for NH3 emission reduction commitments (both 
for  2020-2029  and  for  2030  onwards),  highlighting  the  need  for  additional  measures 
addressing NH3 emissions. NMVOC, NOx and PM2.5 show similar occurences of projected 

(19)  Article  10(2)  refers  to  Annex  I,  Table  C  of  Directive  (EU)  2016/2284  which  details  the  reporting 

requirements for emissions and projections. 

(20)  Article 8(5) of Directive (EU) 2016/2284 refers to its Annex IV, Part 2 which details requirements for 

projections. 

(21)  COM(2022) 673 final. 
(22)  Croatia did not submit projections in 2023 (and therefore received a letter of formal notice), while Spain, 
Hungary and Slovenia submitted projections too late (after 15 May 2023, i.e. 2 months after the legal 
reporting deadline) and Portugal resubmitted their 2021 submission. These submissions could therefore 
not be quality checked as part of the detailed technical review and are not included in the summary here. 
As Germany submitted its projections after 26 April 2023 but before 15 May 2023, its submission was 
reviewed, but in less detail.  

(23)  A detailed summary of the 2023 review of projections is available in the horizontal review report. 

5 

 
 
non-compliance.  Except  for  a  few  specific  cases,  meeting  the  SO2  emission  reduction 
commitments does not currently appear to be an issue across the EU.  

Under the ‘with measures’ scenario, the analysis further shows that 13 Member States (24) 
project in 2025 to fulfil all 2020-2029 emission reduction commitments, while the number 
falls to eight (25) for the 2030 commitments (see Annex 1 to this report). All Member States 
not reaching their emission reduction commitments with existing measures need to put in 
place additional measures. However, two Member States that project non-compliance with 
one or more emission reduction commitments in their  ‘with measures’ scenario did not 
report a ‘with additional measures’ scenario (26).  

In  parallel,  of  the  15  Member  States  that  reported  a  ‘with  additional  measures’ 
scenario (27),  four  still  fail  to  project  compliance  with  all  of  the  emission  reduction 
commitments,  both  in  2025  and  in  2030 (28).  These  Member  States  (along  with  those 
projected to be in non-compliance in the ‘with measures’ scenario and not reporting a ‘with 
additional measures’ scenario) will need to put in place additional measures to fulfil their 
emission reduction commitments.  

Projections submitted by Member States were also assessed against the linear reduction 
trajectory between the 2020-2029 and the 2030 emission reduction commitments (as per 
Article 4(2) of the Directive). While 13 Member States project their 2025 emissions to be 
in  line  with  the  2020-2029  emission  reduction  commitment  under  the  ‘with  measures’ 
scenario,  this  number  drops  to  eight (29)  when  assessed  against  the  linear  reduction 
trajectory in 2025 (this analysis uses the ‘with measures’ scenario since there will be very 
little time for additional measures to deliver effects by 2025).  

Projections need to be of good quality for a reliable assessment of the future risk of non-
compliance. This also allows Member States to adopt well-targeted additional measures 
addressing  the  sectors  and  sources  of  pollution  where  more  effort  is  required.  The 
Commission reviews Member States’ emission projections for each reporting cycle (every 
2 years) (30) and takes into account the latest reporting guidelines. In 2023, the Commission 
adopted a delegated act (31) making targeted amendments to two annexes of the Directive 
that require Member States to use, as of 2025, the latest template (32) for the reporting of 
projections  adopted  under  the  UNECE  Air  Convention.  This  will  produce  emission 
projections in higher resolution by disaggregating source sectors in the same way as it is 
done  for  inventories,  giving  Member  States  an  improved  basis  for  designing  targeted 
additional measures. Already in 2023, while not yet mandatory to use, around half of the 
Member  States  reported  their  projections  in  the  more  disaggregated  version  of  the 
submission template. 

(24)  Belgium, Bulgaria, Cyprus, Czechia, Germany, Denmark, France, Greece, Italy, Malta, the Netherlands, 

Slovakia and Finland.  

(25)  Belgium, Cyprus, Czechia, Denmark, Greece, Italy, the Netherlands and Finland. 
(26)  Austria and Sweden. 
(27)  See Chapter 3.3 in the 2023 horizontal review report. 
(28)  For 2025: Estonia, Ireland, Lithuania and Poland. For 2030: Bulgaria, Ireland, Luxembourg and Malta.  
(29)  Belgium, Cyprus, Czechia, Denmark, Greece, Italy, the Netherlands and Finland. 
(30)  See: 

https://environment.ec.europa.eu/topics/air/reducing-emissions-air-pollutants/national-air-

pollution-control-programmes-and-projections_en   

(31)  Commission  Delegated  Directive  (EU)  2024/299  of  27  October  2023  amending  Directive  (EU) 
2016/2284  of  the  European  Parliament  and  of  the  Council  on  the  methodology  for  the  reporting  of 
projected emissions of certain atmospheric pollutants. 

(32)  Annex  IV  template  available  here:  https://www.ceip.at/reporting-instructions/annexes-to-the-2023-

reporting-guidelines. 

6 

 
 
3.  ANALYSIS OF THE NATIONAL AIR POLLUTION CONTROL PROGRAMMES  

3.1. 

Fulfilment of legal requirements 

Article  6(1)  of  the  Directive  requires  Member  States  to  adopt  a  national  air  pollution 
control programme (NAPCP) to show how they intend to limit their annual anthropogenic 
emissions to meet their emission reduction commitments. The NAPCP constitutes a central 
governance instrument that allows Member States to coordinate and agree their policies 
and  measures  (PaMs)  to  ensure  national  emission  reduction  commitments  are  met.  Its 
preparation  requires  consultation  and  involvement  of  competent  authorities  at  different 
levels and of several different sectors, such as environment, agriculture, energy, climate, 
transport, industry and finance. A particular emphasis is put on ensuring coherence with 
plans and programmes for all relevant policy areas. Furthermore, the NAPCP is a tool to 
communicate a Member State’s pollution control policies and to involve the public in the 
policymaking process, through consultations.  

In accordance with Article 6(10) of the Directive, the Commission has specified the format 
of  the  NAPCP  in  Commission  Implementing  Decision  (EU)  2018/1522 (33)  setting  out 
mandatory and optional content, based on Article 6 and Annex III Part 1 to the Directive. 
The additional PaMs selected for adoption by Member States to further reduce emissions 
constitute an essential part of the mandatory content. These additional PaMs have to be 
reported  via  the  ‘EEA-PaM  tool’,  a  web  tool  developed  by  the  European  Environment 
Agency  (EEA).  The  Commission  has  also  prepared  guidance  for  the  development  of 
NAPCPs (34), in line with Article 6(9) of the Directive. The guidance helps Member States 
to draw up an NAPCP in the required format and in compliance with the requirements of 
the Directive. The first NAPCPs were due by 1 April 2019. NAPCPs must be updated at 
least every 4 years and earlier if new data so requires. In 2023, updated NAPCPs were due 
for a number of Member States (35).  

Due to substantial delays in providing the first NAPCPs, infringement procedures for non-
submission were opened for five Member States in February (36) and July 2020 (37). All 
Member States concerned have subsequently submitted their NAPCP and the procedures 
have been closed.  

Since  May  2020  (the  cut-off  date  for  the  NAPCP  submissions  considered  in  the  first 
implementation  report),  the  Commission  has  received  and  analysed  first  NAPCPs  from 
Greece,  Italy,  Luxembourg  and  Romania,  as  well  as  updated  NAPCPs  from  Belgium, 
Cyprus,  Denmark,  Estonia,  Finland  and  France.  The  Commission  has  also  recently 
received udpated NAPCPs from the Netherlands, Poland and Czechia, but these had not 

(33)  Commission  Implementing  Decision  (EU)  2018/1522  of  11  October  2018  laying  down  a  common 
format for national air pollution control programmes under Directive (EU) 2016/2284 of the European 
Parliament and of the Council on the reduction of national emissions of certain atmospheric pollutants, 
OJ L 256, 12.10.2018, p. 87. 

(34)  Communication  from  the  Commission  on  Guidance  for  the  development  of  National  Air  Pollution 
Control Programmes under Directive (EU) 2016/2284 of the European Parliament and the Council on 
the reduction of national emissions of certain atmospheric pollutants, OJ C 77, 1.3.2019, p. 1.  

(35)  As not all Member States submitted their first NAPCPs by the 1 April 2019 deadline, NAPCP updates 
will still be submitted throughout 2024 (and later) in line with the requirement to update every 4 years.  

(36)  Greece, Malta and Romania. 
(37)  Italy and Luxembourg. 

7 

 
 
yet been analysed in detail at the time this report was drafted (38). In addition, Ireland and 
Luxembourg submitted updated PaMs in line with Article 6(4), covered in the next section.  

Of the 10 NAPCPs received since May 2020, the common format for the NAPCP was used 
by six Member States (39), partially used by three (40) and not used by one (41). 

According to Article 6(5) of the Directive, Member States have to consult the public in 
line with Directive 2003/35/EC (42) on the draft NAPCP. Of the four Member States that 
submitted the first NAPCPs in the period covered by this report, three (43) carried out a 
public consultation, whereas one (44) did not provide evidence that a consultation had been 
conducted. Of the six updated NAPCPs, two (45) underwent a public consultation, in one 
case (46) it was unclear, and three (47) contained no evidence of a public consultation having 
been carried out. 

On  the  reporting  of  mandatory  content  of  the  NAPCP,  the  majority  of  the  documents 
analysed did so fully or did so with relatively minor gaps (48), but there is a general lack of 
detail  on  additional  PaMs,  which  rendered  an  in-depth  analysis  more  difficult.  Most 
Member States provided little information on optional content. 

The projections that Member States used in their NAPCP are in most cases (49) consistent 
with their latest submission of projected air pollutant emissions under Article 10(2) of the 
Directive.  For  three  Member  States (50)  major,  and  for  one  Member  State (51)  minor 
inconsistencies were identified. Reliable and consistent projections are important to design 
well-targeted PaMs.   

All NAPCPs received from Member States as well as their assessments are published on 
the Commission’s website (52). 

3.2.  Analysis of reported additional policies and measures (PaMs)  

Member States that have not achieved or project not to achieve their emission reduction 
commitments with current policies have to report in their NAPCPs the additional policies 
and measures – both those that they considered for adoption and those that they actually 
selected  -  to  fulfil  their  commitments.  This  reporting  must  be  done  via  the  web-based 
‘EEA-PaM tool’, managed by the European Environment Agency. 

(38)  The analysis of NAPCPs included in this report  follows the 2023 interim horizontal review report of 

NAPCPs, which was finalised in December 2023.  

(39)  Belgium, Cyprus, Finland, France, Greece and Luxembourg.  
(40)  Denmark, Romania and Italy. 
(41)  Estonia.  
(42)  Directive 2003/35/EC of the European Parliament and of the Council of 26 May 2003 providing for 
public  participation  in  respect  of  the  drawing  up  of  certain  plans  and  programmes  relating  to  the 
environment, OJ L 156, 25.6.2003, p. 17. 

(43)  Luxemburg, Romania and Greece. 
(44)  Italy. 
(45)  Denmark and Finland. 
(46)  France. 
(47)  Belgium, Cyprus and Estonia. 
(48)  Belgium, Cyprus, Denmark, Estonia, Finland, Greece, Italy and Romania. 
(49)  Belgium, Denmark, Estonia, Finland, France and Romania.  
(50)  Cyprus, Greece and Italy.  
(51)  Luxembourg. 
(52)  https://environment.ec.europa.eu/topics/air/reducing-emissions-air-pollutants/national-air-pollution-

control-programmes-and-projections_en  

8 

 
 
Member  States  considered  in  this  section  are  the  ones  that  submitted  a  first  or  updated 
NAPCP (Belgium, Cyprus, Denmark, Estonia, Greece, Finland, France, Italy, Luxembourg 
and Romania) as well as the two Member States (Ireland and Luxembourg) that reported 
an update of PaMs only (under Article 6(4) of the Directive), as set out in Section 3.1.  

The extent and level of detail of the reporting by Member States on their additional policies 
and  measures  vary  depending  on  the  country  and  on  the  measure.  Based  on  the  latest 
review of NAPCPs and PaMs (53), several shortcomings identified in previous reviews and 
summarised in the first implementation report clearly remain. These include: 

− 

insufficient  information  to  judge  whether  PaMs  are  truly  additional  and  as  such 
would help bring a non-compliant Member State into compliance; furthermore, for 
around a third of PaMs reported as additional under the ‘with additional measures’ 
scenario, implementation start dates were well before 2023, which put into question 
their status as being ‘additional’;  

−  a lack of quantification of emission reduction impacts from PaMs (and where they 
have been quantified, a lack of information to judge whether they are realistic); and  
−  more generally, and while noting that the quality of reporting varies across Member 
States, a lack of information on the design and focus of PaMs that would enable 
their credibility to be assessed.  

These points also apply to the first NAPCPs that Member States submitted after the 2020 
implementation report. Of those, Greece did not consider additional PaMs for adoption, as 
they  project  to  achieve  all  of  their  emission  reduction  commitments  under  a  ‘with 
measures’  scenario,  while  Italy  and  Romania  selected  24  and  33  additional  PaMs, 
respectively,  targeting  all  pollutants.  PaMs  mostly  target  the  energy  consumption, 
agriculture and transport sectors in the case of Italy, and the energy consumption, transport, 
and industry sectors in the case of Romania. All of the first NAPCP submissions either 
select the agricultural measures referred to in Annex III, Part 2 of the Directive in their 
NAPCP, or provide evidence that these measures are already in place and implemented 
through other programmes or action plans.  

Of  the  six  Member  States  from  which  NAPCP  resubmissions  were  received  in  2023, 
Belgium,  Denmark  and  Finland  did  not  consider  additional  PaMs  for  adoption,  as  they 
project to achieve all of their emission reduction commitments under a  ‘with measures’ 
scenario.  For  the  remaining  PaMs  submissions (54),  the  following  more  detailed 
conclusions are drawn: 

–  According to the information reported via the EEA-PaM tool, of the 78 additional 
single PaMs considered for adoption, 48 were selected for adoption (62% of the 
PaMs  considered).  The  proportion  of  considered  PaMs  that  were  subsequently 
selected for adoption varied significantly between Member States (with none to all 
PaMs considered actually being selected). 

–  The key challenge the Member States are facing is to reduce emissions of pollutants 
from the largest emission sources: agriculture (NH3); combustion in commercial, 
institutional  and  household  sectors  and  road  transport  (PM2.5);  and  industrial 
solvent  use  (NMVOC).  The  analysis  of  PaMs  showed  that  Member  States  have 

(53)  https://circabc.europa.eu/ui/group/cd69a4b9-1a68-4d6c-9c48-77c0399f225d/library/52f82bad-1dae-

4ead-869c-d2bf757621f2/details 
maps/dashboards/overview-of-compliant-air-pollution-policies (EEA PaMs dashboard). 

(NAPCP 

review) 

https://www.eea.europa.eu/data-and-

and 

(54)  The below information includes the Article 6(4) PaM submissions of Ireland and Luxembourg, as well 
as the first NAPCP submission of Romania, which was covered in the 2023 interim horizontal review 
report of NAPCPs, given its late submission.  

9 

 
 
 
prioritised the consideration and adoption of PaMs for those sectors that contribute 
to the largest share of emissions. More than two thirds of the PaMs considered for 
the agriculture sector have been selected for adoption, and over half the transport 
and energy consumption PaMs considered were selected for adoption. However, 
very  few  PaMs  were  considered  and  selected  for  adoption  in  the  industrial 
processes and waste management sectors. 

–  One  Member  State’s (55)  submission  to  the  EEA-PaM  tool  consisted  of  a  single 
‘PaM’,  which  was  in  fact  the  NAPCP  as  a  whole  with  no  additional  detail  on 
individual PaMs selected for adoption. This is considered insufficient.  

3.3.  Links between NAPCPs and other plans  

There are many links between air policies and climate/energy policies, as emitting sources 
of greenhouse gases and of air pollutants are often the same. Therefore, one measure can 
often help to meet both air and climate goals (e.g. developing clean transport modes, better 
insulation of buildings to reduce energy consumption). However, there can sometimes also 
be trade-offs (e.g. the use of bioenergy for domestic heating).  

Air  and  energy/climate  legislation  refer  to  one  another  and  require  links  to  be  made 
between the NAPCPs and the national energy and climate plans (NECPs) (56) submitted 
under  Regulation  (EU)  2018/1999 (57).  The  Commission’s  guidance  on  developing 
NAPCPs specifically invites Member States, when drafting their respective NAPCPs, to 
consider  the  policies  and  measures  planned  also  with  a  view  to  climate  and  energy 
obligations.  In  turn,  Commission  guidance (58)  on  drafting  NECP  updates  encourages 
Member States to update their NECPs closely with their NAPCP updates, paying special 
attention to strengthening the assessment of the impact of planned policies and measures 
on air pollutant emissions.  

Due to different legal deadlines and delays in submitting NAPCPs and NECPs, submission 
dates may not align. Ensuring consistency between the two may therefore need to be done 
on the basis of draft NECPs. Nevertheless, the links between air and climate/energy should 
be  reflected  in  the  final  NECPs  to  be  submitted  by  Member  States  by  30 June 2024. 
According to the Commission’s 2023 assessment of draft updated NECPs (59), more than 
half  of  the  submitted  plans  did  not  include  the  required  information  on  the  impact  of 
policies on projected emissions of the main air pollutants under the Directive, or on the 
alignment of NAPCP with energy and climate programmes. 

(55)  France.  
(56)  See, Directive (EU) 2016/2284 Article 1 (synergies); Annex III, Part 1 (consistency in priorities); Annex 
IV, Part 2 (consistency in projections). In parallel, see Regulation (EU) 2018/1999, Annex I, Section A, 
Paragraph 5(1)(i) which requires reporting projected impacts of the planned policies and measures on 
the emissions of the air pollutants regulated under Directive (EU) 2018/2284. 

(57)  Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the 
Governance of the Energy Union and Climate Action, amending Regulations (EC) No 663/2009 and 
(EC)  No  715/2009  of  the  European  Parliament  and  of  the  Council,  Directives  94/22/EC,  98/70/EC, 
2009/31/EC, 2009/73/EC, 2010/31/EU, 2012/27/EU and 2013/30/EU of the European Parliament and 
of the Council, Council Directives 2009/119/EC and (EU) 2015/652 and repealing Regulation (EU) No 
525/2013 of the European Parliament and of the Council, OJ L 328, 21.12.2018, p. 1.  

(58)  Commission Notice 2022/C 495/02 on the Guidance to Member States for the update of the 2021-2030 

national energy and climate plans. 

(59)  COM(2023) 796 final. 

10 

 
 
 
According to the latest assessment (60), the NAPCPs describe generally well the energy 
and climate change priorities in the policy framework. Most Member States have included 
information  on the key  greenhouse gas reduction targets, as  well as  on their  renewable 
energy  and energy efficiency objectives. Three  Member States (61) clearly state in  their 
PaMs submission that all PaMs have been developed in line with their NECP.  

The analysis of the NAPCPs indicates, however, that links between clean air and climate 
and energy policies could be strengthened, and that the two planning exercises should be 
further  integrated  to  increase  the  effectiveness  of  the  underlying  policies.  This  would 
involve a more systematic assessment of the links between the air and climate and energy 
policies, including  of synergies and trade-offs (62) between them.  The Commission  will 
explore  ways  to  improve  this  aspect  in  future  evaluations  under  both  Regulation  (EU) 
2018/1999 and the Directive. 

In addition to links with energy and climate measures, NAPCPs should also seek synergies 
with agricultural measures to reduce above all ammonia emissions. Ammonia is primarily 
emitted through agricultural activity, both from livestock management and cultivation of 
crops (63). The Commission’s current work on addressing nutrients in an integrated way is 
relevant in this context as it establishes clearer links between air, water, soil, biodiversity 
and agricultural policies. Notable examples include the Farm to Fork Strategy (64) and the 
new Common Agricultural Policy.   

The Commission has, for example, monitored the integration of clean air considerations 
into  Member  States’  2023  strategic  plans  under  the  2023-2027  Common  Agricultural 
Policy. In this context, the Commission focuses on incentivising Member States to develop 
and implement interventions and result indicators that are directly relevant for reducing 
ammonia emissions, given the challenges in implementing the NEC Directive, notably the 
failure of many Member States to further reduce their ammonia emissions. 

4.  ANALYSIS OF THE IMPACTS OF EMISSION REDUCTIONS  

4.1. 

Impacts on air quality and human health 

Reducing  pollutant  emissions  leads  to  decreased  pollutant  concentrations,  improved  air 
quality and less morbidity and mortality linked to air pollution (65).  

Figure 2 shows changes between 2005 and 2020 in annual mean concentrations of PM2.5, 
the air pollutant with the worst impact on human health.  

(60)  https://circabc.europa.eu/ui/group/cd69a4b9-1a68-4d6c-9c48-77c0399f225d/library/52f82bad-1dae-

4ead-869c-d2bf757621f2/details  
(61)  Cyprus, Luxembourg and Romania. 
(62)  As an example of trade-offs, two Member States (Cyprus and Ireland) selected PaMs for adoption that 
prioritised objectives set out in the NECP that conflicted with achieving emission reductions for NH3. 
These PaMs were selected with the aim of reducing greenhouse gas emissions, but are likely to increase 
NH3 emissions if not accompanied by measures aimed at decreasing NH3 emissions. 

(63)  Agriculture accounts for over 90% of ammonia emissions in the EU (https://www.eea.europa.eu/data-

and-maps/dashboards/necd-directive-data-viewer-7)  

(64)  COM(2020) 381 final. 
(65)  https://www.eea.europa.eu/en/analysis/indicators/health-impacts-of-exposure-to  

11 

 
 
These maps show that, although the situation has improved over time (66), many regions 
still have concentrations far over the annual level of 5 µg/m3 recommended in the 2021 
WHO Guidelines (67).  

The Third Clean Air Outlook report (68) projects further improvements in the future, but 
this  will  still  not  be  enough  to  achieve  the  WHO  guideline  level  everywhere  under  the 
baseline situation.  

Figure  2:  Annual  mean  concentrations  of  PM2.5  in  2005  and  2020  (source:  adapted  from 
Third Clean Air Outlook support study (69))  

These changes in concentrations translated into changes in the number of people exposed 
to harmful levels of pollutant concentrations.  

Figure 2 shows a marked reduction in the number of people exposed to levels of  PM2.5 
above 20 µg/m3 (from 140 to 14 million). It also shows that only a minority of people in 
the EU (31 million in 2020) enjoy air quality in line with the recommendations of the latest 
WHO guidelines.   

Figure 3: EU-27 population (in million people) exposed to different concentrations of PM2.5 
(source: adapted from Third Clean Air Outlook) 

(66)  The observed improvement in annual mean concentrations of PM2.5 is largely independent of COVID-
19 lockdown measures. According to the EEA, their impact on the annual mean level of PM2.5 was no 
greater than a median reduction of 5% across all monitoring stations. Larger impacts were observed for 
NO2 (https://www.eea.europa.eu/publications/status-of-air-quality-in-Europe-2022)   

(67)  https://iris.who.int/handle/10665/345329  
(68)  COM/2022/673. 
(69)  Klimont et al., ‘Support to the development of the third Clean Air Outlook’, IIASA, 2022. 

12 

 
 
 
Even though trends over time show an improvement in the situation, in 2021, 97% of the 
EU urban population was still exposed to concentrations of fine particulate matter above 
the latest WHO guidelines.   

The highest concentrations of particulate matter were seen in Central-eastern Europe and 
Northern Italy (as also shown in Figure 2), primarily due to the burning of solid fuels for 
domestic heating and in industry (70). 

Poorer regions in Europe (20% lowest GDP per capita) are often particularly impacted by 
air  pollution,  with  PM2.5  levels  being  higher  by  around  a  third  than  in  richer 
regions (71) (72). Vulnerable groups such as older people, people with preexisting health 
conditions, children, and pregnant women are more likely to be affected by health risks 
due to air pollution while socio-economic factors can contribute to the degree of exposure.    

The  overall  reduction  in  the  negative  health  impacts  of  air  pollution  over  time  (a  near 
halving of premature deaths attributable to exposure to total PM2.5 concentration between 
2005 and 2020) puts the EU well on track to reaching its ‘zero pollution’ target of reducing 
by more than 55% the health impacts of air pollution by 2030 compared to 2005 (73). To 
continue  this  trend,  the  Commission  aims  to  ensure  the  proper  implementation  of  the 
Ambient Air Quality  Directives.  As of  February  2024, 25 infringement  cases were still 
ongoing  on  poor  application  of  the  Ambient  Air  Quality  Directives  by  16  Member 
States (74). The Court of Justice has passed a ruling for 15 cases (75).  

4.2. 

Impacts on ecosystems 

Air pollution not only harms human health, but also leads to acidification, eutrophication 
and  formation  of  ground-level  ozone,  all  of  which  are  detrimental  to  ecosystems 
(freshwater and terrestrial, semi-natural and agricultural ones) and to biodiversity.  

The Third Clean Air Outlook showed that the EU ecosystem area where the critical loads 
for acidification are exceeded fell from 9.0 to 5.5% of the total ecosystem area between 
2015  and  2020.  Compared  to  the  area  affected  by  acidification,  the  area  of  ecosystems 
where nitrogen deposition exceeds critical loads for eutrophication is much larger. There 
has also been less relative improvement, with the share of ecosystem area with nitrogen 
deposition exceeding critical loads falling from 80.2 to 74.9% between 2015 and 2020.  

At Member State level, the highest exceedances of nitrogen critical loads  in 2021 were 
found in the Po Valley in Italy, on the border areas between the Netherlands and Germany, 
along the border between Denmark and Germany and in north-eastern Spain, with some 
additional hotspots in the Netherlands and its border areas with Belgium (76).  

(70)  EEA  ‘Europe’s  air  quality  status  2023’.  https://www.eea.europa.eu/publications/europes-air-quality-

status-2023  

(71)  https://www.eea.europa.eu/en/analysis/indicators/income-related-environmental-inequalities-

associated  

(72)  https://discomap.eea.europa.eu/atlas/?page=Combined-risks-and-

inequalities&views=PM%E2%82%82.%E2%82%85--vs-GDP  

(73)  COM(2022) 673 final. 
(74)  Concerning  Belgium,  Bulgaria,  Czechia,  Germany,  France,  Greece,  Spain,  Italy,  Croatia,  Hungary, 

Poland, Portugal, Romania, Sweden, Slovenia and Slovakia.  

(75)  Concerning Bulgaria, Greece, France, Italy, Hungary, Poland, Slovakia, Romania for PM10; Germany, 

Greece, Spain, France, Italy, Portugal for NO2 and Bulgaria for SO2. 

(76)  EEA (2023) Eutrophication caused by atmospheric nitrogen deposition in Europe.  

13 

 
 
 
This means that Member States will have to introduce further measures (77) to reduce the 
eutrophication impacts of air pollution to achieve, by 2030, the EU zero pollution target of 
reducing by 25% the EU ecosystems where air pollution threatens biodiversity.    

Articles  9  and  10(4)  of  the  Directive  require  Member  States  to  report  these  ecosystem 
impacts every 4 years starting from 1 July 2019, based on a representative network of sites 
which  had  to  be  reported  by  1 July 2018.  The  European  Commission  published  a 
Commission  Notice (78)  and  an  optional  reporting 
its 
accompanying  guide (79),  in  order  to  facilitate  Member  States’  reporting  of  ecosystem 
impacts and subsequent analysis. In both reporting cycles (2018-2019 and 2022-2023), all 
Member States complied with their reporting obligations.  

together  with 

template, 

The  Commission’s  assessment  of  Member  States’  first  reporting  cycle  showed  that  the 
network  of  sites  and  reported  data  were  not  sufficiently  representative  and  adequate  to 
monitor the effects of air pollution on ecosystems. Building on the lessons learnt from this 
first  reporting  cycle,  a  guidance  note  on  site  selection (80)  was  prepared  by  the 
Commission,  supported  by  the  EEA  and  Member  State  experts.  It  aims  to  help  each 
Member  State  set  up  a  representative  monitoring  network.  The  optional  reporting 
template (81) has been adapted following feedback from Member States and the EEA. The 
analysis of the second reporting cycle shows an increase in the total number of sites and 
parameters reported compared to the first submission (+14%). Although the distribution of 
sites is more aligned with the distribution of ecosystem types across the EU, the ecosystem 
types ‘rivers and lakes’ and ‘woodland and forest’ remain overrepresented, while cropland, 
wetland  and  heathland/shrubland  sites  remain  underrepresented.  The  considerable 
differences between the datasets reported by Member States during these two cycles (both 
spatially and temporally, and in terms of monitoring site types, measurement protocols and 
parameters monitored) makes an EU-wide assessment difficult. It also prevents a reference 
point  being  put  in  place  for  the  future  assessment  of  the  Directive’s  longer  term 
effectiveness.  

Member States  do  not  necessarily  need to  set  up new monitoring stations to  fulfil their 
monitoring obligations on air pollution impacts on ecosystems. The Directive explicitly 
requires  Member  States  to  take  a  cost-effective  approach,  by  coordinating  with  other 
monitoring programmes. This approach seems to be widely used by Member States, since 
most  of  the  data  provided  follow  international  protocols,  such  as  those  from  the 
International Cooperative Programmes (ICP) or from other EU directives. This limits the 
administrative costs of the Directive’s requirements to monitor ecosystem impacts. 

Although  the  NAPCP  template  specifies  that  Member  States  should  report  (as  optional 
content)  the  impacts  on  the  environment  of  the  ‘with  additional  measures’  projection 
scenario, none of the NAPCPs or the additional PaMs submitted to date have reported these 
impacts.  

(77)  COM(2022) 673 final. 
(78)  Commission Notice on ecosystem monitoring under Article 9 and Annex V of Directive (EU) 2016/2284 
of  the  European  Parliament  and  of  the  Council  on  the  reduction  of  national  emissions  of  certain 
atmospheric pollutants (NEC-Directive), OJ C 92, 11.3.2019.  

(79)  https://ec.europa.eu/environment/air/reduction/ecosysmonitoring.htm  
(80)  https://circabc.europa.eu/ui/group/cd69a4b9-1a68-4d6c-9c48-77c0399f225d/library/85f4b9c0-e232-

42b7-9940-9262f75ac625/details    

(81)  https://circabc.europa.eu/ui/group/cd69a4b9-1a68-4d6c-9c48-77c0399f225d/library/2922dd49-80d6-

4fd1-b510-812dab4da6be/details    

14 

 
 
4.3.  Costs and benefits of reduced air pollutant emissions  

Information on the costs and benefits of policies and measures selected by Member States 
is  sometimes  provided  in  the  NAPCPs,  but  this  is  not  compulsory.  Of  the  10  NAPCPs 
analysed for this report, only two (82) reported such information. While it is appreciated 
that  these  two  Member  States  made  effort  to  provide  estimates,  there  were  some 
inconsistencies  and  information  gaps.  For  example,  in  the  information  provided  by 
Romania on packages targeting multiple pollutants, it is unclear how the costs, benefits 
and  cost  per  tonne  of  abated  pollutant  is  split  across  multiple  pollutants.  In  addition, 
although Cyprus provided cost estimates for two individual PaMs, the cost per tonne of 
NH3  abated  is  considered  to  be  unrealistic.  This  very  limited  reporting  on  the  costs  of 
Member States’ proposed measures can give rise to doubts on whether the full funding for 
their  implementation  is  secured.  While  cost  estimates  largely  depend  on  national 
circumstances, reporting these estimates would enable an analysis of the relative efficiency 
of various measures. This would in turn help inform future policy choices in the Member 
States concerned or in others (through peer learning).  

The Commission continues to encourage Member States to provide more information on 
the  costs  and  benefits  of  their  air  pollutant  emission  reduction  measures  in  upcoming 
reports, as this information is key for developing future measures. In the meantime, this 
aspect will be analysed in the next Clean Air Outlook, through a modelling methodology.  

The Commission has carried out a cost-benefit analysis for future years under the Third 
Clean Air Outlook. For this, it considered the benefits of reduced pollution (less harm to 
health  and  the  ecosystem,  and  less  damage  to  materials)  versus  the  costs  of  pollution 
abatement measures. As part of the cost-benefit analysis, the health and non-health impacts 
of  air  pollution  were  estimated  and  assigned  a  monetary  value (83).  This  revealed  that 
health impacts clearly exceed non-health impacts. In the baseline scenario, for example, 
the total health damage due to air pollution in 2025 is conservatively estimated at around 
EUR  173  billion  per  year (84),  whereas  non-health  damage  (materials,  crops,  forests, 
ecosystems) is estimated at between EUR 33 and 41 billion per year (all in 2015 prices), 
depending  on  the  valuation  method  used  to  calculate  ecosystem  damage.  On  the  other 
hand, the costs of air pollution reduction measures in EU-27 in 2025 are estimated at EUR 
77 billion per year (in 2015 prices) – far lower than the costs of the impacts of air pollution.  
The  modelling  results  show  that  scenarios  with  more  ambitious  clean  air  policies 
systematically  provide  net  direct  benefits  (i.e.  benefits  minus  costs)  compared  to  the 
baseline. More ambitious clean air policies also positively affect EU GDP in 2030, which 
would increase by 0.26 to 0.28% compared to the baseline. 

5.  OTHER ASPECTS OF THE DIRECTIVE’S IMPLEMENTATION  

5.1.  EU actions supporting the Directive’s implementation 

According  to  Article  12  of  the  Directive,  the  Commission  has  to  regularly  set  up  a 
European Clean Air Forum to help implement EU air quality legislation and policies in a 
coordinated  way.  Since  the  first  report  in  2020,  the  Commission  has  organised,  in 

(82)  Romania (first submission) and Cyprus (updated submission). 
(83)  As explained in  Klimont et al.  ‘Support to the development of the third Clean Air Outlook’, IIASA, 

2022, and its annex, Chapter 5. 

(84)  Counting impacts only from exposure to pollutant concentrations above WHO guideline levels, applying 
a  conservative method to value premature deaths (‘VOLY’) and fully  excluding  impacts  due  to NO2 
exposure to avoid any possible double counting. 

15 

 
 
cooperation with the respective Member States, two further European Clean Air Fora, in 
Madrid on 18-19 November 2021 and in Rotterdam on 23-24 November 2023 (85). Both 
events were met with strong interest from government and industry stakeholders, NGOs  
and members of the public.  

The 2021 Clean Air Forum took place after the publication of the latest WHO air quality 
guidelines  and  amidst  the  preparation  of  the  revision  of  EU  air  quality  legislation.    It 
focused on the themes of zero pollution and health, engagement with cities and citizens, 
access to justice, and linking clean air to climate and biodiversity policies.  

The 2023 Clean Air Forum followed up on the ongoing revision of EU air quality rules, 
and also focused on the themes of social inequality linked to air quality, spatial planning 
and  multimodal  transport,  air  pollutant  emissions  from  maritime  shipping,  healthy 
lifestyles, skills and jobs for clean air, and knowledge sharing. 

The Commission, in cooperation with the Committee of the Regions, has also set up a Zero 
Pollution Stakeholder Platform (86) to help deliver on the flagship initiatives and actions 
set out in the Zero Pollution Action Plan.  

The platform brings together stakeholders and experts in different policy areas, such as 
health, agriculture, research and innovation, transport, digitalisation and the environment. 
Its  objectives  include  setting  out  a  common  vision  on  how  to  achieve  zero  pollution, 
tackling  interlinked  challenges,  such  as  strengthening  a  joint  environment  and  health 
agenda, and developing and sharing good practices on cross-cutting topics.  

The  Commission  also  supports  Member  States  in  implementing  the  Directive  through 
capacity  building  and  the  Ambient  Air  Quality  expert  group.  In  2022,  the  Commission 
hosted a capacity building workshop (87) to disseminate good practices on several aspects 
of the preparation of air pollutant emission projections and NAPCPs.  

The  Commission  also  supports  Member  States  through  the  TAIEX-EIR  peer-to-peer 
tool (88). A recent example was a TAIEX expert mission to help a Member State improve 
its  air  pollutant  emissions  inventory.  A  TAIEX  multi-country  workshop on  agricultural 
measures  to  reduce  ammonia  emissions  is  planned  for  autumn  2024.  The  Technical 
Support Instrument (89) can also help Member States reform or improve the effectiveness 
of clean air policies.  

The Commission’s Joint Research Centre developed the Agricultural Emission Estimation 
(AgrEE)  tool (90)  to  help  Member  States  improve  their  emission  inventories  for  the 
agricultural sector.  

(85)  https://environment.ec.europa.eu/topics/air/clean-air-forum_en   
(86)  https://environment.ec.europa.eu/strategy/zero-pollution-stakeholder-platform_en  
(87)  https://circabc.europa.eu/ui/group/cd69a4b9-1a68-4d6c-9c48-77c0399f225d/library/b879b074-ef81-

4221-b463-d334595e03d8/details?download=true  

(88)  https://environment.ec.europa.eu/law-and-governance/environmental-implementation-review/peer-2-

peer_en. This tool supports multicountry workshops, study visits by or expert missions to a requesting 
Member State.  

(89)  The  Technical  Support  Instrument  (TSI)  is  the  EU  programme  that  provides  tailor-made  technical 
(https://reform-
to  design 

to  EU  Member  States 

implement 

reforms 

and 

expertise 
support.ec.europa.eu/index_en).  

(90)  https://edgar.jrc.ec.europa.eu/agree_tool/public/ (EU Login required to access). 

16 

 
 
Since  2014  Copernicus (91)  supplies,  through  its  Core  Atmosphere  Monitoring  Service 
(CAMS),  continuous  data  and  information  describing  air  quality  levels  and  trends  at 
national and European level. Cooperation with Copernicus Climate Change Services has 
led  to  the  development  of  a  web-based  tool (92)  to  identify  if  any  EU  Member  State 
experienced  an  exceptionally  cold  winter  or  an  exceptionally  dry  summer  in  a  specific 
year, as this information is essential for making use of the flexibility provided by Article 
5(2) of the Directive. This web tool ensures that the Commission’s assessment of those 
flexibility applications will be consistent and transparent.  

In 2021, the Commission together with the EEA launched the European Air Quality Index 
webpage (93) and application for mobile devices that allow users to understand more about 
the quality of the air close to their home or workplaces.  

5.2.  Uptake of EU funds to support the Directive’s objectives 

Article 7 of the Directive requires the Commission  ‘to endeavour to facilitate [Member 
States’]  access  to  existing  Union  funds’  to  support  the  achievement  of  the  Directive’s 
objectives.  Article  11(1)(c)  of  the  Directive  requires  the  Commission  to  report  on  this 
uptake.  

EU  funding  has  been  made  available  under  various  financing  programmes,  and 
successfully used by Member States over the years to improve air quality. This funding 
either  directly  supports  clean  air  projects  or  effectively  includes  clean  air  objectives  in 
other  investments  (e.g.  infrastructure,  rural  and  regional  development).  Several  LIFE, 
Horizon 2020 and Horizon Europe projects supported the reduction of pollutant emissions 
as well as monitoring and citizen awareness of air pollution issues.  

To monitor progress in the Member States’ uptake of these EU funds, the Commission has 
developed  a  methodology (94)  that  assesses  the  extent  to  which  each  funding  stream 
contributes to  clean air objectives. The Commission reports annually on clean air financing 
as part of its draft budget, for each relevant funding programme. Numbers published in 
2023  show  that,  for  2021-2027,  the  EU  budget  -  including  NextGenerationEU  -  is 
dedicating an estimated EUR 147 billion, or 8.3% of the multiannual financial framework, 
to  the  clean  air  objective.  Figure  4  illustrates  the  share  of  projected  clean  air  spending 
across  programmes (95).  The  biggest  contribution  in  the  current  programming  period  is 
projected to come from the Recovery and Resilience Facility, as well as European Regional 
and Development and Cohesion Funds.   

(91)  Copernicus is the Earth Observation component of the EU Space Programme. 
(92)  https://cds.climate.copernicus.eu/cdsapp#!/software/app-necd?tab=overview  
(93)  https://www.eea.europa.eu/themes/air/air-quality-index  
(94)  Presented in Annex 4 of the first implementation report COM(2020) 266 final, and complemented by 
information  available  at:  https://commission.europa.eu/strategy-and-policy/eu-budget/performance-
and-reporting/horizontal-priorities/green-budgeting/clean-air-tracking_en#clean-air-methodology 

(95)  https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/horizontal-

priorities/green-budgeting/clean-air-tracking_en.  As  explained  in  the  methodology,  the  estimate  for 
CAP  funding  is  based  on  2021  and  2022  only  and  the  existing  methodology  for  clean  air  tracking 
developed for the 2014-2020 MFF. For the years following this, specifically 2023-2027, the clean air 
tracking methodology will be adapted to the changed conditions of the CAP implementation for these 
years.  

17 

 
 
 
Figure  4:  Projected  clean  air  contribution  from  2021  to  2027  (million  EUR).  Note:  The 
estimate for CAP funding only covers 2021 and 2022 (source: European Commission (96))  

5.3.  Links with international agreements  

The Directive links closely with the UNECE Convention on Long-range Transboundary 
Air  Pollution  (the  Air  Convention)  and  its  protocols (97),  and  the  two  legal  regimes 
cooperate  with  each  other  as  far  as  possible,  notably  on  the  reporting  of  emission 
inventories and projections. A joint inventory guidebook for common methodology has 
been  developed  and  is  continuously  being  improved  with  the  support  of  the  EEA (98). 
Guidance documents (99, 100) are also published regularly under the Air Convention.  

The  amended  Gothenburg  Protocol  to  the  Air  Convention,  which  entered  into  force  on 
7 October 2019,  and  the  Directive  are  broadly  aligned  in  terms  of  emission  reduction 
commitments for 2020-2029. The Gothenburg Protocol was recently reviewed within the 
Air Convention framework, providing an opportunity to consider a further alignment of 
these two legal regimes, including by developing a common approach to e.g. methane and 
black  carbon  emissions.  The  review  resulted  in  the  Air  Convention  Parties  taking  the 
decision, in December 2023, to start the process to revise the Gothenburg Protocol. The 
revision process will start in 2024, with the aim to complete negotiations by end of 2026.  

6.  CONCLUSION 

Putting  the implementation of  the Directive on the right  track from  the outset  has  been 
crucial  to  ensure  timely  reductions  in  air  pollutants  emissions,  contribute  effectively  to 
improved human and ecosystem health and deliver on the zero pollution ambition under 
the European Green Deal and its Zero Pollution Action Plan.  

(96)  https://commission.europa.eu/strategy-and-policy/eu-budget/performance-and-reporting/horizontal-

priorities/green-budgeting/clean-air-tracking_en 
(97)  https://ec.europa.eu/environment/air/policy/index.htm  
(98)  https://unece.org/emissions-reporting       
(99)  https://unece.org/publications/environment-policy/air-convention 
(100) https://unece.org/gothenburg-protocol     

18 

 
 
 
 
This  is  why  the  Commission  has  followed  up  from  the  very  beginning  on  cases  where 
Member  States’  air  pollutant  emission  inventories  showed  non-compliance.  The 
Commission also closely monitors Member States’ follow-up on cases and calls on them 
to take tangible steps in the form of updated policies and measures (and timely submissions 
of updated NAPCPs, where due) in line with the legal deadlines.  

All  pollutants  for  which  the  Directive  sets  emission  reduction  commitments  require 
continued  attention.  This  is  particularly  important  as  the  more  stringent  reduction 
commitments  for  2030  onwards  draw  closer  and  given  the  aim  to  align  EU  air  quality 
standards more closely with the 2021 WHO air quality guidelines (101). The one pollutant 
that  stands  out  as  particularly  problematic  remains  ammonia,  for  which  prospects  of 
meeting the Directive’s emission reduction commitments remain bleak.  In order to help 
Member States to meet this specific objective, the Directive included an annex setting out 
(mandatory and non-mandatory) measures and listing well-established practices that are 
proven to reduce ammonia emissions. Member States need to step up their efforts to ensure 
these  measures  and  practices  are  actually  implemented,  including  by  engaging  with 
relevant  stakeholders  and  ensuring  a  coherent  approach  to  other  national  processes,  for 
example on implementing the Common Agricultural Policy strategic plans.  

Other  regulated  pollutants  have  directly  benefited  from  the  more  ambitious  energy  and 
climate policies through the Fit for 55 legislative package, the REPowerEU plan and, most 
recently, the 2040 climate target plan (102). These initiatives provide a major boost also for 
clean  air  objectives,  where  a  stronger  climate  ambition  translates  into  increased  energy 
efficiency and a faster roll-out of non-combustible renewable energy sources. This holds 
true  in  particular  for  emissions  of  fine  particulate  matter,  nitrogen  oxides  and  sulphur 
dioxide.  To  maximise  these  co-benefits,  it  is  important  that  Member  States  coordinate 
national planning processes accordingly. This means that NECPs and NAPCPs should be 
consistent with  one another, something that Member States are encouraged to  take into 
account when finalising their NECPs by June 2024, and when updating their NAPCPs.  

The Commission continues to provide Member States with various types of support to help 
them implement the Directive. For example, capacity building support, which mainly takes 
the form of a rigorous review of Member States’ inventories, projections, NAPCPs and 
ecosystem data submissions. This exercise involves exchanges with Member State experts 
and  results  in  practical  recommendations  for  improving  future  submissions.  This  is 
important because high-quality data are necessary to address sources of emissions in an 
informed and well-targeted way. Other forms of support available to Member States upon 
request  include theTechnical  Support  Instrument, the TAIEX-EIR  peer-to-peer tool and 
stakeholder exchanges. Last but not least, EU funding continues to be available to support 
initiatives related to clean air.  

Complementing this report, the fourth Clean Air Outlook, due for the end of 2024, will 
provide an updated analysis of costs and benefits in achieving the Directive’s objectives, 
and  highlight  any  additional  actions  that  are  needed  at  national  and  EU  level.  Both 
documents will inform the upcoming review of the Directive, due to be finalised by 2025, 
which will analyse in more detail the Directive and its implementation.  

(101) The Commission proposed to revise the Ambient Air quality Directives and as part of this EU air quality 
standards on 26 October 2022 (COM(2022) 542 final/2).  Council and Parliament reached a  political 
agreement  on  a  revised  Directive  in  early  2024  (https://www.consilium.europa.eu/en/press/press-
releases/2024/02/20/air-quality-council-and-parliament-strike-deal-to-strengthen-standards-in-the-eu/) 

(102) COM(2024) 63 final 

19