COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - CROATIA Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security
Date: 2025-07-07
Institutions: Directorate-General for Environment, European Commission
Subjects: Croatia, EU environmental policy, application of EU law, biodiversity, circular economy, climate change policy, environmental law, governance, pollution control measures, waste management

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 7.7.2025  SWD(2025) 303 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review           Country Report - CROATIA                     Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Croatia  2 

Contents 

EXECUTIVE SUMMARY ..................................................................................................................................... 2 

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT........................................................................................................ 4 
Transitioning to a circular economy ............................................................................................................... 4 
Waste management ....................................................................................................................................... 6 
2. BIODIVERSITY AND NATURAL CAPITAL ..................................................................................................................... 12 
Global and EU biodiversity frameworks ....................................................................................................... 12 
Nature protection and restoration – Natura 2000 ....................................................................................... 12 
Recovery of species ....................................................................................................................................... 14 
Recovery of ecosystems ................................................................................................................................ 15 
Prevention and management of invasive alien species ................................................................................ 20 
Ecosystem assessment and accounting ........................................................................................................ 21 
3. ZERO POLLUTION ............................................................................................................................................... 22 
Clean air........................................................................................................................................................ 22 
Industrial emissions ...................................................................................................................................... 23 
Major industrial accidents prevention – Seveso ........................................................................................... 25 
Mercury Regulation ...................................................................................................................................... 27 
Noise ............................................................................................................................................................. 27 
Water quality and management .................................................................................................................. 28 
Chemicals...................................................................................................................................................... 33 
4. CLIMATE ACTION ................................................................................................................................................ 36 
The EU emissions trading system ................................................................................................................. 36 
Effort sharing ................................................................................................................................................ 37 
Land use, land-use change and forestry ....................................................................................................... 38 
Adaptation to climate change ...................................................................................................................... 38 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ...................................................................... 39 

5. FINANCING ....................................................................................................................................................... 39 
Climate finance landmarks ........................................................................................................................... 39 
Environmental financing and investments ................................................................................................... 39 
Public financial management ....................................................................................................................... 44 
6. ENVIRONMENTAL GOVERNANCE ............................................................................................................................ 48 
Information, public participation and access to justice ................................................................................ 48 
Compliance assurance .................................................................................................................................. 50 
EU-supported environmental capacity building ........................................................................................... 53 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
 
 
 
Croatia  3 

Executive summary 

In  May  2016,  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
reporting 
tool  based  on  analysis,  dialogue  and 
collaboration  with  EU  Member  States  to  improve  the 
implementation  of  existing  EU  environmental  policy  and 
legislation (1). Following previous cycles in 2017, 2019 and 
2022,  this  report  assesses  the  progress  made  while 
the  main  outstanding  challenges  and 
describing 
opportunities 
legal 
implementation in Croatia. The purpose of this report is to 
provide information on the implementation performance 
and draw attention to the most effective ways to address 
the implementation gaps  that  impact human health and 
the environment and hamper the economic development 
and competitiveness of the country. The report relies on 
detailed  sectoral  implementation  reports  collected  or 
issued  by  the  Commission  under  specific  environmental 
legislation. 

environmental 

regarding 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
account factors such as the gravity of the environmental 
implementation issue in light of the impact on the quality 
of life of the citizens, the distance to targets and financial 
implications. 

Despite  the  efforts  made  since  the  last  Environmental 
Implementation  Review,  reforms  and  investments  in 
waste  management  and  the  circular  economy  are  still 
needed to move away from reliance on waste disposal of 
municipal  waste  in  landfills,  which  remains  significant. 
Croatia missed by a wide margin the 2020 target to recycle 
50 % of its municipal waste and requested to postpone the 
attainment of the 2025 target for preparing for reuse and 
recycling  55 %  of  municipal  waste  and  the  65 %  target 
recycling plastic and glass packaging waste. Furthermore, 
Croatia  has  several  ongoing  infringement  cases  in  the 
waste sector that call for urgent action. Croatia’s circular 
material  use  rate  is  low  (6.2 %)  and  far  from  the  EU 
average (11.8 %). Hence, there is scope for improvement 
in circular economy performance by extending circularity 
measures  to  all  economic  sectors  and  considering  the 
whole life cycle of products from design to end of life. This 
would reduce both the environmental impact of products 
and reliance on imported primary raw materials. 

(1) 

from 

the  Commission 

the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 

to 

Croatia 
is  progressing  on  site-specific  conservation 
objectives  for  its  Natura  2000  sites  that  have  been 
established  for  143  out  of  745  special  areas  of 
conservation and all 38 special protection areas. Yet more 
effort is needed to complete this work and to put in place 
conservation measures for all sites to mitigate pressures 
coming  from  agriculture,  forestry,  fisheries,  energy  and 
water  management.  Improvements  are  also  needed  for 
the  use  of  the  appropriate  assessment  provided  by  the 
Habitat  Directive,  which 
infringement 
proceedings. 

is  subject  to 

Urban  waste  water  collected  in  Croatia  is  not  being 
properly  treated  as  required  by  EU  law.  The  level  of 
compliance  was  extremely 
in  2020  (7 %),  and 
investments  are  being  implemented  with  a  slow  pace. 
Croatia should continue investing in this sector as a matter 
of urgency while taking into account the additional targets 
set in the recast Urban Wastewater Treatment Directive. 

low 

The  overall  environmental  investment  needs  to  enable 
Croatia  to  meet  its  objectives  in  the  areas  of  pollution 
prevention  and  control,  circular  economy  and  waste, 
water protection and management, and biodiversity and 
ecosystems are estimated to be EUR 2.9 billion per year. 
The  current  investment  gap  in  Croatia  stands  at  an 
estimated  EUR 1.2 billion  per  year.  Despite  additional 
funds available (mainly through the national recovery and 
resilience  plan),  the  Croatian  environmental  investment 
gap has not reduced much and is above the EU average. 

On environmental governance, Croatia needs to improve 
the public’s access to courts with regard to issues involving 
environmental planning (particularly for water, nature and 
air quality) and better inform the public about their access 
to justice rights. These issues were already raised in 2022 
and 
improvements. 
Furthermore,  spatial  data  should  be  made  more  widely 
accessible in the implementation of the Inspire Directive. 

there  have  been  no  visible 

On the positive side, Croatia’s bathing waters are among 
the  cleanest  in  the  EU.  96.7 %  of  them  are  of  excellent 
quality. Croatia also has a good performance level when it 
comes  to  recycling  construction  and  demolition  waste, 

Environmental  Implementation  Review,  COM(2016) 316 
final  of  27 May  2016,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Croatia 

 
 
with 81.8% in 2022, above the EU average of 79,8% and 
increasing since the last measurement in 2020. 

Croatia  4 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
Croatia  5 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial systems  by  reducing  input  materials,  keeping 
products  and  materials  in  the  loop  for  longer  and 
reducing  waste  generation,  thus  decoupling  economic 
growth from resource consumption. A circular economy 
has  considerable  potential  to  increase  competitiveness 
and  job  creation  and  will  also  promote  innovation  and 
provide  access  to  new  markets.  With  the  2020  circular 
economy action plan (CEAP) (2) measures either in place 
or  legislatively  advanced,  EU  Member  States  will  now 
have to focus on a swift and effective implementation. 

The 2020 CEAP launched the legislative process for a set 
of  initiatives  that  will  now  have  to  be  implemented  by 
national  governments  across  the  EU.  These  initiatives 
life-cycle 
introduced  following  a  holistic 
were  all 
approach, with measures addressing the different stages 
of a product’s life cycle, from design through use to end 
of life. 

In the CEAP, the EU sets as its overarching objective the 
doubling of its circular material use rate (CMUR) by 2030. 

The CMUR is a measure of one aspect of circularity: the 
share  of  the  total  amount  of  material  used  in  the 
economy  that  is  accounted  for  by  recycled  waste.  A 
higher  CMUR  value  means  that  more  secondary 
materials  were  used  as  a  substitute  for  raw  materials, 
thus  reducing  the  environmental  impacts  of  extracting 
primary material. 

Croatia’s  circular  use  of  material  was  6.2 %  in  2023, 
dropping down from 6.8 % in 2022 and following a slow 
but  steady  increase  since  2015  (Figure 1).  The  gap 
between Croatia’s rate and the EU average of 11.8 % in 
2023 has been getting smaller, but current increase rates 
are still too slow to close the gap at the speed needed. 

(2) 

from  the  Commission  to  the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – A new circular 
economy action plan for a cleaner and more competitive Europe, 

15

10

5

0

2013

2015

2017

2019

2021

2023

Croatia

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur, last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_cu
r. 

10 December 

2024, 

product 

Improving 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic 
resource 
(GDP). 
productivity  can  help  to  minimise  negative  impacts  on 
the environment and reduce dependency on volatile raw 
material  markets.  As  shown 
in  Figure 2,  Croatia’s 
resource productivity, with EUR 1.23 generated per kg of 
material consumed in 2023, is below the EU average of 
EUR 2.23 per kg. 

Figure 2: Resource productivity (EUR/kg), 2013–2023 

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Croatia

EU-27

NB:  The  unit  of  measurement  used  is  EUR/kg  chain-linked  volume. 
Chain-linked  volumes  focus  on  changes  on  quantities  and  prices  of 
commodities  in  previous  years,  taking  account  of  inflation,  and  are 
indexed to the nearest appropriate year, in this case 2015. 

Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
7 August 
2024, 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

10 December 

accessed 

2024, 

final 

COM(2020) 98 
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A98%3AFIN. 

11 March 

2020, 

of 

https://eur-

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular strategies at the national, regional and city levels. 
These  should  be  tailored  to  each  national  and  local 
reality, to harness the proximity economy’s (3) potential, 
while following the principles of a holistic whole-value-
chain approach. 

Since  the 
launch  of  the  online  European  Circular 
Economy  Stakeholder  Platform  in  2017 (4)  national, 
regional and local authorities have used the platform to 
share their strategies, roadmaps and good practices, for 
example  alternative  business  models  and  innovative 
technologies. 

Croatia does not have a comprehensive circular economy 
policy framework. However, references to  the need for 
circularity and some initiatives can be found in different 
policies.  These  include  the  latest  waste  management 
plan  for  2023–2028 (5),  the  food  waste  prevention  and 
reduction plan (6), the national development strategy to 
2030 (7)  and  the  low  carbon  development  strategy  to 
2030 (8). 

In  2022,  the  World  Bank  published  the  results  of  the 
project  providing  technical  assistance  on  circular 
economy  approaches  in  solid  waste  management  co-
funded  by  the  EU’s  Cohesion  Fund.  The  analysis  and 
recommendations  focused  on  the  demolition  and 
construction sector, which is important for the country’s 
economy  and  has  significant  potential  for  increased 
circularity  and  decarbonisation.  The  guidelines  for  the 
circular use of construction waste from buildings with the 
status of a cultural good, which were adopted under the 
Croatian recover and resilience plan (RRP), constitute a 
first step to make this sector more circular. Furthermore, 
a  management  system  for  mineral  materials  resulting 
from  the  earthquakes  (and  reconstruction)  in  Sisak-
Moslavina  County and  in  Zagreb was  set up to prevent 

Croatia  6 

excessive  generation  of  construction  and  demolition 
waste. 

Reforms related to the circular economy were included 
in  the  Croatian  RRP (9)  and  reflected 
in  sectoral 
legislation  and/or  plans  for  sustainable  tourism,  skills, 
space and building development, construction waste and 
biowaste. 

Furthermore,  Croatian  cohesion  policy  programmes 
support  the  investments  of  small  and  medium-sized 
enterprises  in  innovative  circular  economy  solutions, 
recycling yards and educational measures. 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
consumption,  with  public  authorities’ 
European 
purchasing power representing around 14 % of EU GDP. 
Public procurement using green or circular criteria (life-
cycle analysis, PaaS (platform as a service), second hand) 
can help drive the demand for sustainable products that 
meet reparability and recyclability standards. 

In  Croatia,  uptake  of  green  public  procurement (10)  is 
monitored annually through the official Electronic Public 
Procurement portal. According to the data gathered, in 
2023  public  purchase  through  public  procurement 
represented about 20 % of Croatian GDP, and about 11 % 
of deriving public contracts included elements of green 
public  procurement (11).  Starting 
in  January  2025, 
contracting  authorities  in  Croatia  are  required  to  apply 
green  public  procurement  criteria  for  the  procurement 
of specific product groups (12). 

The EU Ecolabel and the eco-management and audit 
scheme  

The  number  of  EU  Ecolabel  product  groups  and  the 
number of eco-management and audit scheme (EMAS)-
licensed  organisations  in  each  country  provide  some 
indication of the extent to which the private sector and 
in  that  country  are  actively 
national  stakeholders 

(3) 

(4) 

‘Proximity  and 

European  Commission, 
social  economy 
ecosystem’,  European  Commission  website,  https://single-
market-economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 

Stakeholder 

Economy 

Platform 

to  2028 –  Provisional 

(5)  Ministry  of  Economy  and  Sustainable  Development,  Waste 
management plan of the Republic of Croatia for the period from 
translation,  Zagreb,  2023, 
2023 
https://mingo.gov.hr/UserDocsImages/UPRAVA-ZA-PROCJENU-
UTJECAJA-NA-OKOLIS-ODRZIVO-GOSPODARENJE-
OTPADOM/Sektor%20za%20održivo%20gospodarenje%20otpa
dom/PGO%20eng_web%2011_12_2023.pdf.  
https://narodne-
novine.nn.hr/clanci/sluzbeni/2022_12_156_2535.html. 
https://hrvatska2030.hr/. 

(7) 

(6) 

to 

(9) 

view 

Zagreb, 

(8)  Ministry of Economy and Sustainable Development, Low-carbon 
development strategy of the Republic of Croatia until 2030 with 
2021, 
2050, 
a 
https://mingo.gov.hr/UserDocsImages/klimatske_aktivnosti/od
rzivi_razvoj/NUS/lts_nus_eng.pdf. 
https://commission.europa.eu/document/download/9898347f-
8119-4a40-bff4-
28c8a18ae0be_en?filename=recovery_and_resilience_plan_for
_croatia_hr.pdf. 
https://zelenanabava.hr/hrvatska-predvodnica-zelene-
tranzicije-vlada-rh-donijela-odluku-o-provedbi-zelene-javne-
nabave/. 

(10) 

(11) 

(12) 

https://www.javnanabava.hr/userdocsimages/userfiles/file/Sta
tistička%20izvješća/Godišnja/Statisticko_izvjesce_JN_2023.pdf. 
https://narodne-
novine.nn.hr/clanci/sluzbeni/2024_11_137_2260.html. 

2025 Environmental Implementation Review – Croatia 

 
 
engaged in the transition to a circular economy. The EU 
Ecolabel  is  awarded  to  products  with  best-in-class 
environmental  performance.  EMAS 
is  a  voluntary 
environment  management  scheme  aimed  at  reducing 
the environmental impacts of organisations. 

In  September  2024,  Croatia  had  57  products  and  26 
licences registered in the EU Ecolabel scheme out of the 
total 98 977 products and 2 983 licences in the EU. Take-
up  of  the  EU  Ecolabel  in  the  country  is  therefore  low, 
although 
increased  compared  with  past 
reports (13). Moreover, three organisations from Croatia 
are currently registered in EMAS, the same as in October 
2021 (14) 

it  has 

Croatia’s  CMUR  decreased  by  0.6  percentage  points  in 
2023.  This represents  a  slight step back  since  the 2022 
priority action to take measures to increase the rate. 

Some  progress  has  been  made  on  the  priority  actions 
suggesting  strengthening  the  policy  framework,  as 
measures aiming to transition to a circular economy have 
been introduced. However, a unified and comprehensive 
approach is needed. 

2025 priority actions 

•  Speed  up  the  transition  to  a  circular  economy  by 
implementing an updated national strategy and the 
EU framework and recommendations, in particular to 
complement it with upstream circularity measures. 
•  Develop a unified circular economy strategy focusing 
on  waste  prevention  and  resource  efficiency, 
especially for priority waste streams. 
•  Adopt measures to increase the CMUR. 

Waste management 

Turning waste into a resource is supported by:  

(i) 

(ii) 

addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements 
on the design  of products to ensure that they are 
more sustainable;  
fully  implementing  EU  waste  legislation,  which 
includes  the  waste  hierarchy,  the  obligation  to 
ensure  separate  collection  of  waste, 
landfill 
diversion targets, etc.;  

(iii)  reducing  waste  generation  per  capita  and 

in 

(iv) 

absolute terms;  
increasing  the  recycling  rates  of  waste  containing 
critical  raw  materials  (CRMs),  with  a  view  to 
reducing dependencies and building resilient value 
chains,  and  stimulating  demand  for  recycled 

Croatia  7 

(v) 

content in all products;  
limiting  energy 
materials; and  

recovery 

to  non-recyclable 

(vi)  phasing out landfilling of recyclable or recoverable 

waste. 

One  of  the  main  objectives  of  the  EU  Waste  Law  is  to 
decouple  economic  growth  from 
its  environmental 
impacts.  

The EU’s approach to waste management is based on the 
waste  treatment  hierarchy:  prevention,  preparing  for 
reuse,  recycling,  recovery  and,  as  the  least  preferred 
option,  disposal 
landfilling  and 
includes 
incineration without energy recovery). 

(which 

All legislative proposals in the field of waste management 
put forward by the Commission since 2021 are intended 
to encourage Member States to promote better product 
design,  to  require  producers  to  cover  the  costs  of 
managing the waste resulting from their products and to 
ensure that waste is managed at the higher levels of the 
waste hierarchy.  

The total amount of waste generated in Croatia has more 
than doubled in the last 12 years. This trend is primarily 
driven  by  significant  mineral  waste.  When  excluding 
major  mineral  waste  categories,  Croatia’s  waste 
generation  follows  a  similar  trend,  largely  driven  by 
recyclable waste, which dominates as the largest waste 
fraction.  Croatia’s  GDP  increased  throughout  the  time 
period examined, with a drop in 2020, most likely due to 
the  COVID-19  outbreak.  No  decoupling  between  waste 
generation and economic growth is observed. 

Figure 3:  Generation  of  waste  (total  and  excluding 
major mineral waste), population and GDP, 2010–2022 

accessed 

income)’, 

15 October 

nama_10_gdp, 

Sources:  Eurostat,  ‘GDP  and  main  components  (output,  expenditure 
and 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cu
stom_9301905/default/table; Eurostat, ‘Generation of waste by waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen,  last 
updated 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/defaul
t/table?lang=en; Eurostat, ‘Population change – Demographic balance 
and  crude  rates  at  national  level’,  demo_grind,  accessed  15 October 
2024, 

30 September 

22 October 

accessed 

2024, 

(13) 

European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
website, 
https://environment.ec.europa.eu/topics/circular-economy/eu-
ecolabel/businesses/ecolabel-facts-and-figures_en. 

(14) 

As  of  October  2024.  European  Commission,  ‘EMAS  Register’, 
European 
website, 
Commission 
https://webgate.ec.europa.eu/emas2/public/registration/list. 

2025 Environmental Implementation Review – Croatia 

 
 
  
Croatia  8 

measures  such  as  increasing  the  recycled  content  in 
construction  products  and  the  circular  design (17)  of 
construction  works.  The  Croatian  RRP 
includes 
investments  in  recycling  yards  for  construction  waste 
and a reform regarding the circular use of construction 
waste from buildings with the status of cultural goods. In 
2022, 81.8 % of construction and demolition waste was 
recycled, excluding backfilling, above the EU average of 
79,8%18.  

Boosting implementation – the 2023 Waste Early 
Warning Report 

This  section  focuses  on  the  management  of  municipal 
waste (19),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste Early Warning Report (20) identifying the general 
trends in waste management and the Member States at 
risk of missing 2025 waste targets (see Figure 4). Croatia 
is in the category of countries at risk of missing both the 
municipal  waste  and  the  packaging  waste  targets. 
Croatia is also at risk of not meeting the 2035 target of a 
maximum of 10 % of municipal waste being landfilled. 

https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default
/table?lang=en&category=demo.demo_ind. 

Critical raw materials  

Currently, Croatia’s waste management plan lacks a CRM 
strategy.  However,  Croatia’s  reliance  on  imports  for 
36.3 % of its materials in 2022, well above the EU average 
of  22.4 %,  highlights  its  vulnerability  to  supply  chain 
disruptions.  By 
in  circular 
economy  initiatives,  Croatia  can  not  only  reduce  its 
environmental impact but also strengthen resilience and 
sustainability in the raw material supply, fostering long-
term economic and ecological benefits. 

investments 

increasing 

Construction and demolition waste 

Construction and demolition waste accounts for almost 
40 % of all waste generated in the EU. A recent study (15) 
by  the  Joint  Research  Centre  shows  that  preparing  for 
reuse  and  recycling  operations  are  preferred  over 
landfilling  from  an  environmental 
incineration  and 
perspective  for  most  of  the  different  streams  of 
construction  and  demolition  waste.  However,  the 
economics  are  often  unfavourable  for  preparing  for 
reuse  and  recycling  compared  with  incineration  and 
landfilling. If available technology were to be applied, it 
is estimated that an increase in preparing for reuse and 
recycling of construction and demolition waste in Croatia 
would lead to additional 33 Mt of greenhouse gas (GHG) 
emission  savings  annually  (more  than  the  combined 
annual  GHG  emissions 
from  Estonia,  Latvia  and 
Luxembourg). 

Measures to further increase the preparing for reuse and 
recycling  rate  of  construction  and  demolition  waste 
include  separate  collection  at  source,  for 
instance 
through  digitalised  pre-demolition  audits (16)  (‘resource 
assessments’);  extended  producer  responsibility  (EPR) 
instruments;  and  upstream 
and  other  economic 

(15) 

(16) 

(17) 

European Commission: Joint Research Centre, Cristobal Garcia, 
J.,  Caro,  D.  et  al.,  Techno-economic  and  environmental 
assessment of construction and demolition waste management 
in  the  European  Union,  Publications  Office  of  the  European 
2024, 
Luxembourg, 
Union, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC135
470. 
European Commission: Directorate-General for Internal Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition  and  pre-renovation  audits  of  construction 
works –  Updated  edition  2024,  Publications  Office  of  the 
European 
2024, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-
01aa75ed71a1/language-en. 
European  Commission,  Circular  Economy –  Principles 
buildings 
https://ec.europa.eu/docsroom/documents/39984. 

for 
2020, 

Luxembourg, 

Brussels, 

design, 

(18)    Eurostat, Treatment of waste, by waste category, hazardousness 
operations, 

and 
https://ec.europa.eu/eurostat/databrowser/view/env_wastrt_
_custom_10204995/bookmark/table?lang=en&bookmarkId=e9
74886c-5051-42f7-96ef-6b5a55343ff1 

management 

waste 

(19)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected  waste 
including  paper  and 
from  households, 
cardboard,  glass,  metals,  plastics,  biowaste,  wood,  textiles, 
packaging,  waste  electrical  and  electronic  equipment,  waste 
batteries  and  accumulators,  and  bulky  waste, 
including 
mattresses  and  furniture;  and  (ii)  mixed  waste  and  separately 
collected waste from other sources, where such waste is similar 
in nature and composition to waste from households (Directive 
2008/98/EC, Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(20) 

2025 Environmental Implementation Review – Croatia 

 
 
Figure 4: Member States’ prospects of meeting the 
preparing for reuse and recycling targets for municipal 
waste and packaging waste  

Member States not at risk of missing the 55 % preparing for 
reuse and recycling target for municipal waste and the 65 % 
recycling target for packaging waste 

Member States at risk of missing the preparing for reuse and 
recycling target for municipal waste but not at risk of missing 
the recycling target for packaging waste 

Member States at risk of missing both targets 

Outside coverage 

Source: European Environment Agency (EEA), ‘Many EU Member States 
not  on  track  to  meet  recycling  targets  for  municipal  waste  and 
packaging waste’, briefing No 28/2022, Copenhagen, 2023. Reference 
data © ESRI.  

targets 

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
reaching  certain  waste  management 
for 
municipal  and  packaging  waste.  Member  States  that 
want to use this possibility have to notify the Commission 
24 months  in  advance  of  the  deadline  and  submit  an 
implementation  plan 
laying  down  the  steps  they 
envisage  to  reach  the  postponed  targets  within  a  new 
time  frame.  Regarding  the  2025  targets,  11  Member 
States have used this prerogative, including Croatia. 

On 23 January 2023, Croatia notified the Commission of 
its intention to postpone the attainment of the preparing 
for  reuse  and  recycling  target  for  municipal  waste  for 
2025  established  by  the  Waste  Framework  Directive. 
Croatia  did  the  same  regarding  the  attainment  of  the 

(21)      Directive  2008/98/EC  of  the  European  Parliament  and  of  the 
Council  of  19  November  2008  on  waste  and  repealing  certain 
Directives, Directive - 2008/98 - EN - Waste framework directive 
- EUR-Lex. 

(22)    European  Parliament  and  Council  Directive  94/62/EC  of  20 
December  1994  on  packaging  and  packaging  waste  (OJ  L  365, 
31/12/1994, p. 10–23), Directive - 94/62 - EN - EUR-Lex. 

Croatia  9 

recycling target for plastic and glass packaging waste for 
2025 established by the Packaging and Packaging Waste 
Directive.  Croatia  submitted  an  implementation  plan 
laying down the measures necessary to attain the targets 
within  a  postponed  time  frame  (i.e.  2030  instead  of 
2025). According to the implementation plan, the main 
measures  Croatia  will  put 
include  the 
amendment of the legislative framework and  increased 
capacity  for  the  processing  and  separate  collection  of 
waste. 

in  place 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission is, on one hand, working together with the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (21), the Packaging and 
Packaging Waste Directive22 and the Directive on Waste 
Electrical and Electronic Equipment (23). 

Municipal waste  

Croatia’s  municipal  waste  generation  has  remained 
relatively stable over the past decade but has increased 
since 2019, reaching 478 kg per capita in 2022, below the 
EU-27 average of 513 kg per capita (Figure 5). 

Figure 5:  Municipal  waste  management  and  recycling 
(including preparation for reuse), 2010–2022 

Source: Eurostat, ‘Municipal waste by waste management operations’, 
2024, 
env_wasmun, 

22 October 

accessed 

(23)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  Directive  - 
2012/19 - EN - EUR-Lex. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
 
 
 
 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/def
ault/table. 

rates, affecting EPR and drawing attention to challenges 
in waste management. 

Croatia  10 

Figure 7: Packaging waste generation, 2010–2022 

The  preparing  for  reuse  and  recycling  rate  improved 
steadily from 2010, reaching 36 % in 2023, but remains 
well  below  the  EU-27  average  of  48 %  and  the  2025 
target  (Figure 6).  Biowaste  composting  or  digestion 
remains minimal, despite it constituting over one third of 
Croatia’s  residual  municipal  waste.  The  2022  data  on 
Croatia’s compliance with the 55 % reuse and recycling 
target for 2025 awaits Eurostat validation. While landfill 
rates  have  significantly  decreased,  they  remain  high, 
sitting  at  56 %  in  2022.  Croatia  lacks  municipal  solid 
waste  incineration  facilities  but  plans  to  enable  energy 
recovery  projects 
its  2030  energy 
development  strategy.  Enhanced  efforts  are  needed  to 
meet recycling and landfill reduction targets. 

line  with 

in 

Figure 6: Recycling (including preparation for reuse) and 
landfill rates (%), 2010–2022 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cus
tom_842634/default/table?lang=en. 

Figure 8:  Packaging  waste  recycling  rates  (%),  2010–
2022 

Source: Eurostat, ‘Municipal waste by waste management operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/def
ault/table. 

22 October 

accessed 

Packaging waste  

Packaging  waste  generation  in  Croatia  has  significantly 
increased  from  47 kg  per  capita  in  2012  to  82 kg  per 
capita  in  2022.  However,  this  is  still  significantly  below 
the estimated European average of 186 kg per capita for 
the same year and the second lowest among the EU-27. 

However, its packaging waste recycling rate was 52 % in 
2022, significantly below the EU average of 65 %. Paper 
and  cardboard  dominate  recycling  efforts  due  to  their 
large  waste  share  and  high  recycling  rate,  though  their 
rate is declining, as is that of plastics recycling. Wooden 
packaging  recycling  has  improved  through  better  EPR 
system organisation, while steel recycling was hindered 
by  facility  issues  that  delayed  processing  to  2023. 
Aluminium  and  steel  recycling  rates  have  remained 
below  2025  targets.  Data  quality  issues,  including  the 
under-reporting  of  packaging  on  the  market,  likely 
contribute  to  an  overestimation  of  effective  recycling 

Source: Eurostat, ‘Packaging waste by waste management operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cus
tom_842634/default/table?lang=en. 

Policies to encourage waste prevention  

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 
of EU waste legislation. They set out key provisions and 
investments to ensure compliance with existing and new 
legal  requirements  (e.g.  on  waste  prevention,  on 
separate  collection  for  certain  waste  streams,  on 
recycling and on landfill targets). 

2025 Environmental Implementation Review – Croatia 

 
 
  
 
  
Croatia’s national waste prevention programme (NWPP) 
is integrated into the national waste management plan 
for 2023–2028, with goals extending to 2035. Despite the 
NWPP’s  provision  for  evaluation  every  six  years,  no 
review of the previous NWPP has been conducted. The 
national waste management plan allocates a budget for 
implementing  planned  waste  prevention  measures.  Its 
overarching  goal  is  to  establish  a  waste  management 
system focused on prevention, aiming to decouple waste 
generation  from  economic  growth,  protect  natural 
resources  and  mitigate  environmental  and  health 
impacts.  The  NWPP  identifies  priority  waste  streams, 
including  municipal,  organic,  electronic,  paper,  plastic, 
construction,  textile  and  marine  litter  waste,  selected 
based on their share in total waste, potential benefits of 
prevention  and  ongoing  activities.  Notably,  the  current 
national  waste  management  plan  lacks  a  quantitative 
target to reduce municipal waste, unlike its predecessor. 
Croatia’s  food  waste  reduction  and  prevention  efforts 
involve a detailed plan for 2023–2028, emphasising the 
entire food value chain. 

Policies to encourage separate collection and recycling  

non-households.  Croatia’s 

In Croatia, residual waste is collected door to door, along 
with paper, cardboard, metals, plastics and glass, which 
are  also  collected  via  drop-off  points.  Textiles  are 
collected  exclusively  through  drop-off  points,  while 
biowaste  collection  is  door  to  door  but  not  in  all 
municipalities.  Civic  amenity  sites  handle  waste  wood 
and  other  recyclable  household  waste.  Businesses  are 
required  to  separately  collect  recyclables,  including 
packaging  waste,  and  sorting  packaging  waste  for 
separate  collection  is  mandatory  for  both  households 
and 
pay-as-you-throw 
scheme,  based  on  container  volume  and  collection 
frequency,  is  widely  implemented.  EPR  applies  to  all 
packaging types but lacks advanced fee modulation, with 
no  packaging  taxes  in  place.  Mandatory  deposit  return 
systems  cover  most  aluminium  drink  cans  and 
polyethylene terephthalate and glass bottles but exclude 
plastic  crates  and  wooden  packaging.  From  January 
2027,  the  system  will  expand  to  cover  multi-layer 
packaging  and  beverage  containers  of  less  than  0.2 l, 
which will mean all drink packaging up to 3 l is covered. 
Despite these measures, challenges remain in optimising 
these systems. 

Croatia  11 

Policies to discourage landfilling or incineration 

A  regulation  introducing  a  landfill  tax (24)  has  entered 
into  force  on  1  January  2025  in  line  with  the  waste 
management  plan.  The  tax  of  30  EUR/t  will  gradually 
increase  to  reach  50  EUR/t  in  2029.  The  reform  was 
included as a milestone of the Croatian RRP 

Infringement cases against Croatia over waste 
management failures 

On  2 May  2024,  the  European  Commission  started  an 
infringement case against Croatia for failure to meet the 
targets laid down in the Waste Framework Directive, the 
Packaging  and  Packaging  Waste  Directive  and  the 
Directive on Waste Electrical and Electronic Equipment. 
In the absence of a satisfactory response and action by 
Croatia,  the  Commission  may  decide  to  take  the 
infringement case further. 

Since 2018, there has been an ongoing infringement case 
against  Croatia  for  the  unsatisfactory  application  of 
Directive 1999/31/EC  on  the 
landfill  of  waste  and 
Directive 2008/98/EC  on  waste  because  of  landfilling 
without  prior  treatment,  and  for  failing  to  establish  an 
integrated and adequate network of waste management 
installations  for  this  purpose. 
In  the  absence  of 
satisfactory  measures  by  Croatian  authorities,  the 
Commission  may  decide  to  take  the  infringement  case 
further. 

Croatia has been referred to the Court of Justice for the 
second time after a condemnation in 2019 for the breach 
of the Waste  Framework Directive  regarding  the illegal 
dump  site 
in  Biljane  Donje,  where  approximately 
140 000 t  of  production  residue  of  the  processing  of 
ferromanganese  and 
silicomanganese  has  been 
deposited  since  2010  directly  on  the  ground,  less  than 
50 m from houses. As Croatia has not taken all necessary 
measures to close and rehabilitate the illegal landfill site, 
a  Court  judgment  of  6  March  2025(25)  resulted  in 
penalties.  

In the 2022 Environmental Implementation Review (EIR), 
Croatia  had  five  priority  actions  in  the  field  of  waste. 
Croatia has made some progress on improving separate 
waste collection, implementing support programmes for 
municipalities  and  optimising  EPR  systems.  Substantial 
progress  has  been  made  with  the  introduction  of  the 
landfill  tax 
in  January  2025.  The  national  waste 
management plan has been fulfilled and aligns with the 
revised Waste Framework Directive. 

(24)  Ministry  of  Economy  and  Sustainable  Development,  Waste 
management plan of the Republic of Croatia for the period from 
2023 
translation,  Zagreb,  2023, 
https://mingo.gov.hr/UserDocsImages/UPRAVA-ZA-PROCJENU-
UTJECAJA-NA-OKOLIS-ODRZIVO-GOSPODARENJE-

to  2028 –  Provisional 

(25) 

OTPADOM/Sektor%20za%20odr%C5%BEivo%20gospodarenje%
20otpadom/PGO%20eng_web%2011_12_2023.pdf. 
Judgment of 6 March 2025, European Commission v Republic of 
Croatia, 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:62023CJ0315 

EU:C:2025:154 

C-315/23, 

2025 Environmental Implementation Review – Croatia 

 
 
Croatia  12 

2025 priority actions  

• 

• 

• 
• 

Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps of the waste hierarchy. In particular, improve 
collection  and  increase  treatment  capacity  for  bio-
waste.   
Improve municipal waste preparation for reuse and 
recycling. 
Increase the recycling rates of packaging waste. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE).  

• 

•  Develop EPR schemes for problematic waste.  
• 
Implement,  harmonise  and  gradually 
increase 
landfill  taxes  to  phase  out  landfilling  of  recyclable 
and recoverable waste. 
Ensure the achievement of the 2025 waste targets, 
following  the  recommendations  made  by  the 
Commission  in  the  early  warning  reports  where 
applicable. 
Invest in waste prevention measures to reduce the 
total amount of waste generated.  

• 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
2. Biodiversity and natural capital 

Croatia  13 

Global and EU biodiversity frameworks

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and action plans (NBSAPs), or to communicate national 
targets  aligned  with  the  global  targets,  by  the  end  of 
2024. 

The EU biodiversity strategy for 2030 (BDS) aims to put 
EU  biodiversity  on  a  path  to  recovery  by  2030.  It  sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
as  measures 
and 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (26)  and  a  dashboard  of  indicators (27) 
provide information on implementation progress. 

implementation 

enable 

to 

recently 

adopted 

EU  Nature  Restoration 
The 
Regulation (28) is the first EU-wide, comprehensive law of 
its kind and a key instrument for the EU to deliver on the 
global  biodiversity  targets  for  2030.  It  lays  down  an 
overarching  objective  at  the  EU  level  to  put  in  place 
effective  restoration  measures  on  20 %  of  EU  land  and 
sea by 2030 and for all ecosystems in need of restoration 
by  2050.  To  achieve  this,  it  sets  binding  targets  for 
Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted  to  the  Convention  on  Biological  Diversity  its 

(26) 

(27) 

(28) 

(29) 

Actions 

Tracker 

Strategy 

Strategy 

Dashboard 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
the 
see  also 
http://data.europa.eu/eli/reg/2024/1991/oj; 
Commission 
law 
the 
on 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 
Parliament  of  the  Republic  of  Croatia,  The  nature  protection 
strategy and action plan of the Republic of Croatia for the period 

page 

web 

report on GBF-aligned EU targets that stem from the BDS 
and from other policy instruments under the European 
Green Deal. 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 
needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

In 

Croatia’s latest NBSAP is the national nature protection 
strategy  and  action  plan  for  2017–2025 (29).  In  August 
2024,  Croatia  uploaded  30  new  national  targets  to  the 
Convention  on  Biological  Diversity’s  online  reporting 
tool (30). 

The EU aims to allocate to biodiversity objectives at least 
7.5 % of annual spending under the EU budget in 2024, 
rising to 10 % in 2026 and 2027. For additional details on 
biodiversity  financing  and  investments  for  Croatia,  see 
Chapter 5. 

Nature protection and restoration – Natura 
2000 

Natura  2000 (31),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (32); and (iii) effective management 

2017–2025, 2017, https://www.cbd.int/doc/world/hr/hr-nbsap-
v3-en.pdf. 
https://ort.cbd.int/national-targets?countries=hr. 

(30) 
(31)  Natura  2000  comprises  sites  of  community  importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as special 
protection  areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 7 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. A special area of conservation (SAC) is an SCI designated 
by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 

(32) 

2025 Environmental Implementation Review – Croatia 

 
 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

Figure 9: Natura 2000 terrestrial protected area 
coverage per Member State (%), 2023 

Croatia  14 

Setting up a complete and coherent network of Natura 
2000 sites 

The  setting  up  of  a  complete  and  coherent  network  of 
Natura  2000  sites 
is  a  cornerstone  of  the  EU’s 
international commitments, under the BDS and GBF, to 
legally  protect  a  minimum  of  30 %  of  its  land  area  and 
30 % of its sea area. 

the 

these 

requires 

commitments 

full 
Meeting 
implementation of Article 3 of the Habitats Directive. The 
Natura 2000 network should represent a complete and 
coherent  ecological network composed of sites hosting 
natural habitat types and species of community interest. 
The  Natura  2000  network  enables  the  natural  habitat 
types  and  the  species’  habitats  concerned  to  be 
maintained  or,  where  appropriate,  restored  to  a 
favourable conservation status in their natural range. 

Croatia hosts 76 habitat types and 244 species covered 
by  the  Habitats  Directive.  The  country  is  also  home  to 
populations  of  125  bird  species  listed  in  Annex I  to  the 
Birds Directive. 

In  2023,  36.7 %  of  Croatia’s  land  area  was  covered  by 
Natura  2000  (EU  average:  18.6 %).  Special  protection 
areas (SPAs) classified under the Birds Directive covered 
30.2 % (EU average: 12.8 %) and SACs under the Habitats 
Directive  covered  28.4 %  (EU  average:  14.3 %)  of  the 
country’s territory. Although the terrestrial network can 
be considered largely complete, there are still gaps in the 
marine  network,  which  requires  the  designation  of 
additional SPAs and SCIs. 

Taking  into  account  both  Natura  2000  sites  and  other 
nationally  designated  protected  areas,  Croatia  legally 
protects  38.2 %  of  its  terrestrial  area  (EU-27  average: 
26 %)  and  9.5 %  of  its  marine  area  (EU-27  average: 
12 %) (33). 

Source: European Environment Agency (EEA), ‘Natura 2000 Barometer’, 
2023  data,  accessed  March  2025,  https://www.eea.europa.eu/data-
and-maps/dashboards/natura-2000-barometer. 

Designating special areas of conservation and setting 
site-specific conservation objectives and measures 

In order to ensure that SCIs contribute to the objectives 
of the Habitats Directive, Member States must designate 
them  as  SACs,  setting  site-specific  conservation 
objectives based on the ecological needs of the species 
and  habitats  present  on  the  sites.  Such  site-specific 
conservation  should  define  attributes  and  targets  that 
describe the habitats or species’ condition as favourable 
or  unfavourable,  addressing key  pressures  and threats. 
Under Article 6 of the Habitats Directive Member States 
must establish and implement measures to achieve these 
objectives.  Article 6  of  the  Habitats  Directive  requires 
Member States to establish and implement conservation 
measures for the realisation of the objectives of the site. 

There  are  745  SACs  and  38  SPAs  in  Croatia.  During  the 
programming  period  2014-2020,  several  national 
projects, co-financed by EU funds, have supported: 

• 

• 
• 

• 

• 

implementation  of  planned  conservation 

the establishment of the Natura 2000 management 
framework; 
the drawing up of management plans for the sites; 
the 
measures; 
the  development  of  monitoring  and  reporting 
systems; and 
the  mapping  of  coastal  and  seabed  habitats  and 
biodiversity in waters under Croatian jurisdiction. 

Site-specific conservation objectives are established  for 
143  out  of  745  SACs  and  for  all  38  SPAs.  Management 

(33) 

Eurostat,  ‘Protected  areas’,  env_bio4, 
last  updated  2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en.  Data  used  are  for  the  terrestrial  protected 

area  percentage  in  2022  and  the  marine  protected  area 
percentage in 2021. 

2025 Environmental Implementation Review – Croatia 

 
 
 
plans with conservation measures were adopted for 365 
sites (corresponding to 65 % of the area of the network). 

Therefore, more efforts are necessary to  establish site-
specific  conservation  objectives  and  to  put  in  place 
practical conservation measures for all sites with regard 
to  activities  linked  to  the  most  important  pressures,  in 
particular  agriculture,  forestry,  fisheries,  energy  and 
water management.  

Some  progress  has  been  made  by  Croatia  on  the  2022 
priority actions, but it is necessary to continue working 
on  them  to  speed  up  and  finalise  their  fulfilment.  The 
2025  priority  actions  therefore  reiterate  the  needs 
identified in 2022, but reflect the improvements made. 

2025 priority actions 

• 

of 

the 

•  Complete the Natura 2000 site designation process  
• 
Finalise 
site-specific 
establishment 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 
Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
the  Nature  Restoration 
implementation  of 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 
Strengthen the collection of reliable data  to assess 
the  conservation  status  of  protected  habitats  and 
species by ensuring that all are covered by a sound 
monitoring system. 
Strengthen  the  integration  of  biodiversity  actions 
into other policies, e.g. energy, agriculture, fisheries, 
forestry,  urban  and  infrastructure  planning  and 
sustainable  tourism,  and  promote  communication 
between stakeholders.   

• 

• 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (34). 

(34) 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
European 

Luxembourg, 

Union, 

Croatia  15 

One of the primary objectives of the Habitats Directive is 
the  maintenance  of  or  restoration  to  favourable 
conservation status of all species of community interest. 
Moreover, the Birds Directive also aims to ensure that all 
wild  birds  in  the  EU  enjoy  a  secure  status.  In  order  to 
achieve these objectives, it will be necessary to address 
key  pressures  and  threats.  The  Birds  Directive  and  the 
Habitats  Directive  lay  down  a  framework  of  species 
protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

According to Croatia’s report on the conservation status 
of habitats and species covered by the  Article 17 of the 
Habitats Directive for 2013–2018 (the first such report it 
had ever submitted), 39.2 % of habitats assessed showed 
good  conservation  status.  However,  the  share  of 
protected  species  assessed  showing  good  conservation 
status  in  2018  was  only  7.14 %.  Many  conservation 
statuses,  particularly 
(46.67 %),  were 
reported as unknown, which indicates a very large gap in 
the  monitoring  system.  As  far  as  birds  are  concerned, 
only  10 %  of  breeding  species  showed  increases  or 
stability  in  their  short-term  population  trends  (for  key 
wintering species, this figure was 11 %). However, there 
is a very large knowledge gap (83 % for breeding species 
and 84 % for key wintering species). 

for  species 

The habitat groups faring poorly are, in particular, dunes, 
bogs, mires and fens, grasslands, freshwater habitats and 
coastal habitats. The species groups faring poorly are, in 
particular, mammals, fish, vascular plants and molluscs. 
However,  it  should  be  noted  that  there  are  large 
knowledge gaps on the conservation status of species. 

Under  Article 17  of  the  Habitats  Directive,  Member 
States are required to report on the conservation status 
of  habitats  and  species  every  six  years.  The  current 
reporting cycle, covering the years 2019 to 2024, is due 
for submission in July 2025. Figures 10 and 11 show the 
latest available conservation status data. 

https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 

2025 Environmental Implementation Review – Croatia 

 
 
Figure 10: Assessments of conservation status of 
habitats for the 2007–2012 and 2013–2018 reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in area conservation 
status in a Member State may result from changes to methods or use 
of better data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

December 

accessed 

2019, 

Figure 11:  Assessments  of  conservation  status  of 
species  for  the  2007–2012  and  2013–2018  reporting 
periods 

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in area conservation 
status in a Member State may result from changes to methods or use 
of better data, rather than reflecting genuine changes. 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

December 

accessed 

2019, 

Croatia  16 

restoring 

favourable 
Progress  on  maintaining  or 
conservation  status  of  species  and  habitats  is  slow,  in 
part  due  to  a  large  knowledge  gap  and  insufficient 
monitoring.  The  main  human-induced  pressures  as 
reported under  Article 17 of  the  Habitats  Directive and 
Article 12  of  the  Birds  Directive  are  from  agriculture, 
forestry,  urban  development,  changes  in  the  water 
regime, climate change and alien species. 

An  infringement  case  is  ongoing  as  Croatia  has  not 
correctly  applied  the  Habitats  Directive  to  ensure  that 
changes  to  wind  farm  projects  affecting  Natura  2000 
sites are assessed appropriately. The correct application 
of rules is crucial to ensure that biodiversity concerns are 
taken into account in decision-making. 

for 

failing 

On  12  February  2025,  the  Commission  started  an 
infringement  case  against  Croatia 
to 
implement  the  measures  required  under  the  Habitats 
Directive to monitor and prevent the incidental capture 
and  killing  of  protected  species  by  fishing  vessels.  If 
shortcomings  are  not  properly  addressed, 
the 
Commission  may  decide  to  take  the  infringement  case 
further. 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 

—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

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

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

high-diversity landscape features; and 
increase the area under organic farming to at least 
25 %. 

The  Vision  for  agriculture  and  food,  adopted  by  the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 

2025 Environmental Implementation Review – Croatia 

 
 
 
adequately targeted toward this objective(35.) 

CAP  and  the  national  CAP  strategic  plans  (SPs)  are  key 
instruments  to  facilitate  and  strengthen  the  efforts  of 
European  farmers  to  protect  biodiversity  and  the 
environment  at 
large.  The  Commission  approved 
Member  States’  CAP  SPs  in  2022  for  the  programming 
period  2023–2027.  The  CAP  is  the  largest  source  of 
funding  for  the  implementation  of  EU  environment 
policy, particularly for biodiversity. SPs should continue 
playing  a  key  role  in  the  protection  of  soil,  water,  air 
quality and biodiversity.  

indicators 

certain  CAP 

While 
focus  on 
result 
interventions favouring sustainable agriculture practices 
that  regenerate  ecosystems,  the 
impact  of  these 
measures  is  difficult  to  assess.  The  uptake  of  the  eco-
schemes is voluntary for farmers. 

The  utilised  agricultural  area  in  Croatia  increased  from 
1 330 970 ha  in  2012  to  1 564 050 ha  in  2016  and 
decreased to 1 486 050 ha in 2023 (36). 

‘share  of  agricultural 

Landscape features are fragments of non-productive and 
typically – but not exclusively – semi-natural vegetation 
present in or adjacent to agricultural land. They provide 
ecosystem  services  and  support  for  biodiversity.  The 
indicator 
land  covered  with 
landscape  features’  is  the  ratio  between  the  area 
covered  by  non-productive  landscape  features  and  the 
area  covered  by  agricultural  land.  Based  on  the  Land 
Use/Cover  Area  Frame  Survey 
landscape  features 
estimates, the share of agricultural land covered by non-
productive landscape features in Croatia is 6.9 %, above 
the EU average. At the EU level, landscape features cover 
5.6 % of agricultural land. 

In 2024, the CAP basic regulations were amended (37) to 
simplify certain rules, inter alia, the standards for good 
agricultural and environmental condition (GAEC) of land. 
These  changes  removed  the  obligation  for  farmers 
benefiting  from  CAP  area-related  support  to  have  a 
minimum  share  of  3–4 %  of  non-productive  area  or 
landscape  features  in  their  arable  land,  but  kept  the 

(35) 

(36) 

(37) 

5 December 

European  Commission,  Vision  for  Agriculture  and  Food, 
https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en  
Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en.  
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 

Croatia  17 

obligation under GAEC 8 to maintain existing landscape 
features. The amended regulations set out an obligation 
for Member States to establish and provide support for 
eco-schemes covering practices for the maintenance of 
non-productive areas, such as land lying fallow, and for 
the establishment of new landscape features on arable 
land. 

The recently adopted Nature Restoration Regulation (38) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (39). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity.  As  shown  in  the  Figure 12,  it  is  estimated 
that 8.94 % of Croatia’s utilised agricultural land area is 
used  for  organic  farming.  This  is  lower  than  the  EU 
average of 10.50 % (40). Croatia is currently contributing 
below the average to achieving the target of 25 % of the 
EU’s agricultural land being used for organic farming by 
2030. 

Figure 12: Share of total utilised agricultural area 
occupied by organic farming per Member State (%), 
2022 

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 

(38) 

(39) 

(40) 

in  cropland  mineral  soils’  and 

Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
which 
is  currently  under  review;  European  Commission, 
Agriculture biologique au sein de l’union européenne, factsheet, 
Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 

2025 Environmental Implementation Review – Croatia 

 
 
 
2024, 
5 December 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

2025 priority action 
• 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
environmental needs of Croatia.  

practices 

address 

and 

to 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
resilience,  adaptation  and 
security  and  climate 
mitigation. 

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 
resilience (41) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 
the  proposed  directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  the  view  of  attaining 
healthy soils by 2050. 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
soil 
compaction, 

soil  organic 

loss  of 

carbon, 

(41) 

(42) 

final 

Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0416. 
Commission  staff  working  document –  Impact  assessment 
report: Annexes – Accompanying the proposal for a directive of 
the European Parliament and of the Council on soil monitoring 
and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 

2023, 

5 July 

of 

Croatia  18 

contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Croatia (42). 

The  greatest  contributor  to  Croatia’s  unhealthy  soils  is 
loss  of  soil  organic  carbon  in  mineral  soils (43),  which 
affects  7 %  of  the  land  area,  representing  76 %  of 
cropland  and  grassland  area,  particularly  in  the  north-
east.  Other  indicators  for  unhealthy  soils  are  negligible 
for Croatia. 

Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
to 
for 
large  herbivores.  Grasslands  are  essential 
agriculture and livestock herding. Natural grasslands also 
play  an  important  role  in  storing  carbon.  However, 
changes  in  agricultural  practices  and  land  uses  have 
caused  grasslands  to  disappear  at  an  alarming  rate, 
making  them  one  of  Europe’s  most  threatened 
ecosystems. 

According  to  the  report  submitted  by  Croatia  under 
Article 17  of  the  Habitats  Directive  for  2013–2018,  the 
majority  of  assessments  of  the  conservation  status  of 
grassland  habitat  types  protected  under  the  Habitats 
Directive are unfavourable and only 28 % are favourable. 
(e.g. 
Agricultural  practices  and  natural 
abandonment)  are  the  main  pressures  on  protected 
grasslands in Croatia. It is therefore crucial to implement 
appropriate  measures  to  address  these  and  other 
pressures in order to improve their conservation status. 
Measures  to  maintain  traditional  agricultural  practices 
favourable to grassland habitat types, as well measures 
to regulate damaging agricultural practices, are urgently 
needed, in particular in Natura 2000 sites designated for 
these habitats’ protection. 

causes 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 

5 July 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

2023, 

ASSESSMENT 

(43)  De Rosa, D., Ballabio, C., Lugato, E., et al., ‘Soil organic carbon 
stocks in European croplands and grasslands: How much have we 
lost in the past decade?’, Global Change Biology, Vol. 30, No 1,, 
2023, e16992, https://doi.org/10.1111/gcb.16992. 

2025 Environmental Implementation Review – Croatia 

 
 
 
Croatia  19 

Several  guidelines  on  forestry  management  were 
published  in  2023.  They  covered  biodiversity-friendly 
afforestation, reforestation and tree planting; closer-to-
nature  forest  management;  and  defining,  mapping, 
monitoring  and  strictly  protecting  primary  and  old-
growth  forests.  Further  guidance  on  payment  schemes 
for ecosystems services has also been published. 

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law  (44) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (45).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

In  2020,  forests  cover  34.7%  of  Croatia’s  territory (46), 
and more than 25 % of the assessments of forest habitats 
show  a  favourable  conservation  status,  which  is  well 
above the EU average (47). In 2020, Croatia had 7 000 ha 
of primary forests (48). On 14 June 2022 the Commission 
used  the  EU  Pilot  mechanism  to  address  a  breach  in 
in  Croatia.  The  Croatian 
respect  of 
response has been received, and it is under assessment. 

logging 

illegal 

special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I to the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 
peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

According  to  the  report  submitted  by  Croatia  under 
Article 17 of the Habitats Directive for 2013–2018, 78 % 
of  assessments  of  the  conservation  status  of  peatland 
habitat types protected under the Habitats Directive are 
unfavourable,  and  the  rest  report  unknown  status. 
Natural  processes  and  human-induced  changes  in  the 
water  regime  are  the  main  pressures  on  peatlands  in 
Croatia. 

With  regard  to  coastal  wetlands,  the  relevant  habitat 
types protected under the Habitats Directive (e.g. habitat 
types  1140,  1150  and  1160)  all  have  unknown 
conservation  status  in  the  report  submitted  by  Croatia 
for  2013–2018.  Therefore  it  is  urgent  to  close  this 
knowledge gap and act accordingly to address potential 
pressures on and threats to these important habitats. 

Forest ecosystems 

Forests are important carbon sinks, and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 
The EU forest strategy for 2030, adopted in July 2021, is 
a  plan  of  actions  to  promote  the  many  services  that 
forests  provide.  Its  key  objective  is  to  ensure  healthy, 
diverse  and  resilient  EU 
forests  that  contribute 
significantly to the achievement of the EU’s biodiversity 
and climate ambitions. About 27 % of the forest area in 
the EU is covered by habitat types listed in Annex I to the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
is  a 
Directives, 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

(44)   Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 
forests, 
2023, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en 

COM(2023)728, 

November 

22 

(45) 

(46) 

Union, 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
European 
2020, 
https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
Forest information system for Europe, ‘Countries – FISE country 
factsheets’,  forest  information  system  for  Europe  website, 
https://forest.eea.europa.eu/countries. 

Luxembourg, 

(47) 

(48) 

the 

base: 

Accompanying 

Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 
European  Commission:  Joint  Research  Centre,  Mapping  and 
assessment  of  primary  and  old-growth  forests  in  Europe, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
p. 13, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC124
671. 

2025 Environmental Implementation Review – Croatia 

 
 
 
Figure 13:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  per  Member  State  (%  of 
assessments), 2013–2018 

Source: Commission staff working document – New EU forest strategy 
for  2030,  SWD(2021) 652 
final  of  16 July  2021,  p. 24,  eur-
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

The  EU  Timber  Regulation  (EUTR) (49)  prohibits  the 
placing on the EU market of illegally harvested timber.  

(EUDR) (50)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(51).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that  are  produced  using  any  of  a 
list  of  seven 
commodities  have  no  links  to  deforestation.  The  EUDR 
repeals the EUTR.  

force 

into 

Marine ecosystems 

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

(49) 

(50) 

Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(51)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 
Commission  Decision  (EU) 2017/848  of  17 May  2017  laying 
down  criteria  and  methodological  standards  on  good 

(52) 

Croatia  20 

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
in  the  MSFD  have  become  available. 
descriptor 
Nevertheless, Member States have to report updates by 
October  2024,  and  these  will  be  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
in  accordance  with  the  MSFD  and  the 
reporting, 
Commission  GES  decision (52),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold  values  for  the  descriptors  in  the  MSFD  that 
may  have  been  established  in  cooperation  with  other 
Member States at the EU or regional level (53). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (54). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
levels  of 
work 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated programmes 
of measures, which are required under Article 13 of the 
MSFD and  which  must  be updated every  six years. The 
Commission has assessed Member States’ programmes 
of measures. However, Croatia reported its programme 
of measures too late to be included in the Commission’s 
general assessment of the programmes of measures (55) 
of the Member States. 

2025 priority action 

•  Report  updates  on  the  assessment  of  the  state  of 
Croatia’s  marine  waters, 
its 
determinations  of  GES (56),  which  are  expected  to 
include  any  threshold  values  for  the  descriptors  in 
the  MSFD  that  may  have  been  established  in 
cooperation with other Member States at the EU or 

targets  and 

its 

environmental  status  of  marine  waters  and  specifications  and 
standardised  methods  for  monitoring  and  assessment,  and 
repealing  Decision 2010/477/EU  (OJ  L 125,  18.5.2017,  p. 43), 
http://data.europa.eu/eli/dec/2017/848/oj. 
Communication from  the  Commission –  Commission notice  on 
the threshold values set under the Marine Strategy Framework 
Directive  (Directive 2008/56/EC)  and  Commission  Decision 
(EU) 2017/848 
11.3.2024), 
(OJ 
http://data.europa.eu/eli/C/2024/2078/oj. 
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 

C/2024/2078, 

C, 

https://mzozt.gov.hr/UserDocsImages/Uprava_vodnoga_gospo
darstva_i_zast_mora/Strategija_upravljanja_morem/Program%
20mjera_2024.pdf. 
In accordance with Article 17 of Directive 2008/56/EC. 

(53) 

(54) 

(55) 

(56) 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
regional level. 

Prevention and management of invasive alien 
species 

Invasive  alien  species  (IAS)  are  a  major  cause  of 
biodiversity  loss  in  the  EU.  Besides  inflicting  direct  and 
indirect damage on nature and the economy, some IAS 
also carry and spread infectious diseases, posing a threat 
to  humans  and  wildlife.  Regulation  (EU)  No 1143/2014 
(the  IAS  Regulation)  aims  to  prevent,  minimise  and 
mitigate  the  adverse  impacts  of  IAS  on  biodiversity.  It 
focuses action on a list of IAS of EU concern (the ‘Union 
list’), which is regularly updated (57). 

The third update of the Union list (58) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS  Regulation (59) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already widespread on their territory. 

This  aligns  with  target 6  of  the  GBF  to  reduce  the 
introduction of IAS by at least 50 % by 2030 and minimise 
their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (60).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (61),  and  at 
USD 423 billion annually at the global level (62). 

The total number of IAS of Union concern in the country 
is 28. This includes 23 species recorded in the previous 
EIR (2021) and 5 new additions. Of these new additions, 
1 was already on the Union  concern list in 2021, and 4 

(57) 

(58) 

Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update  the  list  of  invasive  alien  species  of  Union  concern  (OJ 
L 186,  13.7.2022,  p. 10),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203.  

Croatia  21 

were  added 
Regulation (EU) 2022/1203. 

later  under  Commission  Implementing 

Figure 14:  Number  of  IAS  of  EU  concern,  based  on 
available georeferenced information for Croatia, 2024 

Croatia  made  progress  on  its  2022  priority  action  by 
implementing the action plans to control the spread of 
IAS in accordance with the IAS Regulation. 

2025 priority action 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  the 
capacity of inspection authorities. 

Ecosystem assessment and accounting 

The  BDS  calls  on  Member  States  to  better  integrate 
biodiversity  considerations  into  public  and  business 
decision-making  at  all  levels  and  to  develop  natural 
capital accounting. 

(59) 

Regulation (EU) No 1143/2014 of the European Parliament and 
of  the  Council  of  22 October  2014  on  the  prevention  and 
management  of  the  introduction  and  spread  of  invasive  alien 
species (OJ L 317, 4.11.2014, p. 35). 

(60)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(62) 

(61)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
Summary 
Biodiversity 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

Science-Policy 
on 
for 
Services), 
Invasive  alien  species  assessment,  2023, 

(Intergovernmental 

Ecosystem 

and 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Croatia  22 

Similarly, target 14 of the GBF (63) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (64). 

The  amended  Regulation  (EU) 691/2011  on  European 
environmental  economic  accounts (65)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

An ecosystem assessment is an analysis of the condition 
of ecosystems and the pressures acting on them, as well 
as  the  benefits  that  they  provide  to  people,  either 
directly or indirectly through the economy. 

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 

biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (66). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

Croatia was involved in two Eurostat pilot studies to test 
the  feasibility  of  introducing  ecosystem  accounting  in 
2023  and  2024  (with  regard  to  air  filtration,  crop 
pollination and the local climate). 

Natural  capital  assessments  help  private  businesses  to 
better  understand  both  the  negative  and  positive 
impacts that they have on nature, and to appreciate how 
nature contributes to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

There  is  still  no  Croatian  business  and  biodiversity 
network  member  of  the  EU  Business  &  Biodiversity 
Platform. 

2025 priority action 

• 

Support the development of the national business 
and biodiversity network. 

(63)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  Global 
Framework 
Biodiversity 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem 
policymakers, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 

Assessment – 

Summary 

(64) 

for 

(65) 

(66) 

final 

Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 
introducing  new  environmental  economic  accounts  modules, 
COM(2022) 329 
https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 
The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and 
a cross-media communication strategy.  

11 July 

2022, 

of 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Croatia  23 

3. Zero pollution

Clean air

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

The EU has developed a comprehensive suite of air quality 
policies (67).  These  set  health-based  EU  air  quality 
standards (68)  and  stipulate  Member  States’  national 
emission  reduction  commitments (69)  for  several  air 
pollutants.  

The  air  quality  in  Croatia  is  generally  good,  with  some 
exceptions. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (70)  for  Croatia  attribute  3 800  deaths  each  year  (or 
34 200  years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (71); 450 deaths each year (or 4 100 YLL) to nitrogen 
dioxide (NO2) (72); and 980 deaths each year (or 8 900 YLL) 
to ozone (73). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Croatia since 2005, while GDP growth has 
continued  (see  Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (74)  in  2024, 
Croatia has met its emission reduction commitments for 
2020–2029  for  air  pollutants  NOx,  non-methane  volatile 

organic  compounds  (NMVOC),  sulphur  dioxide  (SO2), 
ammonia  (NH3)  and  PM2.5.  According  to  the 
latest 
projections  submitted  under  Article 10(2)  of  the  NECD, 
Croatia  is  projected  to  meet  its  emission  reduction 
commitments for 2030 onwards for NMVOC, SO2, NH3 and 
PM2.5, but not for NOx. 

Croatia  submitted  its  first  national  air  pollution  control 
programme  (NAPCP)  to  the  Commission  on  11 October 
2019 and plans to adopt an updated NAPCP in 2025 that 
includes  updated  policies  and  measures  to  reduce  air 
emissions. 

Figure 15: Emission trends for main pollutants / GDP in 
Croatia (%), 2005–2022 

250%

200%

150%

100%

50%

0%

NH₃

PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

(67) 

(68) 

(69) 

(70) 

(71) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
Commission 
website, 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en.  
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
European 
website, 
Commission 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants_en. 
EEA, Harm to human health from air pollution in Europe: Burden 
of  disease  2024,  briefing  No 21/2024,  Copenhagen,  2024, 
https://www.eea.europa.eu/en/analysis/publications/harm-to-
human-health-from-air-pollution-2024. 
Particulate matter (PM) is a mixture of aerosol particles (solid and 
liquid) covering a wide range of sizes and chemical compositions. 
PM10  refers  to  particles  with  a  diameter  of  10 µm  or  less.  PM2.5 

refers to particles with a diameter of 2.5 µm or less. PM is emitted 
from many human sources, including combustion. 

(72)  Nitrogen  dioxide  (NO2)  here  pertains  to  a  group  of  gases  called 
NOx, which also comprises nitrogen monoxide (NO). NOx is emitted 
during fuel combustion – for example, from industrial facilities and 
the road transport sector. 
Low-level  ozone 
is  produced  by  photochemical  action  on 
pollution.  This  year,  for  the  first  time,  the  impact  of  long-term 
exposure to ozone has also been taken into account. In previous 
analysis by the EEA, only the impact of short-term exposure was 
estimated. 

(73) 

(74)  Directive (EU) 2016/2284 of the European Parliament and of the 
Council  of  14 December  2016  on  the  reduction  of  national 
emissions of certain atmospheric pollutants, amending Directive 
2003/35/EC  and  repealing  Directive  2001/81/EC  (OJ  L 344, 
17.12.2016, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Figure 16: PM2.5 and NOx emissions by sector in Croatia 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
1,2%

5,7%

78,9%

6,2%

7,4%

0,7%

NOₓ

0,3%

59,9%

12,0%

9,3%

10,5%

8,1%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 
https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

2024, 

In  2023,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive (AAQD) (75) were registered 
for PM10 in one air quality zone  in Croatia. Furthermore, 
the target values for ozone concentrations have not been 
met in two air quality zones (76). 

Persistent  breaches  of  air  quality  requirements,  which 
have  severe  negative  effects  on  health  and  the 
environment,  are  being  followed  up  by  the  European 
Commission through infringement procedures covering all 
for 
Member  States  concerned, 
exceedances of PM10 and PM2.5 limit values. The aim is that 
appropriate  measures  be  put  in  place  to  bring  all  air 
quality zones into compliance. 

including  Croatia 

(75)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 
EEA, 
Eionet 
(https://cdr.eionet.europa.eu/). 

Repository 

11.6.2008, 

Central 

L 152, 

p. 1), 

Data 

(76) 

(OJ 

(77)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 

Croatia  24 

In  the  2022  EIR,  Croatia  received  three  priority  actions. 
Croatia has made some progress on two of them relating 
to the further reduction of emissions in the context of the 
NAPCP.  While  the  latest  data  show  compliance  with  the 
2020–2029  emission  reduction  commitments,  Croatia  is 
still  projected  not  to  reach  the  emission  reduction 
commitment for NOx for 2030 onwards. The third priority 
action  was  to  ensure  full  compliance  with  EU  air  quality 
standards and maintain downward emission trends. Based 
on the latest data, Croatia has made some progress in this 
regard. Since 2019, downward emission trends have been 
reported  for  all  main  pollutants.  However,  exceedances 
above limit values and target values remain for PM10 and 
ozone, requiring further action. 

2025 priority actions 

•  As part of the NAPCP, take action to reduce emissions 

of air pollutants. 

•  Ensure  full  compliance  with  the  current  AAQD 
standards, also in light of future stricter requirements 
under the revised AAQD. 

Industrial emissions 

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

(i)  protect  air,  water  and  soil  and  to  prevent  harmful 

effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii) improve energy and resource efficiency; 
(iv) clean up contaminated sites. 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (77). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (78) . 

In Croatia, there were about 270 installations covered by 
in  2022.  The  main  sectors  were  waste 
the 
management  (33 %),  intensive  rearing  of  poultry  or  pigs 

IED 

emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 
Portal, 
Industrial 
European 
EEA, 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 

Emissions 

(78) 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
(25 %),  the  mineral  sector  (10 %)  and  the  metal  sector 
(8 %). 

Figure 18: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

Croatia  25 

Figure 17 shows the damage  to health and environment 
due to the main industrial air pollutants. As this depends 
on, among other factors, the size of the industrial sector in 
each  Member  State,  the  figure  also  shows  the  ratio 
between the damage and the industrial activity (expressed 
in gross value added (GVA)), which gives an indication of 
the emissions ‘intensity’. Croatia is in 19th place in terms 
of  damage  in  the  EU,  but  comes  10th  for  emissions 
intensity,  above  the  EU  average  of  EUR 27.5/EUR 1 000 
GVA. The main industrial contributors to emissions to air 
(79) are the energy sector and the mineral industry for NOX 
emissions, the energy sector for dust emissions, and the 
energy  sector  and  mineral  sector  for  SO2  and  heavy 
metals. 

Figure 17: Industrial air pollution damage and intensity 
per Member State, 2021 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
https://industry.eea.europa.eu/analyse/industrial-
Portal, 
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 18. 

NB: Cd, cadmium; Hg, mercury; Ni, nickel; Pb, lead; total N, total nitrogen; 
total P, total phosphorous. 

Source:  EEA,  ‘Industrial  pollutant  releases to  water  in Europe’,  30 May 
2024, 
https://www.eea.europa.eu/en/analysis/indicators/industrial-
pollutant-releases-to-water. 

Figure 19 shows the industrial emissions of heavy metals 
to water in Croatia, taking into account the human toxicity 
of each metal, as well as the emissions intensity, based on 
its ratio with industrial activity (expressed in GVA). Croatia 
has the 22nd highest amount of emissions of heavy metals 
to  water  but  is  the  23rd  highest  for  emissions  intensity 
(below the EU average intensity of 0.864 kg/EUR 1 billion 
GVA).  As  shown 
industrial 
contributor to emissions to water in Croatia is the refining 
sector for heavy metals. 

in  Figure 20,  the  main 

Figure 19: Industrial releases and intensity of heavy 
metals to water per Member State, 2022 

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
water  pollution  intensity’,  European  Industrial  Emissions  Portal,  2024, 
https://industry.eea.europa.eu/analyse/industrial-emissions-indicator. 

(79) 

European  Environment  Agency,  LRTAP,  Air  pollutant  emissions 
data viewer (Gothenburg Protocol, LRTAP Convention) 1990-2022, 

https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/air-pollutant-emissions-data-viewer-1990-2022. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
 
 
Figure 20: Relative releases to water from industry in 
Croatia (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals Ecotoxicity

Heavy Metals Human
Toxicity

Refineries

Source: EEA, ‘Industrial reporting under the Industrial Emissions Directive 
2010/75/EU  and  European  Pollutant  Release  and  Transfer  Register 
Regulation (EC) No 166/2006 – ver. 12.0 Sep. 2024 (tabular data)’, EEA 
2024, 
Catalogue, 
Geospatial 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
non-governmental  organisations 
(NGOs),  alongside 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 
requiring  a  site  visit  to  take  place  at  least  every  one  to 
three  years,  using  risk-based  criteria.  In  addition,  IED 
enforcement  provisions  require  Member  States  to 
determine  effective,  proportionate,  and  dissuasive 
penalties  applicable  to 
IED-based 
national provisions. In the revised directive, the provisions 
set that worst infringements can be sanctioned by fines of 
at least 3% of the annual EU turnover of the legal person. 
The  revised  IED  also  introduces  a  right  to  compensation 
for  people  whose  health  has  been  harmed  by  such 
infringements. 

infringements  of 

The development of best available techniques (BATs), BAT 
reference  documents  and  BAT  conclusions  ensures 
effective collaboration between stakeholders and enables 
better implementation of the IED. 

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions on (i) ferrous metal processing, (ii) the textiles 
industry,  (iii)  common  waste  gas  management  and 
treatment  systems 
in  the  chemical  sector  and  (iv) 
smitheries and foundries. 

Croatia  26 

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

Croatia  has  still  not  transposed  some  articles  of  the  IED 
correctly  and  is  subject  to  an  infringement  procedure, 
opened  in  2020.  Among  other  things,  the  definitions  of 
‘installation’,  ‘BATs’  and  ‘baseline  condition’  have  been 
transposed  incorrectly.  In  addition,  national  legislation 
lacks special requirements on the frequency of site visits 
and the timeliness of inspections and fails to lay down a 
clear obligation for the inspection report to describe the 
relevant findings. 

2025 priority actions 

•  Complete the correct transposition of the IED 1.0. 
•  Reduce industrial air pollution damage and intensity. 
•  Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 

•  Ensure  effective  public  participation  and  access  to 

justice in relation to the IED. 

Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 

(i)  control  major-accident  hazards  involving  dangerous 

substances, especially chemicals; 

(ii)  limit  the  consequences  of  such  accidents  for  human 

health and the environment; 

(iii) continuously improve the prevention of, preparedness 

for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive (80)). 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (81)  and  the  report  by 
Croatia on the implementation of the Seveso III Directive 
for 2019–2022 (82). 

In  2024,  of  Croatia’s  71  Seveso  establishments,  36  were 
categorised as lower-tier establishments and 35 as upper-
tier  establishments  (UTEs)  based  on  the  quantity  of 

(80)  Directive  2012/18/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  the  control  of  major-accident  hazards 
involving  dangerous  substances,  amending  and  subsequently 
repealing  Council  Directive  96/82/EC  (OJ  L 197,  24.7.2012,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2012/18/oj. 

(81) 

(82) 

https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 
in September 2024.  
As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
hazardous substances likely to be present. The  UTEs are 
subject  to  more  stringent  requirements.  Figure 21 
presents 
the  number  of  Seveso 
establishments. 

the  change 

in 

Figure 21: Number of Seveso establishments in Croatia, 
2018, 2022 and 2024 

NB: LTE, lower-tier establishment. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Member States are required to draw up external emergency 
plans  (EEPs).  These  EEPs  are  essential  to  allow  proper 
preparation  and  effective  implementation  of  the  actions 
necessary  to  protect  the  environment  and  the  population 
should a major industrial accident occur. 

In 2022, according to Croatia, an EEP was required for all 
35 UTEs, and all of them had one that had been tested in 
the past three years. The summary is shown in Figure 22. 

Croatia  27 

Figure 22: Situation regarding EEPs in Croatia, 2022 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
Implementing  Decision 
(implementing  Directive 
2014/896/EU 
involving 
2012/18/EU  on  the  control  of  major  accident  hazards 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

The information  for  the public referred to in  Annex V to 
the  Seveso III  Directive –  especially  information  about 
how the public concerned will be warned in the event of a 
major accident, the appropriate behaviour in the event of 
a  major  accident  and  the  date  of  the  last  site  visit –  is 
permanently available for all the Seveso establishments in 
Croatia. 

The  share  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 is presented in 
Figure 23.  This  provision  on  knowledge  is  an  important 
provision of the Seveso III Directive, as awareness by the 
public  of 
the 
consequences of a major industrial accident. 

information  may  ameliorate 

this 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Figure 23: Share of UTEs for which information on safety 
measures and appropriate behaviours was actively 
made available to the public per Member State (%), 
2022 

NB: No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

Following  an  infringement  procedure  for  the  incorrect 
transposition  of  the  Seveso III  Directive,  Croatia  has 
amended its legislation and addressed the  shortcomings 
identified. 

2025 priority actions 

• 

• 

Strengthen  compliance  with  requirements  on  safety 
measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response in relation to 
UTEs, in particular  as regards reviewing, testing and 
updating  EEPs,  at  intervals  of  no  more  than  three 
years. 
Ensure  access  to  transparent  and  clear  information 
towards  citizens  on  risks  and  behaviour  in  case  of 
accidents. 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 

Croatia  28 

conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

In  2019,  43 %  of  the  dental  treatments  were  still  using 
dental  amalgam,  which  represented  a  challenge  for 
Croatia to phase out its use by 1 January 2025. However, 
measures  should  have  been  put  in  place  to  ensure  a 
socially  and  economically  sound  phase-out,  including  an 
adequate  reimbursement  of  the  alternatives  to  dental 
amalgam  through  the  health 
In 
addition,  dental  practitioners  undergo  regular  training 
related to new technologies and material in Croatia.  The 
Commission  is  monitoring  whether  the  phase-out  has 
taken  place  under  the  terms  and  conditions  of  the 
regulation. 

insurance  scheme. 

Croatia will also need to ensure that the manufacture and 
export of mercury-containing lamps are prohibited by the 
deadlines set out in the Mercury Regulation. 

Noise 

The Environmental Noise Directive (83) requires a common 
approach to avoid, prevent and reduce the harmful effects 
of  noise.  The  designated  authorities  are  responsible  for 
making  and  approving  noise  maps  and  action  plans  for 
agglomerations,  major  roads,  major  railways  and  major 
airports.  Member  States  decide  on  noise  limits  that  are 
not  set  at  the  EU  level.  Nevertheless,  the  zero-pollution 
action  plan  sets  as  a  2030  target  a  30 %  reduction 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 

(83)  Directive  2002/49/EC  of  the  European  Parliament  and  of  the 
Council  of  25 June  2002  relating  to  the  assessment  and 
management  of  environmental  noise –  Declaration  by  the 
Commission  in  the  Conciliation  Committee  on  the  directive 

relating  to  the  assessment  and  management  of  environmental 
noise (OJ L 189, 18.7.2002, p. 12), https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32002L0049. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
Croatia  29 

the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (84). 

In  Croatia,  environmental  noise  is  estimated  to  cause  at 
ischaemic  heart  disease 
least  around  240  cases  of 
annually (85)  and  some  30 000  people  to  suffer  from 
disturbed sleep(86). 

Based  on  the  latest  set  of  information  analysed,  Croatia 
has  completed  its  noise  mapping  of  agglomerations, 
roads, railways and airports. 

Action  plans  for  noise  management  for  agglomerations, 
roads,  railways  and  airports  must  be  updated  and 
submitted  to  the  Commission  every  five  years.  The 
deadline for reporting noise action plans under the most 
recent  reporting  cycle  was  18 January  2025;  these  plans 
have not been assessed yet. 

Croatia received no priority action in this area in the 2022 
EIR. 

2025 priority action 

•  Complete  and 
management. 

implement  action  plans  on  noise 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional  waters,  coastal  waters  and 
freshwaters (including surface waters and groundwaters) 
be  significantly  reduced.  Achieving,  maintaining  or 
enhancing a good status of waterbodies as defined by the 
Water  Framework  Directive  will  ensure  that  EU  citizens 
benefit  from  good-quality  and  safe  drinking  and  bathing 
water.  It  will  further  ensure  that  the  nutrient  cycle 
in  a  more 
(nitrogen  and  phosphorus) 

is  managed 

sustainable and resource-efficient way. 

Water Framework Directive 

The Water Framework Directive (87) is the cornerstone of 
EU water policy (88). The Water Framework Directive and 
other  water-related  directives (89)  form  the  basis  of 
sustainable and integrated water management in the EU. 
They  aim  to  achieve  a  high  level  of  protection  of  water 
resources,  prevention  of 
further  deterioration  and 
restoration  to  good  status.  These  objectives  are  very 
important 
the  EU’s  competitiveness,  strategic 
autonomy  and  security,  yet  have  become  even  more 
challenging  in  the  face  of  climate  change  affecting  our 
precious water resources. 

for 

The Water Framework Directive establishes a procedural 
framework for reaching good surface water ecological and 
chemical  status  and  good  groundwater  quantitative  and 
chemical status. This implies monitoring and classification 
of all waterbodies, assessment  of pressures and impacts 
and identification of the most cost-effective measures to 
achieve the objectives of the directive. The directive dates 
from 2000 and set an initial deadline of 2015 for achieving 
its objectives, with the option to extend the deadline to 
the  end  of  2027.  Every  six  years,  Member  States  must 
report their river basin management plans (RBMPs) to the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4 February 2025(90). 

surface  waterbodies  and  51 
Croatia  has  1 978 
groundwater bodies, divided into two river basin districts 

(85) 

(84)  WHO, Environmental Noise Guidelines for  the European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 
These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022;  (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial  Pollution  (ETC/ATNI),  Noise 
Indicators  under  the 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and the methodology for health impact calculations in European 
Topic  Centre  on  Air  Pollution  and  Climate  Change  Mitigation 
(ETC/ACM),  Implications  of  environmental  noise  on  health  and 
in  Europe,  Eionet  report  ETC/ACM  No 2018/10, 
wellbeing 
https://www.eionet.europa.eu/etcs/etc-
Bilthoven, 
atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise.  

2018, 

(86)  More information on the adverse health effects of noise pollution 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 

(87) 

(88) 
(89) 

the 

Floods 

include 

the  Groundwater  Directive 

https://environment.ec.europa.eu/topics/water_en. 
These 
(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
lex.europa.eu/eli/dir/2008/105/oj), 
Directive 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 
(https://eur-lex.europa.eu/legal-
Directive 
Urban 
content/EN/TXT/?uri=celex%3A32006L0007), 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
the 
(https://eur-
new 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
(https://eur-lex.europa.eu/legal 
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

Nitrates 
(https://eur-lex.europa.eu/legal-
MSFD 

Drinking  Water 

Treatment 

Directive 

and 

the 

the 

the 

IED 

the 

(90)   WFD and FD report (ENV - Library) 

2025 Environmental Implementation Review – Croatia 

 
 
 
  
Croatia  30 

Figure 25: Chemical status of surface waterbodies in each 
RBMP cycle (%) 

(Adriatic  and  Danube).  Approximately  13 %  of  surface 
waters  are  designated  as  ‘heavily  modified’  and  about 
11 %  as 
‘artificial.  Heavily  modified  and  artificial 
waterbodies must reach good ecological potential rather 
than  good  ecological  status,  which  means  that  all 
measures must be taken to mitigate the adverse impact of 
the sustainable human development activities causing the 
waterbody  to  be  heavily  modified /  artificial,  while  not 
significantly affecting these activities. 

Since  the  second  cycle  of  RBMPs,  the  number  of 
delineated surface waterbodies has increased by 26 % and 
the number of groundwater bodies has increased by 55 %. 
It  follows  from  the  assessment  of  the  third  RBMP  that 
there  has  been  a  deterioration 
in  the  ecological 
status/potential  and  the  chemical  status  of  surface 
waterbodies  compared  with  the  status  reported  in  the 
second  RBMP  (covering  2015–2021).  There  has  been  a 
the  quantitative  status  of 
slight 
groundwater  bodies,  but  no 
in  their 
chemical status. 

improvement 

improvement 

in 

Figures 24–27  show  the  change 
in  the  ecological 
status/potential  and  chemical  status  of  surface  waters, 
and the quantitative and chemical status of groundwater 
in 2010, 2015 and 2021.  

Figure 24:  Ecological 
waterbodies in each RBMP cycle (%) 

status/potential  of 

surface 

The  percentage  of  surface  waterbodies  with  good 
chemical  status  amounts  to  80 %  in  the  third  RBMP, 
representing  a  decrease  from  the  second  one.  It  is  not 
clear  whether  this  decrease  represents  a  genuine 
deterioration  or 
is  due  to  better  monitoring  and 
classification.  All  coastal  and  transitional  waters  fail  to 
show good chemical status, and Croatia fails to identify the 
sources of anthropogenic pressures on these waterbodies. 
No improvements are expected until 2027. 

Failure to achieve good chemical status  is mostly due to 
ubiquitous  persistent  bioaccumulative 
toxic 
substances  (uPBTs),  which  are  difficult  to  address  and 
often  have  transboundary  sources.  In  Croatia,  these  are 
mainly  mercury,  polybrominated  diphenyl  ethers  and 
perfluorooctane sulphonic acid. 

and 

Figure 26: Quantitative status of groundwater bodies in 
each RBMP cycle (%) 

improved  monitoring,  an 

The number of surface  waterbodies  with  good or better 
ecological status/potential has been decreasing since the 
first RBMP, and it amounts to 33 % in the third RBMP. It is 
not entirely clear whether this continuous decrease is due 
improved  classification 
to 
system (i.e. an intercalibration process), more pollution or 
all  of  the  above.  No  improvements  are  expected  until 
2027. 
The  main  pressures  come  from  discharges,  agriculture, 
transport and physical alterations. Water abstractions are 
also a problem. 

There  has  been  a  slight  increase  in  groundwater  bodies 
with  good  quantitative  status  since  the  second  RBMP, 
which  seems  due  to  the  re-delineation  that  took  place. 
Only  one  groundwater  body  is  reported  to  have  poor 
quantitative status, whereas five groundwater bodies are 
reported  to  be  at  risk  of  losing  their  good  quantitative 
status by 2027. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Since  2016,  water  abstractions  have  increased,  due 
potentially to the increase in electricity generation, while 
decreasing  trends  were  observed  in  households  and 
services and industry. 

Figure 27: Chemical status of groundwater bodies in each 
RBMP cycle (%) 

status of coastal and transitional waterbodies, which are 
affected by mass tourism. Another positive element is that 
Croatia  is  on  the  right  track  to  tackle  pressures  on  the 
chemical status of surface and groundwater bodies from 
sources other than agriculture. 

2025 priority actions 

Croatia  31 

• 

• 

Improve  river  continuity  and  ecological 
flows, 
boosting efforts on nature-based solutions to reduce 
hydro-morphological pressures.  
Ensure  periodic  reviews  of  permits  for  discharges, 
abstractions  and  other  water  uses, 
including 
hydropower pressures  

•  Reduce  pollution  from  nutrients,  chemicals,    metals 

• 

and saline discharges  
Improve  the  classification  of  waterbodies  and 
strengthen monitoring systems. 

•  Develop  more  robust  programmes  of  measures, 
tackle  obstacles  identified  in  the  implementation  of 
measures  and  ensure  adequate 
for 
implementation, including through better use of cost 
recovery and the polluter-pays principle. 

financing 

Floods Directive 

Every six years, following the same reporting cycle as the 
RBMPs,  all  Member  States  also  report  their  flood  risk 
management  plans  (FRMPs),  based  on  the  flood  hazard 
and risk maps and the preliminary flood risk assessments 
drawn up during the second cycle (2016–2021). 

The  Commission  assessed  the  FRMPs  and  reported  its 
findings to the European Parliament and to the Council on 
4th  February  2025,  together  with  the  assessment  of  the 
RBMPs. 

Croatia’s  second  FRMP  contains  the  same  objectives  as 
the  first  one.  It  indicates  that  there  has  been  progress 
towards the strategic objectives of the previous plan but 
does  not  provide  details.  The  FRMP 
identifies  72 
measures,  providing  information  on  the  timetable  for 
implementation,  costs  and  progress  since  the  previous 
plan.  The  FRMP  considers  nature-based  solutions  and 
includes  measures  to  address  nature  conservation. 
Reference  is  made  to  adaptation  to  climate  change. 
Croatia  reported  that  coordination  at  the  international 
levels  took  place,  as  well  as  public 
and  regional 
consultation and stakeholder involvement. 

Investments in floods protection measures are planned or 
under  implementation  with  financial  support  from  both 
cohesion  policy  operational  programmes  and 
the 
Recovery and Resilience Facility (RRF). The cohesion policy 
major  project  for  floods  prevention  in  Karlovac,  which 
includes nature-based  solutions, started implementation 

The  percentage  of  groundwater  bodies  with  good 
chemical status (92 %) did not change from the second to 
the  third  RBMP.  No  improvements  are  expected  until 
2027. 

Failure  to  achieve  good  chemical  status  is  due  to  the 
general water quality assessment and to regional saline or 
other intrusions resulting from anthropogenically induced 
sustained changes in flow direction.  The main  issues  are 
nitrates pollution, saline intrusion and water temperature. 

Until the end of 2027, Member States can still apply for 
time-related exemptions, subject to providing evidence of 
compliance  with  the  strict  criteria  set  out  in  the  Water 
Framework  Directive.  After  2027,  the  possibilities  for 
applying for exemptions will be much more limited. 

Some progress has been made on the 2022 priority actions 
regarding  assessing  new  physical  modifications  to 
waterbodies  and  ensuring  that  hydrotechnical  flood 
protection  activities  do  not  lead  to  additional  serious 
hydromorphological  deterioration.  Croatia  has  reported 
operational  measures  to  address  the  morphological 
pressures  on  surface  waterbodies,  mainly  focused  on 
improved 
research 
monitoring.  The  third  RBMP  includes  climate  change 
adaptation  measures;  when  these  measures 
imply 
hydromorphological  changes  to  surface  or  groundwater 
them  only  after  an 
bodies,  Croatia 
environmental impact assessment (EIA). 

into  the  underlying 

issues  and 

considers 

A positive achievement is the improvements made to the 
programme  of  measures  since  the  second  RBMP.  In  the 
third RBMP, Croatia mapped measures in both river basin 
districts against all key types of measures, and basic and 
specific  measures  are  listed  in  great  detail.  A  notable 
exception is key type of measure 19 (‘measures to prevent 
adverse impacts of recreation’) to reduce pressures on the 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
in  the  2014–2020  programming  period  and  continues  in 
the current 2021–2027 programming period. 

water  will  apply,  ensuring  harmonised  Member  States’ 
reporting of PFAS monitoring data in the future. 

Croatia  32 

2025 priority actions 

• 

FRMPs  should  provide  details  on  how  the  FHRMs 
were  used  in  the  choice  of  measures  and  how  to 
consider pluvial flooding.   

•  Better explain the choice and implementation of flood 
prevention  and  protection  measures  (prioritisation, 
monitoring, costs of measures).  
Improve  public 
involvement. 

consultation  and 

stakeholder 

• 

Drinking Water Directive 

The  objectives  of  this  directive  are  to  protect  human 
health  by  ensuring  that  drinking  water  is  fit  for  human 
consumption and by improving access to drinking water. 
The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (91), (ii) a methodology for measuring microplastics 
in drinking water (92) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (93). Member States will have to take 
these  various  Commission  acts 
into  account  when 
implementing the recast directive. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019.  The  quality  of  drinking  water  (supplied  by  large 
water  suppliers) 
in  Croatia  does  not  give  rise  to 
concern (94). 

From  January  2026,  the  European  quality  standards  for 
per-and  poly  fluoroalkyl  substances  (PFAS)  in  drinking 

it 

is  rich 

in  water  resources;  however, 

Croatia 
is 
increasingly  exposed to climate change trends  that  have 
already  led  to  drought  events  in  2024,  particularly  in 
Slavonia and along the coast, with severe impacts on crop 
yields.  The  drinking  water  infrastructure  is  old,  and 
investments  have  been  concentrated  more  on  the 
extension of the network and less on the reconstruction of 
old pipes. Croatia therefore has a high connection rate but 
is one of the Member States with the highest water loss 
rates, with 49 % non-revenue water (95). In the framework 
of  its  national  RRP,  Croatia  adopted  a  national  loss 
reduction action plan in June 2024, which includes several 
measures to reduce water losses and will be followed by 
the adoption of individual water losses reduction plans at 
the level of water operators. 

2025 priority action 

• 

Swiftly  implement  the  measures  included  in  the 
national water loss reduction action plan. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly.  Notices  banning  or  advising  against  bathing 
should be rapidly and easily identifiable. 

Figure 28  shows  that  in  2023,  out  of  the  936  Croatian 
bathing waters, 905 (96.7 %) were of excellent quality, 22 
(2.4 %)  were  of  good  quality  and  5  (0.5 %)  were  of 
sufficient quality. No bathing waters were found to be of 
poor  quality.  Detailed  information  on  Croatia’s  bathing 
waters is available from a national portal (96) and through 
an interactive map viewer provided by the EEA (97). 

(91) 

(92) 

(93)  OJ L, 

https://environment.ec.europa.eu/publications/implementing-
decision-drinking-water-directive-watch-list_en. 
Commission Delegated Decision (EU) 2024/1441 of 11 March 2024 
supplementing  Directive  (EU)  2020/2184  of  the  European 
Parliament and of the Council by laying down a methodology to 
measure microplastics in water intended for human consumption 
(notified  under  document  C(2024) 1459)  (OJ  L,  2024/1441, 
21.5.2024), http://data.europa.eu/eli/dec_del/2024/1441/oj. 
2024/365, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 
OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 
the  Commission  web  page  on  all  six  delegated  acts  for  more 

2024/369, 

(94) 

information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
In summary,  the  compliance  for  all  parameter  groups in Croatia 
was at least 99.92 % in 2017, 99.11 % in 2018 and 99.28 % in 2019. 
(95)  World Bank, Technical assistance on support to reduce water loss 
within the reform of the water sector in Croatia – Output 6: Report 
on  inputs  for  a  final  draft  national  loss  reduction  action  plan, 
Washington, 
2023, 
https://documents.worldbank.org/en/publication/documents-
reports/documentdetail/099120123054036808/p1787970dc657
40290b0a308bbcd0b3379e. Non-revenue water is defined as the 
difference between the system input volume (water supplied) and 
the billed volume (revenue water). 

DC, 

(96)   https://vrtlac.izor.hr/kakvoca/.  
(97) 

EEA, ‘State of bathing water’, EEA website, 2024, State of bathing 
waters in 2023 | European Environment Agency's home page 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Figure 28: Bathing water quality per Member State, 
Albania and Switzerland (%), 2023 

Croatia  33 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the  effects  of  untreated  urban  wastewater.  It  therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
than  secondary,  with  nitrogen  and/or 
treatment 
phosphorus  removal,  to  the  waste  water  generated  in 
urban areas, also known as agglomerations, of more than 
10 000 people, before they are discharged into waters and 
their  catchments,  when  they  are  sensitive  to  nitrogen 
and/or phosphorus (i.e. eutrophic or tending  to become 
eutrophic). 

generating 

agglomerations, 

Overall, in Croatia, the compliance rate was 7 % in 2020. 
3 513 265 
Sixty-eight 
population  equivalent  of  urban  waste  water,  did  not 
comply  with 
the  directive. 
Meanwhile,  171  agglomerations,  generating  893 890 
population  equivalent  of  urban  waste  water,  were  not 
subject  to  the  requirements  of  the  directive  because  in 
2020 they were still under pending deadlines. 

requirements  of 

the 

Pursuant  to  its  Treaty  of  Accession,  Croatia  should  have 
reached  full  compliance  with  the  requirements  of  the 
directive by the end of 2023. This will be assessed by the 
Commission  in  the  context  of  the  next  Member  States’ 
reporting exercise. However, it is already clear that Croatia 
will  need  to  step  up  its  efforts  to  comply  with  its 
obligations under EU law. Many investments are planned 
under the cohesion policy and the national RRP , but they 
are  being  implemented  at  a  slow  pace.  Most  of  the 
investments  planned  in  the  2014–2020  cohesion  policy 
operational 
continuing 
implementation  in  the  2021–2027  programming  period, 
have  been  reallocated  for  implementation  with  RRP 
financial  support  or  will  be  completed  with  national 
funding. 

programme 

either 

are 

Source:  EEA,  European  Bathing  Water  Quality 
No 04/2024, 
https://www.eea.europa.eu/publications/european-bathing-water-
quality-in-2023/. 

in  2023,  briefing 
2024, 

Copenhagen, 

Nitrates Directive 

The  Nitrates  Directive (98)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices.  

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive,  dating  back  to  2021,  warns  that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a  problem in  many parts of the EU. 
The  report  on  the 
implementation  of  the  Nitrates 
Directive covering 2020–2023 will be available in 2025. 

The  analysis  of  Croatia’s  RBMPs  has  identified  nutrients 
important  pressure  on 
from  agriculture  as  an 
groundwater /  surface  water  that 
is  affecting  these 
waters’ good status and as one of the main factors leading 
to Croatia not meeting the Water Framework Directive’s 
objectives. 

2025 priority action 

• 

Tackle  nutrient  pollution,  especially  nitrates  from 
agriculture,  through  the 
implementation  of  the 
Nitrates Directive. 

(98) 

https://environment.ec.europa.eu/topics/water/nitrates_en. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
Figure 29: Proportion of urban waste water that fully 
complies with the UWWTD (%), 2020 

Source: 12th technical assessment of UWWTD implementation, 2024(99) 

This  is  all  the  more  important  as  the  directive  has  been 
revised. The revised directive builds on the current acquis, 
strengthens existing treatment standards and establishes 
a  new  additional  treatment  of  micropollutants  in  urban 
waste  water.  Other  new  requirements  relate  to  moving 
towards  the  energy neutrality of the sector, establishing 
an  EPR  system  to  ensure  sustainable  financing  of 
micropollutant treatment by the most polluting industries 
and ensuring access to sanitation, especially for vulnerable 
and marginalised groups. Croatia has until 31 July 2027 to 
transpose the new directive into its national legal system. 

received  priority  actions 
Since  2017  Croatia  has 
concerning  the  necessity  of  implementing  the  UWWTD, 
but despite some progress made, compliance is far from 
being achieved. 

(99)   https://op.europa.eu/en/publication-detail/-

/publication/4c97f846-44b2-11ef-865a-01aa75ed71a1/language-
en.  

(100)  Communication 

to 

from 

the  Commission 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 
strategy  for  sustainability:  Towards  a  toxic-free  environment, 
COM(2020) 667 
final  of  14 October  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
p. 1), 
L 353, 
No 1907/2006 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(101)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 

Croatia  34 

2025 priority action 

•  Urgently  take  the  necessary  measures  to  ensure  full 
implementation  of  the  current  UWWTD,  taking  into 
account the new requirements of the recast directive. 

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  towards  a  toxic-free  environment (100), 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU’s zero pollution 
ambition –  a  key  commitment  of  the  European  Green 
Deal. 

The  EU’s  chemicals  legislation (101)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (102)  on  the 
implementation 
these 
regulations (103).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because: (i) enforcement authorities are becoming more 

in  the  area  of 

enforcement 

and 

of 

p. 1), 

(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
No 1907/2006 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(102)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
2020, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

Union, 

(103) 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
effective in detecting non-compliant products/companies; 
and (ii) more non-compliant products are being placed on 
the EU market. 

Regulation  is  conducted  every  five  years.  Results  of  the 
coming one are expected in 2025, hence the absence of 
new specific national data on enforcement since 2022. 

Croatia  35 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (104) of the two main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (105).  

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (106).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (107).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

The reporting exercise for Member States from Article 117 
of  the  REACH  Regulation  and  Article 46  of  the  CLP 

Responsibility  for  checking  compliance  with  the  REACH 
Regulation in Croatia lies with the state inspectorate (108). 

In  2022,  Croatia  had  not  devised  or  implemented  any 
strategy  for  the  enforcement  of  the  REACH  or  CLP 
Regulations,  but  there  are  plans  to  devise  one (109).  No 
progress  has  been  reported.  Four 
inspectors  were 
allocated  to  the  enforcement  of  the  REACH  and  CLP 
Regulations  at  the  national  level  and  30  at  the  regional 
level (110).  As  a  result,  the  number  of  REACH  controls 
carried out in the previous reporting period (62) remained 
well below average. 

Croatia  participated  in  an  EU-coordinated  enforcement 
project  on  products  sold  online,  called  the  REACH-EN-
FORCE  (REF)-8  project (111)  in  2020,  and  on  projects  on 
REACH  authorisation  obligation  (REF-9) (112)  in  2021,  on 
integrated control of chemicals in products  (REF-10) (113) 
in  2022  and  on  the  second  harmonised  enforcement 
project 
non-
biocidal 
approved/approved  active  substances 
(BIOCIDES-EN-
FORCE (BEF)-2) (114) in 2022. 

containing 

products 

on 

the 

European 

(104)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
of 
2021, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(105)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally, 
microplastics. 

Luxembourg, 

(106)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 
1272/2008 on classification, labelling and packaging of substances 
and mixtures, OJ L, 2024/2865, 20.11.2024, p.1 (Regulation - EU - 
2024/2865 - EN - EUR-Lex) 

(107)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
UV-328,  the  COP  decision 
lists  some  time-limited  specific 
exemptions. 

(108)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 68, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(109)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 76, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-

Luxembourg, 

Union, 

2020, 

277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

(110)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 74, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(111)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
and 
p. 20, 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

Helsinki, 

articles 

online, 

2021, 

sold 

(112)  European Chemicals Agency, REF-9 project report on enforcement 
of  compliance  with  REACH  authorisation  obligations,  Helsinki, 
2023, 
https://echa.europa.eu/documents/10162/17088/project_report
_ref-9_en.pdf/b2110033-262e-1075-b50c-11b20754bc80. 
(113)  European Chemicals Agency, REF-10 project report on integrated 
chemical 
2023, 
of 
https://echa.europa.eu/documents/10162/17086/ref-
10_project_report_en.pdf/83661988-378d-6268-3f28-
182da198e8ac?t=1702375815496. 

compliance 

products, 

Helsinki, 

(114)  European  Chemicals  Agency,  Second  harmonised  enforcement 
project  on  biocidal  products with  approved/non-approved  active 
substances, 
2023, 
https://echa.europa.eu/documents/10162/17086/bef_2_report_
en.pdf/7432b55c-f4f8-8124-0525-
47d24f96143f?t=1700567655546. 

Helsinki, 

2025 Environmental Implementation Review – Croatia 

 
 
 
Figure 30: Compliance of imported products – results of 
the REF-8 project (%) 

Croatia  36 

In  2022,  Croatia  received  two  priority  actions  related  to 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of non-compliance and devise and implement a 
REACH and CLP  enforcement strategy. In the absence of 
formal  reporting  since  2022,  no  progress  has  been 
reported and these priority actions remain valid in 2025. 

2025 priority actions 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement to move towards a 
policy of zero tolerance of non-compliance. 
Increase involvement in the activities of the Forum for 
Exchange  of  Information  on  Enforcement  of  the 
European  Chemicals  Agency, 
the 
coordinated enforcement projects, called REF projects. 
Increase customs checks and checks of products sold 
online  with  regard  to  compliance  with  chemicals 
legislation.

including 

in 

• 

• 

A risk approach was used for the targeting of controls to 
maximise  the  chances  of  identifying  non-compliance. 
Therefore, non-compliance rates presented above cannot 
be  considered  the  average  non-compliance  rates  of 
products  in  the  EU.  However,  the  proportion  of  non-
compliance  cases  found  in  the  REF-8  project  are  of 
concern. 

Figure 31: Number of REF-8 checks performed per 
100 000 inhabitants (EU average = 1.24) 

Croatia’s  participation  to  the  coordinated  enforcement 
project (REF-8) was below the EU average, which is rather 
low  because  of  the  lack  of  involvement  of  certain  large 
Member States. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Croatia  37 

 4. Climate action 

trading  system  (ETS),  with  the  creation  of  a  new, 
second,  ETS  for  transport  and  buildings  together 
with a dedicated Social Climate Fund to help citizens 
during  the  transition;  (ii)  increasing  targets  under 
the  effort  sharing  regulation;  and  (iii)  a  revised 
regulation  for  Land  Use,  Land  Use  Change  and 
Forestry (116).  The  package  has  been  almost  fully 
adopted,  and  the  Member  States  have  been 
implementing the legislation. 

The  key  strategic  document  at  country  level  is  the 
National  Energy  and  Climate  Plan  (NECP) (117). 
Croatia submitted the NECP in March 2025 after the 
deadline set by the Regulation on the Governance of 
the Energy Union and Climate Action.(118)  

To  minimise  the  impacts  of  climate  policies  on 
vulnerable people and sectors,  Croatia is using the 
Just  Transition  Fund,  Modernisation  Fund  and  will 
use  Social  Climate  Fund  from  2026.  (for  more 
information, see Chapter 5 below). 

Figure 32: Total GHG emissions  (excluding international 
aviation) (%), 1990–2022 

its  determination 

The  impacts  of  climate  change  have  continued  to 
increase  in  recent  years,  inflicting  damage  and 
suffering in the EU and around the world. Globally, 
2023 was the hottest year on record, while Europe 
has  been  warming  twice  as  quickly  as  the  global 
average, and is now the fastest-warming continent. 
The  frequency  and  severity  of  extreme  climate 
events are also increasing. Against this backdrop, the 
EU  has  demonstrated 
to 
implement the European Green Deal and to become 
climate  neutral  and  resilient  by  2050,  ensuring 
sustainable  competitiveness  and  supporting  EU 
industry  in  the  net-zero  transition.  The  European 
Climate  Law  is  the  EU’s  response  to  the  need  for 
action.  It  sets  the  objective  of  achieving  climate 
neutrality  by  2050  and  a  midterm  target  of  a 
reduction in GHG emissions of at least 55 % by 2030, 
and  outlines  the  adaptation  efforts  necessary  to 
adjust  to  climate  change’s  present  and  future 
impacts. Almost all the ‘Fit for 55’ proposals set out 
in the European Green Deal have been agreed in law, 
and the European Commission recommended a new 
intermediate  climate  target  of  a  90 %  reduction  in 
emissions  by  2040.  In  2024,  the  Member  States 
submitted  updated  national  energy  and  climate 
plans  for  2021–2030,  reflecting  the 
increased 
ambition of the revised EU legislation. In 2024, the 
European Commission also released, jointly with the 
EEA, 
risk 
assessment. 

first-ever  European 

climate 

the 

Over the last three decades, since 1990, the EU has 
achieved steady decreases in its emissions, reaching 
a  running  total  in  2022  of – 32.5 % (115).  However, 
the EU and its Member States need to step up their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 
55 %  reduction  in  net  GHG  emissions  by  2030  and 
climate neutrality by 2050. Between 1990 and 2022, 
net  GHG  emissions  of  Croatia  decreased  by  19%, 
making it one of the countries with below-average 
decrease. 

The ‘Fit for 55’ legislative package reflects the need 
to  speed  up  the  green  transition.  It  includes  (i) 
strengthening  and  expanding  the  EU  emissions 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG 
emissions cost-effectively across all Member States. 
It  is  the  world’s  biggest  carbon  market,  covering 
around  40%  of  the  EU’s  total  GHG  emissions  from 
electricity  and  heat  generation,  the  manufacturing 

(115)  EU net domestic emissions, including the land use, land-use 
change  and  forestry  (LULUCF)  sector  and  excluding 
international aviation.  

(116)  A  full  overview  of  the  Fit  for  55  package  is  available  at 

https://commission.europa.eu/strategy-and-
policy/priorities-2019-2024/european-green-

deal/delivering-european-green-deal/fit-55-delivering-
proposals_en. 

(117)  More information about NECP is on the dedicated website 

https://energy.ec.europa.eu/topics/energy-
strategy/national-energy-and-climate-plans-necps_en 
(118)   Article 14 of Regulation 2018/1999 on the Governance of 

the Energy Union and Climate Action 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
industry,  aviation  within  Europe (119)  and,  from 
2024, maritime transport also. 

complete  transposition,  the  Commission  may  decide  to 
take the infringement case further. 

Croatia  38 

The system sets a limit or cap on the total amount of 
GHGs that can be emitted at the EU level. Within this 
limit,  companies  buy  emissions  allowances  (one 
allowance gives the right to emit 1 tonne of CO2 eq 
(carbon dioxide equivalent), in auctions or through 
trading allowances with others. The cap is reduced 
annually  to  ensure  that  overall  emissions  in  the 
sectors covered decrease over time. 

The emissions under the ETS decreased by 45% from 
2005 to 2023. 

In  2023,  about  47 %  of  the  greenhouse  gases 
emitted  by  Croatia’s  ETS  installations  came  from 
power generation, less than the EU average (57 %). 
Of  the  total  emissions  from  all  industry  sectors, 
slightly more than half came from cement and lime 
production,  about  one  fifth  from  refineries,  10 % 
from the chemical industry, only 1 % from the metals 
industry,  and  16 %  from  other  industries.  Between 
2013  and  2019,  the  power  sector  achieved 
reductions  of  24 %,  whereas  emissions 
in  the 
industry sectors only declined by 8 %. Between 2019 
and 2023, greenhouse gas emissions from the power 
sector  have  increased  by  14 %  in  the  industry 
sectors, they have declined by 28 %. From 2013 to 
2023, greenhouse gas emissions declined by 14 % in 
power  generation  and  by  33 %  in  the  industry 
sectors.  This  resulted  in  a  25 %  greenhouse  gas 
emissions reduction in the ETS sectors in this period. 

From 2027, a new emissions trading system, called 
ETS2,  for  buildings,  road  transport  and  additional 
sectors (mainly industry not covered by the current 
ETS)  will  become  fully  operational (120).  Member 
States  should  have  notified  full  transposition  the 
provisions of the revised EU ETS directive related to 
the  new  ETS2  into  national  law  by  30 June  2024. 
Croatia did not communicate full transposition into 
national  law  by  this  deadline.  The  Commission 
therefore started an infringement procedure against 
Croatia on 25 July 2024, for failing to fully transpose 
the  provisions  into  national  law.  In  the  absence  of 
complete transposition, the Commission may decide 
to take the infringement case further. 

On  25 January  2024  the  Commission  started  an 
infringement  case  against  Croatia  for  its  failure  to 
fully  transpose  previous  revisions  of  the  ETS 
directive (121)  into  national  law.  In  the  absence  of  a 

(119)  Flights  between  the  Member  States  including  departing 
flights  to  Norway,  Iceland,  Switzerland  and  the  United 
Kingdom. 

(120)  Directive  (EU)  2023/959  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.
ENG) 

Effort sharing 

The Effort Sharing Regulation (ESR) (122) covers GHG 
emissions  from  domestic  transport  (excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture, 
small  industry  and  waste.  Emissions  from  these 
sectors  account  for  around  60 %  of  the  EU’s 
domestic emissions. The regulation sets the EU-wide 
target  to  reduce  emissions  from  the  effort  sharing 
sectors  by  40 %  by  2030  compared  to  2005  levels. 
This  overall  target  for  the  EU  translates  to  binding 
national  emission  reduction  targets 
for  each 
Member State. Croatia‘s target is –16.7%. 

In addition to the 2030 targets, Member States have 
annual  GHG  emissions 
limits  (annual  emission 
allocations), reducing every year until 2030. 

There  is  some  flexibility  to  take  account  of  annual 
fluctuations in emissions, by trading emissions and 
transfers from the ETS and LULUCF. 

Based on historical emissions and the most updated 
projections  Croatia  is  on  track  to  achieve  its  2030 
ESR target. Projected emissions are 0.4 percentage 
points above its 2030 target. 

The  largest  contributor  is  the  domestic  transport 
sector, which accounted for 35 % of all effort sharing 
emissions in 2022. Sustainable transport has yet to 
take off in Croatia. Road transport is the dominant 
passenger transport mode in Croatia, trains provide 
only 2 % of passenger transport which is way below 
EU average of 6 %. Share of trains in freight transport 
is  21 %,  five  percentage  point  above  EU  average. 
However, only 38 % of the rail network is electrified. 

Only 0.2 % of car fleet were battery electric vehicles 
in  2023  (EU  average  is  1.2 %).  On  the  other  hand, 
Croatia has about 1 280 publicly accessible charging 
points, or one for every  four e-vehicles (above the 
EU average of 1:10). 

The  buildings  sector  is  a  significant  concern  for 
Croatia as well. Croatia needs to step up its efforts in 
the  residential  sector  to  achieve  its  2030  energy 
consumption  target  for  buildings.  Final  energy 
consumption  in  the  residential  sector  increased  by 
around  5 %  between  2017  and  2022  whereas 
emissions from the building sector decreased by 4 % 

(121)  Directive  -  2023/959  -  EN  -  EUR-Lex  and  Directive  - 

2023/958 - EN - EUR-Lex 

(122)  Regulation 

(EU) 

2018/842 

(https://eur-

lex.europa.eu/eli/reg/2018/842). 

2025 Environmental Implementation Review – Croatia 

 
 
in the same period. Share of renewables in heating 
and cooling is 37 % and is growing very slowly. 

change –  Southern  Europe  and  low-lying  coastal 
regions. (123) 

Croatia  39 

Figure 33: Effort-sharing emissions by sector (%), 
2022 

Land use, land-use change and forestry 

The  (Land  use, 
land-use  change  and  forestry) 
LULUCF  sector  plays  a  significant  role  in  achieving 
the EU’s climate neutrality goal. In the EU, this sector 
absorbs  more  GHGs  than 
it  emits,  removing 
significant volumes of carbon from the atmosphere. 
Thus, it is the only sector with negative emissions. 

In Croatia, net carbon removals in the LULUCF sector 
have declined by almost 1 Mt in 2022. 

Croatia‘s target in 2030 is to enhance land removals 
by an additional –0.6 Mt of CO2 equivalent compared 
to the yearly average of the period 2016–2018. The 
latest available projections show a gap to the 2030 
target  of  2.0  Mt  of  CO2  equivalent.  Therefore, 
Croatia needs to apply additional measures to reach 
its 2030 target.  

Croatia  is  vulnerable  to  floods,  drought,  sea-level 
rise  and  heatwaves.  Agriculture  and  water 
management  are  the  sectors  affected  most  but 
hydro and thermal power production also face risks. 
Floods are a  risk  both in terms of expected annual 
damage  and  in  the  population  exposed.  Over  the 
past decades, only 5 % of losses caused by climate-
related  events  were  insured.  Given  the  increasing 
frequency of floods, action taken so far is insufficient 
to limit the damage and safeguard the free flow of 
rivers and aquatic ecosystems. . During 2024, it was 
noted that drought caused damage in all sectors of 
agricultural  production.  In  2024  drought  events 
caused  damage 
in  all  sectors  of  agricultural 
production.  Green  infrastructure  and  nature-based 
solutions are key to mitigating these climate-related 
events. Croatia has a wide protection gap for floods 
and the gap for wildfires requires close monitoring. 
Putting  in  place  the  right  institutional  settings  is 
crucial to climate adaptation. On this front, Croatia 
lacks a governance structure and systems to support 
systematic  and  regular  planning,  monitoring  and 
including  appropriate 
evaluation  of  policies, 
coordination between sectors of government. 

Croatia adopted its national adaptation law in 2019 
and has its national adaptation strategy. There are 
no sectoral or regional adaptation plans. 

Croatia  received  two  priority  actions  in  the  2022 
edition of the review. 

There  is  still  little  progress  in  decarbonisation  of 
transport sector. 

Final energy consumption of building remains above 
EU average and Croatia needs to step up its efforts 
in  the  residential  sector.  On  the  other  hand, 
emissions  from  building  sector  are  decreasing  and 
Croatia is projected to reach its 2030 effort sharing 
target,  provided  it  adopts  and  implements  the 
planned additional measures. 

Adaptation to climate change 

2025 priority action 

Halting all greenhouse gas emissions would still not 
prevent climate impacts that are already occurring. 
Therefore, adaptation to climate change is also a key 
component of climate policy. 

Croatia is in two out of three regions identified as a 
hotspots  of  climate  risks  most  affected  by  climate 

• 

Implement  all  polices  and  measures  that  are 
needed  to  achieve  targets  laid  down  in  the 
Effort  Sharing  Regulation  (ESR)  and  the  Land 
Use  and  Land-Use  Change  and  Forestry 
(LULUCF)  Regulation.  More  detailed  priority 
actions are set out in the assessment of the final 
National Energy and Climate Plan (NECP)(124).

(123)  European  Climate  Risk  Assessment 

(EUCRA).  2024. 
Available at European Climate Risk Assessment (europa.eu) 

(124)    National energy and climate plans. 

2025 Environmental Implementation Review – Croatia 

 
 
 
Croatia  40 

Part II: Enabling framework – implementation tools 

5. Financing 

The  EU  budget  supports  climate  investment  in  Croatia 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022,  Croatia’s  revenues  from  auctioning  reached 
EUR 328 million in total, with 76 % of it spent on climate 
and energy, corresponding to EUR 250 million. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 2.9 billion per year in 
Croatia. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 1.7 billion per year; thus, there is a 
gap of EUR 1.2 billion per year. 

Of  the  environmental  investment  gap,  EUR 592  million 
concerns biodiversity and ecosystems, EUR 272 million the 
water objective, EUR 226 million pollution prevention and 
control and EUR 118 million circular economy. 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the  RRF 
EUR 275.7 billion and EUR CAP 145.9 billion (125). 

In  Croatia,  the  EU  cohesion  policy  (considering  the  EU 
contribution amount) provides EUR 2.5 billion for climate 
action in 2021–2027 (with around two thirds of this via the 

ERDF),  with  a 
EMFAF (126). 

further  EUR 128 million 

from 

the 

The  RFF  contributes  to  climate  finance  in  Croatia  with 
EUR 3.9 billion  up  to  2026,  representing  39 %  of  the 
RRP (127). 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 493 million was assigned 
to Croatia in the reference period (128). 

National financing, including EU emissions trading 
system revenues 

amounted 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
budgets, 
in  2020, 
EUR 112 million  in  2021  and  EUR 143 million  in  2022  in 
Croatia, totalling EUR 328 million in the three-year period. 
In Croatia, according to the law, 100 % of the auctioning 
revenues are spent on climate and energy purposes (129). 

to  EUR 72 million 

From the remaining part of the EU ETS revenues that feed 
into  the  Innovation  Fund  and  the  Modernisation  Fund, 
further  support  is  available  for  climate  action  at  the  EU 
level. 

the  environment 

It should be noted that investment in climate action also 
the 
supports 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (130). 

therefore, 

and, 

Environmental financing and investments 

This section describes Croatia’s investment needs, current 
four 
financing  and  gaps  as 

relate 

they 

the 

to 

(125)  European  Commission,  Statement  of  Estimates  of  the  European 
Commission –  For  the  financial  year  2025,  Publications  Office  of 
pp. 94–96, 
the 
https://commission.europa.eu/document/download/7a0420e1-
599e-4246-9131-ccb7d505d6d9_en?filename=DB2025-
Statement-of-Estimates_1.pdf. 

European  Union, 

Luxembourg, 

2024, 

(126)  See 

the 

Cohesion 

Open 

Data 

Platform 

(https://cohesiondata.ec.europa.eu/). 

(127)  EU  Commission  datasets  and  the  Recovery  and  Resilience 
(https://ec.europa.eu/economy_finance/recovery-

Scoreboard 
and-resilience-scoreboard/index.html). 

(128)  A  list  of  financed  projects  is  provided  by  the  EIB 

(https://www.eib.org/en/projects/loans/index.htm). 

(129)  European  Commission:  Directorate-General 

for 
Climate Action, Progress Report 2023 – Climate action, 
the  European  Union, 
Publications  Office  of 
Luxembourg, 
2023, 
https://climate.ec.europa.eu/news-your-
voice/news/climate-action-progress-report-2023-
2023-10-24_en. 

(130)  NB:  Indirect  investments  (from  climate  and  other 
policies) in support of the environment are accounted 
for via the tracking. 

2025 Environmental Implementation Review – Croatia 

 
 
 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (131). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient  to  enable  Croatia  to  meet  its  objectives  in  the 
areas  of  pollution  prevention  and  control,  the  circular 
economy and waste, water protection and management, 
and biodiversity and ecosystems. The required investment 
is estimated to be EUR 2.9 billion per year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 0.9 billion  per  year,  concerns  biodiversity  and 
ecosystems,  with  around  EUR 0.6–0.7 billion  needed  for 
the  circular  economy,  water  and  tackling  pollution  (in 
2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 1.7 billion  in  Croatia  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 3.4 billion for  Croatia in total, during 2021–2027 (or 
EUR 486.9 million per year). 

Table 1: Key environmental allocations from EU funds to 
Croatia (million EUR), 2021–2027 

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

Agricultural 

CAP 
European 
Guarantee Fund 
European  Agricultural  Fund 
for Rural Development 

EMFAF 

Other MFF sources 

RRF (d) (2021–2026) 

Allocations 

2 265.5 (a) 
1 383.0 
871.2 
11.3 
814.9 (b) 
450.0 
364.9 

62.3 

265.5 (c) 

 2 239 

(131)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 
gap  estimates  are  based  on  the  Directorate-General  for 
Environment’s internal analysis (of 2024). Throughout this finance 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

(132)  https://cinea.ec.europa.eu/programmes/life_en. 
(133)  European  Commission,  Horizon  Europe  (https://research-and-
innovation.ec.europa.eu/funding/funding-opportunities/funding-
programmes-and-open-calls/horizon-europe_en) 

Croatia  41 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations  in  EU  amount  excluding  national  co-financing,  based 
on the tracking in the Common Provisions Regulation (CPR, 2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
information: 
its  publication  date.  Source  and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

L 435 

Annex XI, 

6.12.2021, 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 
Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  
Space  Fund,  Horizon  Europe,  financial 
environment and the Connecting Europe Facility. 
Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

instrument  for  the 

(a) 

(b) 

(c) 

(d) 

Croatia,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
instrument  for  the  environment  (LIFE) 
the  financial 
(EUR 5.4 billion) (132),  Horizon 
programme 
Europe 
(EUR 95.5 billion) (133),  the  Connecting  Europe  Facility 
(EUR 33.7 billion) (134)  and  funds  that  can  be  mobilised 
through the InvestEU programme (135). 

Croatia’s RRP supports climate objectives through funding 
of  EUR 3.9 billion  (39 %  of  total),  with  an  additional 
the 
EUR 1.35 billion 
environment.  

total)  directly 

(13.5 %  of 

for 

EIB  provided 

EUR 197.4 million 

The 
in 
around 
environment-related  financial  contributions  to  Croatia 
from  2021  to  mid  2024,  all  of  which  was  in  the  area  of 
sustainable  energy,  transport  and  industrial  projects, 
which  provides  significant  co-benefits  to  reducing  air 
pollution, environmental noise and other pollution. 

(134)  The  Connecting  Europe  Facility 

includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % will be made available, on a competitive basis, to all Member 
States  eligible  for  the  Cohesion  Fund.  The  remaining  70 %  will 
respect the national envelopes until 31 December 2023. 

(Transport)  also 

(135)  The  InvestEU  Fund  is  set  to  mobilise  over  EUR 372 billion  of 
investment through an EU budget guarantee of EUR 26.2 billion to 
back  the  investment  of  financial  partners such as  the  EIB  group 
and others. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
Croatia  42 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Croatia, the 
total national environmental protection expenditure was 
EUR 1.1 billion 
in  2021, 
representing around 2 % of GDP. 

in  2020  and  EUR 1.2 billion 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Croatia,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
EUR 354 million in 2020, rising to EUR 368 million in 2021, 
representing around 0.6–0.7 % of GDP. 

investment 

protection 

protection 

investment 

Splitting by institutional sector, 36 % of Croatia’s national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 16 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  48 %  from  the  general  business 
sector,  whose  environmental  activities  are  usually 
ancillary  to  its  main  activities.  At  the  EU  level,  38 %  of 
from 
environmental  protection 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (136). 

investment  comes 

from 

Croatia’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 1.7 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
fund (including EIB funds) reaches 46 %, with around 54 % 
national  financing.  The  total  public  financing  (EU  plus 
national public) represents 66 % of the total. 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels  (i.e.  the  gap)  reaches  an  estimated  EUR 1.2 billion 
per  year  in  Croatia,  representing  around    1.81 %  of  the 
national  GDP,  which  is  higher  than  the  EU-average 
(0.77 %). 

Figure 34: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Source: Directorate-General for Environment analysis. 

Table 2  provides 
the  distributions  of  Croatia’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

Table 2: Summary of environmental investment gaps in 
Croatia per year, 2021–2027  

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Investment gap, per year  

% of GDP 

 % of 
total 

Million 
EUR 
(2022 
prices) 

226 

118 

18.8 

0.34 

9.8 

0.18 

 272 

22.5 

0.41 

592 

49.0 

0.88 

Total 

 1 208 

100.0 

1.81 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Croatia’s investment 
needs  are  estimated  to  reach  EUR 0.6 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 0.5 billion,  relates  to  air  pollution  control,  to 

(136)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea, 2024. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
needs to reduce environmental noise reach EUR 0.1 billion 
per  year,  most  of  which  is  delivered  by  the  (same) 
sustainable  energy  and  transport  investments  that  also 
benefit clean air (137). Industrial site remediation requires 
an  estimated  EUR 12 million  per  year.  Microplastics 
pollution  and  the  chemicals  strategy  require  around 
EUR 7–10 million per year (each) (138). 

Current investments 

reach 

control 

investment 
and 

levels  supporting  pollution 
The  current 
estimated 
an 
prevention 
EUR 351 million per year in Croatia in 2021–2027. Most of 
the  financing  concerns  clean  air  (EUR 310 million  per 
year).  Protection  from  environmental  noise  receives 
further 
around  EUR 116 million  per  year,  with  a 
EUR 33 million for site remediation(139). 

In Croatia, the EU MFF provides an estimated 33.1 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further 52.5 % from the RRF, adding up to  85.6 % of the 
total. EIB financing contributes 7.5 % and national sources 
reach 6.9 % . 

The gap 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  Croatia 
needs  to  provide  an  additional  EUR 226 million  per  year 
(0.34 % of GDP), mostly related to clean air and noise. The 
adequate 
the 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

implementation  of 

the  NECP  with 

The latest (2023) NAPCP review report (140) did not cover 
Croatia in terms of compliance with requirements in 2020 
and  2021  and  concerning  the  NECD’s  2030  emission 
reduction  commitments.  Its  future  updated  NAPCPs  will 

(137)  2021 

assessment 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 
Directive 
Commission’s 
implementation 
report 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf. 

Environmental 

Noise 

2023 

(138)  European  Commission,  Third  Clean  Air  Outlook,  Brussels,  2022, 

https://environment.ec.europa.eu/topics/air/clean-air-
outlook_en. See also the impact assessment for the revision of the 
AAQD, available from the Commission web page on the proposed 
revision 
(https://environment.ec.europa.eu/publications/revision-eu-
ambient-air-quality-legislation_en). 

(139)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure  (environmental  protection  expenditure  accounts, 
Eurostat). Note that the bulk of clean air financing is provided as a 
contribution from climate (energy and transport) measures, as per 
the tracking schemes in the Common Provisions Regulation Annex 
I and the RRF Regulation Annex VI. Further information on clean 

Croatia  43 

need  to  report  on  its  policies  and  measures  and  how 
climate, energy and CAP plans and financing baselines are 
taken into account. 

Circular economy and waste 

Investment needs 

Croatia’s investment needs in circular economy and waste 
reach  an  EUR 0.7 billion  per  year  (including  baseline 
investments).  Most  of  this,  around  EUR 580 million  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
for  waste  management 
EUR 150 million  necessary 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (141). 

Current investments 

Circular economy investments across the economy reach 
around EUR 476 billion per year in Croatia in 2021-2027, 
with  a  further  EUR 131 million  provided  for  waste 
management that does not constitute circular economy. 

Around 2.8 % of this combined financing for circularity and 
waste comes from the EU MFF, with a further 8.2 % from 
the RRF, adding up to 11 % of the total. EIB loans did not 
support  circularity  and  waste  during  2021–2024.  The 
share  of  national  sources  is  absolutely  overwhelming, 
reaching 89 % of the total financing (142). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Croatia  needs  to  increase 
circular  economy 
investments  by  an  estimated 
additional 
EUR 100 million 
EUR 18 million concerning waste management action, not 

year,  with 

per 

an 

air 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(140)  European Commission, ‘National air pollution control programmes 
website, 
European 

Commission 

tracking: 

projections’, 

and 
https://environment.ec.europa.eu/topics/air/reducing-
emissions-air-pollutants/national-air-pollution-control-
programmes-and-projections_en.  

(141)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
Within’, 2017; and European Commission: Directorate-General for 
Environment, Study on investment needs in the waste sector and 
on  the  financing  of  municipal  waste  management  in  Member 
States,  Publications  Office  of  the  European  Union,  Luxembourg, 
2019, 
https://op.europa.eu/en/publication-detail/-
/publication/4d5f8355-bcad-11e9-9d01-01aa75ed71a1. 

(142)  Waste management and circular economy expenditure tracking in 
the EU funds, EIB projects and the national expenditure (Eurostat). 
Datasets:  environmental  protection  expenditure  accounts 
(env_epi) and circular economy private investments (cei_cie012). 

2025 Environmental Implementation Review – Croatia 

 
 
belonging to circular economy. Combined, this amounts to 
EUR 118 million per year, representing 0.18 % of Croatia’s 
GDP. 

Of  the  circular  economy  gap,  EUR 26 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 74 million constitutes further investment need to 
unlock Croatia’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 680 million (in 2022 prices) in Croatia. This comprises 
investment needs both for the water industry and for the 
protection  and  the  management  of  water.  Of  the  total 
annual need, EUR 286 million relates to the management 
of waste water (also including additional costs associated 
with  the  revised  UWWTD).  A  further  EUR 53 million  is 
necessary  for  drinking-water-related  investments  and 
around  EUR 338 million 
the  protection  and 
management of water (143). 

for 

Current investments 

Water investments in Croatia are estimated to be around 
EUR 408 million per year (in 2022 prices) in 2021–2027. Of 
this,  EUR 275 million supports wastewater  management, 
EUR 68 million drinking water and around EUR 63 million 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Of the total water financing, 27.7 % is provided by the EU 
MFF  (mostly  through  cohesion  policy),  with  a  further 
13.3 % from the RRF, reaching 41 % combined. Most of the 
financing comes from national sources (59 %) (144). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 

(143)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
2020, 
28 May 
States’, 
https://commission.europa.eu/news/estimating-investment-
needs-and-financing-capacities-water-related-investment-eu-
member-states-2020-05-28_en;  and  OECD,  Financing  Water 
Supply, Sanitation and flood Protection: Challenges in EU Member 
States  and  policy  options,  OECD  Publishing,  Paris,  2020, 
https://www.oecd-ilibrary.org/environment/financing-water-
supply-sanitation-and-flood-protection_6893cdac-en. 

(144)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (environmental protection 
expenditure accounts, Eurostat). 

(145)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

Commission 

frameworks’, 
https://environment.ec.europa.eu/topics/nature-and-
biodiversity/natura-2000/financing-natura-2000_en. 

European 

Croatia  44 

Croatia’s  water  investment  gap  reaches  EUR 272 million 
per year (0.41 % of GDP), with most of it assigned to the 
Water Framework Directive requirements in general and 
small  amounts  allocated 
to  wastewater  measures 
(EUR 11 million per year). 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 0.9 billion per year (in 2022 prices) in 
Croatia 
includes  the  following 
financing needs: 

in  2021–2027.  This 

• 

• 

• 

action 

prioritised 

framework (145) 
Croatia’s 
concerning  the  Natura  2000  areas:  EUR 227 million 
per year, mostly running costs; 
additional BDS costs (146): EUR 454 million per year on 
top of the framework; 
sustainable 
EUR 233 million per year. 

management 

costs (147): 

soil 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 323 million per year (in 2022 prices) in 2021–2027. 
72.1 % of the is considered direct financing to biodiversity 
and ecosystems, with a 100 % coefficient  in the tracking 
schemes. 

19.5 % of the total financing is estimated to come from EU 
cohesion  policy,  34 %  from  the  CAP,  6.1 %  from  Horizon 
Europe,  around  2.4 %  from  LIFE  and  2.3 %  from  the 
EMFAF. The EU MFF altogether accounts for 64.8 % of the 
financing  and  the  RRF  for  3.4 %,  adding  up  to  a  total  of 
68 %  from  the  EU  budget.  The  rest,  32 %,  comes  from 
national sources (148). 

Croatia  is  the  Member  State  with  the  highest  share  of 
biodiversity  financing  programmed  under  the  cohesion 
policy  EU  contribution  amount:  10.7 %  (disregarding 
ESF+). However, only 0.8 % of RRF funds and 17.9 % of CAP 
in 
funds  have  been  programmed  for 

investments 

(146)  See European Commission: Directorate-General for Environment, 
Biodiversity  Financing  and  Tracking –  Final  report,  Publications 
2022, 
Office 
https://op.europa.eu/en/publication-detail/-
/publication/793eb6ec-dbd6-11ec-a534-
01aa75ed71a1/language-en. 

European  Union, 

Luxembourg, 

the 

of 

(147)  See Proposal for a Directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 
2023, 
COM(2023) 416 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en.  

5 July 

final 

of 

(148)  Based 

on 

biodiversity 

tracking 

in 

the 

EU 

budget 

(https://circabc.europa.eu/ui/group/3f466d71-92a7-49eb-9c63-
6cb0fadf29dc/library/8e44293a-d97f-496d-8769-50365780acde), 
and national expenditure into biodiversity from the Classification 
of the Functions of Government accounts. 

2025 Environmental Implementation Review – Croatia 

 
 
biodiversity in Croatia in 2021–2027, which  is below  the 
EU average (see Figure 35). 

Figure 35: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Croatia’s 
investment gap is estimated to be around EUR 0.6 billion 
per year, corresponding to 0.88 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools to 
achieve climate and environmental goals. Some Member 
States  already  use  green  budgeting  tools  for  identifying 
and  tracking  green  expenditures  and/or  revenues  (149). 
Green budgeting practices provide increased transparency 
on the environmental implications of budgetary policies.  

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (150).  

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  technical 
support instrument (TSI) project on green budgeting from 

(149)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
Practices, 
https://economy-
finance.ec.europa.eu/economic-and-fiscal-governance/national-
fiscal-frameworks-eu-member-states/green-budgeting-
eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0  

2023, 

(150)  European  Commission, 

reference 

framework’, 

‘European  Union  green  budgeting 
https://economy-

2022, 

Croatia  45 

2021 to 2024 (151). Croatia participated  and has also been 
selected  for  the  next  round  of  TSI  projects  on  green 
budgeting, starting in 2025, where the country will expand 
peer-to-peer learning through civil servants’ exchanges. 

Beyond  Climate-proofing,  to  improve  policy  outcomes, 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (152)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 2.3 billion in 
Croatia in 2022, representing 3.3 % of its GDP (EU average: 
2.0 %).  Energy  taxes  formed  the  largest  component  of 
environmental taxes, accounting for 2 % of GDP, which is 
higher than the EU average of 1.6 %. Transport taxes, at 
0.6 % of GDP, were above the EU average (0.4 %), as were 
taxes  on  pollution  and  resources,  at  0.7 %  (EU  average: 
0.08 %). 
in  Croatia 
accounted for 9 % of total revenues from taxes and social 

In  2022,  environmental  taxes 

finance.ec.europa.eu/economic-and-fiscal-governance/green-
budgeting-eu_en. 

(151)  https://reform-support.ec.europa.eu/what-we-do/revenue-

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 

(152)  Commission notice – Technical guidance on the climate proofing 
of infrastructure in the period 2021–2027 (OJ C 373, 16.09.2021, 
p. 1), 
https://op.europa.eu/en/publication-detail/-
/publication/23a24b21-16d0-11ec-b4fe-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
Croatia  46 

use  (with  links  to  nature  and  ecosystems)  and  3.8 % 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

In  2021–2023,  31.7 %  of  the  European  green  bonds 
(excluding  those  issued  by  supranational  entities)  was 
issued  by  financial  corporates,  29.1 %  by  sovereign 
governments  and  23.1 %  by  non-financial  corporates. 
8.3 % of the issuances was linked to government-backed 
entities, 6.4 % to developments banks and 1.4 % to local 
governments. 

Additionally,  to  (not  included  in)  the  above,  Croatia  had 
four green and/or sustainability bonds issuances in 2022–
2024 worth about 905 million in EUR plus 300  million in 
Croatian Kuna (in 2022). Of this, around EUR 544.8 million 
took  place  during  2022-2023156,  and  EUR  400  million  in 
2024.  

Figure 37: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023  

Data source: Climatebonds.net, with some additional data from national 
sources (e.g. Croatia, Slovenia).  

security  contributions 
5.0 %) (153). 

(above 

the  EU  average  of 

Figure 36: Environmental taxes per Member State, 2022 

The EU Green Deal emphasises the role of well-designed 
tax  reforms  (e.g.  shifts  from  taxing  labour  to  taxing 
pollution) to boost economic growth and resilience, and to 
foster  a  fairer  society  and  a  just  transition  through  the 
right price signals. The Green Deal promotes the ‘polluter-
pays  principle’,  which  makes  polluters  bear  the  costs  to 
prevent, control and remedy pollution. 

to  a  2024  study (154),  Croatia  applies 
According 
environmental taxes used to discourage environmentally 
harmful behaviour in the fields of air, waste, water, use of 
natural  resources,  logging  and  mineral  extraction.  A 
reform  introducing  a  new  landfill  tax  included  in  the 
Croatian  RPP  has  been  adopted  on  1  January  2025.  The 
reform  will  be  beneficial  to  reducing  the  high  landfilling 
rates. 

Green bonds and sustainable bonds 

In 2023, the total value of green bonds issued by Member 
States  was  USD 245 billion  (EUR 227 billion),  up  from 
USD 234 billion (EUR 198 billion) in 2021 (155).  

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 

(153)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(154)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 2, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(155)  Climate  Bonds  Initiative  (https://www.climatebonds.net/).  N.B. 
This data source did not contain issuances for Croatia and Bulgaria 
in the examined period (up to 2023), and a slightly higher amount 
for Slovenia (+0.27 billion) during 2021-2023 in total. 

(156)   Kuna/EUR conversion rate applied for the conversion: 7.53450 as 
fixed mid-2022 at the time of Croatia’s eurozone accession.   

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
 
Environmentally harmful subsidies 

Figure 38:  Energy  subsidies  by  energy  carrier  (billion 
EUR), 2015–2023 

Croatia  47 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 
action  programme  objectives  and 
the  enabling 
conditions (157). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

The overall downward trend of FFS mentioned in past EIRs 
was disrupted from 2022 due to the European response to 
the 2021 energy crisis and subsequent increase in energy 
prices. 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (158). 

For the majority of the Member States (16), the year 2022 
saw  a  peak  in  the  amount  of  overall  FFS.  A  decline  was 
then observed in 2023 (159). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

In  Croatia,  energy  subsidies  showed  moderate  increases 
between  2015  and  2021,  with  FFS  growing  from 
EUR 0.2 billion  (in  2015)  to  EUR 0.4 billion  (in  2021).  In 
2022,  energy  subsidies  quadrupled  overall,  with  FFS 
growing  to  EUR 1.2 billion.  In  2023,  energy  subsidies 
remained  high  overall,  while  FFS  showed  a  decrease, 
lowering to EUR 0.7 billion. 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden (the EU average 
was 0.8 %) (160). 

(157)  Article 3(h) and 3(v) of the eighth environment action programme. 
(158)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
European 
COM(2025), 
Union, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 

For Croatia, the 2022 EIR drew attention to the following 
points for improvement. 

• 

• 

• 

The investment  gap remains  significant  as Croatia is 
still substantially below the EU average for municipal 
and  packaging  waste  recycling,  sewage  systems  are 
underdeveloped and water supply networks face high 
leakage rates. 
In 
terms  of  prioritisation  of  environmental 
investments  in  Croatia,  waste  management  and  the 
circular  economy  are  considered  the  foremost 
priorities, followed by water. Croatia could facilitate 
the increase of the share of private financing for the 
environment  (which  is  around  one  third  overall  in 
Croatia). 
Technical  assistance  could  support  capacity  building 
for the management bodies of the Natura sites, in line 
with the 2019 EIR priority action. 

Croatia’s overall environmental investment gap is close to 
what it was at the time of the 2022 EIR (around 1.8 % of 
GDP,  above  the  EU  average),  largely  in  the  areas  of 
biodiversity  and  ecosystems  and  water,  which  require 
focused action. 

(159)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

(160)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

European 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2025)17&lang=en 

Union, 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
2025 priority action 

environmentally  harmful  subsidies),  EU  funding  and 
private funding to help close the investment gap. 

•  Use more national funding (for instance by increasing 
taxes  in  favour  of  the  environment  and  reducing 

Croatia  48 

2025 Environmental Implementation Review – Croatia 

 
 
 
Croatia  49 

6. Environmental governance  

Information, public participation and access to 
justice 

shared  efficiently 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
is 
and  effectively (161).  Public 
participation  allows  authorities  to  make  decisions  that 
take public concerns into account. Access to justice is a set 
of  guarantees  that  allows  citizens  and  NGOs  to  use 
national courts to protect the environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
legal 
includes  the  right  to  bring 
authorities (162).  It 
challenges (‘legal standing’) (163). 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to set up a European spatial-data infrastructure for sharing 
environmental  spatial 
information  between  public 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographic  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available. 

(161)  The 

Aarhus 

Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text),  the  Access 
to  Environmental  Information  Directive  (Directive  2003/4/EC) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32003L0004) 
Inspire 
Directive  (Directive  2007/2/EC)  (https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002) together create a legal 
foundation for the sharing of environmental information between 
public authorities and with the public. 

and 

the 

(162)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 

Table 3: Croatia dashboard on the implementation of the 
Inspire Directive, 2016–2023 

2016  2023 

Legend 

Effective  coordination  and 
data sharing 

Ensure 
effective 
coordination  

sharing 

Data 
without 
obstacles  

Inspire 
indicators 

■  ■ 

■  ■ 

performance 

(i)  Conformity 
of metadata  

■  ■ 

is 

■ Implementation of this 
well 
provision 
advanced  or 
(nearly) 
complete.  Outstanding 
issues are minor and can 
be 
addressed  easily. 
Percentage > 89 % 

some 

■ Implementation of this 
provision has started and 
made 
or 
substantial  progress  but 
is still not close to being 
completed. 
Percentage = 31–89 % 

is 

■ Implementation of this 
falling 
provision 
behind. 
significantly 
Serious 
are 
necessary  to  close  the 
implementation 
gap. 
Percentage < 31 % 

efforts 

(ii)  Conformity 
of  spatial  data 
sets 

(iii) 
Accessibility  of 
data 
spatial 
through 
sets 
view 
and 
download 
services 

(iv)  Conformity 
of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

Source:  European  Commission,  ‘Croatia’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/croatia_en. 

Croatia’s  progress  in  implementing  the  Inspire  Directive 
has  been  reviewed  based  on  its  2023  country  fiche (164) 
(see Table 3). In 2022, Croatia received a priority action on 
the need to make spatial data more widely accessible and 
to  prioritise  environmental  datasets.  Croatia  has  made 
some progress on the accessibility of spatial data but more 

(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 
2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF). 

(163)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee  rights  of  access  to  justice  and  legal  standing  and  to 
overcome other major barriers to bringing cases on environmental 
protection. 

(164)  European  Commission, 

‘Croatia’, 

Inspire  Knowledge  Base, 

https://knowledge-base.inspire.ec.europa.eu/croatia_en. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
efforts are needed. Therefore the 2022 priority action is 
repeated for 2025. 

establishment of self-consumption and renewable energy 
communities. 

Croatia  50 

Public participation 

Public involvement  at both the planning and the project 
phases maximises transparency and social acceptance of 
programmes  and  projects.  Consultation  with  the  public 
(including  NGOs)  and  environmental,  local  and  regional 
authorities  is  a  key  feature  of  an  effective  impact 
assessment procedure. Such consultation also provides an 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the  EIA  Directive (165)  and  the  Strategic  Environmental 
Assessment (SEA) Directive (166). 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 
the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and continues to support the 
Member  States  in  this  regard  (167)  Croatia  has  not  yet 
to  accelerate  permit-issuing 
taken 
procedures  taking  advantage  of  the  broad  flexibilities 
offered  by  the  EU 
legal  framework,  such  as  the 
establishment  of  one-stop  shops  and  accelerated  short 
issuing  permits  for  renewable  energy 
deadlines  for 
projects.  However,  Croatia  has  taken  measures  to 
alleviate  barriers  and  administrative  procedures  for  the 

steps  aiming 

(screening, 

scoping,  EIA 

The average speed in the EU for issuing permits involving 
is  20.6 months,  with  a  minimum 
an  EIA  procedure 
duration  of  11.4 months  and  a  maximum  duration  of 
75.7 months (168).  The  duration  of  each  step  in  an  EIA 
process 
report,  public 
consultation, reasoned conclusion, development consent) 
varies  considerably  across  Member  States  and  projects. 
The available data show that the average duration of EIA 
process for Croatia is slower than the EU average. Effective 
use of EU procedures can positively influence the timely 
approval of activities underpinning the decarbonisation of 
the economy on the way to net zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a  support  study has been published with information by 
Member State (169). 

includes 

levels (170).  This 

Extensive  and  useable  information  is  available  to  the 
public  on  EIA  and  SEA  cases,  at  both  the  national  and 
regional 
links  to  relevant 
documentation and details of how members of the public 
can  participate  in  the  process.  However,  there  are  no 
centrally  collected  statistics  on  public  participation  in 
practice  and  it  is  not  possible  to  identify  whether 
participation  is  increasing  or  decreasing  or  assess  how 
participation is contributing to improved decision-making. 

The non-conformity case (171) that opened on 19 January 
2019 concerning obligations arising from the EIA Directive 
2011/92/EU as amended by Directive 2014/52/EU is still 
ongoing. 

Access to justice 

Access to justice, guaranteed by Article 19(1) of the Treaty 
on  European  Union  and  Article 47  of  the  EU  Charter  of 
Fundamental Rights, is a fundamental right and part of the 
democratic process. It is vital to ensure the full application 
of EU law in all Member States and the legal protection of 
the  rights  of  individuals,  including  in  environmental 

(165)  Directive  2011/92/EU  of  the  European  Parliament  and  of  the 
Council of 13 December 2011 on the assessment of the effects of 
certain public and private projects on the environment (OJ L 26, 
28.1.2012, 
https://eur-lex.europa.eu/legal-
p. 1), 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(166)  Directive  2001/42/EC  of  the  European  Parliament  and  of  the 
Council of 27 June 2001 on the assessment of the effects of certain 
plans and programmes on the environment (OJ L 197, 21.7.2001, 
p. 30), 
https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32001L0042. 

(167)  Commission Staff  Working  Document  (SWD/2022/0149  final),  18 
May 
2022, (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229
953). 

(168)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 

Impact  Assessment 

revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(169)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

(170)  https://mingor.gov.hr/o-ministarstvu-1065/djelokrug/uprava-za-

procjenu-utjecaja-na-okolis-i-odrzivo-gospodarenje-otpadom-
1271/procjena-utjecaja-na-okolis-puo-spuo/7370 
only). 
INFR(2019)2022. 

(in  Croatian 

(171) 

2025 Environmental Implementation Review – Croatia 

 
 
 
matters.  Access  to  justice  is  essential  to  enable  judicial 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

This  section  provides  a  snapshot  of  the  state  of  play  of 
access to courts by the public, particularly when it comes 
to challenging plans, or the non-adoption of plans, under 
EU law, in the areas of water, waste, air quality and noise, 
irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As  mentioned  in  the  2022  EIR,  Croatia  allows  both 
to  challenge 
individuals  and  environmental  NGOs 
administrative acts of individual scope under Article 168 of 
its Environmental Protection Act (172). 

However,  plans  and  programmes  for  which  SEAs  are 
conducted are considered general acts. Their legality can 
only be reviewed by the High Administrative Court using a 
sui  generis  review  procedure.  Although  anyone  has  the 
right to bring a case for the review of the legality of general 
acts, this right is limited by the condition that a review can 
only  be  initiated  based  on  the  individual  act  that  was 
passed on the basis of the general act, such as a location 
permit issued based on the spatial plan in question. 

Under the general rules of judicial review, when a person 
claims  that  a  public  body  has  failed  to  enact  certain 
decisions,  that  person  may  initiate  a  judicial  review  in 
respect  of  this  failure  if  they  have  legal  standing –  for 
instance, if they feel their right to a healthy life has been 
violated. However,  an  action for judicial review  can only 
be brought before the Administrative Court if the decision 
at  issue  was  an  individualised  decision.  A  judicial  review 
therefore  cannot  be  initiated  in  respect  of  the  public 
authorities’ failure to enact an act of general application. 
The rules on standing for individuals and NGOs wishing to 
obtain an administrative review and bring a legal challenge 
before the national court are limited in such cases. 

In  2022,  priority  actions  were  addressed  to  Croatia 
regarding  access  to  justice,  inviting  authorities  to  (i) 
improve  access  to  courts  by  the  public  concerned  in 
relation to environmental planning, and (ii) better inform 
the  public  about  their  rights.  It  can  be  concluded  that 
there has been no progress  on  either  aspect. In fact, no 
new measures to improve access to courts with regard to 
environmental planning have been taken by Croatia since 
the  last  recommendation  in  2022,  and  the  information 
available online does not give a sufficient and clear picture 

(172)  Croatian  Official  Gazette  Nos 80/13,  153/13,  78/15,  12/18  and 

118/18. 

(173)  https://github.com/INSPIRE-MIF/need-driven-data-

prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx. 

(174)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 

Croatia  51 

of access to justice in environmental matters but is rather 
focused on cost exposure.  

2025 priority actions 

environmental 

•  Make  spatial  data  more  widely  accessible  and 
prioritise 
the 
implementation  of  the  Inspire  Directive,  especially 
those  identified  as  high-value  spatial  datasets  for 
implementing environmental legislation (173). 

datasets 

in 

•  Ensure  the  correct  transposition  of  the  revised  EIA 

Directive. 

•  Ratify the amendment to the United Nations Economic 
Commission  for  Europe  Convention  on  Access  to 
Information,  Public  Participation  in  Decision-making 
and Access to Justice in Environmental Matters. 
Improve  access  to  courts  in  national  environmental 
cases by the public concerned and eliminate practical 
barriers, such as length of proceedings and excessive 
costs in some Member States.  

• 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air  and nature, to manage waste (174) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 
criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place.  

When  inspections  and  other  control  activities  identify 
problems,  a  range  of  responses  may  be  appropriate, 
the  use  of  administrative  and  criminal 
including 
enforcement tools. 

In November 2023, within the framework of the strategic 
partnership  upon  a  proposal  by  Croatia  and  France  a 

compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
Commission 
(https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

document 

working 

staff 

2025 Environmental Implementation Review – Croatia 

 
 
 
regional conference dedicated to strengthening the fight 
against crime affecting the environment was held, which 
representatives  from  Albania,  Bosnia  and  Herzegovina, 
Bulgaria,  Croatia,  France,  Greece,  Kosovo,  Montenegro, 
North Macedonia,  Serbia,  Slovakia,  Slovenia,  Poland and 
Romania attended (175). 

However, as mentioned in the 2022 EIR, there appear to 
be  no  centralised  databases  or  statistics  in  Croatia  on 
environmental  crimes  and  their  outcomes.  General 
publications on crimes, issued by the National Statistical 
Institute, the Prosecutor’s Office and the Ministry of the 
Interior,  provide  some  data.  For  instance,  the  annual 
report on police activity published by the Ministry of the 
Interior  includes  a  summary  of  statistical  data  on  the 
chapter  of  the  Criminal  Code  relating  to  environmental 
crimes.  However,  none  of  the  data  available  provides  a 
clear picture of the outcomes relating to the prosecution 
of environmental crimes (convictions, penalties, etc.). 

It appears that the environmental compliance assurance 
system  in  Croatia  would  benefit  from  allocating  more 
inspections  and 
human  and  financial  resources  to 
enforcement  authorities  and 
from  more  active 
participation 
in  the  work  of  the  Network  for  the 
Implementation and Enforcement of Environmental Law. 
A  more  detailed  assessment  of  compliance  assurance 
activities will be planned for the next EIR. 

Croatia  52 

Between  15 May  2022  and  31 December  2024,  the 
Commission  received  23  complaints  relating  to  the 
environment in Croatia. In terms of complaints per million 
inhabitants, that is 5.95, the third-highest number among 
all Member States (figures 40 and 41). More than half of 
those  complaints  concerned  alleged  breaches  of  nature 
(6) and waste (8) legislation. 

Figure 40: EU complaints 15 May 2022-31 December 2024 

Source: DG Environment complaints data. 

Figure 41: EU complaints per million inhabitants 15 May 
2022-31 December 2024  

Source:  Eurostat,  ‘Population’  tps00001,  accessed  22  January  2025, 
https://ec.europa.eu/eurostat/databrowser/view/tps00001/default/tab
le?lang=en, and DG Environment complaints data. 

Southeast 

(175) 
(https://www.selec.org/strengthening-the-fight-against-crimes-that-
affect-the-environment-in-southeast-europe/) 

Enforcement 

European 

Law 

Center 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
Concerning  compliance  promotion,  monitoring,  and 
criminal  and  administrative  enforcement,  the  2022 
priority  actions  are  not  assessed  here  due  to  a  lack  of 
systematic  information.  Similarly,  the  Commission  is  not 
aware of whether information is easily available online at 
the national level for farmers regarding compliance with 
the Nitrates and Nature Directives, and hence the related 
2022 priority action is not assessed. 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental Crime Directive (ECD) (2024/1203/EU)(176) 
and new sectorial legislation with stronger provisions on 
compliance  monitoring,  enforcement  and  penalties. 
Issues 
the 
the 
implementation  of  the  relevant  new  instruments  are 
highlighted below; a detailed assessment of these topics 
will be included in the next EIR once more implementation 
measures  are  put 
in  place  and  more  systematic 
information is available. 

transposition  and 

important 

for 

The  new  ECD  replaced  the  2008  ECD  and  introduced 
several  new  offence  categories,  such  as  unlawful  ship 
recycling,  unlawful  water  abstraction,  and  serious 
breaches  of  EU 
legislation  on  chemicals,  mercury, 
fluorinated GHG and IAS of EU concern. It also covered the 
establishment  of  qualified  offences,  subject  to  more 
severe penalties where one of the offences defined in the 
directive  leads  to  serious  widespread  and  substantial 
damage  or  destruction  of  the  environment.  Practical 
provisions on the types and levels of penalties for natural 
and  legal  persons  who  commit  an  offence  were  also 
introduced.  Other  provisions  will  help  considerably  to 
improve  the  effectiveness  in  combating  environmental 
crime  of  all  actors  along  the  enforcement  chain.  These 
include  obligations  to  ensure  adequate  resources  and 
investigative  tools,  specialised  regular  training  and  the 
establishment  of  cooperation  mechanisms  within  and 
between Member States as well as national strategies on 
combating environmental crime. 

(176)  Directive  2024/1203/EU  on  the  protection  of  the  environment 
(https://eur-

criminal 

through 
law 
lex.europa.eu/eli/dir/2024/1203/oj/eng), 

(177)  https://www.impel.eu/en. 
(178) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LIFE2
0-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-investigations). 

project 

(179)  https://www.environmentalprosecutors.eu. 
(180)  https://www.eufje.org/index.php?lang=en. 

Croatia  53 

including  by 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
crime, 
in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
invited  to 
specialised  skills  required  and  they  are 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 
Law (177),  EnviCrimeNet (178),  the  European  Network  of 
Prosecutors for the Environment (179) and the EU Forum of 
Judges  for  the  Environment (180).  The  European  Union 
Agency for Law Enforcement  Cooperation  and  European 
Union  Agency 
Justice  Cooperation 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences.  

for  Criminal 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)(181)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (182), which will be finalised in 2025, and which 
was  supported  by  an  external  study (183),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

(181)   Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage, https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626. 
(182)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

(183)  European Commission: Directorate-General for Environment and 
Fogleman,  V.,  Study 
in  support  of  the  evaluation  of  the 
Environmental  Liability  Directive  and  its  implementation –  Final 
report,  Publications  Office  of  the  European  Union,  Luxembourg, 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Croatia 

 
 
 
indicators 

in  assessing 
One  of  the  most  relevant 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the previous reporting period. Fewer ELD cases have been 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 
tendency  in  the  number  of  ELD  occurrences  and  their 
overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  be  compared 
with the overall number of environmental damage cases, 
some  of  which  may  have  been  handled  under  the  other 
liability instruments. 

The ELD has not always been effective in ensuring that the 
polluter  pays,  because  the  liable  operators  often  lack 
financial  capacity  to  carry  out  remediation  measures. 
While the ELD does not provide for a mandatory financial 
security  system,  it  explicitly  calls  for  Member  States  to 
encourage 
financial  security 
instruments  and  markets,  with  the  aim  of  enabling 
operators  to  use  financial  guarantees  to  cover  their 
responsibilities under this directive. 

the  development  of 

From 1 May 2013 to 30 April 2022, Croatia did not identify 
any occurrence of environmental damage under the ELD. 
The reporting requirement of the previous period was not 
applicable to Croatia, as it joined the EU in 2013. 

Croatia  has  proposed  legislation  to  establish  mandatory 
financial security for ELD liabilities for operators carrying 
out  certain  hazardous  activities  (adoption  pending). 
Currently  environmental 
insurance  policies  are  not 
available in Croatia. Environmental extensions to general 
liability policies are available, but most provide cover only 
for remediating off-site land/soil pollution from a sudden 
and  accidental  incident  on  an  insured  site.  They  do  not 
provide cover for the other possible ELD liabilities, notably 
for  environmental  damage  other  than  pollution,  or  for 
gradual pollution. Demand for the extensions is low. 

The 2022 EIR recommended that Croatia further develop 
the  information  system  on  ELD  cases  or  instances  of 
environmental damage and encourage better availability 
of insurance products to ensure that operators can meet 
the costs of any environmental damage for which they are 
liable.  Croatia  has  made  some  progress  on  the  2022 
priority actions by aiming to ensure better availability of 
insurance  products.  Therefore,  the  efforts  to  implement 
2022 priority actions in relation to the ELD should continue 
along with the 2025 priority action. 

(184)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

(185)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-

Croatia  54 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level) covering the ELD and its interactions with other 
national liability-related instruments, to ensure more 
efficient ELD implementation, improve  the expertise 
of  the  competent  authorities  and  raise  awareness 
among all stakeholder groups. 

EU-supported environmental capacity building 

The Commission’s 2023 Compact (184) initiative to enhance 
the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 
of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
for 
the  European 
Commission  are  the  TSI (185)  and  the  TAIEX-EIR  PEER  2 
PEER tool (186). The technical assistance available through 
the cohesion policy is subject to shared management and 
is not dealt with in this subsection. 

the  environment  provided  by 

The Commission’s technical support instrument  

The  TSI  provides  Member  States  with  tailor-made 
technical expertise on the design and implementation of 
reforms.  The  support  is  demand  driven  and  does  not 
require national co-financing. 

The  TSI  had  annual  calls  in  2021,  2022,  2023,  2024  and 
2025.  The  following  environment-related  projects  have 
been selected for Croatia: 

• 

Support to reduce water loss within the water sector 
reform 
in  Croatia,  Ministry  of  Economy  and 
Sustainable  Development  (MESD),  Croatian  Waters 
(CW) (2022)  

• 

•  Bridging the climate financing gap with public policy 
instruments,  Financial  Services  Supervisory  Agency 
(2022)  
ESG  risk  management  framework  for  the  financial 
sector, Financial Services Supervisory Agency (2023)  
Support  for  the  Preparation  of  Social  Climate  Plans, 
Sustainable 
Ministry 
Development (2024)  

Economy 

and 

of 

• 

•  Multi-country  support  to  the  revised  EU  Emissions 
Trading System, Ministry of Economy and Sustainable 
Development (2024)  

funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(186)  See the European Commission web page on the TAIEX-EIR PEER 2 
(https://environment.ec.europa.eu/law-and-

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 

tool 

2025 Environmental Implementation Review – Croatia 

 
 
 
Croatia  55 

• 

• 

Support to reduce water loss within the water sector 
reform in Croatia – Phase 2, Ministry of Economy and 
Sustainable Development  (2024) 
Support  to  the  development  of  the  National 
Restoration  Plans  of  Croatia,  the  Netherlands  and 
Poland,  Ministry  of  Environmental  Protection  and 
Green Transition (2025) 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
multi-country  workshops  are  those  requested  by  the 
European  Commission  to  present  new  and  upcoming 
environmental 
in  all  Member 
legislation  and  policy 
States (187). 

Workshops involving Croatia are as follows: 

•  New aspects in the cross-border cooperation against 
environmental crime (19–20 November 2024); 
•  Online  platform:  EU  batteries,  packaging  and 
packaging waste regulation (28–29 October 2024); 
•  Reducing  air  pollution  in  transport  and  residential 

energy (11–13 June 2024); 

•  Decentralised  biowaste  recycling  in  Austria  (09–

• 

11 October 2023); 
Future  challenges  in  the  air  protection  in  Europe 
(24 November 2022); 

•  Climate  adaptation  and  blue 

infrastructures: 
Examples  across  European  regions  (30  May–01 June 
2022); 

2025 priority action 

• 

Improve overall national environmental governance, 
in  particular  administrative  capacity  to  support  the 
green transition and coordination at the regional and 
local levels. 

(187)  Flagship  multi-country  workshops  in  the  reporting  period  are: 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025);  Industrial safety, awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
quality:  implementation  of  the  NECD  to  further  mainstream  air 
and  broader  pollution 
in  agricultural  policy 
reduction 
(25 September  2024);  Industrial  emissions  transposition  and 
implementation  of  the  revised  directive  (12 September  2024); 
Noise progress towards meeting Member States’ noise limit values 
and  EU  reduction  targets  (5 June  2024);  Best  practice  use  of 

environmental  footprint  methods  on  the  EU  market  (30 May 
2024);  Sustainable  finance  (9 November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13 June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 
in  planning  and  approval  of  renewable  energy  projects 
(17 November 2022); Environmental compliance and governance 
(14 November  2022);  Biowaste  management  (19-20 September 
2022);  Renewable  energy  projects:  permit  granting  processes 
(13 June 2022). NB: The first flagship workshop on zero pollution 
for air, water and soil took place 9 February 2022. 

2025 Environmental Implementation Review – Croatia 

 
 
 
 
 
Croatia  56 

Annex 

2025 priority actions 
Circular economy and waste management 
Transitioning to a circular economy 

• 

Speed up the transition to a circular economy by implementing an updated national strategy and 
the EU framework and recommendations, in particular to complement it with upstream 
circularity measures 

•  Develop a unified circular economy strategy focusing on waste prevention and resource 

efficiency, especially for priority waste streams. 

•  Adopt measures to increase the CMUR. 

Waste management 

• 

Increase reuse of products and scale up waste recycling infrastructure associated with the higher 
steps of the waste hierarchy. In particular, improve collection and increase treatment capacity for 
bio-waste.  
Improve municipal waste preparation for reuse and recycling. 
Increase the recycling rates of packaging waste. 
Increase the collection and recycling rate of waste electronic and electric equipment (WEEE). 

• 
• 
• 
•  Develop EPR schemes for problematic waste .  
• 

Implement, harmonise and gradually increase landfill taxes to phase out landfilling of recyclable 
and recoverable waste. 

•  Ensure the achievement of the 2025 waste targets, following the recommendations made by the 

Commission in the early warning reports where applicable. 
Invest in waste prevention measures to reduce the total amount of waste generated. 

• 

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000  

•  Complete the Natura 2000 site designation process 
•  Finalise the establishment of site-specific conservation objectives and measures for all Natura 2000 
sites (including by adopting their management plans) and ensure their effective implementation. 
implementation  of  Natura  2000  management  plans  and  sufficient 
administrative capacity and financing both for Natura 2000 and the implementation of the Nature 
Restoration  Regulation.  Ensure  implementation  of  Prioritised  Actions  Framework  2021-2027 
(PAFs). 

•  Ensure  the  effective 

•  Strengthen the collection of reliable data to assess the conservation status of protected habitats 

and species by ensuring that all are covered by a sound monitoring system. 

•  PA4: Strengthen the integration of biodiversity actions into other policies, e.g. energy, agriculture, 
fisheries,  forestry,  urban  and  infrastructure  planning  and  sustainable  tourism,  and  promote 
communication between stakeholders.   

Agricultural ecosystems 

Recovery of ecosystems 

• 

Implement eco-schemes and agri-environmental measures and practices to address the 
environmental needs of Croatia. 

Marine ecosystems  

•  Report updates on the assessment of the state of Croatia’s marine waters, its targets and its 

determinations of GES, which are expected to include any threshold values for the descriptors in 
the MSFD that may have been established in cooperation with other Member States at the EU or 
regional level.  

Prevention and management of invasive alien species 

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Croatia  57 

•  Step up implementation of the IAS Regulation, including with regard to enforcement and the 

capacity of inspection authorities. 

•  Support development of the national business and biodiversity network.  

Ecosystem assessment and accounting 

Zero pollution  
Clean air  

•  As part of the NAPCP, take action to reduce emissions of air pollutants. 
•  Ensure full compliance with the current AAQD standards, also in light of future stricter 

requirements under the revised AAQD. 

Industrial emissions  

•  Complete the correct transposition of the IED 1.0. 
•  Reduce industrial air pollution damage and intensity 
•  Engage with industry and environmental NGOs to ensure proper contribution to and 

implementation of BAT conclusions and ensure timely updates to permits following the 
publication of BAT conclusions. 

•  Ensure effective public participation and access to justice in relation to the IED. 

Major industrial accidents prevention – Seveso  
•  Strengthen compliance with requirements on safety measures to prevent major accidents and 
ensure appropriate preparedness and response in relation to UTEs, in particular as regards 
reviewing, testing and updating EEPs, at intervals of no more than three years.  
Ensure access to transparent and clear information towards citizens on risks and behaviour in 
case of accidents 

• 

•  Complete and implement action plans on noise management. 
Water quality and management  

Water Framework Directive 

Noise  

• 

Improve river continuity and ecological flows, boosting efforts on nature-based solutions to 
reduce hydromorphological pressures 

•  Ensure periodic reviews of permits for discharges, abstractions and other water uses, including 

hydropower pressures  

•  Reduce pollution from nutrients, chemicals, metals and saline discharges. 
• 
•  Develop more robust programmes of measures, tackle obstacles identified in the implementation 

Improve the classification of waterbodies and strengthen monitoring systems. 

of measures and ensure adequate financing for implementation, including through better use of 
cost recovery and the polluter-pays principle. 

Floods Directive 

• 

FRMPs should provide details on how the FHRMs were used in the choice of measures and how 
to consider pluvial flooding 

•  Better explain the choice and implementation of flood prevention and protection measures 

(prioritisation, monitoring, costs of measures).  
Improve public consultation and stakeholder involvement. 

• 

Drinking Water Directive 

• 

Swiftly implement the measures included in the national water loss reduction action plan. 

Nitrates Directive 

•  Tackle nutrient pollution, especially nitrates from agriculture, through the implementation of the 

Nitrates Directive.  

Urban Wastewater Treatment Directive 

2025 Environmental Implementation Review – Croatia 

 
 
Croatia  58 

•  Urgently take the necessary measures to ensure full implementation of the current UWWTD, 

taking into account the new requirements of the recast directive. 

Chemicals 
•  Upgrade the administrative capacities in implementation and enforcement to move towards a 

• 

• 

• 

policy of zero of for non-compliance. 
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement 
of the European Chemicals Agency, including in the coordinated enforcement projects, called REF 
projects.  
Increase customs checks and checks of products sold online with regard to compliance with 
chemicals legislation. 

Climate action 

Implement all polices and measures that are needed to achieve targets laid down in the Effort 
Sharing Regulation (ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) 
Regulation. More detailed priority actions are set out in the assessment of the final National 
Energy and Climate Plan (NECP). 

Financing 
•  Use more national funding (for instance by increasing taxes in favour of the environment and 
reducing environmentally harmful subsidies), EU funding and private funding to help close the 
investment gap. 

Environmental governance 
Information, public participation and access to justice 

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

• 

•  Ensure the correct transposition of the revised EIA Directive. 
•  Ratify  the  amendment  to the  United  Nations Economic  Commission  for  Europe  Convention  on 
Access  to  Information,  Public  Participation  in  Decision-making  and  Access  to  Justice  in 
Environmental Matters. 
Improve access to courts in national environmental cases by the public concerned and eliminate 
practical barriers, such as length of proceedings and excessive costs in some Member States. 
Compliance assurance 
•  Encourage  the  use  of  training  programmes  provided  by  the  Commission  (or  developed  at  the 
national  level)  covering  the  ELD  and  its  interactions  with  the  other  national  liability-related 
instruments,  to  ensure  more  efficient  ELD  implementation,  improve  the  expertise  of  the 
competent authorities and raise awareness among all stakeholder groups. 

• 

EU-supported environmental capacity building 
Improve overall national environmental governance, in particular administrative capacity to 
support the green transition and coordination at the regional and local levels. 

2025 Environmental Implementation Review – Croatia