COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - BELGIUM 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: Belgium, 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) 301 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review          Country Report - BELGIUM                 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) 302 final} - {SWD(2025) 303 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}  
 
 
Contents 

EXECUTIVE SUMMARY .............................................................................................................................................. 3 

PART I: THEMATIC AREAS ......................................................................................................................................... 5 

1. 

2. 

3. 

4. 

CIRCULAR ECONOMY AND WASTE MANAGEMENT ........................................................................................................... 5 
Transitioning to a circular economy ........................................................................................................................ 5 
Waste management ............................................................................................................................................... 8 
BIODIVERSITY AND NATURAL CAPITAL ......................................................................................................................... 14 
Global and EU biodiversity frameworks ................................................................................................................ 14 
Nature protection and restoration – Natura 2000 ................................................................................................ 14 
Recovery of species ............................................................................................................................................... 17 
Recovery of ecosystems ........................................................................................................................................ 18 
Prevention and management of invasive alien species ........................................................................................ 23 
Ecosystem assessment and accounting ................................................................................................................ 24 
ZERO POLLUTION ................................................................................................................................................... 26 
Clean air ................................................................................................................................................................ 26 
Industrial emissions ............................................................................................................................................... 27 
Major industrial accidents prevention – Seveso .................................................................................................... 29 
Mercury Regulation ............................................................................................................................................... 31 
Noise ..................................................................................................................................................................... 31 
Water quality and management ........................................................................................................................... 31 
Chemicals .............................................................................................................................................................. 36 
CLIMATE ACTION ................................................................................................................................................... 40 
The EU emissions trading system .......................................................................................................................... 40 
Effort sharing ........................................................................................................................................................ 41 
Land use, land-use change and forestry................................................................................................................ 42 
Adaptation to climate change ............................................................................................................................... 42 

PART II: ENABLING FRAMEWORK: IMPLEMENTATION TOOLS ................................................................................. 43 

5. FINANCING ................................................................................................................................................................ 43 
Climate finance landmarks.................................................................................................................................... 43 
Environmental financing and investments ............................................................................................................ 44 
Public financial management ................................................................................................................................ 48 
6. ENVIRONMENTAL GOVERNANCE .................................................................................................................................... 52 
Information, public participation and access to justice ........................................................................................ 52 
Compliance assurance........................................................................................................................................... 55 
EU-supported environmental capacity building .................................................................................................... 57 

 
 
 
 
 
 
 
 
Belgium  2 

Executive summary 

In  May  2016  the  European  Commission  launched  the 
Environmental  Implementation  Review  (EIR),  a  regular 
tool  based  on  analysis,  dialogue  and 
reporting 
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 Belgium. The purpose of this report is 
implementation 
to  provide 
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 
sectoral 
report 
implementation  reports  collected  or 
issued  by  the 
Commission under specific environmental legislation. 

relies  on  detailed 

information  on 

environmental 

regarding 

the 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
consideration 
factors  such  as  the  gravity  of  the 
environmental implementation issue in light of the impact 
on the quality of life of citizens, the distance to target, and 
financial  implications.  In  Belgium  such  challenges  have 
been 
Environmental 
Implementation Review in 2017 and require urgent action. 

lingering 

since 

first 

the 

Belgium  is  one  of  the  EU’s  best  performers  on  circular 
economy  as  regards  resource  productivity,  secondary 
materials  use  and  waste  management.  Belgium  is  in  the 
category of countries not considered at risk of missing the 
municipal  and  packaging  waste  targets.  However,  the 
market for recycled products is still limited and needs to 
grow to provide economic opportunities for products that 
are  collected  separately  and  recycled.  Further  progress 
could be made by introducing new economic instruments 
to prevent waste by avoiding the incineration of reusable 
or  recyclable  waste –  especially  in  the  Brussels  Region – 
and  by  making  the  reuse  and  recycling  of  waste  more 
economically attractive. 

is 

Belgium 
its  national 
in  the  process  of  updating 
biodiversity strategy to align its objectives with the EU and 
global  2030  targets.  A  revised  draft  of  the  national 
biodiversity  strategy,  which  now  includes  the  comments 
and suggestions received during public consultations (2), is 
available.  Its  adoption  is  envisaged  by  early  2025.  The 
coverage of Natura 2000 and nationally protected areas in 
Belgium  is  below  the  EU  average.  There  is  still  room  for 
further consolidation of the  protected area  coverage, as 

(1) 

from 

the  Commission 

Communication 
the  European 
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 
Environmental  Implementation  Review,  COM(2016) 316  final  of 

to 

illustrated by the recent designation of two national parks 
in  the  Walloon  Region.  However,  for  marine  protected 
area, Belgium ranks above the 30 % EU target. 

The problem of nitrogen deposition affecting natural areas 
and  ecosystems  is  tackled  by  the  nitrogen  decree  of 
24 January  2024,  which  aims  to  progressively  reduce 
nitrogen deposition in Natura 2000 sites. However, several 
appeals  have  been  made  against  the  decree.  Organic 
farming practices in Belgium are below the EU average and 
have not significantly contributed to achieving the target 
of farming 25 % of the EU’s agricultural land organically by 
2030. 

Belgium  has  not  met  the  objectives  of  the  Water 
Framework Directive given the heavy impact of pollutants 
from agriculture on the quality of groundwater / surface 
waters.  Pollution  of  groundwater  and  surface  waters  by 
nitrates remains widespread in Flanders. 

Urban  wastewater  collected  in  Belgium  is  overall  being 
properly treated as required by EU law. Belgium has yet to 
transpose the new nitrogen decree into its national legal 
system. 

The overall environmental investment needed to enable 
Belgium  to  meet  its  main  environmental  objectives  is 
EUR 3.7 billion per year, broken down as follows: circular 
economy  (EUR 886 million);  pollution  prevention  and 
control  (EUR 1.5 billion);  and  water  (EUR 1.4 billion).  , 
Additional  investment  is  needed  over  current  levels  in 
order to meet these environmental objectives and address 
climate  change;  this  is  known  as  the  investment  gap. 
Annually  in  Belgium,  it  represents  around  0.67 %  of  the 
national gross domestic product, which is lower than the 
EU average (0.77 %). 

With  regard  to  environmental  governance,  Belgium 
needs  to  (i)  ensure  that  relevant 
information  on 
environmental  impact  assessment  (EIA)  and  strategic 
environmental  assessment  procedures  (including  on 
public  participation  opportunities  and  the  publication  of 
final  decisions)  is  electronically  accessible;  (ii)  provide 
information on the average duration of all steps in the EIA 
process; (iii) ratify the amendment to the United Nations 
Economic  Commission 
for  Europe  Convention  on 
Environmental  Impact  Assessment  in  a  Transboundary 
Context  and  its  Protocol  on  Strategic  Environmental 
Assessment;  and  (iv)  improve  access  to  courts  for  the 
public  concerned  in  national  environmental  cases  and 
eliminate  practical  barriers,  such  as  excessive  costs.  On 
the  positive  side,  Belgium  continues  to  properly 

(2) 

2016, 

https://eur-lex.europa.eu/legal-

27 May 
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 
https://www.health.belgium.be/fr/consultation-publique-
sur-le-projet-de-la-mise-jour-de-la-strategie-nationale-de-la-
belgique-sur-0. 

2025 Environmental Implementation Review – Belgium 

 
 
implement  the  Inspire  Directive,  and  both  Flanders  and 
Wallonia 
procedures 
(environmental and  urban) for  renewable energy source 
projects.  Good  practices  identified  in  the  past  include 

single-permit 

introduced 

Belgium  3 

specialised  environmental  review  boards  for  EIAs  (2022) 
and a report on inspections by the Flemish Prosecutions 
Office (2017). 

 2025 Environmental Implementation Review – Belgium 

 
 
 
Belgium  4 

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 
circular  economy  has 
resource 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
in  place  or 
action  plan  (CEAP) (3)  measures  either 
legislatively advanced, EU Member States will now have to 
focus on a swift and effective implementation. 

consumption.  A 

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 
were all introduced following a holistic life-cycle 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.  

Figure 1 shows that the circular use of material in Belgium 
increased  from  2022  to  2023,  reaching  19.7 %  after  a 
downward  trend  since  2020.  In  2023,  the  CMUR  in 
Belgium was well above the EU average of 11.8 %. As of 
2023, Belgium was the EU’s fourth most advanced country 
for  circular  secondary  material  usage,  behind  the 
Netherlands (30.6 %), Italy (20.8 %) and Malta (19.8 %). 

25

20

15

10

5

0

2013

2015

2017

2019

2021

2023

Belgium

EU-27

Source: Eurostat, ‘Circular material use rate’, env_ac_cur, last updated 
13 November 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/view/env_ac_cur/default/t
able?lang=en. 

10 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
can help to minimise negative impacts on the environment 
and reduce dependency on volatile raw material markets. 
As shown in Figure 2, Belgium generated EUR 2.84 per kg 
of material consumed in 2023, putting Belgium well above 
the  EU’s  average  of  EUR 2.23  per  kg  for  resource 
productivity.  However,  the  latest  data  show  there  has 
been a recent decline in Belgian resource productivity. 

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

4,0

3,0

2,0

1,0

0,0

2013

2015

2017

2019

2021

2023

Belgium

EU-27

NB:  The  unit  of  measure  used  is  EUR/kg  chain-linked  volume  (2015). 
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 
2024, 
7 August 

9 December 

accessed 

2024, 

(3) 

from 

the  Commission 

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, 

to 

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

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Belgium 

 
 
 
 
https://ec.europa.eu/eurostat/databrowser/view/env_ac_rp/default/ta
ble?lang=en. 

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 (4)  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 (5)  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. 

In  December  2021  Belgium  adopted  a  new  full-fledged 
action  plan  for  a  circular  economy  2021–2024  at  the 
federal level (6). This plan aims to encourage opportunities 
related to the circular economy in terms of innovation, job 
creation  and  competitiveness  in  Belgium.  This  plan,  and 
the transition to a circular economy in general, also aim to 
combat 
and 
environmental degradation. Through this plan, the federal 
state  will  activate  the  levers  and  competences  at  its 
disposal, in particular product policy, consumer protection 
policy, public procurement and tax policy. Regional plans 
are  the  driving  force  behind  Belgium’s  transition  at  the 
policy level. 

biodiversity 

change, 

climate 

loss 

In the Brussels Region, the regional government adopted 
the  Brussels 
for  a  circular 
regional  programme 
economy (7)  in  2016  with  111  measures  laying  out  a 
strategy to transition from a linear to a circular economy 
by  2025.  The  programme  set  a  10-year  implementation 
framework to move Brussels’ economy towards a circular 
model. To ensure the programme is kept up to date and 
remains relevant, it is revised every 18 months. From April 
2022,  it  has  been  included  in  the  regional  strategy  for 
economic transition 2022–2030 (8). 

The  Walloon  waste  resources  plan,  adopted  in  2018 
following  a  broad  public  consultation,  already  included 
among its strategic directions operational objectives and 
regional  policy  measures 
for  the  prevention  and 
management  of  household  and  industrial  waste  and  a 
major focus on resource circularity.  The plan deals with 

(4) 

(5) 

(6) 

(7) 

website, 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
https://single-market-
European 
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
https://www.health.belgium.be/fr/plan-daction-federal-pour-
une-economie-circulaire-2021-2024. 
https://www.circulareconomy.brussels/a-propos/le-
prec/?lang=en. 

Stakeholder 

Economy 

Platform 

Belgium  5 

waste generally and focuses specifically on the reduction 
of  food  loss  and  waste,  the  recovery  of  biowaste  and 
plastics,  better  management  of  construction  and 
demolition  waste,  the  efficiency  of  extended  producer 
responsibility systems and the fight against fly-tipping. In 
addition,  the  Circular  Wallonia  regional  strategy  was 
adopted  on  4 February  2021.  This  strategy  uses  a 
participatory process to take a systemic approach to the 
transition  towards  a  circular  economy.  It  identifies  six 
priority value chains: construction and buildings; plastics; 
metallurgy  (including  rare/critical  metals  and  batteries); 
water; textiles; and the  food  industry and food systems. 
The  implementation  report  of  the  Circular  Wallonia 
strategy was published in September 2024. 

In  the  Flemish  Region,  the  Vision  2050  strategy  was 
approved in 2016. It identified the circular economy as one 
of the seven transitions needed by 2050 and launched a 
policy  process  for  increased  circularity.  Other  important 
circular  economy  policies  and  measures  in  the  Flemish 
Region  can  be  found  in  the  Circular  Economy  Country 
Profile 2024 – Belgium report, published by the European 
Environment Agency (EEA) (9). 

The  Local  Materials  Plan  2023–2030 (10)  for  household 
waste  and  similar  industrial  waste  was  approved  by  the 
Flemish government on 26 May 2023. It was declared to 
the  European  Commission  as  both  a  prevention 
programme  and  as  a  waste  management  plan.  The  plan 
aims  for  an  absolute  stabilisation  of  total  waste 
production, a decrease in certain specific waste streams, 
an increase in reuse, a 30 % decrease in residual waste and 
a decrease in incineration and littering. The plan contains 
several  obligations  for  local  authorities  and  over  70 
actions  that  will  be  taken  by the  Flemish  government  in 
the coming years to reach the objectives. 

The Flemish Region has also had an action plan on circular 
food  loss  and  biomass  in  place  since  2021  and  one  on 
plastics since 2020. Implementation of both action plans is 
ongoing, with goals set for 2025.  

As  part  of  the  country’s  recovery  and  resilience  plan 
(RRP) (11), the Flemish Region adopted a recovery plan for 
Flemish  resilience (12),  aiming  to  support  an  accelerated 
shift  towards  a  maximum  circular  economy  through 
European funds. The Belgium Builds Back Circular federal 
investment  plan  is  set  to  invest  EUR 28.97 million  from 
in  order  to  stimulate  research  and 
2022  to  2026 

(8) 

(9) 

(10) 
(11) 
(12) 

https://shiftingeconomy-
brussels.translate.goog/?_x_tr_sl=fr&_x_tr_tl=en&_x_tr_hl=en-
US&_x_tr_pto=wapp. 
https://www.eionet.europa.eu/etcs/etc-ce/belgium_2024-ce-
country-profile_final.pdf.  
https://ovam.vlaanderen.be/lokaal-materialenplan-2023-2030. 
https://nextgenbelgium.be/fr/.  
https://www.vlaanderen.be/publicaties/relanceplan-vlaamse-
regering-vlaamse-veerkracht. 

2025 Environmental Implementation Review – Belgium 

 
 
development  in  companies  and  research  institutions  on 
the  following  three  pillars:  eco-design,  substitution  of 
substances  of  concern,  and  raising  awareness  and 
informing small and medium-sized enterprises about the 
circular economy. 

In 2024 a new infringement procedure was opened against 
Belgium  for  not  meeting  the  agreed  collection  rate  of 
waste electrical and electronic equipment (WEEE) in 2021 
(INFR(2024)2121). 

Green public procurement  

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  around  14 %  of  EU  GDP. 
Public  procurement  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  Belgium,  a  detailed  strategy  on  sustainable  public 
procurement has been in place for the federal government 
departments since 2014, combining the green and social 
aspects of public procurement. A revision of this strategy 
was announced in 2022. Specific regulations in the context 
of sustainable public procurement were adopted for wood 
(2005),  vehicles  (2009,  2010  and  2022)  and  energy 
efficiency  (2013),  with  specific  legislative  and  policy 
documents  in  the  country’s  three  regions  and  at  the 
federal level. 

Green  public  procurement  criteria  have  been  developed 
by the Flemish Region and at the federal level thanks to 
initiatives by several departments. In most cases, the EU 
green  public  procurement  criteria  are  the  basis  for 
national-level  discussions  with  stakeholders.  To  date, 
federal  green/sustainable  public  procurement  criteria 
have  been  developed  for  about  70  product  and  service 
groups. 

the 

coalition  agreement  of 

Sustainable  public  procurement  is  anchored  in  the  new 
2024–2029 
Flemish 
government.  The  coalition  agreement  states  that  the 
Flemish  government  must  pursue  a 
sustainable 
procurement  policy.  Coordination  is  provided  between 
the  actions  offered  by  the  various  policy  domains, 
whereby  all  partners  involved  in  an  action  are  jointly 
responsible  for  achieving  it.  Current  actions  include  the 
sustainable public procurement criteria tool, which offers 
sustainability criteria to all public buyers, and the roll-out 
of  the  CO2  Performance  Ladder,  which  is  aimed  at 
structurally reducing the greenhouse gas (GHG) impact of 
the works sector. 

Belgium  6 

Recently,  a  tool  has  been  created  for  sustainable  public 
procurement (13). It implements soft criteria. The tool is a 
collaboration with the Dutch government. There is also a 
federal website for sustainable purchases (14). 

The Brussels Region has a framework with three levels: (i) 
developing standards, for example for clean vehicles and 
sustainable  buildings  construction  and  renovation;  (ii) 
providing  information,  training  sessions  and  help  desk 
advice;  and  (iii)  establishing  a  mandatory  framework  for 
the public authorities dependent on the Brussels Region. 

On 4 February 2021, the Walloon Region adopted its first 
strategy for the circular economy. Public procurement is 
identified  therein  as  a  lever  to  initiate  the  region’s 
transition  to  a  circular  economy.  The  strategy  outlines 
several goals for 2025, such as: 

—  50 %  of  relevant  public  procurement  contracts 
will  integrate  circular  economy  principles  or 
circular criteria; 

—  75 % of public ICT contracts  will be circular  and 

ethical; 

—  all  public  demolition/deconstruction  contracts 
and subsidised contracts will include a materials 
inventory and selective deconstruction; 

—  reuse  materials  will  be  used  in  all  public  works 
contracts  and  progressively  in  works  subsidised 
by the Walloon Region. 

In  March  2024  the  Walloon  Region  launched  a  call  for 
applications  for  support  for  contracting  authorities  in 
rethinking their procurement policies to incorporate more 
circular  considerations.  These  public  authorities  will  be 
supported commensurately with their level of experience. 
Tools,  meetings  and  capacity-building  workshops  will 
complement this initiative to maximise the promotion of 
circular  transition  in  public  procurement.  A  meeting 
between  buyers  and  suppliers  of  circular  offers  will  be 
organised to foster dialogue between the public and the 
private  sectors.  The  Walloon  waste  resources  plan 
formally  provides  for  supporting  the  prevention  and 
recovery  of  construction  and  demolition  waste  through 
public works contracts, in particular by imposing the use 
of  recycled  materials.  Furthermore,  the  updated  2024 
edition  of  the  standard  specifications  for  building 
works (15) 
for  construction 
the  obligation 
companies  to  complete  a  construction  site  waste 
management plan according to an established model, and 
to  sort  waste  into  different  categories  in  order  to 
maximise the recovery and circularity of materials. These 
into  the  special 
clauses  must  now  be 
specifications and implemented. 

integrated 

includes 

(13) 

https://www.vlaanderen.be/het-facilitair-bedrijf-
overheidsopdrachten-en-raamcontracten/duurzame-en-
innovatieve-overheidsopdrachten/acties-en-goede-
voorbeelden/mvoo-criteriatool. 

(14) 
(15) 

https://www.gidsvoorduurzameaankopen.be/nl. 
https://batiments.wallonie.be/home.html. 

2025 Environmental Implementation Review – Belgium 

 
 
A study on recommendations for the federal government 
regarding circular procurement was produced in 2024. 

in  2024,  creating  a  reparability 

Following  the  example  of  France,  federal  legislation  was 
index  for 
passed 
dishwashers,  vacuum  cleaners,  pressure  washers, 
lawnmowers  and 
laptops.  The  repair  score  will  be 
displayed in shops starting in May 2025. 

The European Commission has highlighted a best practice 
from  Belgium  in  this  area:  Materialenbank (16),  based  in 
Leuven,  is  a  project  launched  in  2020  as  a  joint  effort 
between the Leuven City Council, Atelier Circuler (a non-
profit organisation active in the woodworking sector) and 
Wonen  en  Werken  (a  social  economy  organisation  that 
provides  employment  opportunities  to  people  from 
disadvantaged backgrounds). Its main activity consists of 
finding  construction  waste  materials  (mainly  wood  and 
stone)  in  the  Leuven  area  of  the  Flemish  Region  and 
recovering,  processing  and  reselling  them.  Reclaimed 
materials are purchased and used in the Leuven area by 
local  renovation  contractors  as  well  as  the  municipal 
government,  the  local  hospital  and  the  local  university. 
Materialenbank  closes  the  circle  in  terms  of  the  use  of 
building  materials  and  contributes  to  the  circular  and 
social economy of the city of Leuven. 

The EU Ecolabel and the eco-management and audit 
scheme  

The number of EU Ecolabel products and the number of 
eco-management  and  audit  scheme  (EMAS)-registered 
organisations in each country provide some indication of 
the  extent  to  which  the  private  sector  and  national 
stakeholders  in  that  country are  actively  engaged  in  the 
transition  to  a  circular  economy.  The  EU  Ecolabel  is 
awarded  to  products  with  best-in-class  environmental 
is  a  voluntary  environment 
performance.  EMAS 
the 
at 
scheme 
management 
environmental impacts of organisations. 

reducing 

aimed 

As  of  September  2024,  Belgium  had  3 947  Ecolabel 
products  out  of  the  EU  total  of  98 977,  and  68  Ecolabel 
licenses out of the 2 983 awarded, showing good take-up 
with regard to both products and licences (17). Moreover, 
59 organisations from Belgium are currently registered in 
EMAS, four more than in 2021 (18). 

No  priority  actions  specifically  on  the  circular  economy 
and  not  related  to  waste  were  suggested  in  the  2022 
environmental 
implementation  review  (EIR)  country 
report. 

(16) 
(17) 

https://www.leuven.be/materialenbank#welke-materialen/.  
European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
2025, 
https://environment.ec.europa.eu/topics/circular-economy/eu-
ecolabel/businesses/ecolabel-facts-and-figures_en. 

9 January 

accessed 

website, 

Belgium  7 

2025 priority action 

• 

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. 

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 
legislation,  which 
includes  the  waste  hierarchy,  the  obligation  to 
ensure separate collection of waste, landfill diversion 
targets, etc.; 

implementing  EU  waste 

(iii)  reducing waste generation per capita and in absolute 

(iv) 

(v) 

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  content  in  all 
products; 
limiting energy recovery to non-recyclable materials; 
and 

(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 
landfilling  and 
includes 
option,  disposal 
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. 

(18) 

As  of  October  2024.  European  Commission,  ‘EMAS  register’, 
European  Commission  website,  accessed  9 January  2025, 
https://webgate.ec.europa.eu/emas2/public/registration/list. 

2025 Environmental Implementation Review – Belgium 

 
 
Waste  generation  in  Belgium  shows  an  increasing  trend 
from  2012  onwards,  followed  by  a  decrease  in  2022 
(Figure 3).  Overall,  no  clear  decoupling  of  waste 
generation from economic growth is visible over the 12-
year period. 

Belgium’s  overall  performance  in  waste  generation  and 
management  is  good.  This  can  be  seen  by  taking  into 
account  the  indicator  for  recycling  and  circular  material 
use combined with the country’s production of waste per 
capita, which is below the EU average. 

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

accessed 

15 October 

nama_10_gdp, 

NB: Waste generation data for odd years are interpolated. 
Sources: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_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/default/
table?lang=en; Eurostat, ‘Population change – Demographic balance and 
crude  rates  at  national  level’,  demo_grind,  accessed  15 October  2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default/t
able?lang=en&category=demo.demo_ind. 

30 September 

22 October 

accessed 

2024, 

Critical raw materials 

In Belgium, waste management is a regional competence. 
The  three  Belgian  regions  have  established  regulatory 
frameworks concerning waste, including waste flows that 
contain significant amounts of CRMs, and are in line with 
existing  EU 
legislation.  Legislation  on  the  separate 
collection and recycling of WEEE, batteries and end-of-life 
vehicles  is in place. The most  important  instruments are 
extended producer responsibility schemes for these waste 
streams. 

Each  regional  government  has  also  concluded  specific 
the 
conventions/agreements  with 
environmental 
organisations representing the sectors concerned. 

The  regions  impose  recycling  targets  of  95 %  for  ferrous 
and  non-ferrous  metals  from  the  dismantling  and 
treatment  of  WEEE,  batteries  and  end-of-life  vehicles. 

Belgium  8 

These  targets  are  largely  met  for  the  relevant  waste 
streams.  The  regions  require  specific  reporting  on  the 
treatment  of  these  waste  streams  (quantities  of  waste 
respectively reused, recycled, recovered and disposed of; 
from 
treatment  methods;  material 
treatment; etc.). 

flows  resulting 

The Walloon decree of 9 March 2023 on waste, material 
circularity  and  public  cleanliness  specifically  mentions 
CRMs. 

to  enable  public  authorities 

The first version of Circular Wallonia aims to increase the 
implementation  of  the  circular  economy 
in  public 
procurement.  A  great  deal  of  awareness-raising, 
information-sharing, education and support work is under 
way 
(municipalities, 
administrations, etc.) to incorporate circular clauses into 
public  works,  supply  or  service  contracts.  However,  no 
effort  has  been  made  to  specifically  increase  the  use  of 
secondary CRMs. This could be the subject of a new focus 
as part of the new version of the Circular Wallonia strategy 
in  order  to  match  the  priorities  of  the  Critical  Raw 
Materials Act. 

In  the  Brussels  Region,  there  is no specific  strategy  with 
regard  to  CRMs.  The  regional  resources  and  waste 
indirectly  addresses  CRMs 
management  plan  (2018) 
through  general  strategic  objectives  or  by  specifically 
targeting waste streams that are identified by the Futuram 
project. A new plan will be adopted by the government in 
2025 and will include a specific strategy related to CRMs, 
in accordance with the EU legislation on CRMs. 

In the context of the Flemish Region, a study was carried 
out by Circular Flanders with a link to CRMs (19). Circular 
Flanders 
is  a  partnership  of  Flemish  authorities, 
companies,  civil  society,  and academia  to  reflect  on  and 
discuss the Flemish circular economy (20).  

Finally,  under  the umbrella  of  the  Belgian  federal  action 
plan for the circular economy 2021–2024, several projects 
are ongoing that may consider CRMs, though none of the 
projects specifically targets these materials. 

Overall,  the  regional  policies  may  benefit  from  focusing 
more  specifically  on  CRM  recuperation  from  relevant 
waste streams. 

Construction and demolition waste 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (21) 

(19) 

https://ce-center.vlaanderen-
circulair.be/nl/publicaties/publicatie-2/17-circular-economy-and-
the-energy-transition-potential-of-a-flemish-circularity-hub-for-
ev-li-ion-batteries. 

(20)   Circular Flanders - Hub of the Flemish Circular Economy. 

(21) 

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  Union,  Luxembourg, 
2024, 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
by  the  Joint  Research  Centre  shows  that  preparing  for 
reuse  and  recycling  operations  are  preferred  over 
incineration  and 
landfilling  from  an  environmental 
perspective  for  most  of  the  different  streams  of 
the 
construction  and  demolition  waste.  However, 
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 Belgium would lead 
to 33 Mt of GHG emission savings annually (more than the 
combined annual GHG emissions from Estonia, Latvia and 
Luxembourg). 

The  preparing  for  reuse  and  recycling  rate  of  mineral 
construction and demolition waste in Belgium in 2022 was 
53.2 %  compared  with  the  EU  average  of  79.8 %. 
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 (22)  (so-called  resource 
assessments); extended producer responsibility and other 
economic  instruments;  and  upstream  measures  such  as 
increasing the recycled  content  in construction products 
and the circular design (23) of construction works. 

Boosting implementation – the 2023 Waste Early 
Warning Report 

This  section  focuses  on  the  management  of  municipal 
waste (24),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste  Early  Warning  Report (25)  identifying  the  general 
trends in waste management and the  Member States at 
risk of missing 2025 waste targets (see Figure 4). Belgium 
is  in  the  category  of  countries  not  considered  at  risk  of 
missing the municipal and packaging waste targets. 

(22) 

(23) 

https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 
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 Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for buildings 
design, 
2020, 
Brussels, 
https://ec.europa.eu/docsroom/documents/39984. 

Belgium  9 

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 either the 55 % 
preparing 
for 
municipal  waste  and  the  65 %  target  for  packaging 
waste  

for  reuse  and  recycling  target 

Member  States  at  risk  of  missing  the  preparing  for 
re-use 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 

Sources: EEA, ‘Many EU Member States not on track to meet recycling 
targets for municipal waste and packaging waste’, briefing No 28/2022, 
Copenhagen,  2023,  https://www.eea.europa.eu/publications/many-eu-
member-states. Reference data © ESRI. 

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

(24)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected waste from households, including paper and cardboard, 
glass, metals, plastics, biowaste, wood, textiles, packaging, WEEE, 
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 
from  households 
(Directive 2008/98/EC, Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en.  

composition 

to  waste 

and 

(25) 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
 
Regarding  the  2025  targets,  11  Member  States,  not 
including  Belgium,  have  used  this  prerogative.  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 (26), the Packaging and 
Packaging Waste Directive (27) and the Directive on Waste 
Electrical and Electronic Equipment (28). 

Municipal waste 

In Belgium in 2022, the rate for recycling and preparation 
for reuse was 55 % for municipal waste, and the recycling 
rate  was  80 %  for  packaging  waste.  Less  than  2 %  of 
municipal waste is landfilled. 

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

Belgium  10 

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

NB: There is a break in the series in 2020. As of reference year 2020, new 
reporting rules apply for calculating recycled municipal waste pursuant 
to  the  targets  laid  down  in  Article 11.2(c–e)  of  Directive 2008/98/EC. 
However, it is unclear based on the information available whether these 
new reporting rules have been fully implemented in Belgium yet. 
Source:  Eurostat,  ‘Municipal  waste  by  waste  management  operations’, 
env_wasmun, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table.  

22 October 

accessed 

Packaging waste 

The  recycling  rates  for  packaging  waste  materials  have 
stayed  relatively  stable  over  the  past  decade,  with  the 
exception  of  plastics  packaging,  which  increased  above 
the 2025 target in 2022. 

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

22 October 

accessed 

While Belgium performs comparatively well already, there 
is  still  room  for  improvement,  especially  by  diverting 
waste  from 
incineration  to  recycling.  For  example, 
separate  collection  could  be  improved  in  the  Brussels 
Region.  On  the  other  hand,  Belgium  has  reinforced  the 
provisions  for  biowaste  collection,  with  some  plans  to 
expand food waste collection. 

(26) 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. 
(27)  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. 

(28)  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 – Belgium 

 
 
 
 
 
 
 
 
 
 
Figure 7: Packaging waste generation, 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__cust
om_842634/default/table?lang=en. 

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

changed,  pursuant 

NB:  As  of  reference  year  2020,  the  rules  for  calculating  recycled 
packaging  waste  have 
to  Article 6a  of 
Directive 94/62/EC. Belgium has been applying the new calculation rules 
since reference year 2020. 
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__cust
om_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 

Belgium  11 

legal requirements (e.g. on waste prevention, on separate 
collection for certain waste streams, on recycling and on 
landfill targets). 

Belgium’s waste prevention programmes are developed at 
the  regional  level.  In  the  Brussels  Region,  the  waste 
prevention  programme  is  integrated  into  the  resources 
and  waste  management  plan  2018–2023.  The  Flemish 
Region  integrates  its  waste  prevention  programme  into 
several programmes and plans, with prevention and reuse 
as priority areas, including within the local materials plan 
2023–2030.  The  Walloon  Region’s  waste  prevention 
programme  is  part  of  the  Walloon  waste  resources  plan 
and  aims  to  optimise  resource  use  and  promote  waste 
prevention actions, with reuse being a priority area. 

Policies to encourage separate collection and recycling 

Separate  collection  is  prevalent  in  Belgium.  There  are 
differences  in  separate  collection  rates  between  the 
regions  (the  Brussels  Region  at  40 %  in  2021  versus  the 
Flemish  and  Walloon  Regions  at  70 %  and  75 % 
respectively  in  2022).  These  figures  relate  to  household 
waste, and the gap should indeed be closed. The gap can 
be attributed to the particularity of the  Brussels  Region, 
which  is  a  fully  urban  area  where  sorting  is  often  more 
complex  than  in  rural  areas.  The  resource  and  waste 
management  plan  provides  measures 
improve 
performance  despite  the  complex  situation (29).  Belgium 
and  especially  the  Flemish  Region  have  focused  on 
collecting  waste  separately  and  on  recycling  waste  over 
the past 10 to 15 years. However, the market for recycled 
products  is  still  limited  and  needs  to  grow  to  provide 
economic  opportunities  for  the  separately  collected  and 
recycled  products.  In  addition,  recycled  products  and 
secondary recycled materials have to compete with non-
recycled  and  primary  raw  materials.  A  recent  trend  has 
been that more complex products are being placed on the 
market, making it more challenging to repair, dismantle or 
recycle  them.  There  is  also a  lack  of  transparency  about 
the contents of products, making recycling more difficult. 

to 

Belgium  will  need  to  make  further  efforts  to  meet  the 
more  ambitious  recycling  targets  for  the  period  up  to 
2035 (30),  in  particular  the  related  target  to  reduce  the 
incineration  of  municipal  waste,  which  has  gradually 
increased from 42.8 % in 2017 to 45 % in 2022. 

(29) 

Commission  staff  working  document –  Country  Report  Belgium 
2020,  SWD(2020) 500  final  of  26 February  2020,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?qid=1584543810241&uri=CELEX%3A52020SC0
500,  p. 69.  The 
Environnement 

following  documents 
this 

from  Bruxelles 
hypothesis: 

confirm 

https://document.environnement.brussels/opac_css/elecfile/RA
P_2020_BenchmarkACR.pdf; 
https://app.bruxellesenvironnement.be/multimedia/ZeroWasteF
astForward_Colloque-11022020.pdf (slide 189). 
(EU) 2018/851,  Directive 

(EU) 2018/852,  Directive 

(30)  Directive 

(EU) 2018/850 and Directive (EU) 2018/849. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
is  collected  separately (32). 

Both the Flemish and Walloon Regions report that around 
70 % of their municipal waste is collected separately (31), 
whereas  the  Brussels  Region  reports  that  only  around 
37 % 
In  2023,  biowaste 
collection became mandatory in the Brussels Region with 
the aim of improving its recycling rate, and it is required 
for  all  households  and  companies  in  the  Flemish  and 
Walloon  Regions  from  2024  onwards,  unless  composted 
at the source. Furthermore, all three regions have banned 
the use of lightweight plastic bags. In 2022, Belgium had a 
recycling  rate  for  packaging  of  80 %,  well  above  the  EU 
average (65.4 %) (33). 

Policies to discourage landfilling or incineration 

All  three  Belgian  regions  already  have  a  system  in  place 
that taxes incinerated waste, and they all encourage heat 
recovery from waste incineration. Further progress could 
be  made  by  introducing  new  economic  instruments  to 
prevent waste by: (i) avoiding the incineration of reusable 
or recyclable waste (especially in the Brussels Region); and 
(ii)  making  the  reuse  and  recycling  of  waste  more 
economically attractive. 

Belgium  12 

The 2022 EIR listed two priority actions for Belgium. The 
country has made some progress in shifting reusable and 
recyclable  waste  away  from 
including 
through  economic  instruments,  but  there  is  still  further 
potential.  Belgium  has  made  substantial  progress  in 
ensuring that regional waste management plans are in line 
with the revised Waste Framework Directive. 

incineration, 

2025 priority actions 

• 

• 

• 

• 

through 

including 

economic 

Further shift reusable and recyclable waste away from 
incineration, 
economic 
instruments. 
Improve  separate  collection  at  the  source  e.g. 
through 
in 
infrastructure  for  separate  collection,  sorting  and 
recycling, and increasing public awareness. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 

instruments, 

investing 

(31)  OVAM,  https://publicaties.vlaanderen.be/view-file/54649 , 2023, 

(32) 

p. 12; Vivre la Wallonie, No 35, 2017, p. 15. 
Bruxelles Environnement, Plan de gestion des ressources et dechet 
(2018–2023),  Brussels,  2024, 
(PGRD) –  Rapport  d’activité 

https://document.environnement.brussels/opac_css/doc_num.p
hp?explnum_id=11178. 
https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Packaging_waste_statistics 

(33) 

2025 Environmental Implementation Review – Belgium 

 
 
 
2. 

Biodiversity and natural capital 

Global and EU biodiversity frameworks

Belgium  13 

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 
in  December  2022,  sets 
framework  (GBF),  adopted 
comprehensive  and  measurable 
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.  

targets 

to 

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 to enable implementation and commitments 
to  support  global  biodiversity.  A  BDS  actions  tracker (34) 
and a dashboard of indicators (35) provide information on 
implementation progress.  

recently 

adopted 

EU  Nature 

The 
Restoration 
Regulation (36) 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. 

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 

is 

Belgium 
its  national 
in  the  process  of  updating 
biodiversity  strategy  to  align  its  objectives  with  EU  and 
global 2030 targets. A drafting group was set up in 2023 
including  representatives  from  the  federal  government, 
the  three  regions  (the  Flemish,  Brussels  and  Walloon 
Regions)  and  the  three  language  communities  (Flemish-
speaking,  French-speaking  and  German-speaking).  A 
revised draft  of the  national  biodiversity  strategy, which 
now  includes  the  comments  and  suggestions  received 
during public consultations (37), is available. Its adoption is 
envisaged by early 2025.[To be updated in 2025] 

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  details on biodiversity financing  and investments for 
Belgium, see Chapter 5. 

2025 priority action 

• 

Submit  to  the  Convention  on  Biological  Diversity  an 
updated  NBSAP  or  national  targets  following  the 
adoption 
Kunming-Montreal  Global 
Biodiversity Framework. 

the 

of 

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

Nature protection and restoration – Natura 
2000 

Natura  2000 (38),  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. 

(34) 

(35) 

(36) 

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 
29.7.2024), 
Regulation 
(OJ 
the 
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). 

L 2024/1991, 
see 

(EU) 2022/869 

page 

web 

(37) 

https://www.health.belgium.be/fr/consultation-publique-sur-le-
projet-de-la-mise-jour-de-la-strategie-nationale-de-la-belgique-
sur-0. 

(38))  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 9 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. 

2025 Environmental Implementation Review – Belgium 

 
 
Belgium  14 

average  12.8 %)  and  SACs  under  the  Habitats  Directive 
covering 10.7 % (EU-27 average 14.3 %) of the territory. 

The coverage of the Belgian marine part of the North Sea 
by  Natura  2000  sites  is  1 317 km2  (38 %  of  the  Belgian 
marine area), combining two SACs (covering 1 178 km2 or 
34 % of the marine area) and three SPAs (covering 316 km2 
or 9 % of the marine area). 

Taking into consideration both the Natura 2000 network 
and other nationally designated protected sites, Belgium 
legally  protects  14.7 %  of  its  land  area  (EU-27  average 
26 %)  and  37.8 %  of  its  marine  area  (EU-27  average 
12.3 %) (43). 

While  the  completeness  of  the  Belgian  Natura  2000 
network  is  considered  to  be  high  overall,  there  remain 
some  insufficiencies  in  relation  to  Habitats  Directive 
Annex II  species  that  have  recolonised  Belgium  recently, 
such  as  Canis  lupus  (Flemish  and  Walloon  Regions)  and 
Cucujus cinnaberinus (Flemish Region). 

is  currently  an 

insufficient 
For  bird  species,  there 
designation  of  SPAs  for  breeding  populations  of  two 
Annex I  species  (Anarhynchus  alexandrinus  and  Asio 
flammeus)  as  well  as  for  the  breeding  populations  of  a 
range of SPA trigger species (e.g. Limosa limosa and Larus 
fuscus).  Since  the  designation  of  the  SAC  Vlakte  van  de 
Raan,  which  encompasses  the  previously  adopted  SCI 
Vlakte van de Raan, network sufficiency can be assumed 
for  the  marine  part  of  the  network  of  sites  under  the 
Habitats Directive. 

The  coverage  of  Natura  2000  and  nationally  protected 
land areas in Belgium is below the EU average. While this 
level  of 
can  be  explained  by  the  above-average 
urbanisation and the very high population density, there 
is still room for further consolidation of the protected area 
coverage, as illustrated be the recent designation of two 
national  parks  in  the  Walloon  Region.  However,  with 
regard  to  protected  marine  areas,  Belgium  ranks  above 
the 30 % EU target. 

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) (39); and (iii) effective 
management of all Natura 2000 sites through the setting 
of site-specific conservation objectives and measures. 

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 by 2030. 

the 

these 

requires 

commitments 

Meeting 
full 
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. 

The 
implementation  of  the  EU  Birds  and  Habitats 
Directives and the setting up of the Natura 2000 network 
are  regional  responsibilities  in  Belgium,  shared  between 
the  Flemish,  Walloon  and  Brussels  Regions.  The  Natura 
2000  network  in  Belgian  marine  waters  is  a  federal 
competence. 

Belgium is home to 59 habitat types (40) and 86 species (41) 
covered by the Habitats Directive. The country also hosts 
breeding  populations  of  188  bird  taxa,  83  of  which  are 
listed in Annex I to the Birds Directive (42). 

As shown in Figure 9, in 2023, 12.7 % of the national land 
territory of Belgium was covered by Natura 2000 sites (EU 
average  18.6 %),  with  special  protection  areas  (SPAs) 
classified under the Birds Directive covering 10.4 % (EU-27 

(39) 

(40) 

(41) 

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. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17  dashboard,  Annex I 
total,  19 December  2019, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/general-information-on-habitats-and-species-article-17-
national-summary-dashboards-archived. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17  dashboard,  Annex I 
total,  19 December  2019, 
https://www.eea.europa.eu/en/analysis/maps-and-

(42) 

(43) 

charts/general-information-on-habitats-and-species-article-17-
national-summary-dashboards-archived. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12  dashboard,  Annex I  total,  last  updated  11 May  2023, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/general-information-on-bird-species-populations-article-
12-national-summary-dashboards-archived.  This  counting  only 
takes into account bird taxa for which information was requested. 
Eurostat  dataset  env_bio4,  protected area percentage  for  2022, 
accessed 12 March 2025. . 

2025 Environmental Implementation Review – Belgium 

 
 
Belgium  15 

populations  in  the  region.  The  Walloon  Region  does  not 
yet  have  site-specific  conservation  objectives  for  its 
Natura 2000 sites. Instead, it applies a unique land-parcel-
specific legal protection regime to all land parcels within 
the Natura 2000 network, which seems to be effective in 
terms  of  both  preventing  deterioration  and  steering 
restoration measures (see below for further details). 

The  setting  of  conservation  measures  for  Natura  2000 
sites  in  the  Flemish  and  Walloon  Regions  is  a  work  in 
progress.  Priority  measures  have  been  identified  in  the 
designation acts for each SAC and SPA. 

Any  landowner  in  the  Flemish  Region,  public,  private  or 
non-governmental  organisation  (NGO),  may  apply  for  a 
‘nature  management  plan’  on  a  voluntary  basis  and 
receive  subsidies  for  nature management  after  approval 
of  the  plan.  The  submission  and  approval  of  nature 
is  a  continuing  process.  At  the 
management  plans 
moment,  approximately  65 %  of 
the  site-specific 
conservation objectives for habitats are under appropriate 
is 
that 
management,  meaning 
approved  in  a  nature  management  plan.  The  nitrogen 
decree,  adopted 
in  2024,  states  that  appropriate 
management  should  be  in  place  for  all  site-specific 
conservation objectives by 2030. 

their  management 

The problem of nitrogen deposition affecting natural areas 
and  ecosystems  is  tackled  by  the  nitrogen  decree  of 
24 January  2024,  which  aims  to  progressively  reduce 
nitrogen deposition in Natura 2000 sites, with the goal of 
reaching by 2045 levels that do not cause degradation to 
protected  habitats.  The  decree  includes  mandatory  and 
unpopular  measures,  such  as  significantly  reducing  pig 
numbers in the Flemish Region by 2030. However, several 
appeals have been made against the decree. 

The Walloon Region, on the other hand, has a scheme to 
prevent  site-level  deterioration  that  applies  to  all 
individual land sections within the Natura 2000 network, 
irrespective  of  their  ownership  status.  This  scheme  is 
based  on  a  combination  of  (i)  a  legal  regime  of  general 
restrictions; and (ii) land-parcel-specific restrictions based 
on  the  current  land-use  and  restoration  potential  of 
individual land parcels (the so-called management units). 
The  scheme  covers  100 %  of  the  area  of  the  Walloon 
site-specific 
Natura  2000  network. 
management plans are currently being drawn up as part 
of the ongoing LIFE Belgian nature integrated project (44). 
In addition, under Article 72 of Regulation (EU) 2021/2115 
forestry 
of  2 December  2021, 
compensation is granted annually to compensate for the 
specific disadvantages associated with the designation of 
areas as Natura 2000 sites. 

In  addition, 

agricultural 

and 

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

Source: EEA, ‘Natura 2000 Barometer’, 2023 data, accessed March 
2025, https://www.eea.europa.eu/en/analysis/maps-and-
charts/natura-2000-barometer-dashboards. 

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

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 
objectives  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.  

All  Belgian  Natura  2000  sites  proposed  under  the  EU 
Habitats Directive have been designated as SACs. 

Both  the  Walloon  and  Flemish  Regions  have  regional 
conservation objectives for their network of sites. 

For the Flemish Region, these objectives have been broken 
down into site-specific conservation objectives for all SACs 
and  SPAs.  As  a  result  of  the  spatial  assignment  of  areas 
with  SAC  designation  to  conservation  objectives,  a 
significant  share  of  the  land  within  the  Flemish  Natura 
2000  sites  is  excluded  from  any  target  setting.  Although 
located  inside  the  network  for  SACs,  this  land  therefore 
remains de facto unprotected. 

Furthermore, it seems that the Flemish Region has not set 
any site-specific objectives for any migratory bird species 
not listed in Annex I to the Birds Directive, despite the EU 
certain  migratory  breeding  bird 
significance  of 

(44) 

https://biodiversite.wallonie.be/fr/life-integre.html?IDC=6174. 

2025 Environmental Implementation Review – Belgium 

 
 
 
There  are  currently  no  identified  deficiencies  in  the 
Brussels  Region  for  the  designation  of  SACs  or  for 
conservation  objectives  and  measures.  The  Brussels 
Region has set site-specific conservation objectives for all 
SACs,  including  the  description  of  general  conservation 
measures for the target habitats and ecological demands 
for  the  target  species.  These  objectives,  measures  and 
ecological demands are being further developed in more 
detailed  management  plans  for  specific  subsites  within 
the network. 

The most worrying deficiency in the management of the 
Belgian  Natura  2000  network  is  the  lack  of  effective 
management of the marine Natura 2000 sites. Site-specific 
conservation objectives have been set for the two marine 
SACs (Vlaamse Banken and Vlakte van de Raan). However, 
not  all  required  conservation  measures  have  yet  been 
adopted  (missing  are  those  affecting  fisheries).  A  first 
proposal  for  measures  to  restrict  bottom  trawling  via  a 
joint recommendation under the common fisheries policy 
was rejected by the European Parliament in 2018. In 2019 
the federal government started a new process in order to 
come  to  a  new,  scientifically  underpinned  proposal  for 
measures restricting bottom trawling. Given its extremely 
damaging nature, Belgium should ensure that this practice 
is not carried out in violation of both Articles 6(2) and 6(3) 
of  the  Habitats  Directive.  The  adoption  in  2016  of  the 
Royal  Decree  clarifying 
the 
implementation  of  Natura  2000  improved  the  fulfilment 
of  these  articles,  as  an  appropriate  assessment  is  now 
mandatory for many activities, including sand extraction. 
A revision of the Marine Environment Act was adopted on 
11 December 2022. 

the  procedures 

for 

Belgium  16 

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 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 (45). 

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. 

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. 

According  to  the  report  submitted  by  Belgium  on  the 
conservation  status  of  habitats  and  species  covered  by 
Article 17  of  the  Habitats  Directive  for  2013–2018,  the 
share  of  habitats  assessed  to  be  in  good  conservation 
status in 2018 was 4.3 %. 

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

As  regards  the  three  marine  SPA  areas,  site-specific 
objectives  have  not  yet  been  formulated.  The  overall 
objective  is  to  maintain  their  current  status  and  their 
function as foraging areas for marine bird species. For the 
Vlaamse Banken and the three SPAs, management plans 
containing a variety of measures have been adopted. The 
existing  sites  are  currently  being  damaged  in  an  almost 
systematic way, notably through regular bottom trawling 
(including from non-Belgian vessels, which are allowed to 
fish  in  Belgian  waters  according  to  the  EU’s  common 
fisheries  policy).  Management  measures  addressing  the 
impact  from  fisheries  are  to  be  adopted  via  a  joint 
recommendation (see above for the marine SACs). 

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 

NB: The values shown for 2007–2012 with those for 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. 

(45) 

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

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

2025 Environmental Implementation Review – Belgium 

 
 
 
Belgium  17 

Source:  EEA,  ‘Conservation  status  and  trends  of  habitats  and  species’, 
19 December 2019, https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived.  

For  protected  species,  the  share  assessed  to  be  in  good 
conservation status in 2018 was 25.4 %. 

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

for  nature-based  solutions 

Canal  It  Up  and  Port  de  Bruxelles)  is  a  good-practice 
example 
in  an  urban 
environment. It consists of 84 floating ecosystem modules 
creating  224 m²  of  floating  habitat,  in  which  17  native 
plant  species  provide  a  habitat  for  birds,  fish  and 
pollinators,  while  some  phytodepuration  plants  help  to 
filter the water. 

2025 priority actions 

• 

of 

the 

establishment 

Finalise 
site-specific 
conservation objectives and  measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 
•  Reinforce  action  for  habitats  and  species  with 
for 
increased 
and 

unfavourable  conservation  status 
example, 
connectivity,  better  policy 
integration, and increased funding. 

restoration  measures, 

coordination 

through, 

Recovery of ecosystems 

Agricultural ecosystems 

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

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 2019, https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

showed 

short-term 

increasing  or 

With  regard  to  birds,  56 %  of  the  breeding  species  in 
Belgium 
stable 
population  trends  in  2013–2018.  For  wintering  species 
requiring  the  designation  of  SPAs,  the  corresponding 
figure  is  7.6 %  for  2013–2018,  but  there  is  a  large 
proportion  (69 %)  of  bird  species  with  unknown  short-
term trends (46).  

All Belgian regional authorities are currently implementing 
measures  dedicated  to  restoring  populations  of  species 
that have shown deteriorating conservation status trends 
in  the  most  recent  reporting  under  Article 17  of  the 
Habitats Directive. To achieve the objectives of EU nature 
legislation in terms of favourable conservation statuses for 
these  species,  these  efforts  must  be  continued  and, 
ideally, upscaled. 

The ‘floating islands’ in the Brussels port (47) (introduced 
by Bruxelles Environnement, Ecorce, Ecocéan, Biomatrix, 

(46) 

EEA,  ‘Winter  population  trends’,  Article 12  dashboard, 
updated 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/winter-population-trends-article-12-national-summary-
dashboards-archived. 

11 May 

last 
2023, 

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; 
restore at least 10 % of agricultural area to have high-
diversity landscape features; and 

there 

that 

— 

— 

— 

increase  the  area  under  organic  farming  to  at 

— 
least 25 %. 

The  “Vision  for  agriculture  and  food”(48)  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  adequately  targeted 
toward this objective. 

(47)  We Love Brussels, ‘Floating green islands launched in the Port of 
2022, 

Brussels’, 
https://welovebrussels.org/2022/04/floating-green-islands-port-
of-brussels/. 

27 April 

(48) 
food/vision-agriculture-and-food_en 

https://agriculture.ec.europa.eu/overview-vision-agriculture-

2025 Environmental Implementation Review – Belgium 

 
 
 
 
Belgium  18 

such as land lying fallow, and for the establishment of new 
landscape features on arable land. 

The  recently  adopted  Nature  Restoration  Regulation (51) 
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 for at 
least  two  out  of  three 
indicators  for  agricultural 
ecosystems (52).  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  Figure  12,  it  is  estimated  that 
7.6 % of Belgium’s utilised agricultural land area is used for 
organic  farming.  This 
is  below  the  EU  average  of 
10.50 % (53). This is not contributing much to achieving the 
target  of  25 %  of  the  EU’s  agricultural 
land  being 
organically farmed 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 
2024, 
5 December 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/t
able?lang=en. 

The  CAP  and  national  CAP  strategic  plans  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  strategic plans in 2022 for the  programming 
period 2023-2027. The CAP is the largest source of funding 
implementation  of  EU 
for 
contributing 
for 
environmental  policy, 
biodiversity.  Strategic  plans  should  continue  to  support 
the protection of soil, water, air quality and biodiversity. 

thisis  particular 

true 

the 

to 

While certain CAP result indicators focus on the national 
measures 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  Belgium  increased  from 
1 333 910 hectares in 2012 to 1 368 310 hectares in 2021 
and decreased to 1 361 910 ha in 2022 (49). 

‘share  of  agricultural 

Landscape features are small fragments of non-productive 
and  (typically,  but  not  strictly)  semi-natural  vegetation 
present in, or adjacent to, agricultural land. They provide 
ecosystem  services  and  support  for  biodiversity.  The 
land  covered  with 
indicator 
landscape features’ is the ratio between the area covered 
by  non-productive 
landscape  features  and  the  area 
covered  by  agricultural  land.  Based  on  the  landscape 
features  estimates  of  the  Land  Use/Cover  Area  Frame 
Survey,  the  share  of  agricultural  land  covered  with  non-
productive landscape features in Belgium is 5.6 %, which 
corresponds to the EU average. 

In  2024,  the  CAP  basic  regulations  were  amended (50), 
inter  alia,  regarding  the  standards  for  good  agricultural 
and  environmental  conditions  (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 areas or landscape features on 
their farms. The amended regulation does not remove the 
obligation  under  GAEC 8  to  retain  existing  landscape 
features, but sets out an obligation for Member States to 
establish and provide support for eco-schemes, covering 
practices  for  the  maintenance  of  non-productive  areas, 

(49) 

(50) 

(51) 

5 December 

(EU)  2021/2116  as 

Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/defa
ult/table?lang=en. 
Regulation (EU) 2024/1468 of the European Parliament and of the 
Council  of  14 May  2024  amending  Regulations  (EU)  2021/2115 
regards  good  agricultural  and 
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 
L,  2024/1468,  24.5.2024), 
controls  and  penalties 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Regulation (EU) 2024/1991 of the European Parliament and of the 
Council  of  24 June  2024  on  nature  restoration  and  amending 

(OJ 

(52) 

(53) 

(EU)  2022/869 

(OJ  L,  2024/1991,  29.7.2024), 

Regulation 
http://data.europa.eu/eli/reg/2024/1991/oj. 
‘Grassland  butterfly  index’,  ‘stock  of  organic  carbon  in  cropland 
mineral  soils’  and  ‘share  of  agricultural  land  with  high-diversity 
landscape features’. 
Last available information from Eurostat, currently under review; 
see  also  European  Commission:  Directorate-General 
for 
Agriculture  and  Rural  Development,  ‘Agriculture  biologique  au 
sein 
européenne’, 
https://agriculture.ec.europa.eu/document/download/c67458ed
-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-organic-
farning_fr.pdf&prefLang=en. 

l’union 

de 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
2025 priority actions 
• 

Step-up efforts to further reduce nitrogen deposition, 
in  particular  in  Natura  2000  sites  with  nitrogen-
sensitive species and habitats. 
Implement  eco-schemes  and  agri-environmental 
measures and practices to address the environmental 
needs of Belgium. 
Implement and scale up the uptake of organic farming 
practices. 

• 

• 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
security and climate resilience, adaptation and 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 (54)  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 
compaction, 
soil 
contamination, soil salinisation and the presence in soil of 
impact 
nitrogen  and  phosphorus 
assessment accompanying the proposal, which builds on 

in  excess.  The 

soil  organic 

loss  of 

carbon, 

(54) 

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. 

2023, 

5 July 

final 

of 

Belgium  19 

the data available in the EU Soil Observatory, points to the 
following soil degradation issues in Belgium (55). 

In  about  35 %  of  the  area,  excessive  concentrations  of 
nutrients  (phosphorus  concentrations  above  50 mg/kg 
and nitrogen concentrations above 50 kg/ha) are found in 
soils,  particularly  in  the  northern  part  of  the  country. 
Unsustainable  soil  erosion  by  water,  wind,  tillage  and 
harvest  affects  17 %  of  the  national  territory,  which 
represents 63 % of croplands. 

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 
large herbivores.  Grasslands are essential for agriculture 
and  livestock  herding.  Natural  grasslands  also  play  an 
important  role  in  storing  carbon.  However,  changes  in 
land  uses  have  caused 
agricultural  practices  and 
grasslands to disappear at an alarming rate, making them 
one of Europe’s most threatened ecosystems. 

In  the  latest  report  in  accordance  with  Article 17  of  the 
Habitats  Directive  (from  2019),  all  species-rich  grassland 
habitats  in  Belgium  still  have  unfavourable  conservation 
status,  and  often  still  show  further  declines  in  terms  of 
area and habitat quality. 

Species-rich  grasslands  in  Belgium  are  mainly  under 
pressure  from  the  abandonment  of  traditional  nature-
friendly  management  practices  and 
land-use 
intensification  (high  levels  of  fertilisers  and  excessive 
mowing  frequencies),  as  well  as  from  atmospheric 
nitrogen  deposition,  this  pressure  being  particularly 
important in the Flemish Region. 

from 

However,  in  the  parts  of  Belgium  within  the  continental 
biogeographical  region  (i.e.  the  south-east  including  the 
Ardennes), positive trends are reported for three (out of a 
total of 10) Annex I grassland habitats, largely as a result 
of the extensive habitat restoration measures carried out 
since 1995 in the form of a number of successful initiatives 
by  the  LIFE  Belgian  nature  integrated  project.  For  other 
grasslands,  however  (in  particular  for  species-rich  hay 
meadows),  the  measures  undertaken  so  far  are  still 
insufficient to reverse the overall negative trend. 

In the parts of Belgium within the Atlantic biogeographical 
region (the Flemish Region and the north-western parts of 
the Walloon Region), the status of grasslands is worse, as 
not  one single parameter for any of the  seven grassland 

(55) 

Commission  staff  working  document – 
report –  Annexes,  SWD(2023) 417 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT%20ASSESSMENT%20REPORT_ANNEXES_SWD_2023_
417_part4.pdf. 

Impact  assessment 
final  of  5 July  2023, 

2025 Environmental Implementation Review – Belgium 

 
 
habitat types is reported to show a positive trend, which 
is  consistent  with  the  overall  finding  of  higher  land-use 
pressures and excessive nitrogen deposition in that part of 
the country. 

For  several  key  grassland  habitat  types,  the  remaining 
high-quality  areas  in  Belgium  are  now  almost  entirely 
restricted  to  nature  reserves  within  Natura  2000  sites. 
These  reserves  are  owned  and  managed  either  by  the 
state or by conservation NGOs. 

To  achieve  the  objectives  of  EU  nature  legislation,  the 
efforts  to  restore  the  coverage  and  habitat  quality  of 
species-rich grasslands in Belgium must be continued and, 
ideally, upscaled. 

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 special 
type of wetland 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. 

In  the  latest  report  in  accordance  with  Article 17  of  the 
Habitats  Directive  (from  2019),  all  wetland  habitats  in 
Belgium  still  have  an  unfavourable  conservation  status. 
However, with the exception of one specific habitat in the 
continental  biogeographical  region  that 
is  naturally 
confined  to  very  small  and  highly  scattered  areas 
(‘Petrifying  springs  with  tufa  formation’),  conservation 
status  trends  show  that  Annex I  wetland  habitats  in 
Belgium are no longer deteriorating. 

Within  the  continental  biogeographical  region  (i.e.  the 
south-eastern  parts  of  Belgium  including  the  Ardennes), 
positive trends are reported for  four out of a total of six 
Annex I  wetland  habitat  types,  largely  as  a  result  of 
extensive habitat  restoration measures carried  out  since 
1995 in the form of a number of successful initiatives by 
the LIFE Belgian nature integrated project. 

Within  the  Atlantic  biogeographical  region  (mostly  the 
Flemish Region), the situation is less positive, however, as 

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

November 

22 

Belgium  20 

the  restoration  measures  taken  so  far,  despite  covering 
significant areas, have not yet translated into any positive 
conservation  status  trends.  This  is  consistent  with  the 
overall finding of higher land-use pressures and excessive 
nitrogen deposition in that part of the country. 

Both  the  Walloon  and  the  Flemish  CAP  strategic  plans 
have  applied  GAEC 2  to  the  protection  on  wetlands  and 
peatlands since 2023. 

To  achieve  the  objectives  of  EU  nature  legislation,  the 
efforts  to  restore  wetland  habitats  in  Belgium  must  be 
continued and, ideally, upscaled. 

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  Directives, 
including  those  for  which  there  is  a  requirement  to 
designate Natura 2000 sites and to protect breeding sites 
and resting places. 

Several  Commission  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 (56) 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 (57).  The  share  of 
forested  areas  in  the  EU  with  a  bad  conservation  status 
increased from 27 % in 2015 to 31 % in 2018. 

(57) 

EEA, State of Nature in the EU: Results from reporting under the 
Nature Directives 2013–2018, Publications Office of the European 
Union, 
2020, 
Luxembourg, 
https://www.eea.europa.eu/publications/state-of-nature-in-the-
eu-2020. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
Belgium  21 

Forests covered 22.8 % of Belgium’s land area in 2020 (58), 
and  the  situation  of  forest  habitats  protected  under  the 
Habitats  Directive  is  particularly  worrying,  as  more  than 
half  of  the  protected  forests  assessed  have  a  poor 
status (59). 

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

• 

Improve conservation status of forests by promoting 
sustainable 
forest  management  and  ensuring 
compliance  with  the  Habitats  Directive  before 
granting/renewing permits for forest logging. 

•  Bring levels of nitrogen deposition under the critical 
threshold  to  allow  forest  habitat  types  protected 
under the Habitats Directive to recover. 

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 
to  be  developed  and 
comprise  different 
implemented over six-year cycles. 

steps 

in 

Since  the  2022  EIR  report,  no  additional  data  regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
the  MSFD  have  become  available. 
Nevertheless,  Member  States  had  to  report  updates  by 
15 October  2024,  and  these  are  being  assessed  by  the 
Commission. In the context of this round of reporting, in 
accordance  with  the  MSFD  and  the  Commission  GES 
decision (63), 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 (64).  Belgium  reported  the  data  relating  to 
Articles 8, 9 and 10 as required by Article 17 of the MSFD; 
is  now  under  the  assessment  of  the 
these  data 
Commission 

The  Commission  assessed  the  updated  monitoring 
programme  reported  by  Member  States  in  2020 (65).  At 
that  time  their  updates  on  the  elements,  features  and 
parameters  identified  monitoring  gaps.  The  Commission 
recommended that Member States should prioritise work 

(63) 

(62)   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  environmental 
status  of  marine  waters  and  specifications  and  standardised 
for  monitoring  and  assessment,  and  repealing 
methods 
Decision 2010/477/EU 
p. 43), 
L 125, 
http://data.europa.eu/eli/dec/2017/848/oj. 
Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 
(Directive 2008/56/EC)  and 
Strategy  Framework  Directive 
Commission  Decision 
(OJ  C,  C/2024/2078, 
11.3.2024), 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. 

(EU) 2017/848 

18.5.2017, 

(65) 

(64) 

(OJ 

Source: Commission staff working document – New EU forest strategy for 
eur-
of 
2030, 
lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0652. 

SWD(2021) 652 

16 July 

2021, 

p. 24, 

final 

. 

The EU Timber Regulation (EUTR) (60) prohibits the placing 
on the EU market of illegally harvested timber.  

On  29 June  2023,  the  Regulation  on  Deforestation-free 
Products (EUDR) (61) entered into force (62). The regulation 
seeks to guarantee that products in the EU that are made 
using  any  of  seven  listed  commodities  have  no  links  to 
deforestation.  The  Regulation  on  Deforestation-free 
Products repeals the EU Timber Regulation.  

2025 priority action  

(58) 

(59) 

(60) 

(61) 

Forest  information  system  for  Europe,  ‘Countries –  FISE  country 
factsheets’,  forest 
information  system  for  Europe  website, 
accessed 9 January 2025, https://forest.eea.europa.eu/countries. 
Commission  staff  working  document –  Stakeholder  consultation 
and  evidence  base,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 
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. 
European  Commission, 
‘Regulation  on  deforestation-free 
products’,  European  Commission  website,  accessed  9 January 
2025, 
https://environment.ec.europa.eu/topics/forests/deforestation/r
egulation-deforestation-free-products_en. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
to address those gaps at all levels of implementation of the 
MSFD. 

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. 

Figure 14: Level of adequacy of Belgium’s updated 
programme of measures under Article 13 of the MSFD 
(2022 reporting exercise) 

Source: Technical assessment carried out by the European Commission, 
pursuant  to  Article 16  of  the  MSFD,  based  on  the  data  reported  by 
Belgium in March 2022. 

Belgium’s  updated  programme  of  measures  scores 
unevenly  across  the  different  descriptors.  Measures  for 
biodiversity  (D1),  sea-floor  integrity  (D6),  hydrographical 
changes  (D7),  contaminants  in  seafood  (D8),  litter  (D10) 
and  energy  (D11)  showed  positive  adequacy  (‘good’  or 
‘very good’). 

For  non-indigenous  species  (D2),  commercial  fish  and 
shellfish (D3), eutrophication (D5) and contaminants (D8), 
the  assessment  revealed  moderate  adequacy,  signalling 
room for progress in defining effective and comprehensive 
measures in these areas. For instance, while measures for 
introduction  of  non-
D2  adequately  considered  the 

(66) 

(67) 

(68) 

Implementing  Regulations 

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 
(EU) 
amended  by  Commission 
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. 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203. 
Regulation (EU) No 1143/2014 of the European Parliament and of 
the  Council  of  22 October  2014  on  the  prevention  and 

Belgium  22 

indigenous species via shipping, they did not cover risks of 
introduction through aquaculture or offshore wind farms. 
Lastly,  measures  for  food  webs  (D4)  were  assessed  as 
poorly  adequate,  emphasising  the  need  for  targeted 
actions  addressing  more  directly  the  pressures  on  this 
descriptor. 

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 (66). 

The third update of the Union list (67) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS Regulation (68) 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 (69). More recent studies have put this cost 
at  USD 28 billion  per  year  in  the  EU,  increasing  to 
USD 148.2 billion  by  2040 (70),  and  at  USD 423 billion 
annually at the global level (71). 

management  of  the  introduction  and  spread  of  invasive  alien 
species (OJ L 317, 4.11.2014, p. 35). 

(69)  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. 

(71) 

(70)  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. 
IPBES (Intergovernmental Science-Policy Platform on Biodiversity 
and  Ecosystem  Services),  Summary  for  Policymakers –  Invasive 
alien 
2023, 
assessment, 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

species 

Bonn, 

2025 Environmental Implementation Review – Belgium 

 
 
 
Figure 15: Number of IAS of EU concern, based on 
available georeferenced information for Belgium, 2024  

accounting. 

Belgium  23 

Similarly, target 14 of the GBF (72) 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 (73). 

The  amended  Regulation  (EU) 691/2011  on  European 
environmental  economic  accounts (74)  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. 

is 

regionalised.  Therefore 

In  Belgium,  environmental  policy  related  to  land-use 
the  priorities, 
planning 
knowledge  gaps,  support  needed  and  state  of  research 
depend on the region. The Brussels Region has not taken 
any initiatives yet in developing natural capital accounting. 
The  Walloon  Region  has  just  started  implementing  its 
Nature Value Explorer tool (75). Therefore the information 
provided mainly focuses on the Flemish Region. 

A key motivation for developing natural capital accounting 
for  the  Flemish  Region  relates  to  the  ambition  to  bring 
together and structure data in support of better policy and 
public  debate.  Thematic  policy  prioritises  four  research 
subjects:  climate;  health;  the  monitoring  of  sustainable 
development goals and development of indicators beyond 
GDP;  and  the  monitoring  of  land-use  change.  In  the 
Flemish  Region,  both  the  extent  account  and  the 
ecosystem  supply  and  use  accounts  (in  physical  and 
monetary terms) are published. 

Challenges  identified  by  this  data  in  the  Flemish  Region 
relate to carbon storage in biomass; the health effects of 
green space; functional biodiversity and its contribution to 
the supply of ecosystem services; and the accuracy of the 
base  layers  of  the  land-use/land-cover  map.  Moreover, 

/publication/81ff1498-b91d-11eb-8aca-01aa75ed71a1/language-
en. 

(74)  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, 
https://eur-
COM(2022) 329 
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 
https://ipbes.net/policy-support/tools-
instruments/natuurwaardeverkenner-nature-value-explorer. 

11 July 

2022, 

final 

(75) 

of 

NB: This includes 40 species recorded in the previous EIR (2021) and 
21 new additions. Of these new additions, 12 were already on the 
Union concern list in 2021, and nine were added later under 
Commission Implementing Regulation (EU) 2022/1203. 

Total invasive alien species of Union Concern in the 
country: 61 

This includes 40 species recorded in the previous EIR 
(2021) and 21 new additions. Of these new additions, 12 
were already on the Union Concern list in 2021, and 9 
were added later under Commission Implementing 
Regulation (EU) 2022/1203. 

In June 2022 Belgium adopted its national action plan on 
the unintentional introduction and spread of IAS. 

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 

(72)  Decision 15/4  adopted  by  the  Conference  of  the  Parties  to  the 
Convention  on  Biological  Diversity:  Kunming–Montreal  Global 
Biodiversity Framework (https://www.cbd.int/doc/decisions/cop-
15/cop-15-dec-04-en.pdf). 
European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem Assessment – Summary for policymakers, Publications 
Office 
2021, 
https://op.europa.eu/en/publication-detail/-

European  Union, 

Luxembourg, 

the 

(73) 

of 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
Belgium  24 

Two  of  Belgium’s  2022  priority  actions  on  (i)  supporting 
the  mapping  and  assessment  of  ecosystems  and  their 
services  and  (ii)  the  development  of  natural  capital 
accounting cannot be assessed due to lack of data and will 
be assessed in the next cycle of the EIR. The other priority 
action  on  supporting  national  business  and  biodiversity 
platforms is assessed as having made substantial progress 
since  there  are  two  business  and  biodiversity  networks 
active in Belgium, and both are active members of the EU 
Business & Biodiversity Platform. 

the  relevant  data,  knowledge,  skills  and  resources  are 
scattered across different entities, which impedes building 
appropriate ecosystem models. 

increasing  number  of  platforms,  networks  and 
An 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (76).  These  platforms  and  communities  are  key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers.  

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 
their  success.  Such  understanding 
contributes to the implementation of the EU’s BDS.  

to 

The EU  Business  &  Biodiversity 

(76) 
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.   

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
Belgium  25 

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 (77).  These  set  health-based  EU  air  quality 
standards (78)  and  stipulate  Member  States’  national 
emission  reduction  commitments (79)  for  several  air 
pollutants. 

Air  quality  in  Belgium  is  generally  good  with  some 
exceptions. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (80) for Belgium attribute 4 100 deaths each year (or 
41 300  years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (81);  1 200  deaths  each  year  (or  12 300  YLL)  to 
nitrogen dioxide (NO2) (82); and 1 400 deaths each year (or 
13 700 YLL) to ozone (83). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Belgium since 2005, while GDP growth has 
continued  (see  Figure 16).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (84)  in  2024, 
Belgium  meets  its  emission  reduction  commitments  for 
2020–2029  for  air  pollutants  NOx,  non-methane  volatile 
organic  compounds  (NMVOC),  sulphur  dioxide  (SO2), 

(77) 

(78) 

(79) 

(80) 

(81) 

‘Air 

standards’, 

Commission, 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
quality 
European 
https://environment.ec.europa.eu/topics/air/air-quality/eu-air-
quality-standards_en.  
European  Commission,  ‘Reducing  emissions  of  air  pollutants’, 
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  status,  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. 

ammonia  (NH3)  and  PM2.5.  According  to  the  projections 
submitted  under  Article 10(2)  of  the  NECD  in  2023, 
Belgium  is  projected  to  meet  its  emission  reduction 
commitments  for  2030  onwards  for  NOx,  NMVOC,  SO2, 
NH3 and PM2.5. 

Belgium  submitted  its  updated  national  air  pollution 
control  programme  (NAPCP)  to  the  Commission  on 
27 April 2023. 

Figure 16: Emission trends of main pollutants / GDP in 
Belgium (%), 2005–2022 

200%

150%

100%

50%

0%

NH₃

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, 

(82)  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. 

(83) 

(84)  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, 
https://eur-lex.europa.eu/legal-
17.12.2016, 
content/EN/TXT/?uri=uriserv:OJ.L_.2016.344.01.0001.01.ENG. 

p. 1), 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
Figure 17: PM2.5 and NOx emissions by sector in Belgium 
(%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
4,6%

17,9%

49,9%

24,2%

1,2%

2,2%

NOₓ

0,3%

44,9%

9,8%

23,4%

9,9%

11,7%

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) (85) were registered 
in  Belgium. 
for  NO2 
Furthermore,  the  target  value  for  arsenic  concentration 
has not been met in one air quality zone (87). 

in  two  air  quality  zones (86) 

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  NO2  limit  values  (INFR(2016)2005).  The 
aim is that appropriate measures are put in place to bring 
all air quality zones into compliance. 

including  Belgium 

In  the  2022  EIR,  Belgium  received  three  priority  actions. 
The first priority action was to further reduce emissions in 

(OJ 

L 152, 

(85)  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. 
Antwerp and Ghent. 
Eionet 
EEA, 
(https://cdr.eionet.europa.eu). 

Repository 

11.6.2008, 

(86) 
(87) 

Central 

p. 1), 

Data 

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

Belgium  26 

the  context  of  the  NAPCP.  Belgium  has  fulfilled  this  as 
current emissions have been reduced to meet the 2020–
2029  as  well  as  the  2030-onwards  emission  reduction 
commitments.  The  second  priority  action  was  to  ensure 
full compliance with EU air quality standards and maintain 
downward  emission  trends.  Based  on  the  latest  data, 
Belgium  has  made  some  progress  in  this  regard.  Since 
2019, downward emission trends have been reported for 
all main air pollutants. However, exceedances above limit 
values  and  target  values  remain  for  NO2  and  arsenic, 
requiring further action. The third priority action received 
by  Belgium  was  to  ratify  the  amended  Gothenburg 
Protocol,  the  Protocol  on  Heavy  Metals  and  the  Aarhus 
Protocol, which has been fulfilled. 

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,  including 
water; 

(iv)  contribute to decarbonisation. 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (88). 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  (89). 

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 

(89) 

2025 Environmental Implementation Review – Belgium 

 
 
 
In  Belgium,  around  2 457  industrial  installations  are 
required to have a permit based on the IED. 

industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 19. 

Belgium  27 

The  industrial  sectors  in  Belgium  with  the  most  IED 
installations in 2022 were: (i) intensive rearing of poultry 
or  pigs  (44 %);  (ii)  waste  management  (19.6 %);  (iii) 
chemicals  production  (10.8 %);  (iv)  food  and  drink 
production  (7.7 %);  and  (v)  surface  treatment  of  metals 
(7.5 %). 

Figure 18  shows  the  damage  to  health  and 
the 
environment due to the main industrial air pollutants. As 
this  depends,  among  other  factors,  on  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. Belgium has 
the seventh highest damage level and is also the Member 
State with the seventh highest emissions intensity, above 
the EU average of EUR 27.5/EUR 1 000 GVA. 

The  main  industrial  contributors  to  emissions  to  air  (90) 
are: 

• 

‘other  activities’  (mostly  the  surface  treatment  of 
metals, the intensive rearing of poultry or pigs and the 
production  of  pulp  paper)  for  NMVOCs,  NH3,  copper 
(Cu), zinc (Zn), cadmium (Cd), nickel (Ni) and PM2.5; 
•  metal production for lead (Pb), arsenic (As) and SOX;  
•  chemicals  production  for  NMVOCs,  NOX,  SOX,  Ni,  As 

and mercury (Hg); 

•  electricity production for NOX, Zn, As, Hg, Ni, chromium 

(Cr), Cd, Pb and dioxins; 

•  waste management for dioxins. 

Figure 18: Industrial air pollution damage and intensity 
per Member State, 2021 

Figure 19: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

NB: Cd, cadmium; Hg, mercury; Ni, nickel; Pb, lead; total N, total nitrogen; 
TOC, total organic carbon; 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. 

With regard to Belgium in particular, Figure 20 shows the 
industrial emissions of heavy metals to water, taking into 
account  the  human  toxicity  of  each  metal,  as  well  as 
emissions  intensity,  based  on  the  ratio  with  industrial 
activity (expressed in GVA). 

Belgium has the 9th highest amount of emissions of heavy 
metals  to  water  and  is  in  the  11th  position  for  emission 
intensity  of 
(above 
intensity 
0.864 kg/EUR 1 billion GVA). 

the  EU 

average 

Figure 20: Industrial releases and intensity of heavy 
metals to water per Member State, 2022 

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

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.  

As shown in Figure 21, the main industrial contributors to 
in  Belgium  are:  (i)  landfills  for 
emissions  to  water 
municipal  waste;  (ii)  pulp  and  paper  production  (for 
nitrogen, phosphorous and total organic carbon); (iii) the 

(90) 
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 – Belgium 

 
 
 
 
 
metals industry; (iv) chemicals production and (v) landfills 
for heavy metals. 

treatment  systems 
smitheries and foundries. 

in  the  chemical  sector;  and  (iv) 

Belgium  28 

Figure 21: Relative releases to water from industry in 
Belgium (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human
Toxicity

Polycyclic
aromatic
hydrocarbons
(PAHs)

Total organic
carbon (TOC)

Total nitrogen

Total
phosphorus

Chemicals
Extractive industry
Food and drink
Non-ferrous metal
Other manufacturing
Pulp, paper and wood

Electricity and heat production
Ferrous metal
Incineration with energy recovery
Non-metallic minerals
Other waste management
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  Geospatial  Data  Catalogue,  13 September  2024, 
https://sdi.eea.europa.eu/catalogue/srv/api/records/cf5e54c1-be99-
4426-bcad-baa26c4f27a0?language=all. 

IED 

contains  mandatory 

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 
NGOs,  alongside  competent  authorities,  play  a  role  in 
ensuring compliance of these permits with EU legislation. 
The 
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  infringements  of  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. 

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  for:  (i)  ferrous  metal  processing;  (ii)  the 
textiles industry; (iii) common waste gas management and 

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. 

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
•  Reduce 
industrial  releases  to  water,  and  their 

• 

• 

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; 
limit the consequences of such accidents for human 
health and the environment; 

(ii) 

(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 (91). 

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 (92)  and  the  report  by 
Belgium on the implementation of the Seveso III Directive 
for 2019–2022 (93). 

In Belgium, in 2024, of the 397 Seveso establishments, 165 
are  categorised  as  lower-tier  establishments  and  232  as 
upper-tier establishments (UTEs) based on the quantity of 
hazardous  substances  likely  to  be  present  in  them.  The 
UTEs  are  subject  to  more  stringent  requirements.  The 
change in of the number of Seveso establishments  since 
2018 is presented in Figure 22. 

(91)  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. 

(92) 

(93) 

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 – Belgium 

 
 
 
Figure 22: Number of Seveso establishments in Belgium, 
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, 
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.. 

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs) for certain UTEs. These EEPs are 
essential  to  allow  proper  preparation  and  effective 
implementation  of  the  necessary  actions  to  protect  the 
environment and the population should a major industrial 
accident occur. According to Belgium, in 2022, an EEP was 
required for 219 UTEs out of 227 UTEs in total; 219 UTEs 
had an EEP and all of these EEPs had been tested over the 
last three years. The summary of EEPs in Belgium is shown 
in Figure 23. 

Figure 23: Situation regarding EEPs in Belgium, 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, 

2022, 

(94) No data available for Greece 

Belgium  29 

/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  following  types  of  information  are  permanently 
available  for  all  Seveso  establishments  in  Belgium:  (i) 
information  for  the  public  referred  to  in  Annex V  to  the 
Seveso III  Directive,  especially  about  how  the  public 
concerned will be warned if there is a major accident; (ii) 
information about appropriate behaviour in the event of a 
major accident; and (iii) information containing the date 
of the last site visit.  

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  in  the  EU-27  was 
actively made available to the public in recent  years are 
presented in Figure 24(94). This provision on knowledge is 
an  important  provision  of  the  Seveso III  Directive,  as 
information  may 
awareness  by  the  public  of  this 
ameliorate  the  consequences  of  a  major 
industrial 
accident. 

Figure 24: Share of UTEs for which information on safety 
measures and requisite behaviours was actively made 
available to the public per Member State (%), 2022 

N.B. 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, 
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.. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
Belgium  30 

Mercury Regulation 

disturbed by transport noise. 

The  Mercury  Regulation  establishes  measures  and 
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). 

Measures  should  have  been  put  in  place  in  Belgium  to 
ensure  a  socially  and  economically  sound  phase-out, 
including the training of dental practitioners and adequate 
reimbursement  for  the  alternatives  to  dental  amalgam 
through the health insurance scheme. The Commission is 
monitoring whether the phase-out of dental amalgam has 
taken  place  under  the  terms  and  conditions  of  the 
regulation.  Belgium  will  also  need  to  ensure  that  the 
manufacture and export of mercury-containing lamps are 
prohibited  by  the  deadlines  required  by  the  Mercury 
Regulation. 

Noise 

The Environmental Noise Directive (95) 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 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (96). 

In Belgium, environmental noise is estimated to cause at 
ischaemic  heart  disease 
least  around  670  cases  of 
annually (97)  and  some  140  000  people  to  suffer  from 
disturbed sleep(98). 

Based on the latest set of information analysed, Belgium 
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 as yet. 

Belgium  received  no  priority  action  on  this  topic  in  the 
2022 EIR. 

2025 priority action 

• 

Complete  and  implement  action  plans  on  noise 
management. 

Water quality and management 

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

(95)  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. 

(96)  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) 

(97) 

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  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise.  

Bilthoven, 

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

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 

2025 Environmental Implementation Review – Belgium 

 
 
  
Water Framework Directive 

The Water Framework Directive (99) is the cornerstone of 
EU water policy (100). The Water Framework Directive and 
other  water-related  directives (101)  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 4th February 2025(102). 

Belgium has 560 surface waterbodies (533 rivers, 18 lakes, 
7  transitional  bodies,  1  coastal  body,  1  territorial  body) 
and 81 groundwater bodies, divided over four river basins 
(Scheldt, Meuse, Rhine and Seine), which are subdivided 
into eight river basin districts. 

improvement 

It  follows  from  the  assessment  of  the  third  RBMPs  that 
there  has  only  been  a  minor 
in  the 
ecological status/potential of surface waterbodies, and no 
improvement in their chemical status compared with the 
status  reported  in  the  second  RBMPs  (covering  2015–
2021).  Heavily  modified  water  and  artificial  waterbodies 
must  reach  good  ecological  potential  rather  than  good 
ecological status, which means that all measures must be 

(99) 

https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 

(100)  https://environment.ec.europa.eu/topics/water_en. 
(101)  These 

the  Groundwater  Directive 

include 

(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 
content/EN/TXT/?uri=celex%3A32006L0007), 
UWWTD 
(https://eur-lex.europa.eu/legal-

Floods 

the 

the 

Belgium  31 

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. 

The following figures show the evolution of the ecological 
status/potential  and  the  chemical  status  of  surface 
waters,  and  of  the  quantitative  and  chemical  status  of 
groundwater in 2010, 2015 and 2021. 

Figure 25: Ecological status/potential of surface 
waterbodies in each RBMP cycle (%) 

Only 27.4 % of surface waterbodies  have a  good or  high 
ecological  status/potential.  Most  of  these  are  in  the 
Walloon Region (43 %), whereas the Flemish Region only 
has  0.5 %.  All  three  surface  waterbodies  in  the  Brussels 
Region have below good potential. The North Sea coastal 
waterbody has a moderate status. 

The main challenges come from agricultural (nitrates and 
pesticides  pollution),  population  density  (land  use  and 
wastewater 
hydromorphological 
pressures.  Legacy  pollution  and  transboundary  pollution 
are also problems. 

discharges) 

and 

Directive 

content/EN/TXT/?uri=celex%3A31991L0271),  the  new  Drinking 
(https://eur-lex.europa.eu/legal-
Water 
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Nitrates 
(https://eur-lex.europa.eu/legal-
Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
MSFD 
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

and 

the 

IED 

the 

the 

(102) ENV - Bibliothèque 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
 
 
 
Figure 26: Chemical status of surface waterbodies in 
each RBMP cycle (%) 

Figure 28: Chemical status of groundwater bodies in 
each RBMP cycle (%) 

Belgium  32 

and 

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  the  Flemish  and 
Brussels  Regions,  these  uPBTs  are  mainly  mercury,  per- 
and polyfluoroalkyl substances (PFAS) and heptachlor, and 
in  the  Walloon  Region,  they  are  mainly  mercury  and 
polybrominated  diphenyl  ethers.  Non-uPBT  substances 
causing  poor  chemical  status  are  largely  metals  (Pb,  Cd 
and Ni) along with industrial chemicals (nonylphenol and 
di(2-ethylhexyl) phthalate). 

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

For  the  Flemish  Region,  the  top  five  pollutants  causing 
failure  to  achieve  good  chemical  status  in  groundwater 
bodies  are  nitrates,  potassium,  pesticides,  N,N-
dimethylsulfamide  and  bentazone.  For  the  Walloon 
Region, failure is mainly due to nitrates, phosphates and 
pesticides,  which  are  all  associated  with  agricultural 
activities. 

Until the end of 2027, Member States can 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. 

a 

impact 

assessment  of 

thorough  assessment  of 

A positive point is that the third Belgian RBMPs are based 
the  main 
on 
solid 
pressures/impacts;  a 
the 
effectiveness of existing measures and a gap analysis; and 
a shortlist of additional measures based on effectiveness, 
technical  feasibility,  support,  costs  and  benefits.  In  the 
Flemish  Region,  the  Flemish  Blue  Deal  sets  out  an 
ambitious  plan  to  combat  water  scarcity  and  manage 
drought  risks,  and  the  ‘great  river  acceleration’  special 
action  plan  includes  over  1 000  actions  to  reduce,  inter 
alia,  the 
impacts  of  nitrates  and  phosphates  from 
agriculture. 

There has been a  slight  decrease  in  groundwater bodies 
with  good  quantitative  status  since  the  second  RBMPs, 
with 10 out of 81 having poor quantitative status, nine of 
which are in the Flemish Region. 

Water abstraction is a significant and increasing pressure, 
and  40  out  of  81  groundwater  bodies  (mainly  in  the 
Flemish Region) have been identified as at risk of failing to 
achieve good quantitative status by 2027. 

In  2024, 
legal  case 
the  Commission  opened  a 
(INFR(2024)2231) alleging that Article 11(3) of the Water 
Framework  Directive  must  be  understood  as  requiring 
that  authorisations  for  abstraction  of  and  discharge  into 
water are always subject to periodic review and that the 
review  interval  should  not  exceed  12 years.  Belgian 
(regional)  law  does  not  always  require  review  or  has 
review intervals that are too long. The reply is outstanding. 

2025 priority actions 

Without prejudice to the list of recommended actions in 
the Commission report to the European Parliament and to 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
the  Council  on  the  assessment  of  the  third  RBMPs,  the 
following priority actions can be highlighted: 

• 

• 

Improve  river  continuity  and  ecological 
flows, 
boosting efforts to introduce 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. 

•  Better justify exemptions to the achievement of good 

• 

status. 
Improve  the  classification  of  water  bodies  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 the 
cost recovery and 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  (FHRMs)  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. 

The  main  progress  resulting  from  the  assessment  of  the 
second FRMPs is that all of Belgium’s FRMPs now include 
a  clear  and  explicit  description  of  the  measures  with 
regard  to  their  aims,  location,  implementation  process 
and  timeline,  as  well  as  their  costs  (for  the  FRMP  as  a 
whole in the case of the Flemish Region, and for individual 
measures, for all three regions).  Furthermore, all FRMPs 
report  geographic  coverage  for  all  measures.  Very 
importantly, the second FRMPs describe climate impacts 

(103)  https://environment.ec.europa.eu/publications/implementing-

decision-drinking-water-directive-watch-list_en. 

(104)  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, 
23.4.2024, 
OJ L, 

(105)  OJ L, 

2024/369, 

Belgium  33 

on  flooding  and  prioritise  addressing  the  impacts  of 
climate change on flood risk to a greater extent. There is 
better international and interregional cooperation, as well 
as broad stakeholder involvement. 

2025 priority actions 

• 

FRMPs  should  provide  details  on  how  the  FHRMs 
were  used  in  the  choice  of  measures  and  how  to 
consider pluvial flooding. 
• 
Consider future climate scenarios in the FRMPs. 
•  Better explain the choice and implementation of flood 
prevention and protection measures (prioritarisation, 
monitoring, costs of measures). 

Drinking Water Directive 

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 (103), (ii) a methodology for measuring microplastics 
in drinking water (104) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (105). 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  Belgium  does  not  give  rise  to 
concern (106). 

From  January  2026,  the  European  quality  standards  for 
PFAS  in  drinking  water  will  apply,  ensuring  harmonised 
Member States reporting of PFAS monitoring data in the 
future. 

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 

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 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
In summary, the compliance for all parameter groups in Belgium 
was at least 98.52 % in 2017, 98.83 % in 2018 and 98.71 % in 2019. 

(106) 

2025 Environmental Implementation Review – Belgium 

 
 
 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 
promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

Figure 29  shows  that  in  2023,  out  of  the  130  Belgian 
bathing waters, 88 (67.7 %) were of excellent quality, 39 
(30 %)  were  of  good  quality  and  3  (2.3 %)  were  of 
sufficient quality. No bathing waters were found to be of 
poor  quality.  Detailed  information  on  Belgian  bathing 
waters is available from a national portal (107) and via an 
interactive map viewer from the EEA (108). 

Figure 29: Bathing water quality per Member State (%), 
2023  

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  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive (109),  dating  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. 
implementation  of  the  Nitrates 
The  report  on  the 
Directive covering 2020–2023 will be available in 2025. 

The analysis of Belgium’s RBMPs has identified nutrients 
important  pressure  on 
from  agriculture  as  an 
groundwater /  surface  waters  that  affects  their  good 

(107)  For the Flemish Region, www.kwaliteitzwemwater.be, and for the 

Walloon Region, http://environnement.wallonie.be/baignade. 

(108)  EEA, 

‘State  of  bathing  water’,  EEA  website,  2024, 

https://www.eea.europa.eu/en/topics/in-depth/bathing-
water/state-of-bathing-water. 

Belgium  34 

status and is one of the main  causes of not meeting the 
Water  Framework  Directive  objectives.  In  July  2024,  the 
Commission  decided  to  refer  Belgium  to  the  Court  of 
Justice for its failure to take reinforced action against the 
pollution  of  water  by  nitrates  (under  Article 5(5)  of  the 
Nitrates Directive) (110). 

According  to  the  latest  information  available  on  the 
implementation of the Nitrates Directive, the pollution by 
nitrates  of  groundwater  and  surface  waters  remains 
widespread in the Flemish Region. The Flemish Region has 
seen  significant  increases  in  certain  areas  and  stable 
values in other areas, but at levels exceeding the threshold 
of  50 mg/l  for  nitrates  or  remaining  very  close  to  that 
threshold. Almost all (97 %) surface waters in the Flemish 
Region were reported to be in a eutrophic state by the end 
of  2019.  Thus,  what  was  identified  as  a  rather  positive 
trend  in  the  previous  EIR  reports  has  now  turned  into  a 
clearly  negative  trend,  with  the  pollution  of  water  by 
nitrates in the Flemish Region being among the highest in 
the  EU.  In  the  Walloon  Region,  reporting  shows  that 
less  worrisome  overall,  with 
pollution 
concentrations in groundwater generally showing a trend 
of  reduction.  However, 
for  surface  waters,  some 
monitoring stations in the Walloon Region are starting to 
show  an  upward  trend,  and  15 %  of  surface  waters  are 
eutrophic. 

levels  are 

2025 priority action 

•  Tackle  nutrient  pollution,  especially  nitrates  from 
implementation  of  the 

agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the effects of untreated urban waste water. 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). 

Overall, in Belgium, the compliance rate is 95 % in 2020. 
Only five agglomerations, generating 456 000 population 

(109)  https://environment.ec.europa.eu/topics/water/nitrates_en. 
(110)  Case INFR(2022)2051. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
equivalent of urban waste water, did not comply with the 
requirements of the directive. 

Figure 30: Proportion of urban waste water that fully 
complies with the UWWTD (%), year 2020 

The evaluation of 2022 priority actions for water reveals 
that, despite some progress made, Belgium  has not fully 
implemented the UWWTD. 

2025 priority action 

Belgium  35 

• 

the  necessary  measures 

Take 
full 
implementation  of  the  current  UWWTD,  taking  into 
account the new requirements of the recast directive. 

to  ensure 

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 (112), 
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 (113)  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 (114)  on  the 
implementation 
these 
regulations (115).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
law  enforcement.  Recorded 
notably 

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) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(114)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, 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, 

(115) 

Source:  European  Commission:  Directorate-General  for  Environment, 
Fribourg-Blanc,  B.,  Dhuygelaere,  N.,  Berland,  J.  and  Imbert,  F.,  12th 
technical  assessment  of  UWWTD  implementation  –  Final  version, 
Publications  Office  of  the  European  Union,  2024,  12th  technical 
assessment of UWWTD implementation - Publications Office of the EU.  

The  directive  has  been  revised(111)  in  order  to,  among 
other things, strengthen existing treatment standards and 
establish a new additional treatment of micropollutants in 
urban  waste  water.  Other  new  requirements  relate  to 
moving  towards  energy  neutrality 
for  the  sector, 
establishing  an  extended  producer  responsibility  system 
to  ensure  sustainable 
financing  of  micropollutant 
treatment  by the  most  polluting industries and ensuring 
access  to  sanitation,  especially  for  vulnerable  and 
marginalised  groups.  Belgium  has  until  31  July  2027  to 
transpose the new directive into its national legal system. 

(111)   Directive (EU) 2024/3019 of the European Parliament and of the 
Council  of  27  November  2024  concerning  urban  wastewater 
treatment (recast). 

(112)  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, 
final  of  14 October  2020,  https://eur-
COM(2020) 667 
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) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(113)  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 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
Belgium  36 

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

In August 2021, the Commission published a  measurable 
assessment  of the enforcement (116) 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 of REACH (117). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (118).  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 (119).  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. 

Responsibility  for  checking  compliance  with  REACH  in 
Belgium lies within the following authorities:  

• 

• 

• 

• 

the Federal Public Service Health, Food Chain Safety 
the  Directorate-General 
and  Environment; 
for 
Environment;  and 
the  Federal  Environmental 
Inspection (also responsible for checking compliance 
with the CLP Regulation); 
the  Federal  Public  Service  Employment,  Labour  and 
Social  Dialogue 
for  checking 
(also  responsible 
compliance with the CLP Regulation); 
in the Flemish Region, the Environment Department – 
Enforcement Section; 
in the Brussels Region, Bruxelles Environnement; 

• 

in  the  Walloon  Region,  the  Directorate-General  for 
Agriculture, Natural Resources and the Environment. 

A reporting exercise for Member States from  Article 117 
of  the  REACH  Regulation  and  Article 46  of  the  CLP 
Regulation  is  conducted  every  five  years.  Results  of  the 
coming one are expected in 2025, hence the absence of 
new national-specific data on enforcement since 2022. 

In  2022,  Belgium  had  not  yet  devised  a  REACH 
enforcement  strategy.  It  only  had  a  CLP  strategy,  which 
was  partially  implemented (120).  The  implementation  of 
the  REACH  Regulation  is  partly  a  federal  competence, 
partly a regional competence and partly a competence of 
individual  local  communities.  The  complexity  of  the 
application  and  enforcement  of  the  REACH  Regulation 
requires  a  coordinated  approach.  The  National  Forum 
REACH ensures a coordinated approach to the controls of 
the various authorised inspection services. In accordance 
with  Article 17  of  the  agreement  of  cooperation  from 
17 October  2011  between  the  federal  and  regional 
authorities, the National Forum REACH draws up annually 
a national plan in view of coordinating the control policy 
in Belgium. This annual plan is submitted for advice to the 
Belgian REACH Committee. 

The  Federal  Environmental  Inspection  also  establishes  a 
detailed  annual  inspection  plan  covering  its  activities 
under the Law on Product Standards (including REACH and 
CLP  Regulations).  With  regard  to  enforcement,  Belgium 
prioritises areas that are the most sensitive to consumers 
(children  and  the  general  public).  According  to  the  last 
reporting  exercise,  in  2019,  17.5  full-time  equivalent 
workers were allocated to the enforcement of the Law on 
the  Federal  Environmental 
Product  Standards  by 
Inspection (including, but not limited to, REACH and CLP 
enforcement) (121). Note that regional inspection services 
are also competent for REACH enforcement. 

Every  year,  Belgium  participates 
in  EU  coordinated 
enforcement  projects  called  REACH-EN-FORCE  (REF) 
projects. In 2020, Belgium participated in one such project 

the 

European 

(116)  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/. 
(117)  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, 

(118)  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). 

(119)  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. 

(120)  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-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(121)  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 
p. 74, 
European 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – Belgium 

 
 
on products sold online, called the REF-8 project (122). The 
project  report  was  completed  in  November  2021,  so  it 
could not be taken into account in the previous EIR. 

Figure 31: Compliance of imported products – results of 
the REF-8 project (%) 

Figure 32: Number of REF-8 controls performed per 
100 000 inhabitants (EU average = 1.24) 

Belgium  37 

A risk approach was used for the targeting of controls in 
identifying  non-
order  to  maximise  the  chances  of 
compliance.  Therefore, 
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. 

the  non-compliance 

Belgium’s  level  of  participation  in  the  REF-8  project  was 
around the EU average, which is rather low because of the 
lack of involvement of certain large Member States. 

Based on this project and others conducted with the help 
of  the  European  Chemicals  Agency  in  the  past  years, 
online sales have been proven to correspond consistently 
to  higher  non-compliance  rates  in  controls  performed 
across  the  EU,  in  particular  when  related  to  imported 
products. 

in 

capacities 

implementation 

In 2022, Belgium received two priority actions: to upgrade 
administrative 
and 
enforcement  towards  a  policy  of  zero  tolerance  for 
instances of non-compliance; and to fully implement the 
enforcement  strategy  for  the  CLP  Regulation  and  devise 
and  implement  a  strategy  for  the  enforcement  of  the 
REACH Regulation. In the absence of reporting since 2022, 
no progress has been reported and these priority actions 
remain valid in 2025. 

2025 priority actions 

•  Upgrade administrative capacities in 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 
the 
in 
European  Chemicals  Agency, 
coordinated enforcement projects, called REFs. 

including 

• 

https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475. 

(122)  European Chemicals Agency, REF-8 project report on enforcement 
of the CLP, REACH and BPR duties related to substances, mixtures 
p. 20, 
and 

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
• 

Increase customs checks and checks of products sold 
online  with  regard  to  compliance  with  chemicals 
legislation. 

Belgium  38 

2025 Environmental Implementation Review – Belgium 

 
Belgium  39 

4. Climate action 

Forestry (124). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

The  key  strategic  document  at  country  level  is  the 
NECP (125).  Belgium  had  not  submitted  the  NECP  by  the 
end of March 2025. The legal deadline for the submission 
was in June 2024. 

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

Figure 33: Total GHG  emissions (excluding international 
aviation) (%), 1990–2022 

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 its determination 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 
law,  and  the  European 
in 
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  (NECPs)  for  2021–2030,  reflecting  the 
increased ambition of the revised EU legislation. In 2024, 
the European Commission also released, jointly with the 
EEA, the first-ever European climate risk assessment. 

its  Member  States  need 

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 % (123).  However,  the  EU 
their 
and 
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 Belgium decreased by 28%, making it one of 
the countries with below-average decrease. 

to  step  up 

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

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  industry,  aviation  within  Europe (126) 
and, from 2024, maritime transport also. 

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. 

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

(124)  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. 

(125)  More  information  about  NECP  is  on  the  dedicated  website 
https://energy.ec.europa.eu/topics/energy-strategy/national-
energy-and-climate-plans-necps_en. 

(126)  Flights between the Member States including departing flights to 

Norway, Iceland, Switzerland and the United Kingdom. 

2025 Environmental Implementation Review – Belgium 

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

In  2023,  only  23 %  of  GHGs  emitted  by  Belgium’s  ETS 
installations  came  from  power  generation,  much  below 
the  EU  average  of  57 %.  The  chemical  industry  emitted 
more than a quarter (28 %) of the total emissions from all 
industry  sectors,  refineries  one  fifth  (20 %),  cement  and 
lime  production  also  nearly  one  fifth  (17 %),  the  metals 
industry  emitted  18 %,  and  18 %  of  the  emissions  came 
from other industries. Between 2019 and 2023, the power 
registered  a  significantly  higher  emissions 
sector 
industry  sectors  (16 %). 
reduction  (33 %)  than  the 
Between 2013 and 2023, GHG emissions declined by 37 % 
in power generation and by 15 % in the industry sectors, 
with larger reductions in the cement and line industry. This 
resulted in a 22 % reduction overall. 

the  current  ETS)  will  become 

From  2027,  a  new  ETS,  called  ETS2,  for  buildings,  road 
transport  and  additional  sectors  (mainly  industry  not 
covered  by 
fully 
operational (127). 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.  Belgium  did  not  communicate 
full 
transposition  into  national  law  by  this  deadline.  The 
Commission therefore opened an infringement procedure 
against  Belgium  on  25 July  2024,  by  sending  a  letter  of 
formal notice for failing to fully transpose the provisions 
into national law. 

Belgium  has  since  partially  notified  transposition  of  the 
relevant  provisions  of  the  ETS  2  Directive  to  the 
Commission. The monitoring and reporting requirements 
and the obligation to hold a permit to carry out activities 
under ETS2 will commence on 1 January 2025.. 

The  Commission  also  opened  infringement  procedures 
against Belgium on 25 January 2024, by sending a letter of 
formal  notice  for  failing  to  fully  transpose  previous 
revisions of ETS  Directive (128) into national law. Belgium 
has  since  notified  partial  transposition  of  either  one  or 
both  revisions  to  the  Commission.  In  the  absence  of  a 
complete  transposition,  the  Commission  may  decide  to 
issue a reasoned opinion. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation (ESR) (129)  covers  GHG 
emissions 
(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 

(127)  Directive 

(EU) 

2023/959 

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

content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG). 

(128)  Directive 

- 

2023/959 

content/EN/TXT/?uri=CELEX:32023L0959) 

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

and  Directive 

Belgium  40 

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. Belgium‘s target is –47%. 

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 Belgium will need to implement new measures 
and/or  use  available  flexibilities  to  achieve  its  2030  ESR 
target. 

Projected gap is 4.4 percentage points to the 2030 target. 

The largest  contributor is the domestic transport  sector, 
which accounted for 38 % of all effort sharing emissions in 
2022. 

transport 

Continued momentum is crucial to accelerate the take-up 
of  zero-emission 
in  Belgium.  Passenger 
transport in Belgium is split by means of transport broadly 
in  line  with  the  EU  average  (share  of  passenger  cars  is 
85 %).  At  2.6 %  in  2023,  the  share  of  battery  electric 
vehicles  in  Belgium’s  passenger  cars  fleet  has  grown 
dynamically (EU average is 1.2 %), as has the number of 
publicly  accessible  charging  points,  reaching  35  000  in 
2023,  or  one  charging  point  for  every  eight  e-vehicles 
(above the EU average of 1:10). Freight is predominantly 
transported by road. At 12 %, inland waterways transport 
more than twice the share of freight than the EU average 
(5.4 %).  Belgium  has  the  second  highest  share  of 
electrified railway lines in the EU, at 87 % (EU average is 
56 %). 

Buildings  accounted  for  32 %  of  effort  sharing  emissions 
and  have  decreased  by  32 %  since  2005.  Nevertheless, 
Belgium  needs  to  step  up  its  efforts  in  the  residential 
sector  to  achieve  a  meaningful  contribution  to  its  2030 
reduction  target  for  energy  consumption  by  buildings. 
Share of renewable energy in heating and cooling of 10 % 
remains very low compared to the EU average (25 %). 

2023/958 
content/EN/TXT/?uri=CELEX:32023L0958). 
2018/842 
(EU) 

(129)  Regulation 

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

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

(https://eur-

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
Belgium  41 

indicating  decent 
categories, including floods (the highest risk). 

insurance  coverage 

for  all 

risk 

Belgium adopted its national adaptation strategy and plan 
in 2010 and 2017 respectively. At this moment, steps are 
being taken to update both documents. 

The  first  risk  assessment  by  CERAC,  which  identifies  the 
climate related risks within 5 thematic clusters will play a 
key role in this renewal. 

The  Regional  and  Federal  Adaptation  Plans  have  been 
updated recently. 

2025 priority actions 

European  Commission  identified  four  priority  actions  in 
the 2022 edition of the review. 

There is some progress in reducing emissions in transport 
sector,  but  emissions  per  capita  and  per  passenger  km 
remains above EU average. 

There  is  a  progress  regarding  hydrogen  and  carbon 
capture,  use  and  storage.  Belgium  invests  in  hydrogen 
infrastructure (a backbone pipeline, a  pipeline to France 
and receiving terminals), and has five hydrogen candidate 
projects  for  the  next  (PCI)/(PMI)  list.  It  is  also  active  in 
carbon  capture  and  storage,  with  projects  intending  to 
capture  and  transport  CO2  from  the  industrial  areas 
around the ports of Antwerp-Bruges and Gent to storage 
under  either  the  Dutch  or  the  Norwegian  continental 
shelf. In 2023 the EU first CCS transport from Antwerp to 
Denmark and the storage under the sea in Denmark was 
realised. 

capacity 

renewable 

energy 
infrastructure, 

Belgium  displays  positive  developments  in  terms  of 
increased 
installed, 
development  of  energy 
including  for 
hydrogen,  energy  efficiency  measures.  However,  further 
efforts  are  needed  to  accelerate  the  clean  energy 
transition. Belgium is highly dependent on fossil fuels and 
remains dependent on imports from non-EU countries for 
most clean energy technologies. 

2025 priority actions 

• 
• 

Submit the final energy and climate plan (NECP)(131). 
Implement all policies 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. 

Figure 34: Effort-sharing emissions by sector (%), 2022 

Land use, land-use change and forestry 

The 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. 

Belgium’s LULUCF sector has been a net carbon sink since 
1990, albeit removals have been decreasing. 

Belgium‘s target in 2030 is to enhance land removals by an 
additional  −0.3  Mt  of  CO2  equivalent  compared  to  the 
yearly  average  of  the  period  2016–2018.  The  latest 
projections show a surplus compared to the 2030 target of 
−0.3 Mt of CO2 equivalent. Therefore, Belgium is on track 
to meet this target. 

Adaptation to climate change 

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

Belgium  has  one  out  of  three  regions  identified  as  a 
hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions (130). 

Water  management  is  increasingly  identified  as  a  key 
affected  sector,  and  for  all  sectors  the  water-related 
hazards,  fluvial  and  pluvial  floods  and  droughts,  are 
signalled.  The  climate  protection  gap  in  Belgium  is  low, 

(130)  European 

Climate 

(EUCRA). 
https://climate-adapt.eea.europa.eu/en/eu-adaptation-
policy/key-eu-actions/european-climate-risk-assessment. 

Assessment 

Risk 

2024, 

131  

The  plan  will  be  assessed  and  the  assessment,  providing  more 
detailed  priority  actions, will  be  available  on  the  Commission 
website at National energy and climate plans.  

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
 
 
Part II: Enabling framework: implementation tools 
5. Financing 

Belgium  42 

The  EU  budget  supports  climate  investment  in  Belgium 
with  significant  amounts  in  the  2021–2027  period,  with 
revenues from the EU ETS also feeding into the national 
budget.  During  2020–2022,  Belgium’s  revenues  from 
auctioning reached EUR 1.5 billion in total, with 25 % of it 
to 
spent  on  climate  and  energy,  corresponding 
EUR 342 million. 

In  addition,  the  annual  investment  needed  to  meet  its 
in  the  areas  of  pollution 
environmental  objectives 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 14.4 billion per year in 
Belgium. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 10.7 billion per year; thus, there is 
a gap of EUR 3.7 billion per year. 

The  environmental  investment  gap  is  concentrated  in 
pollution prevention and control (EUR 1.5 billion per year) 
and in the water field (EUR 1.4 billion per year), while also 
being present in the circular economy (EUR 0.9 billion per 
year). 

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, the cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
Recovery  and  Resilience  Facility  (RRF)  275.7 billion,  and 
the CAP 145.9 billion (132). 

In  Belgium,  the  EU  cohesion  policy  (considering  the  EU 
for 
contribution  amount)  provides  EUR 703 million 

(132)  European  Commission:  Directorate-General 

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

2024, 

(133)  See 

the 

Cohesion 

Open 

Data 

Platform 

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

climate action in 2021–2027 (with around 44 % of this via 
the ERDF), with a further 23.6 million from the European 
Maritime, Fisheries and Aquaculture Fund (EMFAF) (133). 

The  RFF  contributes  to  climate  finance  in  Belgium  with 
EUR 2.61 billion  up  to  2026,  representing  49.2 %  of  its 
national RRP (134). 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  in  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 4.3 billion was assigned to 
Belgium in the reference period (135). 

National financing, including emissions trading system 
revenues 

to  EUR 356.1 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU ETS,  which  feed  directly  into  national 
budgets,  amounted 
in  2020, 
EUR 533.2 million in 2021 and EUR 657.7 million in 2022 in 
Belgium, totalling EUR 1.5 billion in the three-year period. 
Of this, the share spent on climate action   reached 25 % 
(EUR  341.7  million).  From  2021  onwards  the  direct 
spending of auction revenues has been on hold pending a 
legal  decision  on  the  regions’  and  federal  shares,  and 
revenues  are  being  carried  over  to  future  years.  The 
amount  reported  as  spent  in  2022  covers  only  direct 
revenue  spent.  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 (136). 

It should be noted that investment in climate action also 
the 
supports 
environmental  investments  described  in  the  following 

the  environment 

therefore, 

and, 

(134)  EU  Commission  datasets  and  the  recovery  and  resilience 
(https://ec.europa.eu/economy_finance/recovery-

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

(135)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

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

(136)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-24_en. 

Luxembourg, 

Union, 

 2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
Belgium  43 

Cohesion policy 
ERDF 
Just Transition Fund 

Agricultural 

CAP 
European 
Guarantee Fund  
European  Agricultural  Fund 
for Rural Development  

EMFAF 

Other MFF sources 

RRF (d) (2021–2026) 

318.3 (a) 
263.3 
55.0  

867.5 (b) 
611.4 
256.1 

14.3 

411.8 (c) 

 1 754  

(a) 

(b) 

Fund. 

Source 

further 

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 
its  publication  date.  Note  that  Belgium  is  not  eligible  for  the 
Cohesion 
information: 
and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data.  
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 Connecting Europe Fund. 
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 

6.12.2021, 

Annex XI, 

L 435 

Belgium,  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 
the  financial 
instrument  for  the  environment  (LIFE) 
programme (139)  (EUR 5.4 billion),  Horizon  Europe (140) 
Europe 
(EUR 95.5 billion), 

Connecting 

the 

sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (137). 

Environmental financing and investments 

This  section  describes  Belgium’s 
investment  needs, 
current  financing  and  gaps  as  they  relate  to  the  four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (138). 

The environment overall 

Investment needs 

investment  needs  to  be 
The  overall  environmental 
sufficient to enable Belgium 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 14.4 billion  per  year  (in  2022 
prices). 

A  significant  part  of  the  estimated  requirement  (up  to 
EUR 9 billion  a  year)  can  be  attributed  to  the  need  to 
support  the  circular  economy.  The  investment  need  for 
pollution prevention and control is around EUR 2.6 billion 
per  year  and  for  the  water  objective  EUR 2.3 billion  per 
year.  For  biodiversity  and  ecosystems,  the  estimated 
investment  need  is  around  EUR 0.5 billion  per  year  (in 
2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 10.7 billion in Belgium from EU and national 
sources combined (in 2022 prices). 

(c) 

(d) 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 1.6 billion  for  Belgium  in  total  for  2021–2027  (or 
230 million per year). 

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

Instrument 

Allocations  

(137) 

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

(138)  Research,  development  and  innovation  is  accounted  for  under 
each  environmental  objective.  The  financing  needs,  baselines, 
gaps  estimates  are  based  on  the  Directorate-General  for 
internal  analysis  (of  2024).  Throughout  this 
Environment’s 

chapter,  specific  references are  provided to  the  most  important 
data sources used.  

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

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
Belgium  44 

protection 

investment 

Split by institutional sector,  25.2 % of  Belgium’s national 
environmental 
(capital 
expenditure) comes from the general government budget, 
from  specialist  private-sector 
with  46.4 %  coming 
producers (of environmental protection services, such as 
waste and water companies) and 28.3 % from the general 
business  sector,  whose  environmental  activities  are 
usually  ancillary  to  their  main  activities.  At  the  EU  level, 
around  38 %  of  environmental  protection  investment 
comes  from  governments,  40 %  from  specialist  private-
sector producers and 22 % from the business sector (143). 

Belgium’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 10.7 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national  private  expenditure.  Of  the  total,  EU  funding 
(including  EIB  funds)  represents 
  8%,  and  national 
financing 92 %. The total public financing (EU plus national 
public) represents 31.2 % 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 3.7 billion 
per  year  in  Belgium,  representing  around  0.67 %  of  the 
national GDP, being lower than the EU average (0.77 %). 

Figure 35: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Fund (141) (EUR 33.7 billion)  and 
mobilised through the InvestEU programme (142). 

funds 

that  can  be 

Belgium’s  RRP  supports  climate  objectives  through 
funding  of  EUR 2.61 billion  (49.2 %  of  the  total)  with  an 
additional  EUR 0.2 billion  (3.8 %  of  the  total)  directly  for 
the environment. 

Certain parts of Belgium’s RRP have a strong focus on the 
environment. Component 1.3  ‘Climate and environment’ 
focuses  on 
strengthening 
restoring  biodiversity, 
adaptability  and  resilience  to  climate  change,  and  water 
management.  Investments  will  aim  at  a  coherent  set  of 
natural areas, forests and riverbeds to act as carbon sinks 
and  mitigate  the  consequences  of  floods  and  droughts. 
This  component  has  a  budget  of  EUR 400 million. 
Component 5.3  ‘Circular  economy’  contributes  to  the 
development  of a  circular  and low-carbon economy This 
component supports innovation in waste and raw material 
processing,  and  develops  circular  economy  training. 
Investments  include,  for  example,  the  federal  initiative 
Belgium  Builds  Back  Circular,  the  recycling  hub  in  the 
Flemish  Region  and  the  deployment  of  the  Circular 
Wallonia strategy. 

The  EIB  provided  around  EUR 3 billion  in  environment-
related financing to Belgium from 2021 to mid 2024, half 
of  which  went  to  water  measures  and  the  other  half  to 
sustainable energy, transport and industrial projects, with 
significant  co-benefits  to  clean  air,  environmental  noise 
and other pollution. 

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 Belgium, the 
total national environmental protection expenditure was 
EUR 15.3 billion  in  2020  and  EUR 16.7 billion  in  2021, 
representing 3.3 % of GDP in both years. 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
59.9 billion  in  2021  in  the  EU-27,  representing  around 
In  Belgium,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
EUR 2.4 billion  in  both  2020  and  2021,  representing 
around 0.5 % of GDP. 

investment 

protection 

Source: Analysis of Directorate-General for Environment. 

(141)  The  Connecting  Europe  Facility  Transport  part  also  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. 

(142)  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. 

(143)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Belgium 

 
 
 
The following table provides the distributions of Belgium’s 
environmental  investment  gap  (expressed  in  various 
forms) by environmental objective. 

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

EUR 834 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (144).  Industrial  site  remediation 
requires  an  estimated  EUR 101 million  per  year. 
Microplastics pollution and the chemicals strategy require 
around EUR 60–80 million per year (each) (145). 

Belgium  45 

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Investment gap per year  

Current investments 

% of GDP 

 % of 
total 

Million 
EUR 
(2022 
prices) 

1 512 

41.0 

0.28 

886 

24.0 

0.16 

1 392 

37.7 

0.25 

investment 

levels  supporting  pollution 
The  current 
prevention and control reach an estimated EUR 1.1 billion 
per year in Belgium in 2021–2027. Most of the financing 
concerns clean air  (EUR 681 million per year). Protection 
around 
from 
EUR 228 million 
further 
EUR 118 million 
from  radiation  and 
EUR 66 million for site remediation.146 

(each)  per  year,  with  a 
for  protection 

environmental 

receives 

noise 

In Belgium, the EU MFF provides an estimated 5.8 % of the 
clean air financing (mostly via the cohesion policy), with a 
further  15.4 % from the RRF, adding up to  21.2 %  of the 
total.  EIB  financing  contributes  17.7 %  and  national 
sources reach 61.1 % (147). 

– 

– 

– 

The gap 

Total 

 3 694 

100.0 

0.67 

NB: For biodiversity and ecosystems, there is no significant gap envisaged 
based on currently available data.  
Source: Directorate-General for Environment analysis.  

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Belgium’s investment 
needs  are  estimated  to  reach  EUR 2.6 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 1.9 billion,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
reach 
needs 

environmental 

reduce 

noise 

to 

(144)  2021 

assessment 

Phenomena 

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

Environmental 

Noise 

2023 

(145)  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). 
Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA 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 

146  

To meet its environmental objectives concerning pollution 
prevention and control (towards zero pollution), Belgium 
needs  to  provide  an  additional  EUR 1.5 billion  per  year 
(0.28 % 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 

According to the latest (2023) NAPCP review report (148), 
Belgium complied with ammonia reduction requirements 
in  2020  and  2021,  and  is  at  low  risk  of  non-compliance 
with  ammonia  concerning  the  NECD’s  2030  emission 
reduction  commitments,  based  on  the  policies  and 
measures  in  its  NAPCP  that  take  into  account  climate, 
energy and CAP plans and financing baselines. 

information  on  clean  air 

Annex  VI.  Further 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 

tracking: 

(147)  Through the tracking of EU funds, EIB projects and national 

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

Commission 

projections’, 

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

2025 Environmental Implementation Review – Belgium 

 
 
Circular economy and waste 

Investment needs 

Belgium’s investment needs in the circular economy and 
waste  reach  EUR 9.1 billion  per  year  (including  baseline 
investments).  Most  of  this,  around  EUR 7.9 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 1.2 billion  necessary 
for  waste  management 
(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 (149). 

Current investments 

Circular economy investments across the economy reach 
around  EUR 7 billion  per  year  in  Belgium  in  2021-2027, 
with  a 
for  waste 
management  that  is  not  considered  part  of  the  circular 
economy. 

further  EUR 1.1 billion  provided 

Around 0.2 % of the combined financing for circularity and 
waste  management  comes  from  the  EU  MFF,  with  a 
further 0.5 % from the RRF, adding to  0.7 % of the total. 
EIB  loans  identified  in  support  of  circularity  and  waste 
management represent 0.1 % of the total. Accordingly, the 
share of national sources is overwhelming, reaching 99 % 
of the total financing (150). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Belgium  needs  to  increase 
investments  by  an  estimated 
circular  economy 
EUR 819 million 
additional 
EUR 68 million 
for  waste  management  action  not 
belonging  to  the  circular  economy.  Combined,  this 
amounts to EUR 887 million per year, representing 0.16 % 
of Belgium’s GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 214 million  relates  to 
recent  initiatives,  such  as  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 

Belgium  46 

digital tools, CRM recycling and measures proposed under 
the  amendment  of  the  Waste  Framework  Directive,  and 
EUR 604 million  constitutes 
investment 
needed to unlock Belgium’s circular economy potential. 

further 

the 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 2.3 billion (in 2022 prices) in Belgium. This comprises 
investment  needs  for  both  the  water  industry  and  the 
protection and management of water. The largest part of 
the  total  annual  need,  EUR 1.8 billion,  relates  to  the 
management  of  waste  water  (including  additional  costs 
associated  with 
further 
EUR 59 million  is  necessary  for  drinking-water-related 
investments  and  around  EUR 363 million 
the 
protection and management of water (151). 

revised  UWWTD).  A 

the 

for 

Current investments 

Water investments in Belgium are estimated to be around 
EUR 868 million per year (in 2022 prices) in 2021–2027. Of 
this,  EUR 649 million supports wastewater  management, 
EUR 68 million drinking water and around EUR 146 million 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Of the total water financing, 1.4 % is provided by the EU 
MFF and 1.2% from the RRF for Belgium. EIB financing is 
significant, around 24 %, while the bulk of water financing 
comes from national sources (73.7 %) (152). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Belgium’s  water  investment  gap  reaches  EUR 1.4 billion 
per year (0.25 % of GDP), with most of it related to waste 
water  (EUR 1.2 billion  per  year).  Additional  elements  of 
the  Water  Framework  Directive 
require  around 
EUR 217 million per year over existing levels of financing. 

(149)  See Systemiq and Ellen MacArthur Foundation, Achieving ‘Growth 
2017, 

Within’, 
https://www.ellenmacarthurfoundation.org/achieving-growth-
within;  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. 

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

(151)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU member 
states’, 
2020, 
28 May 
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.  

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

2025 Environmental Implementation Review – Belgium 

 
 
Belgium  47 

Biodiversity and ecosystems 

Investment needs 

Figure 36: 2021–2027 contributions to biodiversity from 
the main EU instruments per Member State (% of policy 
total) 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 0.5 billion per year (in 2022 prices) in 
Belgium 
includes  the  following 
financing needs: 

in  2021–2027.  This 

the 

Natura 

•  Belgium’s  prioritised  action  frameworks (153), 
areas: 

concerning 
EUR 343 million per year, mostly running costs; 
additional BDS costs (154): EUR 22 million per year 
on top of the frameworks;  
sustainable 
EUR 126 million. 

soil  management 

costs (155): 

• 

• 

2000 

million per year.97 
Current investments 

The current level of biodiversity financing is estimated to 
be EUR 588 million per year (in 2022 prices) in 2021–2027. 
Of this, 93 % is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

Of the total financing, 0.3 % is estimated to come from the 
EU  cohesion  policy,  20 %  from  the  CAP,  3.3 %  from 
Horizon Europe and around 1 % from both the EMFAF and 
the LIFE programme. The EU MFF altogether accounts for 
21.2 % of the financing and the RRF for 3.5 %, adding up to 
a total of 25 % from the EU budget. The rest, 75 % comes 
from national sources (156). 

At 2.9 %, Belgium has a relatively high share of RRF funding 
dedicated  to  supporting  measures 
for  biodiversity 
compared  with  other  Member  States.  Belgium  has  also 
programmed  21 %  of  its  CAP  budget  for  2021–2027  for 
biodiversity, which is above the EU average. Lastly, 3.9 % 
of Belgium’s cohesion policy EU contribution is estimated 
to  contribute  to  biodiversity,  disregarding  ESF+  (see 
Figure 36). 

(153)  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 

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

European  Union, 

Luxembourg, 

the 

of 

(155)  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 

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,  Belgium’s 
financing resources are estimated to be proportionate to 
its  needs,  without  a  major  financing  gap,  based  on  the 
currently available data. 

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(157). 
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 (158). 

(156)  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.  

(157)  European  Commission,  Green  Budgeting  in  the  EU.  Key  Insights 
from the 2023 European Commission Survey of Green Budgeting 
https://economy-
Practices, 
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, 

(158)  European  Commission, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

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

2025 Environmental Implementation Review – Belgium 

 
 
 
 
Belgium  48 

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 
2021 to 2024(159). Belgium participated. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (160),  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

formed  the 

Total environmental taxes amounted to EUR 12.3 billion 
in  Belgium  in  2022,  representing  2.2 %  of  its  GDP  (EU 
average:  2.0 %).  Energy  taxes 
largest 
component of environmental taxes, accounting for 1.6 % 
of  GDP,  similarly  to  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  0.11 %  (EU 
average 0.08 %). In 2022, environmental taxes in Belgium 
accounted  for  5.1 %  of  total  revenues  from  taxes  and 
social  security  contributions  (around  the  EU  average  of 
5.0 %) (161). 

Figure 37: 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. 

According to a 2024 study (162), Belgium applies emission 
charges to water (biochemical oxygen demand, pesticides 
and  other),  a  solid  waste  landfill  fee,  a  manure  tax, 
product charges (vehicle tax, batteries, levies on plastics, 
aluminium sheets and strips, cameras disposal, paints, inks 
and  solvents),  and  user  charges  (water  abstraction  and 
disposal volumes, road pricing). Specific examples of good 
practices  are  the  tax  on  environmental  impacts  from 
farming in the Walloon Region (163) and incineration taxes 
landfill  of  specific 
complemented  by  bans  on  the 
substances in the Flemish and Walloon Regions. Taxes on 
mineral extraction charged per volume (m3) or weight (kg 
or t) of materials extracted cover the extraction of various 
natural  resources,  for  example  coal,  lignite  or  peat 
extraction.  The  same  study  recommends  a  tax  on 
pesticides (164). 

With regard to the use of the fees collected from landfill 
and  incineration  taxes  in  the  Walloon  Region,  the  tax 

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

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

(163)

/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(160)  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. 

(161)  Eurostat, ‘Environmental taxes accounts’, env_eta.  
(162)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
https://op.europa.eu/en/publication-detail/-
Annex 1, 

https://agriculture.wallonie.be/home/environnement/taxee

nvironnementale/la-taxe-sur-les-charges-environnementales-
generees-par-les-exploitations-agricoles.html. 

(164)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
point 5.2.5,  p. 23,  https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
decree (165) stipulates that the revenue from these taxes is 
allocated  exclusively  to  the  Waste  Management  Fund, 
created  within  the  revenue  budget  and  the  general 
expenditure budget of the Walloon Region. 

According  to  the  same  2024  study (166),  the  Walloon 
Region applies a tax on environmental costs generated by 
agricultural activities to take into account environmental 
costs linked in particular to livestock effluents or the use 
of fertilisers and phytosanitary products in crops (167). 

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 (168). 

During  2021–2023,  Belgium  issued  green  bonds  worth 
USD 17.2 billion (EUR 14.6 billion). Of this, the issuance in 
2023 amounted to USD 5 billion (EUR 4.6 billion). 

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

issuances)  was 

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

issued  by 

(165)  See 

Article 44, 

https://wallex.wallonie.be/eli/loi-

(166) 

decret/2007/03/22/2007201247/2024/01/01. 
 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. 

(167)  For an overview of environmental taxes in agriculture, see OECD, 
Taxation  in  Agriculture,  OECD  Publishing,  Paris,  2020,  p. 105, 
https://www.oecd.org/en/publications/taxation-in-
agriculture_073bdf99-en.html.  

Belgium  49 

Figure 38: 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). 

Environmentally harmful subsidies 

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 (169). 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  has  been  a  marked 
increase in annual FFS of 72 % in the EU (170). 

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 (171). In particular, FFS for coal and 

(168)  Climate  bonds  initiative  (https://www.climatebonds.net).  NB. 
Additionally (and not included in this), national sources indicated 
EUR 544.8 million issuance for Croatia, in 2022-2023, and a slightly 
higher  amount  for  Slovenia  (+0.27  billion)  during  2021-2023  in 
total. 

(169)  Articles 3(h)  and  3(v)  of  the  eighth  environment  action 

programme. 

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

Union, 

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

(171)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE . 

2025 Environmental Implementation Review – Belgium 

 
 
 
lignite, natural gas and oil increased in 2022 and a strong 
increase was observed for natural gas subsidies. 

2022 

The 
recommendation for Belgium. 

report 

EIR 

included 

Belgium  50 

the 

following 

In  Belgium,  the  energy  subsidies  showed  increases  from 
2016  to  2022.  As  a  significant  part  of  this,  the  FFS  grew 
from  EUR 3.2 billion  (in  2016)  to  6.5 billion  (in  2022), 
followed by a decrease in 2023. 

• 

Tackle  the  main  environmental  challenges  affecting 
the  country,  through  appropriate  funding,  including 
through the mobilisation of investments and the use 
of EU funds. 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to  less  than  0.1 %  in  Denmark  and  Sweden.  Belgium’s 
value reached 1.2 %, above the EU average (0.8 %) (172). 

Important to note is that Belgium organised a conference 
on  24 March  2023 (173)  on  the  European  Commission’s 
vade mecum for environmental financing (174). 

Figure 39: Energy subsidies by energy carrier in Belgium 
(billion EUR), 2015–2023 

Since the 2022 EIR, Belgium continued to provide funding 
in  the  magnitude  of 
for  environmental  objectives, 
EUR 10 billion  per 
year.  However,  environmental 
financing  gaps  of  0.2–0.3 %  of  GDP  exist  for  several 
environmental  objectives  (in  particular  for  pollution 
prevention  and  control  and  for  water),  adding  up  to 
around  EUR 3.7 billion  per  year  (0.67 %  of  GDP,  slightly 
under the EU average). 

2025 priority action 

light  of  the  financing  gaps  observed  for  most 
In 
environmental  objectives,  a  general  priority  action  is 
provided for Belgium. 

•  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. 

NB: RES, renewable energy source. 
 Source : analysis of Directorate-General Energy 

(172)  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, 

(173)  European  Commission,  ‘The  first  vade  mecum  online  event  on 
environmental  funding –  Belgium,  24 March  2023’,  European 
Commission 
website, 
https://environment.ec.europa.eu/events/first-vademecum-

online-event-environmental-funding-belgium-24th-march-2023-
2023-03-24_en. 

(174)  European Commission: Directorate-General for Environment, Find 
Your EU Funding Programme for the Environment – Supporting the 
environment  under 
financial 
framework  and  NextGenerationEU,  Publications  Office  of  the 
European 
2022, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/33b54f0d-0251-11ed-acce-01aa75ed71a1. 

the  2021–2027  multiannual 

Luxembourg, 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
6. Environmental governance 

Belgium  51 

Information, public participation and access to 
justice 

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

2016 

2023 

Legend 

to 

(iii) 

and 

access 

justice 

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 
in 
decision-making 
environmental  matters.  It  is  of  crucial  importance  to 
public  authorities,  the  public  and  businesses  that 
environmental 
is  shared  efficiently  and 
effectively (175).  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 rights of citizens and ensure 
accountability  of  authorities (176).  It  includes  the  right  to 
bring legal challenges (‘legal standing’) (177). 

information 

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. 

Inspire 
Belgium’s  performance 
Directive is substantial and has been reviewed based on 
its 2023 country fiche (178) (see Table 3). 

implementing  the 

in 

In 2022, Belgium received a priority action on the need to 
improve access to spatial data and services. This action has 
been  adequately  addressed  and  therefore  no  priority 
action is proposed for 2025. 

(175)  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 

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

Effective  coordination  and  data 
sharing 

Ensure 
effective 
coordination  

Data  sharing 
without 
obstacle  

■ 

■ 

Inspire performance indicators 

■ 

■ 

■ 

■ 

■ 
Implementation 
of  this  provision 
is 
well  advanced  or 
(nearly)  completed. 
Outstanding 
issues 
are minor and can be 
addressed 
easily. 
Percentage: > 89 % 
■ 
Implementation 
of  this  provision  has 
started  and  made 
some  or  substantial 
progress  but  is  still 
not  close  to  being 
complete. 
Percentage: 31–89 % 
■ 
Implementation 
is 
of  this  provision 
significantly 
falling 
behind. 
Serious 
efforts  are  necessary 
the 
close 
to 
implementation  gap. 
Percentage: < 31 % 

■ 

■ 

■ 

■ 

■ 

■ 

(i) 
Conformity 
of metadata  

(ii) 
Conformity 
of 
datasets  

spatial 

(iii) 
Accessibility 
of 
spatial 
datasets 
through 
view 
download 
services 

and 

(iv) 
Conformity 
of  network 
services 

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

(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). 

(177)  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. 

(178)  European  Commission, 

‘Belgium’, 

Inspire  Knowledge  Base, 

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

2025 Environmental Implementation Review – Belgium 

 
 
 
 
  
Belgium  52 

Public participation 

Public involvement  at both the planning and the  project 
phase  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 

involvement  and 
This  section  examines  how  public 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (179) 
and  the  Strategic  Environmental  Assessment  (SEA) 
Directive (180). 

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(181).    Belgium  has  already 
taken  steps  towards  accelerating  permit  procedures, 
taking advantage of the broad flexibilities offered by the 
EU  legal  framework,  such  as  the  establishment  of  one-
stop-shop  and  accelerated  short  deadlines  for  permit 
processes  for  renewable  energy  projects.  Furthermore, 
Belgium  has  transposed  the  EU  rules  on  energy 
communities  and  prosumers,  based  on  a  number  of 
enabling conditions, including eased permit requirements 

for  smaller-scale  solar  photovoltaics;  dedicated  supply 
licensing  regimes  and  a  regulatory  framework; 
ICT 
infrastructure  and  financial  incentives  (e.g.  value-added 
tax  exemptions  in  the  Flemish  Region  and  reduced 
network tariffs in the Brussels Region) for energy traded 
between  peers  and  shared  within  multi-apartment 
buildings and energy communities. 

The  average  speed  in  the  EU  for  permit  processes 
involving  an  EIA  procedure 
is  20.6 months,  with  a 
minimum  duration  of  11.4 months  and  a  maximum 
duration of 75.7 months (182). The duration of each step in 
an  EIA  process  (screening,  scoping,  EIA  report,  public 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
The available data for Belgium does not allowing drawing 
conclusions, with data missing for the Walloon Region. A 
priority  action  is  included  for  2025  to  provide  more 
detailed  information  on  the  different  stages  of  the  EIA 
process.  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 (183). 

Belgium has a national website about the implementation 
of  the  Aarhus  Convention (184).  This  website  provides  a 
one-stop  shop  describing  how  public  engagement  is 
organised  across  the  country.  The  website  includes 
information  on  past  or  current  public  consultations  on 
draft legislation, plans or programmes that are organised 
at the federal and/or regional levels. 

At the regional level, only the Flemish Region currently has 
platforms  in  place  to  enable  public  participation  in 

(179)  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, 
https://eur-lex.europa.eu/legal-
p. 1), 
28.1.2012, 
content/EN/TXT/?uri=CELEX%3A32011L0092. 

(180)  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, 
https://eur-lex.europa.eu/legal-
p. 30), 
content/EN/ALL/?uri=CELEX:32001L0042. 

(181) 

Commission  Staff  Working  Document    (SWD/2022/0149 
final),  18  May  2022,  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=165303
4229953. 

Impact  Assessment 

(182)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
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/. 
(183)  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 

(184)  https://www.health.belgium.be/fr/environnement/bienvenue-

sur-le-portail-national-sur-la-convention-daarhus. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
Belgium  53 

licensing  procedures (185)  and  planning  procedures  for 
regional  plans  and  programmes (186).  In  the  Brussels 
Region,  Bruxelles  Environnement/Leefmilieu  Brussel  set 
up a single consultation web page, easily accessible from 
the main page of its website. 

However, statistics on the level of public participation in 
EIA  and  SEA  procedures  are  not  available  at  either  the 
federal or regional level in Belgium. 

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 
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, Belgium has made progress 
by  providing  wider  access  to  justice  to  environmental 
NGOs. 

The  procedure  for 
judicial  review  of  administrative 
decisions by Belgium’s Council of State is laid down in its 
basic  act  (Lois  Coordonnées  sur  le  Conseil  d’État)  and 
complementary regulations.  This procedure can be used 
to challenge any unilateral,  final,  legally binding act of a 
Belgian administrative authority, whether of an individual 
or  regulatory  nature  (i.e.  administrative  decisions  in 
individual  cases  as  well  as  executive  orders  and 
administrative 
laying  down  generally 
applicable rules). 

regulations 

An action to annul an administrative act can be brought by 
any  party  (any  natural  or  legal  person)  that  has  been 
‘harmed’  or  has  an  ‘interest’  at  stake.  Meeting  this 

(185)

https://www.omgevingsloket.be/omvPubliek/?openbaarond

erzoek. 

(186)  https://inspraak.omgeving.vlaanderen.be/. 
(187)

https://etat.environnement.wallonie.be/contents/indicators

heets/TRANSV%202.html. 

(legal  or  natural  persons) 

requirement  does  not  pose  particular  problems  for 
individual  claimants 
in 
environmental  cases,  and  the  standing  requirements  do 
not vary according to the type of environmental legislation 
concerned.  Proof  of  actual  harm  is  not  required.  A 
legitimate interest in the contested act is sufficient. This 
need to have a legitimate interest is not necessarily based 
on a legally recognised subjective right. Whether a natural 
person has the interest required to seek judicial review of 
an administrative decision affecting their environment is 
essentially  a  factual  matter,  which  will be judged by the 
Council of State based on the specific circumstances of the 
case. The council will examine whether the claimant will 
be – or may be – affected by the environmental effects of 
the implementation of the decision. 

Costs  might  be  an  obstacle  to  access  to  environmental 
justice  by  ordinary  people  and  NGOs  in  Belgium.  These 
costs  include  court  fees  and  the  risk  of  having  to  pay  a 
judicial allowance as intervention in the lawyers’ fees and 
the costs of the winning party if the case is lost. If these 
costs are not covered by insurance (which can often be the 
case when a private party is suffering damages that can be 
considered  environmental),  a  party  might  often  hesitate 
before launching procedures. 

In  2022,  Belgium  received  two  priority  actions  on  this 
topic:  (i)  set  up  websites  providing  information  on  and 
facilitating  participation  in  EIA  and  SEA  processes  in  the 
Walloon and Brussels Regions (also raised in the 2019 EIR); 
and (ii) record and regularly publish information on levels 
of public participation in EIA and SEA processes, as well as 
on  their  outcomes  and  on  the  extent  to  which  public 
comments were taken into account in the final decision, 
at both the federal and regional levels. 

The  first  priority  action  has  been  resolved,  as  regards 
providing  information  in  the  Walloon (187),  Brussels (188) 
and  Flemish  Regions (189).  But  the  second  priority  action 
has not been addressed. 

2025 priority actions 

• 

Ensure  that  relevant  information  on  EIA  and  SEA 
(including  on  public  participation 
procedures 
opportunities and on publication of final decisions) is 
electronically accessible in a timely manner, through 

(188)  https://environnement.brussels/pro/services-et-

demandes/permis-denvironnement/comment-preparer-votre-
demande-de-permis-denvironnement. 

(189)  https://www.vlaanderen.be/milieueffectrapport-mer. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
a central portal or easily accessible points of access, 
at the appropriate administrative level. 
Provide  information  on  the  average  duration  of  all 
steps in the EIA process. 

• 

Impact 

Assessment 

•  Ratify  the  amendment  to  the  United  Nations 
Economic  Commission  for  Europe  Convention  on 
a 
Environmental 
Transboundary Context and its Protocol on Strategic 
Environmental Assessment. 
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. 

in 

• 

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 (190) 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. 

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

(191)  https://environnement.brussels/citoyen/nos-actions/prevention-

et-inspection/linspection-environnementale. 

(192)  https://environnement.brussels/blog-pro/dossiers/les-coulisses-

de-linspection-environnementale-des-entreprises-
bruxelles,%20https:/environnement.brussels/blog-

Belgium  54 

For  the  Brussels  Region,  websites  provide  guidance  on 
compliance  with  environmental  obligations  to  prevent 
environmental law infringements (191). This makes part of 
a larger inspections plan with eight axes. One of the axes 
is  dedicated  to  compliance  promotion.  The  emphasis  is 
put  on  three  main  areas:  communication  (e.g.  thematic 
the 
campaigns  or  articles  on 
inspection (192)),  supporting  companies  and  developing 
awareness-raising  projects  (e.g.  the  deployment  of 
monitors 
in  shops  to  explain  waste  management 
legislation (193)). 

the  actions  of 

The  Brussels  Region  also  publishes  inspection  plans  and 
programmes, and reports on industrial installations. 

The  2022  EIR  recommended  that  Belgium  (i)  provide 
further information and support to farmers in the Walloon 
Region  via  governmental 
tools  and  websites  on 
compliance with obligations under the Nature  Directives 
and the Nitrates Directive; (ii) publish inspection plans and 
inspection  reports  on  industrial  installations  in  both  the 
Walloon  and  Flemish  Regions;  and  (iii)  develop  online 
systems  and 
information  to  enable  submission  of 
complaints from the public on environmental damages or 
on issues of compliance with environmental legislation in 
the Walloon and Flemish Regions. On the website of the 
Flemish  government,  information  on  complaints  and 
compliance  issues  is  available (194).Moreover,  as  regards 
point (ii), the environmental inspections carried out by the 
Enforcement  Division  since  1 July  2023  are  available 
online (195).  Detailed  information  is  provided  on  the 
company,  location  and  content  of  inspections  using 
specific  codes (196),  as  well  as  on  the  conclusions  of  the 
inspections (197). 

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  2022  priority  action  is  not 
assessed. 

pro/temoignages/les-protecteurs-de-la-foret-de-
soignes?highlight=bentonite. 
(193)  https://environnement.brussels/blog-

pro/temoignages/comment-mieux-trier-dans-les-commerces-
bruxellois. 

(194)  https://omgeving.vlaanderen.be/nl/wegwijzer/ik-wil-

milieuhinder-melden;  https://omgeving.vlaanderen.be/nl/ik-wil-
een-verzoek-indienen-tot-het-opleggen-van-een-bestuurlijke-
maatregel. 

(195)  https://informatie.omgeving.vlaanderen.be/kaart. 
(196)  https://omgeving.vlaanderen.be/sites/default/files/2023-09/Lijst 

actieve codes Website.xlsx. 

(197)  Compliant, not compliant, not applicable or yet to be assessed. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
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)(198) 
and  new  sectoral  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.  Concrete 
provisions on the types and levels of penalties that can be 
imposed  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 
cooperation 
the  establishment  of 
training  and 
mechanisms within and between Member States as well 
as national strategies on combating environmental crime. 

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 
facilitating  the 
will  provide  support, 
identification and sharing good practices. Member States 
are  expected  to  ensure  the  necessary  resources  and 

including  by 

law 

criminal 

(198)  Directive  2024/1203/EU  on  the  protection  of  the  environment 
through 
(https://eur-
lex.europa.eu/eli/dir/2024/1203/oj/eng), 
(199)  https://www.impel.eu/en. 
(200) 

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 

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

Belgium  55 

specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement  practitioners,  such  the  EU  Network  for  the 
Implementation  and  Enforcement  of  Environmental 
Law (199),  EnviCrimeNet (200),  the  European  Network  of 
Prosecutors for the Environment (201) and the EU Forum of 
Judges for the Environment (202). The Europol and Eurojust 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences.  

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)203  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 (204), which will be finalised in 2025, and which 
was  supported  by  an  external  study (205),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

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 

(203) 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). 
(204)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

(205) 
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 – Belgium 

 
 
 
 
 
 
 
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  29 August  2022,  Belgium  reported 
three occurrences of environmental damage: the Flemish 
Region  did  not  identify  any  occurrences,  the  Brussels 
identified  only  one  biodiversity  damage 
Region 
identified  two 
occurrence  and  the  Walloon  Region 
environmental  damage  occurrences,  one  of 
them 
affecting  land,  water  and  biodiversity  and  the  other 
affecting  water.  In  the  previous  reporting  period,  there 
was  only  one  occurrence  of  environmental  damage 
reported under the ELD by Belgium. 

Although neither the federal  government nor any of the 
three  regions  has  imposed  mandatory  financial  security 
for ELD liabilities, there is demand for such instruments in 
Belgium.  Environmental  insurance  policies  that  cover  all 
liabilities  are  widely  available.  Environmental 
ELD 
extensions  to  general  liability  policies  are  available  but 
typically  provide  cover  for  ELD  liabilities  only  if  these 
liabilities  overlap  with  those  under  other  national 
environmental legislation. Such extensions tend to cover 
only the remediation of the off-site land or soil pollution 
from  a  sudden  and  accidental  incident  and  only  rarely 
cover the remediation of biodiversity damage under the 
ELD. 

The 2022 EIR recommended that Belgium develop online 
information  to  enable  submission  of 
systems  and 

(206)  https://omgeving.vlaanderen.be/nl/klimaat-en-

milieu/milieuschade/ik-vermoed-dat-ik-het-slachtoffer-ben-van-
een-milieuschadegeval-wat-nu. 

(207)  https://environnement.wallonie.be/demandes/1886_demander-

l-action-des-autorites-publiques-en-cas-de-dommage-
environnemental.html. 

(208)  https://environnement.wallonie.be/demandes/1887_demander-

une-exoneration-dans-le-cadre-de-la-responsabilite-
environnementale.html. 

(209)  https://environnement.wallonie.be/demandes/1888_demander-

un-remboursement-dans-le-cadre-de-la-responsabilite-
environnementale.html. 

Belgium  56 

complaints from the public on environmental damages or 
on issues of compliance with environmental legislation in 
the Walloon and Flemish Regions. Information is available 
on complaints and compliance in the Flemish Region (206). 
For the Walloon Region, there are online procedures and 
forms enabling citizens to file a complaint in the event of 
damage caused to the environment. 
On  the  Public  Service  of  Wallonia  environment  website, 
procedures  for  the  following  can  be  found  (with  online 
forms and all the necessary information): 

(i)  requesting action by public authorities in the 

event of environmental damage (207); 
(ii)  applying for exemption in the context of the 

ELD (208); 

(iii)  claiming reimbursement under the ELD (209). 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level)  covering  the  ELD  and  its  interaction  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 

initiative 

The  Commission’s  2023  Compact (210) 
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  environment  provided  by 
the European Commission are the TSI (211) and the TAIEX-
EIR  PEER  2  PEER  tool (212).  The  technical  assistance 
available through the cohesion policy is subject to shared 
management and is not dealt with in this subsection. 

(210)  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). 

(211)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-
funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(212)  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 – Belgium 

 
 
 
 
 
 
 
Belgium  57 

The Commission’s technical support instrument  

•  Building 

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 in Belgium: 
• 

environmental  monitoring 

Integrated 
informs 
adaptive management of coastal wetlands; Research 
Institute for Nature and Forest (INBO) (2025); 
Support  for  the  assessment  of  environmentally 
harmful subsidies and for the preparation of national 
biodiversity  plans  in  Belgium,  the  Netherlands  and 
Finland;  Federal  Public  Service  Health,  Food  Chain 
Safety and Environment (two calls 2024); 
Support for the preparation of Social Climate Plans, a 
TSI  2024  multi-country  project  benefiting  nine 
Member States (Belgium, Czechia, Denmark, Croatia, 
Latvia,  Lithuania,  Romania,  Slovakia  and  Finland); 
Walloon  Air  and  Climate  Agency,  Bruxelles 
Environnement,  Vlaamse  Overheid,  Federal  Public 
Service Health, Food Chain Safety  and  Environment, 
Climate Change Service (2024); 

•  Multi-country  support  for  the  revised  EU  ETS,  a  TSI 
2024  project  benefiting  Belgium,  Croatia,  Romania 
and Finland (2024); 
•  GreenReform  model / 

strengthening  Belgium’s 
capacity  to  model  the  macroeconomic  effects  of 
‘green’  policies  and  investments;  Federal  Planning 
Bureau (2024); 
Integration  of  environmental  dimensions  in  public 
finances – implementing the ‘do no significant harm’ 
principle  in  the  public  funding  programme;  Federal 
government:  Cabinet  of  Secretary  of  State  Dermine 
(2023); 

• 

(213) 

flagship multi-country workshops  in the reporting period are: 
Recast  Drinking 
(3  April  2025); 
  Water  Directive 
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 
quality: 
decarbonation 
implementation of the NEC Directive to further mainstream 
air and broader pollution reduction in agricultural policy (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 

(12  December 

2024);  Air 

policy 

for 
coherence 
in  Belgium;  Federal 

sustainable 
for 

• 

Institute 

development 
Sustainable Development (2023); 
Implementation  of  sustainability  frameworks  for 
Belgian national promotional banks and institutions; 
Participatiemaatschappij 
Regional 
Vlaanderen, 
Investment Company of Wallonia (2022); 
Support for the Renovation Wave and one-stop shops 
in  the  Walloon  Region;  Public  Service  of  Wallonia 
TLPE, Direction des Bâtiments Durables (2022); 
•  Recharge  and  refuel –  clean,  smart  and  fair  urban 

• 

mobility; Brussels Mobility (2022); 

•  Recharge  and  refuel –  clean,  smart  and  fair  urban 
mobility; Flemish Department of Mobility and Public 
Works (2022). 

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 
in  all  Member 
legislation  and  policy 
environmental 
States (213).  

Workshops involving Belgium are as follows: 

• 

• 

• 

Climate adaptation and blue infrastructures: 
Examples across European regions (31 May–1 June 
2022); 
Circular procurement (7 June 2022), hosted by the 
Public Service of Wallonia; 
Future challenges in air protection in Europe 
(24 November 2022) with the EU Czech Presidency; 

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:  permitting 
granting  processes    (13  June  2022).  N.B.  the  first  flagship 
workshop on Zero Pollution for Air, Water and Soil, took place 
9 February 2022. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
Belgium  58 

•  Making space for biodiversity: Regional action to 

•  New aspects in the cross-border cooperation against 

mainstream biodiversity and empower stakeholders 
(21–23 March 2023); 

environmental crime (19–20 November 2024) (214). 

•  Biodiversity, nature conservation and large 

2025 priority action 

predators: Examples across European regions (4–
6 June 2024); 

•  Online platforms: EU batteries, packaging and 

packaging waste regulation (28–29 October 2024); 

• 

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

(214)

https://webgate.ec.europa.eu/TMSWebRestrict/resources/j

s/app/#/library/detail/90076?hasBackBtn=false. 

2025 Environmental Implementation Review – Belgium 

 
 
 
 
 
 
 
 
 
 
Belgium  59 

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.  

• 

• 

• 

• 

• 

• 

Waste management 

Further shift reusable and recyclable waste away from incineration, including through economic instruments. 

Improve separate collection at the source e.g. through economic instruments, investing in infrastructure for separate 
collection, sorting and recycling, and increasing public awareness.  

Increase the collection and recycling rate of waste electronic and electric equipment (WEEE).  

Invest in waste prevention measures to reduce the total amount of waste generated. 

Biodiversity and natural capital 

Global and EU biodiversity frameworks 

Submit to the Convention on Biological Diversity an updated NBSAP or national targets following the adoption of the 
Kunming-Montreal Global Biodiversity Framework. 

Nature protection and restoration – Natura 2000 

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.  

Recovery of species 

•  Reinforce  action  for  habitats  and  species  with  unfavourable  conservation  status  through,  for  example,  restoration 

measures, increased connectivity, better policy coordination and integration, and increased funding 

Recovery of ecosystems 

•  Step-up efforts to further reduce nitrogen deposition, in particular in Natura 2000 sites with nitrogen-sensitive species 

and habitats..  

• 

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

• 

Implement and scale up the uptake of organic farming practices.  

Forest ecosystems 

• 

Improve conservation status of forests by promoting sustainable forest management and ensuring compliance with 
the Habitats Directive before granting/renewing permits for forest logging.  

•  Bring levels of nitrogen deposition under the critical threshold to allow forest habitat types protected under the Habitats 

Directive to recover 

Prevention and management of invasive alien species 

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

authorities.  

Zero pollution 

2025 Environmental Implementation Review – Belgium 

 
 
Belgium  60 

•  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.  

Clean air 

•  Reduce industrial air pollution damage and intensity.  

•  Reduce industrial releases to water and their intensity.  

Industrial emissions  

•  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.  

Noise 

•  Complete and implement action plans on noise management.  

Water quality and management  

Water Framework Directive 

• 

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. 

•  Better justify exemptions to the achievement of good status. 

• 

Improve the classification of water bodies and strengthen monitoring systems. 

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

•  Consider future climate scenarios in the FRMPs. 

•  Better explain the choice and implementation of flood prevention and protection measures (prioritisation, monitoring, 

costs of measures).  

Nitrates Directive   

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

Urban Wastewater Treatment Directive   

• 

Take the necessary measures to ensure full implementation of the current urban wastewater treatment directive, taking 
into account the new requirements of the recast directive.  

Chemicals 

•  Upgrade administrative capacities in 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, 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. 

•  Submit the final energy and climate plan (NECP). 

Climate action 

2025 Environmental Implementation Review – Belgium 

 
Belgium  61 

• 

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.  

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. 

Information, public participation and access to justice   

Environmental governance  

•  Ensure that relevant information on EIA and SEA procedures (including on public participation opportunities and on 
the publication of final decisions) is electronically accessible on a timely basis, through at least a central portal or easily 
accessible points of access, at the appropriate administrative level.  

•  Provide information on the average duration of all steps in the EIA process.  
•  Ratify the amendment to the United Nations Economic Commission for Europe Convention on Environmental Impact 

• 

Assessment in a Transboundary Context and its Protocol on Strategic Environmental Assessment.  
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)  and 
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 – Belgium