COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - POLAND 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: EU environmental policy, Poland, 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) 320 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review           Country Report - POLAND                       Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security        {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 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) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
 
 
 
 
 
Poland  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ....................................................................................................... 4 
Transitioning to a circular economy ..................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL .................................................................................................................... 13 
Global and EU biodiversity frameworks ............................................................................................................. 13 
Nature protection and restoration – Natura 2000 ............................................................................................. 13 
Recovery of species ............................................................................................................................................ 15 
Recovery of ecosystems ..................................................................................................................................... 16 
Prevention and management of invasive alien species ...................................................................................... 23 
Ecosystem assessment and accounting ............................................................................................................. 24 
3. ZERO POLLUTION .............................................................................................................................................. 25 
Clean air ............................................................................................................................................................. 25 
Industrial emissions ............................................................................................................................................ 26 
Major industrial accidents prevention – Seveso ................................................................................................. 29 
Mercury Regulation ............................................................................................................................................ 30 
Noise .................................................................................................................................................................. 30 
Water quality and management ........................................................................................................................ 31 
Chemicals ........................................................................................................................................................... 36 
4. CLIMATE ACTION .............................................................................................................................................. 39 
The EU emissions trading system ....................................................................................................................... 39 
Effort sharing ..................................................................................................................................................... 40 
Land use, land-use change and forestry ............................................................................................................. 41 
Adaptation to climate change ............................................................................................................................ 41 

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

5. FINANCING ...................................................................................................................................................... 43 
Climate finance landmarks ................................................................................................................................. 43 
Environmental financing and investments ......................................................................................................... 43 
Public financial management ............................................................................................................................. 48 
6. ENVIRONMENTAL GOVERNANCE ........................................................................................................................... 51 
Information, public participation and access to justice...................................................................................... 51 
Compliance assurance ........................................................................................................................................ 54 
EU-supported environmental capacity building ................................................................................................. 57 

2025 Environmental Implementation Review – Poland 

 
 
 
 
 
 
 
 
 
Poland  3 

Executive summary

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

environmental 

regarding 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
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  Poland,  some  challenges  have 
lingered  since  the  first  EIR  in  2017  and  require  urgent 
action. 

Despite substantial progress overall, air quality continues 
to  be  a  cause  for  concern  in  some  parts  of  Poland’s 
territory.  Exceedances  of  the  limit  values  for  nitrogen 
dioxide (NO2) persisted in the Wroclaw, Cracow, Warsaw 
and Katowice agglomerations, and for particulate matter 
with a diameter of 10 µm or less (PM10) in Dolny Slask and 
Malopolska  regions.  Furthermore,  the  target  values  for 
ozone concentration have not been met in one air quality 
zone, 
two  air  quality  zones  and 
benzo(a)pyrene  in  twenty-one  air  quality  zones.  The 
Commission remains  concerned by the pace of  changes, 
particularly  with  regard  to  replacing  outdated  solid  fuel 
boilers and measures focusing on the transport sector. 

for  arsenic 

in 

Although some progress has been made regarding waste 
management, Poland is at risk of missing both the target 
of  55 %  for  preparing  municipal  waste  for  reuse  and 
recycling,  and  the  target  of  65 %  for  packaging  waste 
recycling set out in the Waste Framework Directive. With 

(1) 

from 

the  Commission 

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

to 

a landfill rate of 38 % in 2022, the country is also at risk of 
not meeting the 2035 target of landfilling a maximum of 
10 %  of  municipal  waste.  Moreover,  Poland  still  has  not 
closed and rehabilitated some municipal landfills that do 
not comply with the requirements of the Landfill Directive. 

Despite  significant  investment,  including  projects  co-
financed by EU funds, Poland missed the final deadline for 
complying  with  the  Urban  Wastewater  Treatment 
Directive  in  2015.  Over  1 000  agglomerations  are  non-
compliant  and  require  further  action  and  investment  in 
infrastructure. 

The  overall  environmental  investment  needs  to  enable 
Poland  to  meet  its  objectives  in  the  areas  of  pollution 
prevention  and  control,  circular  economy  and  waste, 
water protection and management, and biodiversity and 
ecosystems are estimated to be EUR 20.8 billion per year. 
The  current  investment  gap  stands  at  an  estimated 
EUR 8 billion  per  year  in  Poland.  This  represents  around 
1.22 %  of  the  national  gross  domestic  product,  which  is 
higher than the EU average (0.77 %). 

On  environmental  governance,  Poland  needs  to  ensure 
access  to  justice  beyond  individual  decisions.  Polish  law 
does  not  provide  a  mechanism  for  non-governmental 
organisations  or 
individuals  to  challenge  plans  or 
programmes  adopted  as  regulations  (rozporządzenie), 
such as river basin management plans. Similarly, access to 
a review procedure for plans or programmes adopted as 
local acts, such as air quality plans, is limited. The public 
should  also  be  better  informed  about  their  access  to 
justice rights. 

On  a  positive  note,  Poland  has  achieved  a  noticeable 
reduction  in  the  consumption  of  plastic  carrier  bags  per 
capita – from 23 in 2019 to only 6.6 in 2022, which is the 
second-best result in the EU.  

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Poland since 2005, while GDP growth has 
reduction 
continued.  Poland  meets 
commitments for 2020-2029  for air  pollutants NOx, non-
methane  volatile  organic  compounds  (NMVOC),  sulphur 
dioxide (SO2), ammonia (NH3) and PM2.5. The country also 
projects to meet its emission reduction commitments for 
2030 onwards for NOx, NMVOC, SO2, NH3 and PM2.5.     

its  emission 

implementation  review,  COM(2016) 316 
environmental 
final  of  27 May  2016,  http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Poland  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 resource consumption. A circular economy 
has  considerable  potential  to  increase  competitiveness 
and  job  creation  and  will  also  promote  innovation  and 
provide  access  to  new  markets.  With  the  2020  circular 
economy action plan (CEAP) (2) measures either in place 
or  legislatively  advanced,  EU  Member  States  will  now 
have to focus on a swift and effective implementation. 

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

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

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

Poland’s  CMUR  was  7.5 %  in  2023,  showing  a  slight 
increase following a gradual decline since 2014. This puts 
Poland’s rate below the EU average of 11.8 % (Figure 1). 

(2) 

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

15

10

5

0

2013

2015

2017

2019

2021

2023

Poland

EU-27

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

10 December 

2024, 

product 

Improving 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic 
resource 
(GDP). 
productivity  can  help  to  minimise  negative  impacts  on 
the environment and reduce dependency on volatile raw 
material  markets.  As  shown 
in  Figure 2,  Poland 
generated  EUR 0.86  per  kg  of  material  consumed  in 
2023,  which  puts  the  country’s  resource  productivity 
below the EU average of EUR 2.23 per kg. 

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

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Poland

EU-27

NB:  The  unit  of  measurement  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 
7 August 
2024, 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

10 December 

accessed 

2024, 

final 

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

11 March 

2020, 

of 

https://eur-

2025 Environmental Implementation Review – Poland 

 
 
 
 
Policies and measures 

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

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

In 2019, Poland adopted a roadmap for the transition to 
a  circular  economy (5),  which  focuses  on  four  areas  of 
action:  sustainable  industrial  production,  sustainable 
consumption, bioeconomy and new business models. 

The roadmap provides a set of tools aiming to create the 
conditions  for  the  implementation  of  a  new  economic 
model  in  Poland.  The  actions  included  mainly  concern 
analytical  and  conceptual  work, 
information  and 
promotion,  as  well  as  coordination  in  areas  within  the 
competence of individual ministries. 

The implementation of the roadmap has been slow, but 
include  the  establishment  of  a 
the  first  actions 
government  information  platform  for  circular  economy 
and the establishment of a system of indicators assessing 
the  progress  of  the  transition  to  such  an  economy.  As 
part of Poland’s national recovery and resilience plan (6), 
the  competent  ministry  is  working  on  a  secondary  raw 
materials platform based on end-of-waste legislation. 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
consumption,  with  public  authorities’ 
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. 

‘Proximity  and 

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

Stakeholder 

Economy 

Platform 

(3) 

(4) 

(5) 
(6)

Poland  5 

Poland  adopted  its  first  national  action  plan  on  green 
public procurement (GPP) for 2007–2009, followed by a 
national action plan on sustainable public procurement 
for  2010–2012,  2013–2016  and  2017–2020.  Currently, 
sustainable public procurement (also encompassing GPP) 
is mentioned as one of the top priorities under the state 
purchasing  policy  for  2022–2025,  a  strategic  document 
adopted by the Council of Ministers in January 2022. The 
state  purchasing  policy  is  addressed  to  government 
administration units to include, in particular, green and 
social aspects in their tendering process. No criteria have 
been  developed  at  the  national  level.  However,  the 
the  overall 
Public  Procurement  Office  promotes 
application of the EU GPP criteria  on a  voluntary basis. 
Monitoring  is  based  on  the  analysis  of  information 
delivered  by  contracting  authorities  in  their  annual 
reports on contracts awarded. On that basis, a report on 
the  functioning  of  the  public  procurement  system  is 
prepared annually. 

In January 2022, the Public Procurement Office published 
on its website guidance on the GPP-related provisions (7). 
More recent deliverables include guidance on the use of 
solutions within public contracts to counter the impact of 
the individual components of construction investments 
on the environment (8). 

EU Ecolabel and the eco-management and audit 
scheme 

The  number  of  EU  Ecolabel  product  groups  and  the 
number of eco-management and audit scheme (EMAS)-
licensed  organisations  in  each  country  provide  some 
indication of the extent to which the private sector and 
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 
is  a  voluntary 
environmental  performance.  EMAS 
environment  management  scheme  aimed  at  reducing 
the environmental impacts of organisations. 

As of September 2024, 4 053 out of 98 977 products and 
67 out of 2 983 licences in Poland were registered under 
the  EU  Ecolabel  scheme,  showing  the  good  take-up  of 
products  and  in  particular  of  paints  and  varnishes (9). 
Moreover,  70  organisations  from  Poland  are  currently 

Przewodnik dot. zielonych zamówień publicznych. 

(7) 
(8)  Wskazówki dot. rozwiązań przeciwdziałających oddziaływaniu na 

(9) 

środowisko. 
European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
website, 
http://ec.europa.eu/environment/ecolabel/facts-and-
figures.html. 

https://www.funduszeeuropejskie.gov.pl/media/109762/K

PO.pdf. 

2025 Environmental Implementation Review – Poland 

 
 
 
registered in the European Commission’s EMAS, 3 more 
than in October 2021 (10). 

includes 
option,  disposal 
incineration without energy recovery). 

(which 

landfilling  and 

Poland  6 

While  the  priority  action  from  2019  has  been  fulfilled 
through the adoption of a circular economy roadmap, its 
implementation has been slow, in large part due to the 
impacts of the COVID-19 pandemic. 

Poland’s  CMUR  increased  by  0.8 percentage  points  in 
2023.  This  indicates  some  progress  towards  the  2022 
priority action to take measures to increase the rate. 

2025 priority actions 

•  Adopt measures to increase the CMUR. 
• 

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

Waste management 

Turning waste into a resource is supported by: 

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

— 

—  reducing  waste  generation  per  capita  and 

in 

— 

— 

absolute terms; 
increasing  the  recycling  rates  of  waste  containing 
critical raw materials (CRM), 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 

—  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

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

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. 

In  general,  over  the  last  12 years,  Poland’s  total  waste 
generation has increased, driven primarily by the largest 
waste  category,  ‘other  mineral  wastes’ (11)  (Figure 3). 
Waste generation increased considerably until 2016 and 
started to slowly decline in the following years. This was 
largely due to a reduction in mineral waste from mining 
and quarrying, following the closure of several mines and 
industry.  While  the 
other  changes 
generation  of 
the 
generation  of  two  other  waste  categories –  mixed  and 
recyclable waste – significantly increased. Poland’s GDP 
has increased since 2010, with a drop in 2020, most likely 
due  to  the  COVID-19  outbreak.  Since  2016,  waste 
generation has decoupled from economic growth. 

in  the  mining 
combustion  waste  declined, 

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

accessed 

income)’, 

15 October 

nama_10_gdp, 

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

30 September 

22 October 

accessed 

2024, 

Critical raw materials 

In 2022, Poland adopted its 2050 national raw materials 
policy (12),  which  identifies  strategic  and  critical  raw 
materials  for  the  national  economy,  describes  the 
demand  for  raw  materials  and  indicates  the  actions 

(10) 

European  Commission,  ‘Eco-management  and  audit  scheme 
(EMAS)’,  European  Commission  website,  November  2021, 
http://ec.europa.eu/environment/emas/emas_registrations/st
atistics_graphs_en.htm. 

(11) 
(12) 

‘Other mineral waste’ is part of the ‘mineral waste’ category. 
https://www.gov.pl/web/klimat/polityka-surowcowa-panstwa. 

2025 Environmental Implementation Review – Poland 

 
 
 
Poland  7 

reuse  and  recycling  compared  with  incineration  and 
landfilling. If available technology were to be applied, it 
is estimated that the increase in preparing for reuse and 
recycling  would  lead  to  an  additional  33 Mt  of  GHG 
emission  savings  annually  (more  than  the  combined 
annual  GHG  emissions 
from  Estonia,  Latvia  and 
Luxembourg). 

The rate of recycling and preparing for reuse of mineral 
construction and demolition waste in Poland was 34.1 % 
in  2022,  compared  with  the  EU  average  of  79.8 %. 
Measures  to  further  increase  the  rate  of  recycling  and 
preparation  for  reuse  of  construction  and  demolition 
waste  include  separating  collection  at  the  source –  for 
instance,  through  digitalised  pre-demolition  audits (14) 
(‘resource  assessments’)  and  extended  producer 
responsibility  (EPR)  and  other  economic  instruments. 
Upstream  measures  such  as  increasing  the  recycled 
content  of  construction  products  and  the  circular 
design (15) of construction works can also be beneficial. 

introduced  obligations  concerning  the 
Poland  has 
separate  collection  of  construction  and  demolition 
waste, which entered into force on 1 January 2025. Such 
waste needs to be divided into six fractions (16). 

Boosting 
Warning Report 

implementation –  the  2023  Waste  Early 

This  section  focuses  on  the  management  of  municipal 
waste (17),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste Early Warning Report (18) identifying the general 
trends in waste management and the Member States at 
risk of missing 2025 waste targets (see Figure 4). Poland 
is  at  risk  of  missing  both  the  municipal  waste  and  the 
packaging  waste  targets.  Poland  is  also  at  risk  of  not 
meeting  the  2035  target  of  a  maximum  of  10 %  of 
municipal waste being landfilled (19). 

needed  to  ensure  secure  access  to  such  materials. 
Specific  objectives  of  that  policy  include  acquiring  raw 
materials  from  anthropogenic  deposits  and  supporting 
the development of the circular economy, by: 

• 

• 

• 

from  waste,  with 

preparing an inventory of mining waste landfills and 
assessing the potential for their use; 
developing  a  knowledge  base  on  sources  of  raw 
their  proper 
materials 
classification  and  indication  of  directions  of  their 
use; 
adopting  measures  to  develop  processes  for  the 
recovery of raw materials from waste (in particular, 
strategies and CRMs), including the development of 
processing technology for such waste. 

Poland’s  2028  national  waste  prevention  programme 
(NWPP)  also  lists  two specific  actions concerning CRMs 
that should be implemented by 2028: 

• 

• 

promotion  of  eco-design,  in  particular  focused  on 
extending the lifetime of products containing CRMs, 
and  replacing  CRMs,  where  possible,  with  more 
available materials; 
support  for  research  and  development  projects 
focused  on  recycling  of  CRMs  from  waste  from 
which CRMs had not yet been recovered. 

So  far,  Poland  has  not  adopted  national  legislation 
encouraging  the  use  of  secondary  CRMs,  but  it  has 
legislation – 
adopted 
requiring separate collection of waste containing CRMs. 

laws –  transposing  EU  waste 

Construction and demolition waste 

Construction and demolition waste accounts for almost 
40 %  of  all  waste  generated  in  the  EU. A  recent  study 
(13) by the Joint Research Centre shows that preparing for 
reuse  and  recycling  operations  are  preferred  over 
landfilling  from  an  environmental 
incineration  and 
perspective  for  most  of  the  different  streams  of 
construction  and  demolition  waste.  However,  the 
economics  are  often  unfavourable  for  preparing  for 

(13) 

(14) 

(15) 

the 

European 

Luxembourg, 

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

for 
2020, 

Luxembourg, 

Brussels, 

design, 

Chapter 6a of the Polish Waste Act. 

(16) 
(17)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected  waste 
including  paper  and 
from  households, 
cardboard,  glass,  metals,  plastics,  biowaste,  wood,  textiles, 
packaging  waste,  electrical  and  electronic  equipment,  waste 
batteries  and  accumulators,  and  bulky  waste, 
including 
mattresses  and  furniture;  and  (ii)  mixed  waste  and  separately 
collected waste from other sources, where such waste is similar 
in nature and composition to waste from households (Directive 
2008/98/EC, Article 3.2b). 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 
European Environment Agency (EEA), Circular Economy Country 
Profile – Poland, 2022, https://www.eionet.europa.eu/etcs/etc-
ce/products/etc-ce-reports-2022-5-circular-economy-country-
profiles-a-set-of-30-country-profiles-that-summarise-policies-
and-initiatives-in-the-area-of-circular-economy. 

(18) 

(19) 

2025 Environmental Implementation Review – Poland 

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

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

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

Member States at risk of missing both targets 

Outside coverage 

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

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

In  December  2023,  Poland  notified  its  intention  to 
postpone  the  deadline  for  meeting  the  2025  target  for 
municipal  waste  for  five  years.  According  to  the 
implementation  plan  that  Poland  submitted  to  the 
European  Commission,  setting  out  the  measures 

(20) Commission Decision C(2024) 1810. 
(21) Directive 2008/98/EC of the European Parliament and of the Council 
of  19  November  2008  on  waste  and  repealing  certain  Directives, 
Directive - 2008/98 - EN - Waste framework directive - EUR-Lex. 
(22)  European  Parliament  and  Council  Directive  94/62/EC  of  20 
December  1994  on  packaging  and  packaging  waste  (OJ  L  365, 
31/12/1994, p. 10–23), Directive - 94/62 - EN - EUR-Lex.  

Poland  8 

(2023), 

include 

necessary  to  attain  the  target  within  a  prolonged  time 
frame 
the 
the  main  measures 
construction  and  modernisation  of  municipal  waste 
treatment facilities and the assessment of the weight of 
biowaste  separated  and  recycled  at  the  source.  The 
Commission  found  that  the  plan  submitted  does  not 
comply  with  the  requirements  set  out  in  the  relevant 
waste legislation (20). 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission is, on the one hand, working together with 
the national authorities and stakeholders to speed up the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (21), the Packaging and 
Packaging  Waste  Directive  (22)  and  the  Directive  on 
Waste Electrical and Electronic Equipment (23). 

Municipal waste 

in  Poland 

increased 
Municipal  waste  generation 
between 2010 and 2022 (Figure 5). In 2022, the country 
generated 364 kg of municipal waste per capita, which is 
significantly below the estimated EU-27 average of 515 
kg per capita in the same year. 

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

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

22 October 

accessed 

(23)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  Directive  - 
2012/19  -  EN  -  EUR-Lexhttps://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32012L0019. 

2025 Environmental Implementation Review – Poland 

 
 
 
 
 
 
 
 
Poland  9 

indicate rates of recycling and preparing for reuse of 10 
and  20  percentage  points  below  the  data  shown  in 
Figure 6 for reference years 2021 and 2022, respectively. 
The  2022  data  are  still  awaiting  final  validation  by 
Eurostat. 

In  2023,  the  Commission  opened  an 
infringement 
procedure  against  Poland  for  failure  to  transpose  the 
Waste Framework Directive (24) into Polish law, including 
as regards provisions on EPR. Another case was opened 
in 2024 because Poland did not comply with the waste 
targets  and  collection  rates  set  out  in  the  Waste 
Framework  Directive  and  the  Waste  Electrical  and 
Electronic Equipment Directive (25). 
Previously,  the  Commission  also  called  on  Poland  to 
comply  with  the  EU  rules  on  landfills  by  ensuring  the 
definitive  closure  and  rehabilitation  of  non-compliant 
municipal  landfills (26).  Two  out  of  original  five  landfills 
covered by the infringement remain uncompliant. 

Packaging waste 

Poland’s  packaging  waste  generation  has  significantly 
increased  since  2010  (Figure 7).  In  2019,  the  country 
generated 172 kg of packaging waste per capita, which is 
close to the estimated EU-27 average of 177 kg per capita 
in the same year (27). The data reported do not include 
estimates for online sales, private imports/exports, the 
de minimis rule or free riding (28). However, measures to 
prevent  free  riding  have  been  applied,  and  since  2019 
information on packaging put on the market has had to 
be  reported  through  an  electronic  registry  (Waste 
Database)  by  all  entities  regardless  of  the  amount  of 
packaging products placed on the market (29). 

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

NB: There is a break in the time series in 2013 and 2014; values for years 
2010–2017  are  estimates.  As  of  reference  year  2020,  new  reporting 
rules applied for calculating recycled municipal waste pursuant to the 
targets set out in Article 11.2c–e of Directive 2008/98/EC. Poland has 
implemented the new reporting rules; however, data corresponding to 
these rules are submitted separately to the European Commission and 
are not shown in the figure. 

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

22 October 

accessed 

Since  the  period  of  stagnation,  the  municipal  waste 
recycling  rate  (including  preparing  for  reuse)  in  Poland 
increased  significantly  (Figure 6).  In  2022,  the 
has 
municipal waste recycling rate was 41 %, which is slightly 
below the estimated EU-27 average of 49 % in the same 
year. 

Rates of composting and anaerobic digestion remain low 
in Poland but have been slowly increasing in recent years, 
reaching  14 % 
in  2022,  due  to  the  widespread 
introduction  of  separate  collection  of  biowaste. 
However,  there  is  still  a  need  for  improvement  in  this 
field.  Municipal  waste  incineration  has  increased  over 
time  and  reached  the  level  of  21 %  of  the  municipal 
waste  generated 
in  2022.  At  the  same  time,  the 
landfilling rate significantly decreased to 38 % (Figure 6). 
The data shown in Figure 6 differ from the data reported 
by  the  Polish  authorities  to  show  compliance  with  the 
target for recycling and preparing for reuse of 55 % for 
2025,  as  set  out  in  the  Waste  Framework  Directive. 
Provisional  data  reported  in  response  to  the  target 

(24) 

(25) 

(26)

(27) 

https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008L0098-20180705. 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32012L0019. 

(28) 

(29) 

https://ec.europa.eu/commission/presscorner/detail/en/in

f_22_1769?msclkid=240d7077c24b11eca3f8b0c6ba5a4f12. 
The EU average might have been influenced by not all Member 
States fully applying the reporting rules for packaging waste set 
out in Commission Implementing Decision (EU) 2019/665. 

Eurostat,  Quality  check  report  according  to  Art. 10(3b)  of  the 
Packaging  and  Packaging  Waste  Directive  for  Poland  for  the 
reference year 2019, 2021. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
packaging  waste – 
https://www.eea.europa.eu/publications/many-eu-member-
states/poland/view. 

Poland, 

and 

2025 Environmental Implementation Review – Poland 

 
 
 
 
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__cus
tom_842634/default/table?lang=en. 

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

NB: No data are available  for 2020, 2021 or 2022. Data for steel and 
aluminium packaging separately is not available for 2011 and for 2014-
2017.  As  of  reference  year  2020,  the  rules  for  calculating  recycled 
packaging waste changed, pursuant to Article 6a of Directive 94/62/EC. 
These  new  reporting  rules  have  been  implemented  in  Poland  since 
reference year 2022 (Ministry of Climate and Environment, Information 
provided during the Eionet review of the draft EEA country profile on 
waste management for Poland, 2024). 

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

For packaging waste, the latest available data refer to the 
reference year 2020 and indicate a need to speed up the 

Poland  10 

recycling of total packaging and plastic packaging, as the 
2025 target for packaging waste recycling is 65 %. 

However, Poland’s overall packaging waste recycling rate 
significantly increased between 2010 and 2019 and was 
56 %  in  2019  (Figure 8).  The  overall  packaging  waste 
recycling  rate  is  mainly  driven  by  paper  and  cardboard 
packaging  waste  and  glass  packaging  waste,  as  these 
constitute  the  largest  share  of  all  packaging  waste 
generated  and  have  the  highest  recycling  rates.  The 
recycling  rates  for  paper  and  cardboard  and  glass 
packaging  waste  have  increased  in  recent  years,  and 
were in 2019 at the levels of 80 % and 67 %, respectively. 
Steel packaging waste had the highest reported recycling 
rate in 2019 (100 %), but since it constitutes a very small 
share of packaging waste, the contribution to the overall 
packaging waste recycling rate is limited. 

Policies to encourage waste prevention 

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

Poland’s 2028 national waste management plan (NWMP) 
was  published  in  July  2023.  The  objectives  and  tasks 
presented in the 2028 NWMP relate to 2023–2028 and 
prospectively  to  2035 (30).  Poland’s  2028  NWPP 
is 
integrated in its 2028 NWMP. 

The  Polish  waste  prevention  objectives  focus  on  the 
development  of  reuse  (especially  of  electrical  and 
electronic  equipment  and  parts 
from  end-of-life 
vehicles), the use of fewer raw materials and less energy 
in general, and a shift towards the use of recyclable raw 
materials  and  renewable  energy  sources.  The  NWPP 
identifies  the  following  priority  waste  streams:  food 
waste,  packaging  waste,  mining  waste,  waste  from  the 
sector,  waste  electrical  and  electronic 
energy 
equipment,  and  end-of-life  vehicles.  The  programme 
does not include a specific implementation budget (31). 

In  the  NWPP,  qualitative  and  quantitative  indicators 
were  defined  to  monitor  and  evaluate  the  progress  of 
implementation of the waste prevention measures. The 
values of the indicators will be calculated for subsequent 
years  in  three-year  periods  as  part  of  reports  on  the 
implementation of the NWMP 2028 (Chapter 8). 

(30) 

https://bip.mos.gov.pl/strategie-plany-programy/krajowy-plan-
gospodarki-odpadami/uchwala-nr-96-rady-ministrow-z-dnia-
12-czerwca-2023-r-w-sprawie-krajowego-planu-gospodarki-
odpadami-2028/. 

(31) 

EEA,  Waste  Prevention  Country  Profile –  Poland,  2023, 
https://www.eea.europa.eu/themes/waste/waste-
prevention/countries/2023-waste-prevention-country-fact-
sheets/poland_waste_prevention_2023. 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Information  and  education  campaigns  on  waste 
prevention have been carried out by several institutions, 
including the Ministry of Climate and Environment, the 
Ministry of Agriculture and Rural Development, the Chief 
Inspectorate  for  Environmental  Protection  and  the 
Federation of Polish Food Banks. 

Policies to encourage separate collection and recycling 

Currently,  Poland  has  a  mandatory  pay-as-you-throw 
system in place, but it is targeted only at non-household 
sources  of  municipal  waste.  The  EPR  system  covers  all 
packaging  waste  fractions  from  both  households  and 
non-household  sources,  but  there  is  no  system  of 
advanced  fee  modulation  in  place  to  discourage  the 
inclusion  of  difficult-to-recycle  plastic 
types  or 
combinations of materials. 

is  the  second-best  result 

Poland  has  a  tax  on  plastic  carrier  bags  and  fees  for 
single-use  plastic  products.  Poland  has  achieved  a 
noticeable  reduction  in  the  consumption  of  plastic 
carrier bags per capita – from 23 in  2019 to only 6.6 in 
in  EU (32). 
2022,  which 
Currently,  there  is  a  voluntary  deposit  return  system 
covering  some  specific  glass  drink  bottles  run  by  the 
largest  Polish  breweries,  and  some  deposit  return 
systems  for  plastic  bottles  run  by  major  grocery  store 
chains (33).  Provisions  for  the  operation  of  the  deposit 
return system were adopted in 2023 and were supposed 
to apply from 1 January 2025. However, the application 
of  this  obligation  was  postponed;  the  system  is  now 
expected  to  become  operational  in  October  2025 (34). 
The system will cover plastic bottles up to 3 l, metal cans 
up to 1 l and returnable glass bottles up to 1.5 l. 

Policies to discourage landfilling or incineration 

Poland has a landfill tax of PLN 270/t (EUR 60/t). There is 
a reduced landfill tax for mechanical biological treatment 
outputs that meet certain conditions. The landfill tax is 
considerably higher than the EU-27 average. Poland has 
collected 
banned 
biodegradable  waste  in  2013.  In  addition,  since  2016, 
there has been a ban in place on combustible waste with 
a total organic carbon content above 5 %, loss of ignition 
value  above  8 %  and  calorific  value  exceeding 
6 MJ/kg (35). 

landfilling  of 

separately 

the 

Poland has no incineration tax in place and there is no tax 
on  waste  exported  for  incineration.  However,  waste 

Poland  11 

incineration  plants  have  to  pay  environmental  fees  for 
gas and dust emissions. 

to  meet 

In the 2022 EIR, Poland had six priority actions in the field 
of  waste.  Poland  has  made  no  progress  in  introducing 
incineration  fees  to  make  recycling  more  economically 
attractive,  or  in  providing  municipalities  with  technical 
assistance 
implementation  and 
their 
enforcement  obligations.  Some  progress  was  made  in 
avoiding the construction of new infrastructure for waste 
incineration,  as  well  as  in  the  rehabilitation  of  non-
compliant  landfills.  Poland  made  some  progress  in  the 
enforcement  of  waste  legislation  and  improving  the 
functioning of EPR schemes, although the changes in the 
national law on EPR still  do not correctly transpose the 
EU law in that respect. Work is ongoing on improving EPR 
for  packaging  waste.  Poland  has  also  made  substantial 
progress  in  ensuring  a  national  waste  management 
policy  that  is  in  line  with  revised  Waste  Framework 
Directive is in place. 

2025 priority actions 

• 
• 

• 

• 

• 

• 

• 

Complete the closure of non-compliant landfills. 
Invest in waste prevention measures to reduce the 
total amount of waste generated. 
Improve municipal waste preparation for reuse and 
recycling. 
Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps of the waste hierarchy. In particular, improve 
collection  and 
increase  treatment  capacity  for 
biowaste. 
Improve  separate  collection  at  the  source  (e.g. 
through  using  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. 
Extend 
to  all 
households, and fully introduce cost coverage rules 
as part of EPR for packaging. 

the  pay-as-you-throw 

system 

•  Develop  EPR  schemes  for  problematic  waste  and 

• 

introduce fee modulation. 
Ensure the achievement of the 2025 waste targets, 
following  the  recommendations  made  by  the 
Commission  in  the  early  warning  reports  where 
applicable. 

•  Ratify the Hong Kong Convention on Ship Recycling. 

(32)

(33) 

https://ec.europa.eu/eurostat/databrowser/view/env_was

pcb/default/table?lang=en. 
https://www.portalspozywczy.pl/handel/wiadomosci/lidl-
biedronka-kaufland-i-zabka-testuja-to-co-od-2025-r-bedzie-
obowiazkiem,246048.html. 

(34) 
(35) 

https://www.gov.pl/web/klimat/system-kaucyjny. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
2022, 
packaging  waste – 
municipal 
https://www.eea.europa.eu/publications/many-eu-member-
states/poland/view. 

Poland, 

and 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Poland  12 

Environmental Implementation Review 2025 – Poland 

 
 
 
 
2. Biodiversity and natural capital

Poland  13 

Global and EU biodiversity frameworks

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

The EU biodiversity strategy for 2030 (BDS) aims to put 
EU  biodiversity  on  a  path  to  recovery  by  2030.  It  sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
as  measures 
and 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (36)  and  a  dashboard  of  indicators (37) 
provide information on implementation progress. 

implementation 

enable 

to 

recently 

adopted 

The 
EU  Nature  Restoration 
Regulation (38) is the first continent-wide, comprehensive 
law of its kind and a key instrument for the EU to deliver 
on the global biodiversity targets for 2030. It lays down 
an overarching objective at the EU level to put in place 
effective  restoration  measures  on  20 %  of  EU  land  and 
sea by 2030 and for all ecosystems in need of restoration 
by  2050.  To  achieve  this,  it  sets  binding  targets  for 
Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

The BDS is the main instrument used by the EU to deliver 
on  its  obligation  under  the  GBF.  The  Commission  has 
submitted to the Convention on Biological Diversity CBD 
its report on GBF-aligned EU targets that stem from the 
BDS  and  from  other  policy  instruments  under  the 
European Green Deal. 

(36) 

(37) 

(38) 

Actions 

Tracker 

Strategy 

Strategy 

Biodiversity 

Biodiversity 

EU 
(https://dopa.jrc.ec.europa.eu/kcbd/actions-tracker/). 
EU 
(https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1). 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024);  see 
law 
also 

the  Commission  web  page  on 

Dashboard 

the 

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 

Poland  last  updated  its  biodiversity  strategy  in  2015.  It 
has  not  yet  submitted  to  the  Convention  on  Biological 
Diversity an updated NBSAP or national targets following 
the adoption of the GBF. 

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 
Poland, see Chapter 5. 

Nature protection and restoration – Natura 
2000 

Natura  2000 (39),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (40); 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 

(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

(39)  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. An SAC is an SCI designated by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 

(40) 

Environmental Implementation Review 2025 – Poland 

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

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

Poland  14 

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. 

Poland  hosts  81  habitat  types (41)  and  176  species (42) 
covered by the Habitats Directive. The country also hosts 
populations of 105 bird taxa listed in Annex I to the Birds 
Directive (43). 

As  shown  in  the  Figure 9,  in  2023,  19.6 %  of  the  land 
territory of Poland was covered by Natura 2000 sites (EU 
average: 18.6 %), with special protection areas classified 
under  the  Birds  Directive  covering  15.5 %  (EU  average: 
12.8 %)  and  SCIs  under  the  Habitats  Directive  covering 
11 % (EU average: 14.3 %) of Poland’s territory. 

insufficiencies 

The assessment of the SCIs of the Natura 2000 network 
shows  that  there  are  still  some 
in 
designating  SCIs  and  Poland  still  has  to  complete  its 
Natura 2000 network. Furthermore, some data reported 
to  the  Commission  are  incorrect.  The  Commission  has 
taken legal action to address these gaps by opening an 
infringement case and is closely monitoring progress in 
this case. 

Taking Natura 2000 sites and other nationally designated 
protected  areas  into  account,  Poland  legally  protects 
39.6 %  of  its  terrestrial  areas  (EU  average:  26.1 %)  and 
21.9 %  of  its  marine  areas  (EU  average:  12.3 %) (44). 
Poland  strictly  protects  approximately  1.5 %  of 
its 
territory  (combined  area  of  national  parks  and  nature 
reserves). 

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

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

In order to ensure that SCIs contribute to the objectives 
of the Habitats Directive, Member States must designate 
them  as  SACs,  setting  site-specific  conservation 
objectives based on the ecological needs of the species 
and  habitats  present  on  the  sites.  The  site-specific 
conservation  objectives  must  be  defined  in  terms  of 
attributes  and  targets  that  cover  the  properties  of  the 
feature  of  interest  that  are  necessary  to  describe  its 
condition  as  either  favourable  or  unfavourable.  These 
objectives  must  address  the  key  pressures  and  threats 
present  on  the  site.  Article 6  of  the  Habitats  Directive 
requires  Member  States  to  establish  and  implement 
conservation  measures  for  the  realisation  of  the 
objectives of the site. 

The  six-year  deadline  set  by  the  Habitats  Directive  to 
designate  SCIs  as  SACs  and  decide  on  appropriate 
conservation  objectives  and  measures  has  expired  for 
most of the 868 sites in Poland. 

Since Poland had not designated all SCIs as SACs and had 
not  establish  conservation  objectives  and  conservation 
measures  of  sufficient  quality  for  many  SCIs  within  the 
six-year  deadline  set  in  the  Habitats  Directive,  in  June 
infringement 
2021 

the  Commission 

initiated  an 

(43) 

(44) 

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/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
Eurostat  dataset env_bio4, protected area percentage for 2022, 
accessed 
2022, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/de
fault/table?lang=en. 

March 

(41) 

(42) 

European Environment Agency (EEA), ‘Number of habitats and 
species per Member State’, Article 17 dashboard, Annex I total, 
2019, 
19 December 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
2019, 
Article 17 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 

19 December 

dashboard, 

2025 Environmental Implementation Review – Poland 

 
 
 
procedure.  In  November  2023,  Poland  informed  the 
Commission that the designation of all SACs for which the 
six-year  deadline  had  expired  was  completed.  Not  all 
these sites, however, have management plans in place, 
which means that conservation objectives and measures 
are  still  missing  for  the  sites  without  plans.  The 
Commission  continues  to  monitor  the  adoption  of  the 
conservation objectives and measures. Poland’s progress 
remains  insufficient,  and  the  country  must  step  up  its 
actions to protect and manage its Natura 2000 network. 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (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  2019  to  2024,  is  due  for 
submission  in  July  2025.  Figures 10  and  11  show  the 
latest available conservation status data. 

According  to  the  latest  available  report  submitted  by 
Poland,  for  2013–2018,  20 %  of  assessments  in  2018 
showed  habitats  had  a  good  conservation  status  (the 
same as in the previous reporting period, 2007–2012). As 
for protected species, 37.74 % of assessments showed a 
good conservation status in 2013–2018 (compared with 
in  2007–2012).  Concerning  birds,  18 %  of 
31.99 % 
breeding  species  showed  short-term  increases,  while 

Poland  15 

24 %  showed  stable  population  trends  (for  wintering 
species, these figures were 38 % and 14 %, respectively). 

However,  the  share  of  habitats  with  a  bad  or  poor 
conservation status had increased to 78.26 %, while the 
share  of  assessments  for  species 
in  bad  or  poor 
conservation status had decreased to 46.69 %. The main 
pressures  are  natural  processes,  development  of 
infrastructure,  agriculture,  forestry  and  invasive  alien 
species. 

A good example of actions that can be taken to actively 
contribute  to  species  conservation  is  a  project  co-
financed by the EU through the Cohesion Fund, which in 
May  2024  received  the  Citizens’  Natura  2000  Award: 
‘Best practices for the conservation and management of 
the  black  stork  in  Poland’.  By  2023,  the  project  had 
protected as many as 600–700 breeding sites of the black 
stork,  supporting  55 %  of  the  national  breeding 
population,  through  the  designation  by  the  regional 
forestry  directorate  of  nest  protection  zones  (each 
around 2 800 ha) (46). 

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

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

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

December 

accessed 

2019, 

(45) 

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

Luxembourg, 

Union, 

(46) 

https://environment.ec.europa.eu/news/best-practices-
conservation-and-management-black-stork-poland-2024-
winner-2024-03-14_en. 

2025 Environmental Implementation Review – Poland 

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

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

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

December 

accessed 

2019, 

In February 2022, Poland submitted to the Commission 
its  2021–2027  prioritised  action  framework  for  Natura 
2000.  The  document  sets  out  funding  needs  for 
managing  and  restoring  Natura  2000  sites,  the  green 
infrastructure necessary to ensure the coherence of the 
network,  measures  to  support  protected  species,  and 
administrative and other cross-cutting measures. 

According  to  the  estimates  presented  by  Poland, 
approximately  EUR 689 million  annually  is  required  to 
effectively  manage  and  restore  the  sites  to  achieve 
favourable conservation status for habitats and species 
of EU interest. The highest costs are related to managing 
forest  habitats  (EUR 333 million/year)  and  grasslands 
(EUR 287 million/year).  Filling  knowledge  gaps  was 
estimated to cost EUR 207 million altogether. 

By  far  the  largest  source  of  EU  funding  for  nature  and 
biodiversity  has  been  the  European  Agricultural  and 
Rural  Development  Fund.  As  regards  cohesion  policy 
funds,  the  European  Funds  for  Infrastructure,  Climate 
and Environment programme is the biggest contributor 
to  nature  funding  in  the  current  financial  framework 
(2021–2017).  The  allocation  for  nature  protection, 
biodiversity  and  green 
infrastructure  amounts  to 
EUR 310 million (which accounts for 1.28 % of the whole 
allocation  from  the  European  Funds  for  Infrastructure, 
Climate  and  Environment  programme  (FENIKS).  The 
allocation  from  all  the  regional  programmes  funded  by 
the  European  Regional  Development  Fund  (ERDF) 

Poland  16 

dedicated to different nature-related measures amounts 
to EUR 711 million. 

The  financial  instrument  for  the  environment  (LIFE) 
programme  has  been  widely  used  in  Poland  for  nature 
purposes. Two examples of recent projects are: 

• 

• 

Curlew  in  danger –  protection  of  the  Eurasian 
curlew  Numenius  arquata  in  Poland  (LIFE23-
NAT-PL-LIFEkulikPL); 
Southern  Baltic  coastal  biodiversity –  dune 
habitat  restoration  and  development  of  good 
management  practices  (LIFE23-NAT-PL-LIFE  for 
Dunes PL). 

In  2022,  Poland  started  implementing  its  first  LIFE 
strategic nature project, ‘Restoring wetlands in Poland’ 
(Wetlands GREEN LIFE). 

Poland  has  not  ratified  the  Agreement  on  the 
Conservation of African-Eurasian Migratory Waterbirds. 

In the 2022 EIR, Poland was called upon to complete the 
Natura  2000  designation  process  and  to  ensure  the 
implementation  of  priority  measures  identified  in  the 
prioritised action framework. By 2024, almost all SCIs had 
been formally designated as SACs. For the remaining 16 
sites,  the  six-year deadline for designation as SACs had 
not expired yet. However, by the time of preparation of 
the  current  report,  132  Natura  2000  sites  still  did  not 
have a management plan. 

2025 priority actions 

• 

the 

• 
• 

establishment 

Submit to the Convention on Biological Diversity an 
updated  NBSAP  or  national  targets  following  the 
adoption of the GBF. 
Complete the Natura 2000 site designation process. 
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 
unfavourable  conservation  status  through,  for 
example, 
increased 
restoration  measures, 
connectivity,  better  policy  coordination  and 
integration, and increased funding. 

of 

Recovery of ecosystems 

Agricultural ecosystems 

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

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

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

chemical pesticides; 

2025 Environmental Implementation Review – Poland 

 
 
 
—  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 
is  no 
fertilisers)  while  ensuring 
deterioration of soil fertility; 

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

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

The  “Vision  for  agriculture  and  food”,  adopted  by  the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective (47). 

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  dedicated  to  supporting  biodiversity 
and  plays  a  significant  role 
implementing  EU 
environmental policy. Strategic plans should continue to 
support  the  protection  of  soil,  water,  air  quality  and 
biodiversity. 

in 

indicators 

certain  CAP 

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

The  utilised  agricultural  area  in  Poland  increased  from 
14 529 400 ha  in  2012  to  14 754 860 ha  in  2020  and 
decreased to 14 197 890 ha in 2022 (48). 

(47) 

(48) 

(49) 

(50) 

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

5 December 

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

Poland  17 

Landscape  features  are  small  fragments  of  non-
productive  and  typically –  but  not  exclusively –  semi-
natural vegetation present in, or adjacent to, agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
covered  by  agricultural 
land.  Based  on  the  Land 
landscape  features 
Use/Cover  Area  Frame  Survey 
estimates, the share of agricultural land covered by non-
productive landscape features in Poland is 3.6 %, below 
the EU average. At the EU level, landscape features cover 
5.6 % of agricultural land. 

In 2024, the CAP basic regulations were amended (49) to 
simplify certain rules regarding, inter alia, the standards 
for  good  agricultural  and  environmental  condition  of 
land. These changes removed the obligation for farmers 
benefiting  from  CAP  area-related  support  to  have  a 
minimum  share  of  3–4 %  of  non-productive  area  or 
landscape  features 
in  their  farms.  However,  the 
amended  regulation  does  not  remove  the  obligation 
under  the  GAEC  8  to  maintain  existing  landscape 
features, and sets out an obligation for Member States 
to  establish  and  provide  support  for  eco-schemes 
for  the  maintenance  of  non-
covering  practices 
productive areas, such as land lying fallow, and for the 
establishment of new landscape features on arable land. 

The recently adopted Nature Restoration Regulation (50) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (51). 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 
3.91 % of Poland’s land area is used for organic farming. 
Although the figure has increased significantly over the 
last two decades, it is still among the worst results in the 
EU  and  lower  than  the  EU  average  of  10.50 % (52). 

(51) 

(52) 

in  cropland  mineral  soils’  and 

environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
which 
is  currently  under  review;  European  Commission, 
Agriculture biologique au sein de l’union européenne, factsheet, 
Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 

2025 Environmental Implementation Review – Poland 

 
 
Poland’s contribution to achieving the target of 25 % of 
the EU’s agricultural land being used for organic farming 
by 2030 is therefore insufficient. 

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

2025 priority actions 

• 

• 

Implement  eco-schemes  and  agri-environmental 
the 
and 
measures 
environmental needs of Poland. 
Implement  and  scale  up  the  uptake  of  organic 
farming practices. 

practices 

address 

to 

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. 

(53) 

(54) 

of 

final 

5 July 

2023, 

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

Poland  18 

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 (53) 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  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Poland (54). 

soil  organic 

loss  of 

carbon, 

The  greatest  contributor  to  Poland’s  unhealthy  soils  is 
loss  of  soil  organic  carbon  in  mineral  soils (55),  which 
affects  29 %  of  land  and  58 %  of  total  cropland  and 
grassland  areas.  17 %  of 
territory 
experiences  unsustainable  soil  erosion  by  water,  wind, 
tillage  and  harvest,  mainly  in  the  southern  part  of  the 
country.  8 %  of  soils  contain  nitrogen  concentrations 
above 50 kg/ha, and 8 % of the national territory is highly 
or very highly susceptible to topsoil compaction. 

the  national 

Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 

ASSESSMENT 
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdfhttps://environ
ment.ec.europa.eu/system/files/2023-07/IMPACT 
ASSESSMENT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

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

2025 Environmental Implementation Review – Poland 

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

The  habitat  assessment  conducted  under  Article 17  of 
the  Habitats  Directive  for  2013–2018  has  shown  that 
most  of the grasslands in Poland  have an unfavourable 
conservation  status.  The  main  pressure  is  intensive 
agricultural  use 
increased 
resulting  mainly 
fertilisation  and  herbicide  use.  On  the  opposed  side  of 
the spectrum,  many  meadows and pastures  have been 
abandoned due to their marginal profitability, resulting 
in  the  cessation  of  their  traditional  management 
practices.  This  has  had  a  negative  impact  on  these 
extensive 
habitat 
management. 

types,  which  often 

require 

from 

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  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I to the Habitats 
Directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  greenhouse  gas  (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. 

All  wetland  habitat  types  have  an  unfavourable 
conservation status. The pressure from agriculture is the 
leading cause  of  deterioration, with drainage being the 
main  cause  of  wetland  loss.  Peatland  extraction  for 
horticultural use is also an important pressure. In 2021, 
the  Ministry  of  Climate  and  Environment  prepared  a 

Poland  19 

proposal for a strategy for wetland protection (56), to be 
adopted  by  the  Council  of  Ministers.  At  the  time  of 
writing  the  report,  the  strategy  was  subject  to 
interministerial consultations. 

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, 
forests  that  contribute 
diverse  and  resilient  EU 
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, 
is  a 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

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

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (57) 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 (58).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

In  Poland,  forests  covered  31 %  of  the  country’s 
territory in 2020 (59). More than 75 % of the assessments 
for forests protected under the Habitats Directive reveal 
a bad or poor status (60). 

(56) 

57  

(58) 

https://www.gov.pl/web/susza/strategia-ochrony-obszarow-
wodno-blotnych. 
Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 
forests, 
2023, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en 

COM(2023)728, 

November 

22 

(59) 

(60) 

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

Luxembourg, 

Union, 

https://www.eea.europa.eu/publications/state-of-nature-in-
the-eu-2020. 
EEA,  forest  information  system  for  Europe,  ‘Countries –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. 
Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
from  the  Commission  to  the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 

Accompanying 

base: 

the 

2025 Environmental Implementation Review – Poland 

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

According  to  the  EUTR,  Member  States’  competent 
authorities  must  conduct  regular  checks  on  operators 
and  traders  and  apply  penalties  for  non-compliance. 
With the amendment of Article 20 of the EUTR, reporting 
every two years has been changed to annual reporting, 
and covers the calendar year as of 2019. 

Poland  20 

into 

force 

(EUDR) (62)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(63).  The 
Products 
regulation  seeks  to  guarantee  that  products  in  the  EU 
that  are  made  using  any  of  seven  listed  commodities 
have  no  links  to  deforestation.  The  EUDR  repeals  the 
EUTR.  The Commission has proposed giving  the  parties 
concerned additional time to prepare. If approved, this 
would make the EUDR applicable on 30 December 2025 
for large and medium-sized companies and 30 June 2026 
for micro- and small enterprises. 

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

The  infringement  procedure  concerning  the  Białowieża 
Forest, launched against Poland in case C-441/17, is still 
open.  The  Commission  has  been 
continuously 
monitoring the implementation measures necessary for 
Poland  to  comply  with  the  Court  of  Justice  of  the 
European Union’s judgment, issued on 17 April 2018. The 
Polish authorities have provided a set of measures to be 
taken  to  fully  implement  the  ruling,  including  adopting 
new forest management plans for the affected districts, 
and  the  Commission  services  are  awaiting  their  final 
execution. 

Poland was also condemned by the Court in the ruling of 
2 March 2023 in case C-432/21. The Court confirmed the 
Commission’s claims that Polish law did not comply with 
the requirements for strict protection introduced by the 
that  environmental  non-
Habitats  Directive  and 
governmental  organisations  (NGOs)  were  barred  from 
challenging forest management plans in non-compliance 
with the Habitats Directive and the Aarhus Convention. 
Poland  revoked  the  non-conforming  provision  on  strict 
protection  and  is  currently  working  on  making  the 
necessary  amendments  to  the  Polish  law  as  regards 
access to justice for the public concerned. 

The  EU  Timber  Regulation  (EUTR) (61)  prohibits  the 
placing  on  the  EU  market  of  illegally  harvested  timber. 

strategy  for  2030,  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. 
Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down  the  obligations  of 

(61) 

(62) 

Poland  has  not  implemented  the  obligations  set  out  in 
Article 14(1)  and  (2)  of  the  EUDR  to  ‘designate  one  or 
more competent authorities responsible for fulfilling the 
obligations arising from [this] Regulation and inform the 
Commission thereof at the latest by 30 December 2023’. 
This date remains unchanged, and no additional time is 
envisaged,  as  it  is  a  key  element  of  preparing  for  the 
smooth introduction of the application of the EUDR. 

Progress  in  the  implementation  of  2022  EIR  priority 
actions for forestry has not been sufficient. The Minister 
for Climate and Environment proposed amendments to 
the  Forest  Act  and  to  the  Nature  Conservation  Act  in 
August  2024  to  improve  public  participation  in  forest 
management planning and related access to justice, but 
there  are 
these 
amendments would fully implement the Court of Justice 
ruling in case C-432/21. 

still  concerns  about  whether 

In January 2024, Poland’s new Minister for Climate and 
Environment announced a six-month moratorium on all 
logging  activity  in  key  forested  areas (64).  The  ban 
includes 10 areas of forest throughout Poland deemed to 
be of high ecological value, including biologically diverse 
old-growth forests and important natural areas located 
near urban centres. The areas named thus far encompass 
about  1.5 %  of  Poland’s  state-managed  woodlands.  In 
September  2024,  the  moratorium  was  prolonged.  The 
long-term  strategy  for  the  protection  of  old-growth 
forests,  however,  is  not  clear.  No  document  has  been 

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. 

(63)   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. 
https://www.gov.pl/web/klimat/pierwszy-krok-rzadu-w-
kierunku-ochrony-cennych-lasow. 

(64) 

2025 Environmental Implementation Review – Poland 

 
 
 
to  address 

work 
implementation of the MSFD. 

those  gaps  at  all 

Poland  21 

levels  of 

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 Poland’s updated 
programme of measures under Article 13 of the MSFD 
(2022 reporting exercise) 

adopted to guarantee the comprehensive protection of 
the Białowieża Forest either. 

2025 priority actions 

• 

•  Designate  the  competent  authority  or  authorities 
responsible for fulfilling the obligations arising from 
the EUDR and inform the Commission of the names, 
addresses  and  contact  details  of  said  competent 
authority or authorities. 
Implement  peatland  conservation  and  restoration 
measures and include such measures and objectives 
in the national restoration plans. 
Implement the Court ruling to ensure public access 
to 
justice  regarding  forest  management  plans. 
Ensure  long-term  protection  for  old-growth  and 
ecologically  or  socially  significant  forests,  including 
in  compliance  with  the 
the  Białowieża  Forest, 
Court’s judgment. 

• 

Marine ecosystems 

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

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
in  the  MSFD  have  become  available. 
descriptor 
Nevertheless, Member States had to report updates by 
15 October  2024,  and  these  are  being  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
in  accordance  with  the  MSFD  and  the 
reporting, 
Commission  GES  decision (65),  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 (66). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (67). At 
that time, their updates on the elements, features and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 

(65) 

(66) 

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 
methods for monitoring and assessment, and repealing Decision 
(OJ  L 125,  18.5.2017,  p. 43),  https://eur-
2010/477/EU 
lex.europa.eu/eli/dec/2017/848/oj/eng. 
Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 

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

Poland’s  updated  programme  of  measures  was  overall 
positively  assessed,  scoring  ‘good’  or  ‘very  good’  on  a 
majority of descriptors. 

Poland  achieved  notable  progress 
in  addressing 
environmental  pressures  for  non-indigenous  species 
(D2), contaminants in seafood (D9) and energy (D11) in 
particular, with improvements in the scope and precision 
of  measures  compared  with 
first  cycle  of 
implementation. 

the 

for 

Still,  some  gaps  persist,  regarding, 
instance, 
contaminants (D8), where some important sources such 
as  coal  combustion  and  heavy 
industry  remain 
insufficiently  covered;  and  biodiversity  (D1),  where  the 
anticipated  effectiveness  of  measures  in  achieving  GES 
was not clearly established. 

2025 priority action 

Strategy  Framework  Directive  (Directive  2008/56/EC)  and 
Commission  Decision  (EU)  2017/848  (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. 

(67) 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Poland  22 

its 

•  Report  updates  on  the  assessment  of  the  state  of 
Poland’s  marine  waters, 
its 
determinations  of  GES (68),  which  are  expected  to 
include  any  threshold  values  for  the  descriptors  in 
the  MSFD  that  may  have  been  established  in 
cooperation with other Member States at the EU or 
regional level. 

target  and 

(68) 

In accordance with Article 17 of Directive 2008/56/EC. 

2025 Environmental Implementation Review – Poland 

 
 
Prevention and management of invasive alien 
species 

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

Poland  23 

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 (69). 

The third update of the Union list (70) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS Regulation (71) 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 (72).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (73),  and  at 
USD 423 billion annually at the global level (74). 

The total number of IAS of Union concern in the country 
is 33. This includes 23 species recorded in the previous 
EIR  (2021)  and  10  additions.  Of  these  10  additions,  6 
were  already  on  the  Union  concern  list  in  2021,  and  4 
were  added 
later  under  Commission  Implementing 
Regulation (EU) 2022/1203. 

(69) 

(70) 

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

Since  the  2022  EIR,  Poland  has  taken  appropriate 
measures to comply with Article 13 of the IAS regulation. 

2025 priority action 

• 

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

(71) 

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

(72)  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. 

(74) 

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

Science-Policy 
Services), 

(Intergovernmental 

Ecosystem 

and 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Poland  24 

Ecosystem assessment and accounting 

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

Similarly, target 14 of the GBF (75) 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 (76). 

The amended regulation (EU) No 691/2011 on European 
environmental  economic  accounts (77)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

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

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 

Platform (78). 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 to their success. Such understanding 
contributes to the implementation of the EU’s BDS. 

In  the  2022  EIR,  Poland  received  priority  actions  on 
supporting the mapping and assessment of ecosystems 
and  ecosystem  services,  and  ecosystem  accounting 
development, as well as on supporting the development 
of  national  business  and  biodiversity  platforms.  No 
progress was recorded in supporting the development of 
a  national business  and  biodiversity  network –  and still 
no  Polish  businesses  or  biodiversity  networks  are 
members  of  the  EU  Business  &  Biodiversity  Platform. 
Therefore, the related priority action is reiterated in this 
report. 

2025 priority actions 

• 

Support  the  development  of  the  national  business 
and biodiversity network. 

•  Ratify  the  Nagoya  Protocol  on  Access  to  Genetic 
Resources  and  the  Fair  and  Equitable  Sharing  of 
Benefits  Arising  from  their  Utilization  to  the 
Convention on Biological Diversity.

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

Assessment – 

Summary 

(76) 

for 

(77) 

(78) 

of 

final 

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

11 July 

2022, 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Poland  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 (79).  These  set  health-based  EU  air  quality 
standards (80)  and  stipulate  Member  States’  national 
emission  reduction  commitments (81)  for  several  air 
pollutants.  

The  air  quality  in  Poland  continues  to  give  cause  for 
concern in some parts of its territory. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (82) for Poland attribute 34 700 deaths each year (or 
391 000 years of life lost (YLL)) to fine particulate matter 
(PM2.5) (83),  3 100  deaths  each  year  (or  35 200 YLL)  to 
nitrogen dioxide (NO2) (84), and 5 400 deaths each year (or 
60 700 YLL) to ozone (85). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Poland 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) (86)  in  2024, 
Poland  has  met  its  emission reduction  commitments  for 
2020–2029 for air pollutants nitrogen oxides (NOx), non-
methane  volatile  organic  compounds  (NMVOC),  sulphur 

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

Poland  submitted 
its  updated  national  air  pollution 
control  programme  (NAPCP)  to  the  Commission  on 
22 November 2023. 

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

300%

250%

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, 

(79) 

(80) 

(81) 

(82) 

(83) 

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

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

(84)  Nitrogen  dioxide  (NO2)  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. 

(85) 

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

p. 1), 

2025 Environmental Implementation Review – Poland 

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

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
1,81%

4,44%

NOₓ

0,34%

39,28%

84,23%

13,85%

6,77%

1,26%

1,49%

12,55%

21,24%

12,74%

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) (87) were registered 
for NO2 in four air quality zones (88), and for PM10 in two 
air  quality  zones (89)  in  Poland.  Furthermore,  the  target 
values for ozone concentrations have not been met in 1 air 
quality  zone,  for  arsenic  concentrations  in  2  air  quality 
zones,  and  for  benzo(a)pyrene  concentrations  in  21  air 
quality zones (90). 

Persistent  breaches  of  air  quality  requirements,  which 
have severe negative effects on health and environment, 
are  being  followed  up  by  the  European  Commission 
through  infringement  procedures  covering  all  Member 
States  concerned,  including  Poland,  for  exceedances  of 
PM10  and  NO2  limit  values.  The  Court  of  Justice  of  the 
European Union delivered a judgement on exceedances of 
PM10  limit  values  in  2018  (C-336/16)  confirming  non-
compliance  with  Directive  2008/50/EC.  The  aim  is  that 

Poland  26 

appropriate measures will be put in place to bring all air 
quality  zones  into  compliance.  Infringement  procedures 
have  also  been  opened  for  Member  States  not  meeting 
the  emission  reduction  commitments  for  2020–2029, 
including for Poland regarding NMVOC and PM2.5. 

Poland  has  not  yet  ratified  the  amended  Gothenburg 
Protocol, the Protocol on Heavy Metals and the Persistent 
Organic  Pollutants  Protocol  under  the  United  Nations 
Economic Commission for Europe Air Convention. 

In the 2022 EIR, Poland received three priority actions. The 
first one was to further reduce emissions in the context of 
the NAPCP. Poland has made substantial progress on this, 
as  the  latest  reported  data  show  that  the  2020–2029 
emission reduction commitments have been met and that 
the  emission  reduction  commitments  for  2030  onwards 
are  projected  to  be  reached.  The  second  priority  action 
was  to  ensure  full  compliance  with  EU  air  quality 
standards and maintain downward emission trends. Based 
on the latest data, Poland has made some progress in this 
regard. Since 2019, downward emission trends have been 
reported  for  all  main  pollutants.  However,  exceedances 
above limit values and target values remain for NO2, PM10, 
ozone,  arsenic  and  benzo(a)pyrene,  requiring  further 
action. The third priority action received by Poland was to 
ratify the amended Gothenburg Protocol, the Protocol on 
Heavy  Metals  and  the  Persistent  Organic  Pollutants 
Protocol. Poland has made some progress, but still has not 
ratified the three mentioned protocols. 

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. 

•  Accelerate  the  ratification  of  relevant  international 

conventions and protocols. 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 
—  protect  air,  water,  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

—  prevent and manage waste; 
— 

improve  energy  and  resource  efficiency,  including 
water; 

—  contribute to decarbonisation. 

(87)  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. 

11.6.2008, 

L 152, 

p. 1), 

(OJ 

(88) 

(89) 
(90) 

Aglomeracja  Wroclawska,  Aglomeracja  Krakowska,  Aglomeracja 
Warszawska and Aglomeracja Górnoslaska. 
Strefa Dolnoslaska and Strefa Malopolska. 
EEA, 
Eionet 
(https://cdr.eionet.europa.eu/). 

Repository 

Central 

Data 

2025 Environmental Implementation Review – Poland 

 
 
 
The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (91). 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 (92).A total of 4 899 industrial installations in Poland 
that  fell  under  the  scope  of  the  IED  in  2022.  Of  these, 
nearly  a  third  (28 %)  were  establishments  dedicated  to 
intensive  rearing  of  poultry  or  pigs.  The  other  primary 
sectors 
(20 %),  waste 
management (13 %), the metal industry (10 %), the food 
and drink sector (8 %), and the chemical industry (8 %). 

included  energy  production 

Figure 18  shows  the  damage  to  human  health  and  the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions ‘intensity’. Poland has 
the second-highest damage in the EU, and ranks third in 
emissions intensity, significantly exceeding the EU average 
of EUR 27.5 / EUR 1 000 GVA. 

The primary industrial source of air emissions (93) in Poland 
is  the  energy  sector,  which  is  a  major  contributor  to 
emissions of NOx, SO2, mercury (Hg), and nickel (Ni), while 
the metal industry is a significant  source of copper (Cu), 
lead  (Pb),  and  zinc  (Zn)  emissions.  Additionally,  the 
chemical  industry  is  a  key  contributor  to  emissions  of 
NMVOC. 

Poland  27 

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

Source: EEA, ‘Industrial pollution intensity indicators – EU large industry 
air  pollution  damage  costs  intensity’,  European  Industrial  Emissions 
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 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 19. 

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

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

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

Figure 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  its  ratio 
with the industrial activity (expressed in GVA). Poland has 
the third highest emissions of heavy metals to water and 
is in fourth position for emissions intensity, above the EU 

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

(92) 

(93) 

European 

Emissions 

EEA, 
Portal, 
Industrial 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 
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 – Poland 

 
 
 
 
average intensity of 0.864 kg / billion EUR GVA. As shown 
in Figure 21, the main industrial contributors to emissions 
to water in Poland are the waste management sector for 
total organic carbon, phosphorus and  heavy metals, and 
the chemicals sector for nitrogen and hydrocarbons. 

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

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

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

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human
Toxicity

Polycyclic
aromatic
hydrocarbons
(PAHs)

Total nitrogen Total organic
carbon (TOC)

Total
phosphorus

Chemicals
Extractive industry
Food and drink
Incineration with energy recovery
Livestock
Non-metallic minerals
Pulp, paper and wood
Wastewater treatment

Electricity and heat production
Ferrous metal
Fuel processing
Landfill
Non-ferrous metal
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 
2024, 
Catalogue, 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

13 September 

Data 

Since  2023,  Poland  has  been  subject  to  an  infringement 
procedure  for  failure  to  correctly  transpose  the  IED  into 
national law. 

IED  provisions  on  public  information  and  participation 
require Member States to adopt transposition legislation 
enabling members of the public to have access to relevant 

Poland  28 

IED 

contains  mandatory 

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. 
requirements  on 
The 
environmental  inspections,  requiring  a  site  visit  to  take 
place at least every 1–3 years, using risk-based criteria. In 
addition,  IED  enforcement  provisions  require  Member 
to  determine  effective,  proportionate,  and 
States 
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  on  (i)  ferrous  metal  processing;  (ii)  textiles 
industry;  (iii)  common  waste  gas  management  and 
(iv) 
treatment 
slaughterhouses,  animal  by-products  and/or  edible  co-
products industries; and (v) smitheries and foundries. 

the  chemical 

systems 

sector; 

in 

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. 

In  2022,  Poland  received  priority  actions  to  continue 
reducing  emissions  from  the  energy  sector.  The  2021 
report  shows  that  out  of  top  30  thermal  power  stations 
and  other  large  combustion  plants  with  the  highest 
normalised damage costs from emissions of all pollutants 
(normalisation  with  CO2  emissions)  in  2021,  six  are 
located in Poland (94). 

2025 priority actions 

•  Complete the correct transposition of IED 1.0. 
•  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. 

(94) 

EEA, The costs to health and the environment from industrial air 
in  Europe  –  2024  update,  briefing  No 24/2023, 
pollution 
2024, 
Copenhagen, 

https://www.eea.europa.eu/publications/the-cost-to-health-
and-the. 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Major industrial accidents prevention – Seveso 

The  main  objectives  of  EU  policy  on  the  prevention  of 
major industrial accidents are to: 
(i)  control  major-accident  hazards  involving  dangerous 

substances, especially chemicals; 

(ii)  limit  the  consequences  of  such  accidents  for  human 

health and the environment; 

(iii) continuously improve the prevention of, preparedness 

for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive (95)). 

The below overview 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 (96)  and  the  report  by 
Poland on the implementation of the Seveso III Directive 
for 2019–2022 (97). 

In Poland, in 2024, among the 444 Seveso establishments, 
250  were  categorised  as  lower-tier  establishments  and 
194  as  upper-tier  establishments  (UTEs),  based  on  the 
quantity  of  hazardous  substances  likely  to  be  present. 
UTEs  are  subject  to  more  stringent  requirements.  The 
change in the number of Seveso establishments is set out 
in Figure 22. 

Figure 22: Number of Seveso establishments in Poland, 
2018, 2022 and 2024 

NB: LTE, lower-tier establishment. 

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 

2022, 

Poland  29 

established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

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

In Poland, in 2022, an EEP was required for 171 UTEs out 
of a total of 187 UTEs. At the same time, 166 UTEs had an 
EEP  and  156  of  these  EEPs  had  been  tested  within  the 
previous three years. The summary is shown in Figure 23. 

Figure 23: Situation regarding EEPs in Poland, 2022 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
2014/896/EU 
Implementing  Decision 
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. 

The information for the public referred to in  Annex V to 
the Seveso III Directive, especially in relation to how the 
public  will  be  alerted  if  there  is  a  major  accident,  the 
appropriate action to take if there is a major accident, and 
the date of the last site visit, are permanently available for 
all Seveso establishments in Poland. This is an important 
provision in the Seveso III Directive, as public knowledge 
of  this  information  may  reduce  the  consequences  of  a 
major industrial accident. 

(95)  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. 

(96) 

(97) 

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 – Poland 

 
 
 
 
Poland  30 

The  shares  of  UTEs  for  which  information  on  safety 
measures and requisite behaviours was made available to 
the public in all Member States is presented in Figure 24. 

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 

updating  EEPs,  at  intervals  of  no  more  than  three 
years. 
Ensure  access  to  transparent  and  clear  information 
for citizens on risks and behaviour in the event of an 
accident. 
Ensure full and correct transposition of the Seveso III 
Directive. 

• 

• 

Mercury Regulation 

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). 

In 2019, 21 % of dental treatments were still using dental 
amalgam,  which  represented  a  challenge  for  Poland  to 
phase out its use by 1 January 2025. However, measures 
should  have  been  put  in  place  to  ensure  a  socially  and 
economically  sound  phase  out,  including  an  adequate 
reimbursement  of  the  alternatives  to  dental  amalgam 
through the health insurance scheme and the training of 
dental  practitioners.  The  Commission 
is  monitoring 
whether the phase-out  has taken place under the terms 
and conditions of the regulation. 

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

Noise 

The Environmental Noise Directive (98) 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 

NB: No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
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. 

Poland has had some issues with the transposition of the 
Seveso III Directive into national law, as a result of which 
the  Commission  initiated  an  infringement  procedure  in 
2021. 

In  2022,  Poland  received  a  priority  action  to  strengthen 
control  and  enforcement  to  ensure  compliance  with 
Seveso III  Directive  provisions,  especially  on  providing 
information to the public and EEPs. Data reported on the 
implementation of the directive for 2019–2022 for Poland 
show that improvement is still needed in the number of 
EEPs established and tested over the last three years. 

2025 priority actions 

• 

Strengthen  compliance  with  requirements  on  safety 
measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response in relation to 
UTEs, in particular  as regards reviewing, testing and 

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

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

2025 Environmental Implementation Review – Poland 

 
 
 
compared  with  2017  in  the  share  of  people  chronically 
disturbed by transport noise. 

Excessive noise from aircraft, railways and roads is one of 
the main causes of environmental health‐related issues in 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (99). 

In  Poland,  environmental  noise  is  estimated  to  cause  at 
least 1 000 cases of ischaemic heart disease annually (100) 
and some 200 000 people to suffer from disturbed sleep 
(101). 

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

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

An infringement procedure is ongoing for Poland related 
to a lack of reporting on the strategic noise maps and the 
adoption of noise action plans. The failure to comply with 
these obligations was confirmed by the Court of Justice in 
the ruling of 20 April 2023. 

Poland  received  a  priority  action  in  the  2022  EIR  to 
complete  noise  action plans. Given  that  reporting  under 
the most recent reporting cycle for noise action plans was 
due  in  early  2025,  these  have  not  been  assessed. 
Therefore, this priority action is maintained for the  2025 
EIR. 

(99)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 

(100)  These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial  Pollution  (ETC/ATNI),  Noise 
Indicators  under  the 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (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, 

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

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

Poland  31 

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 
water  (including  surface  waters  and  groundwaters)  be 
significantly reduced. Achieving, maintaining or enhancing 
a  good  status  of  waterbodies  as  defined  by  the  Water 
Framework Directive will ensure that EU citizens 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. 

Water Framework Directive 

The Water Framework Directive (102) is the cornerstone of 
EU water policy (103). The Water Framework Directive and 
other  water-related  directives (104)  form  the  basis  of 
sustainable and integrated water management in the EU. 
They  aim  to  achieve  a  high  level  of  protection  of  water 
further  deterioration  and 
resources,  prevention  of 
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  ecological  and  chemical 
status  of  surface  water  and  good  quantitative  and 
chemical  status  of  groundwater.  This  implies  monitoring 
and  classification  of  all  waterbodies,  assessment  of 
pressures and impacts, and identification of the most cost-

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

content/EN/TXT/?uri=CELEX:32000L0060. 

(103)  https://environment.ec.europa.eu/topics/water_en. 
(104)  These 

the  Groundwater  Directive 

the 

Floods 

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 
Urban 
content/EN/TXT/?uri=celex%3A32006L0007), 
Wastewater 
(https://eur-
Directive 
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A31991L0271), 
(https://eur-
new 
the 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32020L2184), 
Directive 
content/EN/ALL/?uri=celex%3A31991L0676), 
(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

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

Drinking  Water 

Treatment 

Directive 

and 

the 

the 

the 

the 

IED 

2025 Environmental Implementation Review – Poland 

 
 
  
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.  The 
RBMPs  should  cover  their  river  basin  districts  (RBDs), 
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 (105). 

Poland  has  4 240  surface  waterbodies  and  174 
groundwater  bodies,  divided  over  nine  RBDs  (Danube, 
Vistula,  Świeża,  Jarft,  Elbe,  Oder,  Pregola,  Nemunas  and 
Dniester).  Approximately  18 %  of  surface  waters  are 
designated  as  ‘heavily  modified’  and  about  2 %  as 
‘artificial’.  Heavily  modified  and  artificial  waterbodies 
must  reach  good  ecological  potential  rather  than  good 
ecological status, which means that all measures must be 
taken  to  mitigate  the  adverse  impact  of  the  sustainable 
human development  activities causing the waterbody to 
be  heavily  modified/artificial,  while  not  significantly 
affecting these activities. 

It  follows  from  the  assessment  of  the  third  RBMPs  that 
there has been a significant deterioration in the ecological 
status/potential  and  in  the  chemical  status  of  surface 
waterbodies,  compared  with  the  status  reported  in  the 
second  RBMPs  (covering  2015–2021).  There  has  been  a 
slight  deterioration 
the  quantitative  status  of 
groundwater  bodies,  and  a  slight  improvement  in  their 
chemical status. 

in 

show 

Figures 25–28 
the  evolution  of  ecological 
status/potential  and  the  chemical  status  of  surface 
waters,  and  of  the  quantitative  and  chemical  status  of 
groundwaters in 2010, 2015 and 2021. 

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

Poland  32 

Worryingly, the number of surface waterbodies in good or 
better  ecological  status/potential  has  decreased  from 
31 % to 8.4 % since the second RBMPs. Furthermore, none 
of  the  transitional  and  coastal  waterbodies  have  a  good 
ecological status. 

A striking example is the deterioration of the Oder River 
which,  in  summer  2022  and  to  a  lesser  extent  in  the 
summers,  experienced  an  uncontrolled 
following 
blooming of an intrusive algae and, as a consequence, a 
stark reduction in population of several species of fish and 
molluscs.  Failure  to  take  appropriate  measures,  such  as 
review  of  water  permits  for  saline  discharges  or  re-
naturalisation of the river has left the river vulnerable to 
potential  recurrence  of  the  algae  bloom  and  further 
deterioration.  

In  general,  the  water  management  system  in  Poland 
should  put  more  emphasis  on  restoring  the  ecological 
functions  of  the  rivers,  favouring  nature-based  solutions 
over  grey 
in  order  to  ensure  the 
continuation of all sustainable water uses.   

infrastructure, 

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

Only 24.8 % of surface waterbodies have a good chemical 
status,  representing  a  significant  deterioration  since  the 
second RBMPs. 

Failure to achieve good chemical status is mostly due to 
toxic 
ubiquitous  persistent  bioaccumulative 
substances, which are difficult to address and often have 
transboundary  sources.  In  Poland,  these  are  mainly 
polycyclic 
aromatic  hydrocarbons,  polybrominated 
diphenyl ethers, and mercury and its compounds. 

and 

(105)  

ENV - Bibliothèque 

2025 Environmental Implementation Review – Poland 

0 20 40  0  0 100 1st2nd3rdSWB chemical status for P GoodFailing to achieve goodUnknown 
 
 
 
 
 
Figure 27: Quantitative status of groundwater bodies in 
each RBMP cycle (%) 

It is not clear how many groundwater bodies are covered 
by quantitative monitoring. 

The  number  of  groundwater  bodies  with  a  poor 
quantitative status has increased from 13 to 15 since the 
second RBMPs. 

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

All groundwater bodies and all substances causing risk of 
deterioration in chemical status are subject to monitoring. 
It is not clear, however, if all core parameters of the Water 
Framework  Directive –  that  is,  nitrates,  ammonia,  pH, 
electrical  conductivity  and  oxygen –  are  included  in  the 
monitoring of groundwaters in all RBDs. 

The number of groundwater bodies with a poor chemical 
status  has  decreased  from  14  to  9  since  the  second 
RBMPs. 

Failure to achieve good chemical status is mostly due to 
the diffuse pollution from urban and mining activities, as 
well as to saline intrusion, caused by ingress or upwelling 
of saline waters from drained groundwater layers. 

Until the end of 2027, Member States can still apply 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 exemptions will 
be much more limited. 

The  2022  EIR  recommended  that  Poland  (i)  assess  new 
physical changes to waterbodies in line with Article 4(7) of 

Poland  33 

the Water  Framework  Directive and consider alternative 
options  and  suitable  mitigation  measures,  and  (ii) 
continue current efforts to further reduce pollution from 
waterbodies. 

Some  progress  has  been  made  in  following  up  on  these 
priority actions, but much remains to be done. 

A positive aspect is that the planning of measures in the 
third RBMPs considers several aspects, such as flood risk 
management  plans  and  surface  water  restoration 
programmes,  albeit  without  explicitly 
indicating  the 
relative priority of these aspects. The measures are linked 
with  the  significant  pressures  in  the  Vistula  and  Oder 
RBDs, and in terms of rivers and groundwaters in all RBDs. 
For surface waters, the measures have been assessed at 
the  waterbody  level  using  a  cost-effectiveness  analysis 
including  effectiveness  criteria,  feasibility,  number  of 
pressures to be reduced and the time for the action to be 
effective. However, similar information is not provided for 
groundwaters. 

2025 priority actions 

Without prejudice to the list of recommended actions in 
the Commission report to the European Parliament and to 
the  Council  on  the  assessment  of  the  third  RBMPs,  the 
following priority actions can be highlighted. 

• 

• 

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

financing 

An infringement opened in 2014 for  failure to transpose 
the  Water  Framework  Directive –  as  well  as  poor 
application of its provisions, such as the derogations under 
Article 4(5) and 4(7) – is still pending. Poland must step up 
its actions to fully comply with the deadline to achieve a 
good status for all waterbodies by 2027. Furthermore, any 
derogation  from  the  2027  deadline  or  any  derogation 
from the prohibition on the deterioration of water status 
granted  to  a  project  must  be  justified  sufficiently  and  in 
detail. 

2025 Environmental Implementation Review – Poland 

 
 
 
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  (PFRAs)  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  was  that  the  second  plan  presented  a 
detailed  process  for  reviewing  and  revising  the  sub-
objectives set in the first FRMPs. Moreover, three of the 
second FRMPs present indicators showing progress since 
the corresponding first FRMPs. In addition, a description 
of  the  measures  is  provided  in  all  the  FRMPs,  and  the 
process of prioritisation of measures is clearly presented. 
The  methodology  for  monitoring, 
in  particular,  the 
approach  to  indicators,  has  been  strengthened.  Climate 
change  was  included  in  the  process  of  determining  the 
types  of  activities  of  the  FRMPs.  The  second  FRMPs 
described in more detail how cooperation in international 
river basins functions. 

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 FRMPs. 

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

consultation  and 

stakeholder 

• 

Drinking Water Directive 

The 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 

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

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

(107)  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, 

(108)  OJ L, 

2024/369, 

Poland  34 

several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (106), (ii) a methodology for measuring microplastics 
in drinking water (107) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (108). Member States will have to take 
these  various  Commission  acts 
into  account  when 
implementing the recast directive. 

Finally, the Commission has 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 Poland does not give rise to concern (109). 

Poland  has  not  communicated  its  national  measures 
transposing  the  recast  Drinking  Water  Directive  into  its 
the 
national 
Commission launched an infringement procedure against 
the country in December 2023. 

the  Commission.  Therefore, 

law 

to 

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

2025 priority action 

• 

Take  action  to  ensure  full  compliance  with  the 
Drinking Water Directive. 

Bathing Water Directive 

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

Figure 29 shows that in 2023, out of the 739 Polish bathing 
waters,  54.9 % were of excellent  quality, 14.3 % were of 
good  quality  and  4.5 %  were  of  sufficient  quality,  while 
2.8 % were of poor quality and 23.4 % were not classified. 

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  parametric groups in Poland 
was  at  least  99.99 %  in  2017,  100.00 %  in  2018  and  99.99 %  in 
2019. 

(109) 

2025 Environmental Implementation Review – Poland 

 
 
Detailed information on Polish bathing waters is available 
via an interactive map viewer from the EEA (110). 

Poland  has  some  issues  with  the  transposition  of  the 
Bathing  Water  Directive,  for  which  the  Commission 
initiated an infringement procedure in October 2020. 

Figure 29: Bathing water quality per Member State, 
Albania and Switzerland (%), 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  Nitrates  Directive (111)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

The  latest  Commission  report  on  the  implementation  of 
the  Nitrates  Directive (112),  dating  to  2022,  warns  that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a  problem in  many parts of the EU. 
The  report  on  the 
implementation  of  the  Nitrates 
Directive covering 2020–2023 will be available in 2025. 

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

Poland  35 

2025 priority action 

• 

Tackle  nutrient  pollution,  especially  nitrates  from 
agriculture,  through  the 
implementation  of  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  wastewater.  It  therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  wastewater  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
treatment 
than  secondary,  with  nitrogen  and/or 
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 Poland, the compliance rate was 71 % in 2020. 
340  agglomerations,  generating  10 742 589  population 
equivalents of urban wastewater, did not comply with the 
requirements of the directive. 

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

Source:  12th  technical  assessment  of  UWWTD 
Publications Office of the EU 

implementation  - 

Therefore,  already  in  2017,  the  Commission  opened  an 
infringement procedure against Poland. In February 2022, 
the Commission decided to refer Poland to the  Court  of 
Justice.  It  is  essential  that  Poland  takes  the  necessary 
measures  to  fully  comply  with  the  requirements  of  the 
directive. 

This  is  all  the  more  important  as  the  directive  has  been 

(110)  EEA, 

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

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

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

content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

(112)  https://environment.ec.europa.eu/topics/water/nitrates_en. 

2025 Environmental Implementation Review – Poland 

 
 
 
 
revised.  The  revised  directive113  builds  on  the  current 
acquis,  strengthening  existing  treatment  standards  and 
establishing an additional treatment of micropollutants in 
urban  wastewater.  Other  new  requirements  relate  to 
moving  towards  the  energy  neutrality  of  the  sector, 
establishing an EPR system to ensure sustainable financing 
of  micropollutant  treatment  by  the  most  polluting 
industries, and ensuring access to sanitation, especially for 
vulnerable  and  marginalised  groups.  Poland has until  31 
July 2027 to transpose the new directive into its national 
legal system. 

The  2022  EIR  recommended  that  Poland  complete  its 
implementation of the UWWTD for all agglomerations, by 
building up the necessary infrastructure. 

Despite  some  progress  made,  Poland  did  not  fully 
implement the UWWTD. 

2025 priority action 

• 

the  necessary  measures 

Take 
full 
implementation  of  the  current  urban  wastewater 
treatment  directive,  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 

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

(114)  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 

(115)  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  (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, 
p. 1), 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907;  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 

Poland  36 

sustainability  towards  a  toxic-free  environment (114), 
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 (115) provides a baseline The 
legislation (116)  provides  a  baseline 
EU’s  chemicals 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  Registration,  Evaluation, 
the  enforcement  of 
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 (117)  on  the 
implementation 
these 
regulations (118).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies 
and (ii) more non-compliant products are being placed on 
the EU market. 

in  the  area  of 

of 

67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
No 1907/2006 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 

p. 1), 

(116)  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 
(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. 
(117)  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, 

(118) 

2025 Environmental Implementation Review – Poland 

 
 
Poland  37 

absence  of  new  country-specific  data  on  enforcement 
since 2022. 

Since the last EIR, Poland had not devised and not planned 
to devise any strategy for the enforcement of the REACH 
and  CLP  Regulations (124).  In  addition,  Poland’s  report 
required  under  Article 117  of  the  REACH  Regulation  and 
Article 46 of the CLP Regulation contained no data about 
staff  members  allocated  or  controls  carried  out  in  the 
reporting period (2015–2019) (125). 

In  2020,  Poland  participated 
in  an  EU  coordinated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE  (REF)-8  project (126).  The  report  was 
adopted 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 (%) 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (119) of the two main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 
chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (120). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (121).  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 (122).  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  the  REACH 
Regulation 
following 
authorities (123): 

in  Poland 

lies  with 

the 

• 

the  State  Sanitary  Inspectorate  (lead  enforcement 
authority), 
the Chief Inspectorate for Environmental Protection, 
the State Labour Inspectorate, 
the Trade Inspection, 
the State Fire Service, 

• 
• 
• 
• 
•  National  Revenue  Administration  (Customs  and 

Revenue Office). 

The  Member  States’  reporting  exercise  set  out 
in 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 

(119)  European  Commission,  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU-level enforcement indicators, Publications Office 
of the European Union, Luxembourg, 2021. 

(120)  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. 

(121)  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). 

(122)  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. 

A  risk-based  approach  was  used  for  the  targeting  of 
control  measures  in  order  to  maximise  the  chances  of 
identifying  non-compliance. 
the  non-
compliance rates presented above cannot be considered 

Therefore, 

(123)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU level enforcement indicators, Publications Office 
of the European Union, Luxembourg, 2021. 

(124)  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 Union, Luxembourg, 2020, p. 76. 

(125)  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 Union, Luxembourg, 2020, pp. 87–88. 

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

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Poland 

 
 
 
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. 

proved  to  correspond  consistently  to  higher  non-
compliance  rates  in  checks  performed  across  the  E,  in 
particular when related to imported products. 

Poland  38 

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

In  2022,  Poland  received  two  priority  actions  related  to 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of instances of non-compliance and was invited 
to devise and implement strategies to enforce the REACH 
and  CLP  Regulations.  In  the  absence  of  reporting  since 
2022, no progress has been shown and this priority action 
remains  valid  in  2025,  partly  because  of  the  experience 
with the REF-8 project. 

2025 priority actions 

• 

• 

Poland  participated,  to  a  limited  extent,  in  the  REF-8 
coordinated enforcement project. Online sales have been 

•  Upgrade 

the 

capacities 

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

including 

in 

2025 Environmental Implementation Review – Poland 

 
 
 
 
Poland  39 

4. Climate action

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 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. 

Forestry (128). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

The  key  strategic  document  at  the  country  level  is  the 
National Energy and Climate Plan (NECP) (129). Poland had 
not  submitted the NECP by the end of March 2025.  The 
legal deadline for the submission was in June 2024.  

Poland has not submitted its Long-Term Strategy required 
by  the  Governance  Regulation (130),  the  Commission 
therefore  opened  an  infringement  procedure  against 
Poland  on  29 September  2022  by  sending  a  letter  of 
formal  notice.  As  a  second  step,  on  16  November  2023, 
the Commission sent a reasoned opinion to Poland. 

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

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

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 % (127).  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 Poland decreased by 23%, 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 (131) 
and, from 2024, also maritime transport. 

(127)  EU net domestic emissions, including the land use, land-use 

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

change and forestry (LULUCF) sector and excluding international 
aviation. 

https://energy.ec.europa.eu/topics/energy-strategy/national-
energy-and-climate-plans-necps_en. 

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

(130)  Article  15(1)  of  Regulation 2018/1999.  Regulation  -  2018/1999 - 

https://commission.europa.eu/strategy-and-policy/priorities-
2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

EN - EUR-Lex. 

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

Norway, Iceland, Switzerland and the United Kingdom. 

2025 Environmental Implementation Review – Poland 

 
 
 
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 t 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. 

In Poland, the emissions under the ETS decreased by 31% 
from 2005 to 2023. 

from  cement  and 

GHG emissions covered by the ETS in Poland continue to 
be dominated by the power sector, which accounted for 
71 %  in  2023.  This  is  significantly  more  than  the  EU 
average  (57 %),  underlining  the  importance  of  energy 
transformation  in  Poland  to  reduce  exposure  to  carbon 
costs. In 2023, emissions from the power sector were 21 % 
lower than in 2019 and 35 % lower than in 2013. In 2023, 
Poland’s industry emissions covered by the EU ETS came 
mostly 
(25 %), 
industries  classified  as  ‘other’  (30 %),  and  refineries 
(20 %),  as  well  as  from  the  metals  industry  (16 %)  and 
chemicals  production  (10 %).  Industry  emissions  have 
been increasing since 2013, except for a dip in 2020 due to 
the  COVID-19  pandemic  and  reduced  manufacturing 
capacity but declined in 2023. In 2023, industry emissions 
were 15 % higher than in 2013, albeit only 7 % higher than 
in  2019.  Overall,  in  2023,  Poland’s  ETS  emissions  were 
17 % lower than in 2019 and 26 % lower than in 2013. 

lime  production 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors 
(mainly  industry  not  covered  by  the  current  ETS)  will 
become  fully  operational (132).  Member  States  should 
have  notified  full  transposition  of  the  provisions  of  the 
revised  EU  ETS  Directive  related  to  the  new  ETS2  into 
national law by 30 June 2024. 

Poland  did  not  communicate  full  transposition 
into 
national law by this deadline. Therefore, on 25 July 2024, 
the  Commission  opened  an 
infringement  procedure 
against  Poland  for  its  failure  to  fully  transpose  the 
provisions  into  national  law.  Poland  had  two  months  to 
respond  and  address  the  shortcomings  raised  by  the 
Commission. In the absence of a satisfactory response, the 
Commission  may  decide  to  take  the  infringement  case 
further. 

The  Commission  also  opened  infringement  procedures 
against  Poland on  25 January 2024 for  its  failure to fully 
transpose  previous  revisions  of  ETS  Directive (133)  into 
since  notified  partial 
national 
transposition  of  either  one  or  both  revisions  to  the 
Commission. In the absence of a complete transposition, 

law.  Poland  has 

Poland  40 

the Commission may decide to take the infringement case 
further. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation (ESR) (134)  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 
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. Poland‘s target is –17.7%. 

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

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

Based  on  historical  emissions  and  the  most  updated 
projections, Poland will need to implement new measures 
and/or  use  available  flexibilities  to  achieve  its  2030  ESR 
target. Projected gap is 3.6 percentage points to the 2030 
target. 

The largest  contributor is the domestic transport  sector, 
which accounted for 35 % of all effort sharing emissions in 
2022.  Transport  emissions  are  a  very  high  concern  for 
Poland, as they have increased by 91 % since 2005. Poland 
still  has  far  to  go  in  curbing  this  rise,  and  its  uptake  of 
electric vehicles is still at an early stage. At  just  0.1 % in 
2022,  the  share  of  battery  electric  vehicles  in  Poland’s 
passenger car fleet is still very low (EU average is 1.2 %). 
However,  in  2023,  its  5  070  publicly  accessible  charging 
points  provided  a  charging  point  for  every  10  electric 
vehicles,  in  line  with  the  EU  average.  Rail  travel  has 
decreased  in  the  past  decade,  both  for  passengers 
(reaching 6 %, in line with the EU average) and for freight 
(21 %), making the split between road and rail transport 
more balanced than the EU average. 63 % of Poland’s rail 
network is electrified (EU average: 56 %). 

Buildings accounted for 24 % of all effort sharing emissions 
in 2022. Emissions have decreased by 16 %. Nevertheless, 
Poland needs to step up its efforts to improve the energy 
efficiency  of  buildings  if  it  is  to  achieve  a  meaningful 
contribution  to  the  2030  reduction  target  for  energy 
consumption  in  the  sector.  Final  energy  consumption  in 
in  2022  as 
residential  buildings 

increased  by  2.4 % 

(132)  Directive (EU) 2023/959 (https://eur-lex.europa.eu/legal-

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

(133)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 - EN 

(134)  Regulation (EU) 2018/842 (https://eur-
lex.europa.eu/eli/reg/2018/842). 

- EUR-Lex. 

2025 Environmental Implementation Review – Poland 

 
 
long-term 
compared  to  2021,  while  the  national 
renovation  strategy  aims  to  reduce  buildings’  primary 
energy consumption by 4 % between 2018 and 2030. 

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

Land use, land-use change and forestry 

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

Poland  41 

Poland  is  vulnerable  to  events  linked  to  climate  change, 
notably  facing  an  increased  risk  of  drought  and  flooding 
affecting agriculture and water management. Only 5–20 % 
of climate-related economic losses in Poland in 1980- 2020 
were insured. Poland’s protection gap for climate events 
remains significant, particularly for flooding. 

Poland  adopted  its  national  adaptation  strategy  in  2013 
but has never updated it. There are no regional or sectoral 
adaptation  plans.  Poland  has  taken  steps  to  update  its 
national  adaptation  strategy,  develop  its  vulnerability 
assessment  and implement  actions to counteract  water-
related  risks.  Appropriate  institutional  mechanisms  are 
crucial for climate adaptation. In this regard, Poland shows 
institutional  weaknesses  that  hamper  effective  central 
coordination.  Likewise,  a  legal  framework  with  regularly 
updated  targets  and  strategic  objectives 
is  missing. 
Moreover,  there  is  considerable  scope  for  integrating 
climate adaptation and public funding considerations into 
sectoral policies, for policy monitoring and for predicting 
climate risks. 

The European Commission identified  five priority actions 
in the 2022 EIR. 

Emission  intensity  of  energy  mix  remains  an  issue  for 
Poland.  The  share  of  renewables  and  nuclear  energy  in 
energy  mix  is  one  of  the  lowest  in  the  EU.  Since  2022, 
Poland  has  adopted  four  Territorial  Just  Transition  Plans 
(TJTPs)  for  the  regions  that  face  the  biggest  socio-
economic challenges in phasing out coal and reducing CO2 
emissions. Progress on the implementation of these plans 
is limited. 

Poland  is  facing  significant  challenges  in  enhancing  the 
carbon-absorbing capacity of its land-use sector, as carbon 
removals  have  declined  at  a  worrying  speed  in  recent 
years. 

There  is  some  progress  in  wind  power  development. 
Poland  improved  the  legislation  for  installations  of  the 
onshore wind power. However, some significant  hurdles 
in the permitting procedure remain. 

There is some progress in energy system integration and 
grid investments and there are several ongoing projects. 
However,  electricity  grid  remains  a  major  bottleneck  for 
the expansion of the renewable energy. 

is  no  progress  regarding  decarbonisation  of 

There 
transport. 

Poland  exhibits  considerable  manufacturing  capacity  for 
clean  technologies  and  has  great  potential  for  further 
increases, notably in the battery and solar PV supply chain. 

Poland‘s target  for 2030 is to enhance land removals by 
additional  –3.3  Mt  of  CO2  equivalent  compared  to  the 
yearly  average  of  the  period  2016–2018.  The  latest 
available projections show a gap to target of 5.9 Mt of CO2 
equivalent  in  2030.  Therefore,  Poland  needs  to  apply 
additional measures to reach its 2030 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. 

Poland has one out of three region categories identified as 
a  hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions (135). 

(135)  European  Climate  Risk  Assessment  (EUCRA).  2024.  Available  at 

European Climate Risk Assessment (europa.eu). 

2025 Environmental Implementation Review – Poland 

 
 
 
2025 priority action 

• 

Submit  the  final  national  energy  and  climate  plan 
(NECP) (136). 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.

Poland  42 

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

2025 Environmental Implementation Review – Poland 

 
 
 
 
 
Poland  43 

Part II: Enabling framework – implementation tools 

5. Financing

The EU budget supports climate investment in Poland with 
significant amounts in 2021–2027, with revenues from the 
ETS  also  feeding  into  the  national  budget.  During  2020–
from  auctioning  reached 
2022,  Poland’s  revenues 
EUR 13 727 million  in  total,  with  half  of  that  spent  on 
climate and energy. 

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 20.8 billion per year in 
Poland. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 12.8 billion per year; thus, there is 
a gap of EUR 8 billion per year. 

the 

annual 

Of 
gap, 
environmental 
EUR 3.7 billion  concerns  biodiversity  and  ecosystems, 
EUR 1.6 billion  pollution  prevention 
control, 
EUR 1.5 billion  water  and  EUR 1.3 billion  the  circular 
economy. 

investment 

and 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy  provides  EUR 120 billion  (over  half  of  it  through 
(RRF) 
ERDF), 
EUR 275.7 billion and CAP EUR 145.9 billion (137). 

recovery  and 

resilience 

facility 

the 

In  Poland,  the  EU  cohesion  policy  (considering  the  EU 
contribution amount) provides EUR 26.9 billion for climate 
action in 2021–2027 (with 58 % of this via the ERDF), with 
a  further  EUR 321 million  from  the  European  Maritime, 
Fisheries and Aquaculture Fund (138). 

The  RRF  contributes  to  climate  finance  in  Poland  with 
EUR 27.9 billion  up  to  2026,  representing  46.6 %  of  the 
RRP (139). 

(EIB)  provided 
Investment  Bank 
The  European 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid-2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 8.9 billion was assigned to 
Poland in the reference period (140). 

National financing, including EU emissions trading 
system revenues 

to  EUR 3 158 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
in  2020, 
budgets,  amounted 
EUR 5 594 million in 2021 and EUR 4 976 million in 2022, 
in  Poland,  totalling  EUR 13 727 million  in  the  three-year 
period.  In  Poland,  revenues  are  not  earmarked –  for 
example, projects have been reported for around 50 % of 
revenues each year (141). 

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

the  environment 

It should be noted that investment in climate action also 
the 
supports 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (142). 

therefore, 

and, 

Environmental financing and investments 

This section describes Poland’s investment needs, current 
four 
financing  and  gaps  as 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 

relate 

they 

the 

to 

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

European  Union, 

Luxembourg, 

2024, 

(138)  See 

the 

Cohesion 

Open 

Data 

Platform 

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

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

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

(140)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

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

(141)  European  Commission:  Directorate-General 

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

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

Environmental Implementation Review 2022 – Poland 

 
 
Poland  44 

between the EIR preparation cut-off date (31 October 2024) and 
its  publication  date.  Source  and 
information: 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

(b) 

(c) 

(d) 

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. 

6.12.2021, 

Annex XI, 

L 435 

Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  

Space  Fund,  Horizon  Europe,  financial 
environment and the Connecting Europe Facility. 

instrument  for  the 

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. 

Poland,  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 that are open to all Member States. These include the 
LIFE  programme  (EUR 5.4 billion) (144),  Horizon  Europe 

waste,  water  protection  and  management,  and 
biodiversity and ecosystems (143). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient  to  enable  Poland  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 20.8 billion  per  year  (in  2022 
prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 6.3 billion per year, can be attributed to the need to 
support pollution prevention and control, EUR 5.2 billion a 
year  to  the  circular  economy,  EUR 5 billion  a  year  to 
biodiversity  and  ecosystems,  and  4.3 billion  a  year  to 
water (in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 12.8 billion  in  Poland  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 22.6 billion for Poland in total, during 2021–2027 (or 
EUR 3.2 billion per year). 

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

Allocations 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural 
Guarantee Fund 
European  Agricultural  Fund 
for Rural Development 

European Maritime, 
Fisheries and Aquaculture 
Fund 

Other MFF sources 

RRF (d) (2021–2026) 

16 617.1 (a) 
10 589.3 
4 968.4 
1 059.4 
4 823.8 (b) 
3 575.1 
1 248.7 

278.2 

904.9 (c) 

14 223 

(a) 

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 

(143)  Research, development and innovation are accounted under each 
environmental objective. The financing needs, baselines and gaps 
estimates are based on the Directorate-General for Environment’s 

internal  analysis  (of  2024).  Throughout  this  chapter,  specific 
references are provided to the most important data sources used. 

(144)  https://cinea.ec.europa.eu/programmes/life_en. 

2025 Environmental Implementation Review – Poland 

 
 
 
 
(EUR 95.5 billion) (145),  the  Connecting  Europe  Facility 
(EUR 33.7 billion) (146) and the InvestEU programme (147). 

national  financing.  The  total  public  financing  (EU  plus 
national public) represents 66 % of the total. 

Poland  45 

Poland’s RRP supports climate objectives through funding 
of EUR 27.9 billion (47 % of total), with an additional 3.1 % 
for the environment (EUR 1.83 billion). 

The EIB provided around EUR 3.98 billion in environment-
related  financial  contributions  to  Poland  from  2021  to 
mid-2024, most of which, EUR 180.8 million (86 %), was in 
the  area  of  sustainable  energy,  transport  and  industrial 
projects,  which  provides  significant  co-benefits  to 
reducing  air  pollution,  environmental  noise  and  other 
pollution. 

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  Poland,  the 
total national environmental protection expenditure was 
EUR 14.8 billion 
in  2021, 
representing 2.8 % and 2.4 % of GDP, respectively. 

in  2020  and  EUR 14 billion 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Poland,  the  national 
0.4 %  of  the  EU’s  GDP. 
environmental 
reached 
protection 
EUR 2.6 billion  in  2020,  rising  to  EUR 2.7 billion  in  2021, 
representing 0.5 % of GDP. 

investment 

protection 

investment 

Split  by  institutional  sector,  41 %  of  Poland’s  national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 16 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  43 %  from  the  business  sector, 
whose environmental activities are usually ancillary to its 
main  activities.  At  the  EU  level,  38 %  of  environmental 
protection  investment  comes  from  governments,  40 % 
from  specialist  private-sector  producers  and  22 %  from 
the general business sector (148). 

Poland’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 12.8 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
fund (including EIB funds) reaches 43 %, with around 57 % 

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 8 billion per 
year in Poland, representing around 1.22 % of the national 
GDP, being higher than the EU-average (0.77 %). 

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

Source: Analysis of Directorate-General for Environment. 

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

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

Environmental 
objective 

Investment gap, per year  

% of GDP 

% of 
total 

Million 
EUR 
(2022 
prices) 

Pollution prevention 
and control 

1 578 

19.7 

0.2 

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

(146)  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. 

(147)  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. 

(148)  Eurostat, 

’Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Poland 

 
 
 
Poland  46 

1 251 

15.6 

0.2 

further 37 % from the RRF, adding up to 67 % of the total. 
EIB financing contributes 10 % and national sources reach 
24 % (151). 

1 513 

18.9 

0.2 

The gap 

0.6 

1.2 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  Poland 
needs  to  provide  an  additional  EUR 1.6 billion  per  year 
(0.24 % 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 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

3 669 

45.8 

Total 

8 011 

100.0 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In pollution prevention and control,  Poland’s investment 
needs  are  estimated  to  reach  EUR 6.3 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 6.1 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 
needs to reduce environmental noise reach EUR 1 billion 
per  year,  most  of  which  is  delivered  by  the  (same) 
sustainable  energy  and  transport  investments  that  also 
benefit clean air (149). Industrial site remediation requires 
an  estimated  EUR 121 million  per  year.  Microplastics 
pollution  and  the  chemicals  strategy  require  around 
EUR 70–90 million per year (each) (150). 

Current investments 

investment 

The  current 
levels  supporting  pollution 
prevention and control reach an estimated EUR 4.8 billion 
per  year  in  Poland  in  2021–2027.  Most  of  the  financing 
concerns  clean  air  (EUR 4.3 billion  per  year).  Protection 
from environmental noise receive around  EUR 1.3 billion 
per  year,  with  a 
for  site 
remediation. 

further  EUR 111 million 

In Poland, the EU MFF provides an estimated 29 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 

According to the latest (2023) NAPCP review report (152), 
Poland complied with ammonia reduction requirements in 
2020 and 2021 (while missed those for NMVOC and PM2.5), 
while it is not at risk of non-compliance with the NECD’s 
2030  emission  reduction  commitments,  based  on  the 
policies and measures in its NAPCP that takes into account 
climate, energy and CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

Poland’s investment needs in circular economy and waste 
reach  an  EUR 5.2 billion  per  year  (including  baseline 
investments).  Most  of  this,  around  EUR 4.8 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 0.4 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 (153). 

(149)  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 

(150)  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). 

(151)  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 

information  on  clean  air 

Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(152)  European Commission, ‘National air pollution control programmes 
website, 
European 

projections’, 

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

Commission 

(153)  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. 

2025 Environmental Implementation Review – Poland 

 
 
Current investments 

Circular economy investments across the economy reach 
around  EUR 3.8 billion  per  year  in  Poland  in  2021-2027, 
for  waste 
further  EUR 0.1 billion  provided 
with  a 
management that does not constitute circular economy. 

Around 2.8 % of this combined financing for circularity and 
waste  comes  from  the  EU  MFF,  with  a  further  0.6 % 
contribution from the RRF, adding up to 3.4 % of the total. 
EIB  loans  identified  in  support  of  circularity  and  waste 
represent 0.4 % of the total. The share of national sources 
is  absolutely  overwhelming,  reaching  96 %  of  the  total 
financing (154). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Poland  needs  to  increase 
investments  by  an  estimated 
circular  economy 
EUR 979 million 
additional 
EUR 272 million  concerning  waste  management  action, 
not  belonging  to  circular  economy.  Combined,  this 
amounts  to  EUR 1 251 million  per  year,  representing 
0.19 % of Poland’s GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 256 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 723 million constitutes further investment need 
to unlock Poland’s circular economy potential. 

Water protection and management 

Investment needs 

Poland  47 

investments  and  around  EUR 435 million 
protection and management of water (155). 

for 

the 

Current investments 

Water investments in Poland are estimated to be around 
EUR 2.8 billion per year (in 2022 prices) in 2021–2027. Of 
this,  EUR 1.3 billion  supports  wastewater  management, 
EUR 1.2 billion drinking water and around  EUR 0.3 billion 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Of the total financing,  15.9 % is provided by the EU MFF 
(mostly  through  cohesion  policy),  with  a  further  3.2 % 
support  from  the  RRF,  reaching  19.1 %  combined.  EIB 
financing  is  around  2.2 %  of  the  total,  while  the  bulk  of 
financing comes from national sources (79 %) (156). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Poland’s water investment gap reaches EUR 1.5 b million 
per  year  (0.23 %  of  GDP),  with  EUR 1.1 billion  linked  to 
wastewater  measures.  Drinking  water  measures  require 
an  additional  EUR 321 million  per  year  and  the  other 
aspects  of  the  Water  Framework  Directive  around 
EUR 103 million  per  year  over  the  existing  levels  of 
financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 5 billion per year (in 2022 prices) in 
Poland in 2021–2027. This includes the following financing 
needs: 

The  annual  water  investment  needs  reach  an  estimated 
EUR 4.3 billion  (in  2022  prices)  in  2021-2027  in  Poland. 
This  comprises  investment  needs  both  for  the  water 
industry and  for  the  protection  and  the  management  of 
water. Of the total annual need, EUR 2.4 billion relates to 
the management of wastewater (also including additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 1.5 billion  is  necessary  for  drinking  water-related 

• 

• 

• 

action 

prioritised 

framework (157), 
Poland’s 
concerning the Natura 2000 areas: EUR 1 293 million 
per year (mostly running costs); 
additional BDS costs (158): EUR 2 392 million per year 
on top of the prioritised action framework; 
sustainable 
EUR 1.3 billion per year. 

management 

costs (159): 

soil 

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

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

(156)  Water investment levels are estimated through tracking EU funds, 
EIB projects and national expenditure (EPEA accounts, Eurostat). 
(157)  European Commission, ‘Financing Natura 2000 – Prioritised action 
website, 

European 

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

Commission 

(158)  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 

(159)  See Proposal for a directive of the European Parliament and of the 
Council  on  soil  monitoring  and  resilience  (Soil  Monitoring  Law) 

2025 Environmental Implementation Review – Poland 

 
 
 
Current investments 

The current level of biodiversity financing is estimated to 
be EUR 1.3 billion per year (in 2022 prices) in 2021–2027. 
71 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

4 %  of  the  total  financing  is estimated  to  come  from  EU 
cohesion  policy,  49.5 %  from  the  CAP,  4 %  from  Horizon 
Europe,  and  around  1.5 %  from  LIFE  and  2 %  from  the 
European Maritime, Fisheries and Aquaculture Fund. The 
EU MFF altogether accounts for 82 % of the financing and 
the RRF for 1.7 %, adding up to a total of 83.4 % from the 
EU  budget.  The  rest,  17 %,  comes  from  national 
sources (160). 

Poland is the Member State with the second-lowest share 
of biodiversity financing programmed under CAP: 15.8 % 
of its CAP budget. Moreover, only 5.1 % of cohesion policy 
funds  (disregarding  ESF+)  in  2021–2027,  and  0.3 %  RRF 
funds  have  been  programmed  for 
in 
biodiversity in Poland (see Figure 36). 

investments 

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

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Poland’s 

Poland  48 

investment gap is estimated to be around EUR 3.7 billion 
per year, corresponding to 0.6 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States  already  use  green  budgeting  tools  for  identifying 
and  tracking  green  expenditures  and/or  revenues  (161). 
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 (162). 

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 (163), in which Poland participated. 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (164)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 18.3 billion in 
Poland in 2022, representing 2.8 % of its GDP (EU average: 
2.0 %).  Energy  taxes  formed  the  largest  component  of 
environmental taxes, accounting for 2.6 % of GDP, which 
is higher than the EU average of 1.6 %. Transport taxes, at 
0.2 %  of  GDP,  were  under  the  EU  average  (0.4 %),  while 
taxes on pollution and resources, at 0.09 % were slightly 
above  the  EU  average  (0.08 %).  In  2022,  environmental 
taxes in Poland accounted for 8.1 % of total revenues from 

COM(2023) 416 
https://environment.ec.europa.eu/publications/proposal-
directive-soil-monitoring-and-resilience_en. 
in 

tracking 

(160)  Based  on  biodiversity 

5 July 

final 

of 

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. 

(161)  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-

2023, 

2023, 

eu_en#:~:text=European%20Commission%20Green%20Budgetin
g%20Survey%C2%A0. 

(162)  European  Commission, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

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

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

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

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

2025 Environmental Implementation Review – Poland 

 
 
 
 
taxes  and  social  security  contributions  (above  the  EU 
average of 5.0 %) (165). 

Figure 37: Environmental taxes per Member State, 2022 

Poland  49 

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 had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively), and the share 
of water had remained around 5 %. 

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

issuances)  were 

Figure 38: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023 

The  European  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 (166),  Poland  applies  emission 
charges  (for emission  to water and air), product charges 
(batteries, electronics, plastic, tyres) and user charges (e.g. 
for  water  and  mineral  abstraction)  to  discourage 
environmentally harmful activities and behaviours. 

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. 

During 2021–2023 combined, Poland issued green bonds 
(EUR 8.2 billion).  Of  this,  the 
worth  USD 9.7 billion 
issuance 
to  USD 7 billion 
amounted 
2023 
(EUR 6.5 billion) (167). 

in 

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

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 (168). 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 

(165)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(166)  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)  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. 

(168)  Article 3(h) and 3(v) of the eighth environment action programme. 

2025 Environmental Implementation Review – Poland 

 
 
 
 
 
to  the  2021  energy  crisis  and  subsequent  increase  in 
energy prices. 

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 

Poland  50 

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 103 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (169). 

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 (170). In particular, FFS for coal and 
lignite, natural gas and oil increased in 2022, and a strong 
increase was observed for natural gas subsidies. 

In  Poland,  the  energy  subsidies  showed  an  increasing 
trend between 2015 and 2021, followed by rapid annual 
growth in 2022 and 2023. FFS ranged from EUR 1.5 billion 
to EUR 2.7 billion per year between 2015 and 2021, while 
they reached EUR 5 billion in 2022 and EUR 14.8 billion in 
2023. 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden. Poland’s value 
reached 0.8 %, equal to the EU average (0.8 %) (171). 

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

The 2022 EIR included the following recommendations for 
Poland. 

• 

• 

Poland  should  devise  an  environmental  financing 
strategy  to  maximise  opportunities  for  closing 
gaps,  bringing 
implementation 
environmental 
together all relevant administrative levels. 
Poland should ensure an increased level of financing 
for  the  environment  (both  from  EU  and  private 
sources) to cover the high level of investment needs 
across  the  environmental  objectives  and  to  prevent 
likely financing gaps from leading to investment gaps. 

The overall environmental investment gap has decreased 
since the 2022 EIR, and has now reached around 1.2 % of 
GDP, while still being above the EU average. 

2025 priority action 

Recognising  certain  developments  and  the  fact  that  the 
investment  gap  is  above  the  average,  the  previous 
recommendation is maintained, and further explained. 

•  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.  

(169)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

(171)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 

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

(170)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

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

2025 Environmental Implementation Review – Poland 

 
 
 
 
 
Poland  51 

6. Environmental governance

Information, public participation and access 
to justice 

Table 3: Poland dashboard on the implementation of 
the Inspire Directive, 2016–2023 (176) 

2016 

2023 

Legend 

Citizens can more effectively protect the environment 
if  they  rely  on  the  three  ‘pillars’  of  the  Aarhus 
Convention:  (i)  access  to 
information,  (ii)  public 
participation  in  decision-making  and  (iii)  access  to 
justice  in  environmental  matters.  It 
is  of  crucial 
importance  to  public  authorities,  the  public  and 
businesses  that  environmental  information  is  shared 
efficiently  and  effectively (172).  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 (173).  It  includes  the  right  to  bring  legal 
challenges (‘legal standing’) (174). 

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 
information.  Geographic 
information is needed for good governance at all levels 
and should be readily and transparently available. 

this 

to 

Poland’s  performance  in  implementing  the  Inspire 
Directive  is  substantial  and  has  been  reviewed  based 
on its 2023 country fiche (175) (see Table 3). 

(172)  The  Aarhus  Convention 

(https://unece.org/environment-
policy/public-participation/aarhus-convention/text), 
the 
Access  to  Environmental  Information  Directive  (Directive 
(https://eur-lex.europa.eu/legal-
2003/4/EC) 
Inspire 
content/EN/TXT/?uri=CELEX:32003L0004)  and  the 
Directive 
(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. 

2007/2/EC) 

(Directive 

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

(174)  This  EIR  focuses  on  the  means  used  by  Member  States  to 
guarantee rights of access to justice and legal standing and to 

Effective 
sharing 

coordination  and  data 

Ensure 
coordination 

effective 

Data 
without obstacle 

sharing 

■ 

■ 

Inspire performance indicators 

■ 

■ 

■ 

(i)  Conformity  of 
metadata 

(ii)  Conformity  of 
spatial datasets  

(iii) Accessibility of 
spatial 
datasets 
through  view  and 
download services 

(iv)  Conformity  of 
network services 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■  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 
completed. 
Percentage = 31–
89 % 

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

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

In 2022, Poland received a priority action on the need 
to  make  spatial  data  more  widely  accessible  and 
prioritise the environmental datasets (177). Poland has 

overcome  other  major  barriers  to  bringing  cases  on 
environmental protection. 

(175)  European  Commission,  ‘Poland’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/poland_en; 
European Commission, ‘High-value datasets’, https://inspire-
geoportal.ec.europa.eu/srv/eng/catalog.search#/hvdshome; 
European  Commission,  ‘Indicators in  support  of  Commission 
Decision  (EU)  2019/1372  implementing  Directive  2007/2/EC 
(Inspire)  as  regards  to  monitoring  and  reporting –  Poland’, 
https://inspire-
geoportal.ec.europa.eu/mr/mr2023_details.html?country=pl. 
(176)  European  Commission,  ‘Poland’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/poland_en. 

(177)  European 

Commission’s 

spatial 
list 
datasets (https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityData
List_V2.1_final_20201008.xlsx). 

high-value 

of 

2025 Environmental Implementation Review – Poland 

 
 
 
 
made good progress on improving the accessibility of 
spatial  data,  but  more  efforts  are  needed.  Therefore, 
the 2022 priority action is repeated. 

Public participation 

impact 

assessment  procedure. 

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 
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 
into 
carried  out  with  due  diligence  and  taking 
consideration useful public input, this process leads to 
better-informed  decision-making  and  can  promote 
information  available 
public  acceptance.  Making 
lessening 
increases  stakeholder 
resistance and preventing (or minimising) litigation. On 
the other hand, it is paramount that the procedure is 
effective. 

involvement,  thus 

This  section  examines  how  public  involvement  and 
transparency  are  ensured  under  two  instruments, 
namely  the  Environmental  Impact  Assessment  (EIA) 
Directive (178)  and 
the  Strategic  Environmental 
Assessment (SEA) Directive (179). 

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(180).  Poland  has  not  yet  taken  steps  aiming  to 
accelerate 
taking 
advantages of the broad flexibilities offered by the EU 
legal framework, such as the establishment of one-stop 

permit-issuing 

procedures 

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

(179)  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. 

(180) 

Commission Staff  Working  Document    (SWD/2022/0149 
final),  18  May  2022,  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=165
3034229953). 

Poland  52 

shops  and  accelerated  short  deadlines  for  issuing 
permits for renewable energy projects. 

The  average  speed  in  the  EU  for  issuing  permits 
involving  an  EIA  procedure  is  20.6 months,  with  a 
minimum  duration  of  11.4 months  and  a  maximum 
duration of 75.7 months (181). The duration of each step 
in an EIA process (screening, scoping, EIA report, public 
reasoned  conclusion,  development 
consultation, 
consent) varies considerably between Member States 
and projects. The available data for Poland do not cover 
all  the  steps  of  the  EIA  to  draw  overall  conclusions. 
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 (182). 

Polish  provisions  transposing  the  EIA  and  SEA 
Directives into national law require the general public 
to be informed, including via electronic tools, about the 
initiation of a public participation procedure within an 
EIA or SEA. The public also needs to be informed about 
the practical arrangements for participating (when and 
how  to  get  access  to  the  documentation  available, 
when  and  how  to  submit  comments,  etc.).  After  a 
decision  preceded  by  an  EIA  is  made,  it  must  be 
published, including online. No statistics on the level of 
public participation are available. The situation in this 
regard has not changed since the 2019 EIR. 

The  2019  EIR  recommended  that  Poland  facilitate 
public participation in implementing EU environmental 
legislation.  Since  2019,  Poland  has  only  made  some 
progress on this issue. Therefore, this priority action is 
reiterated. 

Access to justice 

Access  to  justice,  guaranteed  by  Article 19(1)  of  the 
Treaty  on  European  Union  and  Article 47  of  the  EU 

(181)  European Commission: Directorate-General for Environment, 
Collection of information and data on the implementation of 
the  revised  Environmental  Impact  Assessment  (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/, 
tables 5 and 6. 

(182)  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 

2025 Environmental Implementation Review – Poland 

 
 
 
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  outlined 
law  allows 
in  the  2022  EIR,  Polish 
individuals  who  can  prove  that  they  have  a  legal 
interest  or  right,  and  recognised  NGOs,  to  challenge 
individual decisions relating to the environment before 
the administrative authorities and the courts. 

However, access to justice beyond individual decisions 
is not consistently guaranteed. For example, negative 
screening  decisions  from  EIAs  require  the  prior 
participation of applicants. 

Access to a review procedure for plans or programmes 
adopted  as  regulations  (rozporządzenie),  such  as 
RBMPs,  is  extremely  limited.  Polish  law  does  not 
provide  a  mechanism  for  NGOs  or  individuals  to 
challenge such plans or programmes. 

Similarly,  access  to  a  review  procedure  for  plans  or 
programmes adopted as local acts, such as air quality 
plans,  is  limited.  To  establish  standing,  Polish  law 
requires the establishment of an infringement of a legal 
interest or a right. However, according to the case-law 
of Poland, no such infringement can be established as 
regards  environmental  plans  or  programmes,  which 
create  obligations  only  for  authorities  that  are 
responsible  for  the  implementation  of  the  measures 
listed in the plan or a programme. As such, plans and 
programmes adopted as local acts cannot in practice be 
challenged by members of the public concerned. 

To  address  this  non-compliance,  the  Commission 
opened  an  infringement  case,  which  covers  a  lack  of 
standing  for  the  public  concerned  to  challenge  air 
quality plans adopted under the AAQD. In September 
2022,  the  Commission  sent  a  reasoned  opinion  but, 
with a lack of any changes to the law since then, the 
Polish  system  remains  non-compliant.  Poland  should 
amend  the  necessary  provisions  as  soon  as  possible 
with 
to  all  environmental  plans  and 
regard 
programmes. 

(183)  European 

spatial 
list 
datasets (https://github.com/INSPIRE-MIF/need-driven-data-

Commission’s 

high-value 

of 

Poland  53 

As  mentioned  in  previous  sections,  Poland  was  also 
condemned  by  the  Court  of  Justice  in  the  ruling  of 
2 March 2023 in case C-432/21 for lack of guaranteed 
access  to  justice  as  regards  forest  management.  The 
Commission notes that Poland is currently working on 
the necessary amendments to the law, but these steps 
should be accelerated. 

In 2022, a priority action was directed at Poland to (i) 
further  enhance  access  to  courts  for  the  concerned 
public in challenging decisions, acts or omissions; and 
(ii) better inform the public about their access to justice 
rights. There has been no progress. 

2025 priority actions 

• 

• 

•  Make  spatial  data  more  widely  accessible  and 
prioritise environmental datasets in implementing 
the Inspire Directive, especially those identified as 
high-value  spatial  datasets  for 
implementing 
environmental legislation (183). 
Ensure  correct  transposition  of  the  revised  EIA 
Directive. 
Ensure  that  relevant  information  on  EIA  and  SEA 
procedures  (including  on  public  participation 
opportunities  and  on  the  publication  of  final 
decisions)  is  electronically  accessible  in  a  timely 
manner, through at least a central portal or easily 
accessible 
appropriate 
at 
points, 
administrative level. 
national 
Improve 
environmental cases by the public concerned and 
eliminate  practical  barriers,  such  as  length  of 
proceedings and excessive costs in some Member 
States. 

access 

courts 

the 

to 

in 

• 

prioritisation/blob/main/documents/eReporting_PriorityData
List_V2.1_final_20201008.xlsx). 

2025 Environmental Implementation Review – Poland 

 
 
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 (184) 
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 

reasons, 

for  different 

Non-compliance  with  environmental  obligations  may 
occur 
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. 

Poland  54 

national source for conviction outcomes and penalties 
remains unavailable. 

In November 2023, a regional conference dedicated to 
strengthening  the  fight  against  crime  affecting  the 
environment  was  held,  which  representatives  from 
Albania,  Bosnia  and  Herzegovina,  Bulgaria,  Croatia, 
France,  Greece, 
Kosovo,  Montenegro,  North 
Macedonia,  Serbia,  Slovakia,  Slovenia,  Poland  and 
Romania attended (187). 

The 2022 EIR recommended that Poland (i) provide and 
actively  distributes  information  to  help  farmers  meet 
their  obligations  as  regards  Natura  2000;  (ii)  provide 
more  online  information  on  inspection  plans,  the 
number of inspections actually carried out and reports 
on the inspections. Concerning compliance promotion, 
administrative 
monitoring 
enforcement,  the  2022  priority  actions  are  not 
assessed here due to a lack of systematic information. 
Similarly,  the  Commission  is  not  aware  of  whether 
information  is  easily  available  online  at  the  national 
level to farmers regarding compliance with the Nitrates 
and  Nature  Directives,  and  hence  the  2022  priority 
action is not assessed. 

criminal 

and 

and 

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

in 

As  mentioned 
the  2022  EIR,  statistics  on 
environmental  crimes  in  Poland  are  available  for  the 
number  of  proceedings  initiated,  number  of  crimes 
stated and number of crimes for which the perpetrator 
was  found,  via  the  website  of  the  Polish  police 
force (185). 

It  appears  that  since  the  2022  EIR  Poland  has 
strengthened  its  approach  to  tackling  environmental 
crime.  Notably,  the  government 
introduced  strict 
penalties  for  environmental  offences,  targeting  both 
natural and legal persons. 

Between  15 May  2022  and  31 December  2024,  the 
Commission  received  52  complaints  relating  to  the 
environment  in  Poland,  the  fifth  highest  number  of 
complaints for  that period among all Member States, 
although in terms of complaints per million inhabitants 
the amount is 1.41, well below the EU average of 3.2 
(figures  40  and  41).  Over  half  of  these  complaints 
concerned  alleged  breaches  of  the  Nature  Directives, 
while  another  significant  proportion  concerned 
environmental impact assessment issues. 

it  appears 

Regarding  statistics  on  environmental  crime  and 
convictions, 
that  Poland’s  statistics 
office (186) regularly publishes general crime statistics, 
but 
recent 
environmental crime convictions  are not yet centrally 
published. Local sources may occasionally publish data 
on  specific  cases,  but  a  consolidated,  up-to-date 

specific  and  accessible  data  on 

(184)  The  concept 

in  detail 

is  explained 

in  the  European 
Commission’s 201  communication on EU actions to improve 
environmental  compliance  and  governance  (https://eur-
lex.europa.eu/legal-
the 
content/EN/TXT/?uri=CELEX%3A52018DC0010) 
related  Commission  staff  working  document  (https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

and 

(185)  https://statystyka.policja.pl/st/kodeks-karny/przestepstwa-
przeciwko-3/63471,Zniszczenia-w-swiecie-roslinnym-i-
zwierzecym-art-181.html. 

(186)  https://stat.gov.pl/en/. 
(187)  https://www.selec.org/strengthening-the-fight-against-crimes-
that-affect-the-environment-in-southeast-europe/  

2025 Environmental Implementation Review – Poland 

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

Source: DG Environment complaints data. 

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

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

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 
(Directive 
Environmental  Crime  Directive 
(EU) 
2024/1203)(188)  and  new  sectoral 
legislation  with 

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

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

law 

(189)  https://www.impel.eu/en. 
(190) 

LIFE+SATEC 
(https://webgate.ec.europa.eu/life/publicWebsite/project/LI

project 

Poland  55 

stronger  provisions  on  compliance  monitoring, 
enforcement  and  penalties.  Issues  important  for  the 
transposition and 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. 

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  for  natural  and  legal  persons  who 
introduced.  Other 
commit  an  offence  were  also 
provisions  will  help  considerably  to 
improve  the 
effectiveness in combating environmental crime of all 
actors  along  the  enforcement  chain.  These  include 
obligations 
resources  and 
investigative tools, specialised regular training and the 
establishment of cooperation mechanisms within and 
between Member States as well as national strategies 
on combating environmental crime. 

to  ensure  adequate 

and 

approaches. 

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 
The 
strategic 
including  by 
Commission  will  provide  support, 
facilitating  the  identification  and  sharing  of  good 
practices. Member States are expected  to ensure  the 
necessary resources and 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  as  the  EU  Network  for  the  Implementation  and 
Law (189), 
Enforcement 
EnviCrimeNet (190), 
European  Network  of 
Prosecutors  for  the  Environment (191)  and  the  EU 
Forum  of  Judges  for  the  Environment (192).  The 
for  Law  Enforcement 
European  Union  Agency 
Cooperation and European Union Agency for Criminal 
Justice  Cooperation  mechanisms  for  cooperation  on 

Environmental 

the 

of 

FE20-PRE-ES-000001/fight-against-environmental-crime-at-a-
strategic-level-through-the-strengthening-of-envicrimenet-
network-of-experts-in-environmental-criminal-
investigations). 

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

2025 Environmental Implementation Review – Poland 

 
 
 
 
 
cross-border cases should be used more systematically 
for environmental offences.  

aim of enabling operators to use financial guarantees 
to cover their responsibilities under this directive. 

Poland  56 

Environmental Liability Directive 

The Environmental Liability Directive (ELD)(193) 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  tool  and  a  key  enabler  for  better 
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 (194),  which  will  be  finalised  in 
2025,  and  which  was  supported  by  an  external 
study (195),  containing,  among  other  things,  evidence, 
views, reports and other relevant information gathered 
from different  stakeholder groups, including Member 
States. 

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

compared  with 

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 the development  of 
financial  security  instruments  and  markets,  with  the 

From  1 May  2013  to  31 December  2021,  Poland 
reported  236  occurrences  of  environmental  damage 
under  the  ELD  (163  were  land  damage,  63  were 
biodiversity damage, and 39 were water damage, with 
the caveat that some occurrences affected two or even 
all  three  natural  resources),  representing  one  of  the 
largest  decreases  compared  with 
the  previous 
reporting  period,  where  506  environmental  damage 
occurrences  were  reported  under  the  ELD.  Due  to  a 
lack  of  reporting  functions  in  the  registry  of  ELD 
include 
occurrences,  Poland’s 
imminent threats of environmental damage. Poland is 
one  of  the  Member  States  with  the  highest  overall 
number of reported ELD occurrences. Poland’s national 
ELD legislation was, initially, broader in scope than the 
ELD,  including  several  enhanced,  more  stringent  or 
larger scope provisions, while Poland also repealed the 
potentially  overlapping  previous  national  legislation. 
The  diminished  figures  in  Poland  for  the  second 
reporting  period  can  also  be  attributed  to  the 
amendment of the national legislation transposing the 
ELD in 2014, removing some provisions that had been 
more stringent than the ELD. 

report  does  not 

liabilities 

Poland  has  not  introduced  a  separate  mandatory 
financial  security  system  for  ELD  liabilities.  However, 
is 
mandatory  financial  security  for  ELD 
required  in  some  other  legal  acts,  for  example  in 
relation  to  waste  handling  activities  or  activities  that 
require a permit.  Moreover, environmental insurance 
policies that provide cover for on-site and off-site ELD 
liabilities  are  available  as  well.  Some  policies  provide 
cover only for pollution from a sudden and accidental 
incident  on  an  insured  site. Demand  is  moderate  but 
has  been 
increasing.  Environmental 
extensions  to  general  liability  policies  are  available. 
They  do  not  tend  to  provide  cover  for  ELD  liabilities 
other  than  off-site  primary  remediation  if  it  overlaps 
with 
remediation  under  other  environmental 
legislation. Demand for them is greater than demand 
for environmental insurance policies. 

gradually 

2025 priority action 

• 

Encourage  the  use  of  training  programmes 
provided by the Commission (or developed at the 
national level) covering the ELD and its interactions 
liability-related 
with 

national 

other 

the 

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

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

law 

(194)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

(195)  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 – Poland 

 
 
 
to  ensure  more  efficient  ELD 
instruments, 
implementation,  improve  the  expertise  of  the 
competent authorities and raise awareness among 
all stakeholder groups. 

EU-supported environmental capacity 
building 

The  Commission’s  2023  Compact (196)  initiative  to 
enhance  the  administrative  space 
identifies  the 
capacity to lead the green transition as one of three key 
pillars,  along  with  the  public  administration  skills 
agenda  and  the  capacity  for  Europe’s  Digital  Decade. 
Compact also recognises the role of the EIR reporting 
tool in improving environmental governance. The two 
main 
the 
environment  provided  by  the  European  Commission 
are  the  TSI (197)  and  the  TAIEX-EIR  PEER  2  PEER 
tool (198).  The  technical  assistance  available  through 
the cohesion policy is subject  to shared management 
and is not dealt with in this subsection. 

capacity-building 

opportunities 

for 

The Commission’s technical support instrument 

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

In  the  2024  and  2025  TSI  calls,  the  following 
environment-related  projects  were  selected 
for 
Poland: 

• 

Strengthening Poland’s capacity to model the 
macroeconomic effects of ‘green’ policies and 
investments 
the  GreenReform 
model –  the  National  Centre  for  Emissions 
of 
(KOBiZE) / 
Management 
in  the  National 
Environmental  Protection 

Institute 

through 

(196)  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). 

(197)  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). 

(198)  See  the  European  Commission  web  page  on  the  TAIEX-EIR 
PEER  2  PEER  tool  (https://environment.ec.europa.eu/law-
and-governance/environmental-implementation-
review/peer-2-peer_en).  TAIEX:  Technical  Assistance  and 
Information Exchange. 

(199)  Flagship multi-country workshops in the reporting period are: 
Recast Drinking  Water Directive (3 April 2025); Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16 
January  2025); 
Industrial  safety:  awareness  raising  of 
emerging risks linked with climate change and decarbonation 
(12 December 2024); Air quality: implementation of the NEC 

Poland  57 

Research Institute (2024); 

• 

• 

• 

implementation  of  the 

Support  to  the 
just 
transition  in  Poland –  Ministry  of  Development 
Funds and Regional Policy (2024); 
Support in the field of water supply and rainwater 
management – Ministry of Infrastructure (2024); 
• 

Support  to  the  development  of  the  National 
Restoration Plans; multi-country project with 
HR,  NL  and  PL  -  Ministry  of  Climate  and 
Environment (2025). 

Effective  implementation  of  Energy  Performance 
of Buildings Directive (EPBD) in Poland – Ministry 
of Economic Development and Technology (2025). 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

In 2017, the Commission launched the TAIEX-EIR PEER 
2 PEER tool. 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  multicountry  workshops  are 
those  requested  by  the  European  Commission  to 
present  new  and  upcoming  environmental  legislation 
and policy for all Member States (199).  

Workshops involving Poland are as follows: 

• 

• 

Circular  economy  (in  the  Irish  midlands)  (4–
6 October 2022); 
Future challenges for air protection (24 November 
2022), with the Czech Presidency of the Council of 
the European Union; 

•  Make  space  for  biodiversity:  Regional  action  to 
empower 
biodiversity 

mainstream 
stakeholders (21–23 March 2023); 

and 

•  Best  practice  in  applying  Art. 6(3)  of  Habitats 

in  agricultural  policy 

Directive  to  further  mainstream  air  and  broader  pollution 
(25 September  2024); 
reduction 
Industrial emissions transposition and implementation of the 
revised  directive  (12 September  2024);  Noise:  progress 
towards  meeting  Member  States’  noise  limit  values  and  EU 
reduction  targets  (5 June  2024);  Best  practice  use  of 
environmental footprint methods on the EU market (30 May 
2024); Sustainable finance (9 November 2023); Textile waste 
separate collection, treatment and markets (3 October 2023); 
EU  environmental  funding  and  support  (13 June  2023); 
Advisory service for businesses to go circular (24 April 2023); 
Digital product passport implementation (6 December 2022); 
Public  involvement  in  planning  and  approval  of  renewable 
energy  projects 
(17 November  2022);  Environmental 
compliance  and  governance  (14 November  2022);  Biowaste 
management  (19–20 September  2022);  and 
  Renewable 
energy projects: permit granting processes (13 June 2022). NB: 
The first flagship workshop on zero pollution for air, water and 
soil took place 9 February 2022. 

2025 Environmental Implementation Review – Poland 

 
 
 
Directive:  Practical  solutions  to  carry  out  Natura 
impact  assessments  effectively  (25–27 October 
2023); 

•  Biodiversity,  nature  conservation  and 

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

•  Measures to reduce air pollution in transport and 

residential energy (11–13 June 2024); 

•  New  aspects  in  the  cross-border  cooperation 
against  environmental  crime  (19–20 November 
2024). 
Freight  transport  by  rail  (in  relation  to  waste 
transport) (17 - 18 March 2025). 

• 

Poland  58 

The Polish authorities participated in two study visits: 
to  Florence  and  Pisa,  on  the  preparation  of  strategic 
noise maps and action plans (15–16 June 2022); and to 
Bologna,  on  water  management  (UWWTD  and  best 
practices on water reuse in agriculture) (17–18 October 
2022). 

2025 priority action 

• 

overall 

national 

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

2025 Environmental Implementation Review – Poland 

 
 
 
Poland  59 

Annex 

2025 priority actions 

Circular economy and waste management 
Transitioning to a circular economy 

•  Adopt measures to increase the CMUR.  
• 

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 

• 
• 
• 
• 

• 

• 
• 

Complete the closure of non-compliant landfills.  
Invest in waste prevention measures to reduce the total amount of waste generated.  
Improve municipal waste preparation for reuse and recycling.  
Increase reuse of products and scale up waste recycling infrastructure associated with the higher 
steps of the waste hierarchy. In particular, improve collection and increase treatment capacity for 
biowaste. 
Improve separate collection at the source (e.g. through using 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.  
Extend the pay-as-you-throw system to all households, and fully introduce cost coverage rules as 
part of EPR for packaging.  

•  Develop EPR schemes for problematic waste and introduce fee modulation.  
• 

Ensure the achievement of the 2025 waste targets, following the recommendations made by the 
Commission in the early warning reports where applicable.  

•  Ratify the Hong Kong Convention on Ship Recycling.  

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 GBF. 

Nature protection and restoration – Natura 2000 

Complete the Natura 2000 site designation process. 

Recovery of species  

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. 

•  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 

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• 

Implement  eco-schemes  and  agri-environmental  measures  and  practices  to  address  the 
environmental needs of Poland. 
Implement and scale up the uptake of organic farming practices. 

• 
•  Designate the  competent  authority or authorities responsible for fulfilling the obligations arising 
from  the  EUDR  and  inform  the  Commission  of  the  names,  addresses  and  contact details  of  said 
competent authority or authorities. 
Implement  peatland  conservation  and  restoration  measures  and  include  such  measures  and 
objectives in the national restoration plans. 
Implement the Court ruling to ensure public access to justice regarding forest management plans. 
Ensure long-term protection for old-growth and ecologically or socially significant forests, including 
the Białowieża Forest, in compliance with the Court’s judgment. 

• 

• 

•  Report updates on the assessment of the state of Poland’s marine waters, its target and its 

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

Prevention and management of invasive alien species  

• 

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

Ecosystem assessment and accounting  

Support the development of the national business and biodiversity network. 

• 
•  Ratify the Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of 

Benefits Arising from their Utilization to the Convention on Biological Diversity. 

Zero pollution 
Clean air 

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

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

•  Accelerate the ratification of relevant international conventions and protocols. 

Industrial emissions 

• 
Complete the correct transposition of IED 1.0. 
•  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 

Strengthen  compliance  with  requirements  on  safety  measures  to  prevent  major  accidents  and 
ensure  appropriate  preparedness  and  response  in  relation  to  UTEs,  in  particular  as  regards 
reviewing, testing and updating EEPs, at intervals of no more than three years. 
Ensure access to transparent and clear information for citizens on risks and behaviour in the event 
of an accident. 
Ensure full and correct transposition of the Seveso III Directive. 

• 

• 

• 

• 

•  Complete and implement action plans on noise management. 

Noise 

Water quality and management 

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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. 

Improve the classification of water bodies and strengthen monitoring systems. 

•  Reduce pollution from nutrients, chemicals, metals and saline discharges. 
•  Better justify exemptions to the achievement of good status. 
• 
•  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 FRMPs. 

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

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

• 

Drinking Water Directive  

• 

Take actions to ensure full compliance with the Drinking Water Directive.  

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 the 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. 

Climate action 

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

•  Make spatial data more widely accessible and prioritise environmental datasets in implementing 
the  Inspire  Directive,  especially  those  identified  as  high-value  spatial  datasets  for  implementing 
environmental legislation. 
Ensure correct transposition of the revised EIA Directive. 
Ensure  that  relevant  information  on  EIA  and  SEA  procedures  (including  on  public  participation 

• 
• 

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opportunities  and  on  the  publication  of  final  decisions)  is  electronically  accessible  in  a  timely 
manner,  through  at  least  a  central  portal  or  easily  accessible  points,  at  the  appropriate 
administrative level. 
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 – Poland