COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - GERMANY 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, Germany, 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) 310 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review             Country Report - GERMANY                     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) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Germany  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 5 
Transitioning to a circular economy ..................................................................................................................... 5 
Waste management ............................................................................................................................................ 7 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 12 
Global and EU biodiversity frameworks ............................................................................................................. 12 
Nature protection and restoration – Natura 2000 ............................................................................................. 12 
Recovery of species ............................................................................................................................................ 14 
Recovery of ecosystems ..................................................................................................................................... 15 
Prevention and management of invasive alien species ...................................................................................... 20 
Ecosystem assessment and accounting ............................................................................................................. 21 
3. ZERO POLLUTION ..................................................................................................................................................... 23 
Clean air ............................................................................................................................................................. 23 
Industrial emissions ............................................................................................................................................ 24 
Major industrial accidents prevention – Seveso ................................................................................................. 26 
Mercury Regulation ............................................................................................................................................ 28 
Noise .................................................................................................................................................................. 28 
Water quality and management ........................................................................................................................ 29 
Chemicals ........................................................................................................................................................... 33 
4. CLIMATE ACTION ..................................................................................................................................................... 36 
The EU emissions trading system ....................................................................................................................... 37 
Effort sharing ..................................................................................................................................................... 37 
Land use, land-use change and forestry ............................................................................................................. 38 
Adaptation to climate change ............................................................................................................................ 38 

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

5. FINANCING ............................................................................................................................................................. 39 
Climate finance landmarks ................................................................................................................................. 39 
Environmental financing and investments ......................................................................................................... 40 
Public financial management ............................................................................................................................. 44 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 47 
Information, public participation and access to justice...................................................................................... 47 
Compliance assurance ........................................................................................................................................ 49 
EU-supported environmental capacity building ................................................................................................. 52 

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
 
 
Germany  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 
describing 
the  main  outstanding  challenges  and 
opportunities  on  environmental  legal  implementation  in 
Germany.  The  purpose  of  this  report  is  to  provide 
information  on  the  implementation  performance  and 
highlight  the  most  effective  ways  to  address  the 
implementation gaps which 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.  

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  taking  into 
account factors such as the gravity of the environmental 
implementation issue in light of the impact on the quality 
of life of the citizens, the distance to target and financial 
implications.  In  Germany  such  challenges  have  lingered 
since  the  first  Environmental  Implementation  Review  in 
2017  and  require  urgent  action.  Despite  many  nature 
restoration  efforts  of  Germany,  the  condition  of  many 
ecosystems  has  continued  to  deteriorate.  In  Germany, 
the status of 63 % of the species and 69 % of the habitat 
types  listed  in  the  Habitats  Directive  is  classified  as 
“unfavorable-inadequate” or “unfavorable-bad”, and only 
9  %  of  surface  waters  are  in  good  or  better  ecological 
like  the  hay  meadow  have 
status.  Habitat  types 
significantly diminished in size or disappeared completely 
at  various  sites  in  recent  years.  Also,  the  populations  of 
bird species protected by the Birds Directive in Germany 
have decreased to a significant extent. Further restoration 
measures and change in land use practices are needed. 

Pollution  from  agriculture  and  industry  puts  significant 
pressure on water bodies and soils, with nitrate being the 
worst pollutant, causing failure to achieve good chemical 
status in groundwater.  

(1) 

from 

the  Commission 

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

to 

Germany  is  among  the  best  performers  in  the  EU  with 
regard  to  waste  management.  The  recycling  rate  of 
packaging waste stands at 69% in 2022 and the landfill rate 
is below 1%. However, Germany also generates far more 
waste than the EU average. Overall, there appears to be a 
very small decoupling of waste generation from economic 
growth  throughout  the  period  2010-2022.  Nevertheless, 
most recently a positive trend can be observed, as waste 
generation declined across nearly all waste categories.  

The overall investment needs to enable Germany to meet 
its objectives in the main environmental areas amount to 
EUR 80.2 billion per year, broken down as follows: circular 
economy  (EUR  42  billion);  water  (EUR  19.4  billion); 
pollution  prevention  and  control  (EUR  13.4  billion)  and 
biodiversity  and  ecosystems  (EUR  5.7  billion).  To  meet 
these  four  environmental  objectives  beyond  climate 
change, the additional investment need over the current 
levels – the investment gap – is estimated at EUR 20 billion 
per  year  in  Germany,  representing  around  0.52%  of  the 
national GDP, being lower than the EU-average (0.77%). 

In  terms  of  governance,  Germany  has  provided  better 
public  information  on  access  to  justice  by  linking  to  the 
European  eJustice  Portal 
factsheet  on  a  German 
government  website.  Germany  makes  environmental 
implementation  assessment  portals  available  at  the 
federal  and  Länder 
levels.  These  portals  provide 
information  on  projects,  including  short  summaries  and 
details on public participation, the progress made on the 
authorisation  procedure,  and  the  final  decision  on  the 
approval of the project.  

Germany’s  circular use of materials has been increasing 
steadily  over  the  past  decade,  reaching  14%  in  2023, 
compared to the EU average of 11.8%. With the adoption 
of  Germany’s  first  comprehensive  national  circular 
economy  strategy  in  December  2024  this  positive  trend 
will be further supported.  

Through  its  “Action  Plan  on  Nature-based  Solutions  for 
Climate  and  Biodiversity”  (ANK)  –  funded  by  EUR  3.5 
billion  from  2024  to  2027  –  the  government  intends  to 
resilience  and  climate  protection 
strengthen 
performance of German ecosystems. The restoration and 
rewetting of peatlands is an essential component. 

the 

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

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
 
Germany  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 
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. 

consumption.  A 

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

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

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

Germany’s  circular  use  of  materials  has  been  increasing 
steadily  over  the  past  decade,  reaching  14 %  in  2023, 
compared to the EU average of 11.8 %. 

15

10

5

0

2013

2015

2017

2019

2021

2023

Germany

EU-27

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

November 

December 

2024, 

10 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
can help to minimise negative impacts on the environment 
and reduce dependency on volatile raw material markets. 

As shown in Figure 2, with EUR 3.04 generated per kg of 
material  consumed  in  2023,  resource  productivity  in 
Germany is well above the EU average of EUR 2.23 per kg. 
This  positive  performance  is  further  supported  by  a 
continuous  increase  in  Germany’s  resource  productivity 
over the last decade. 

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

4,

3,

2,

1,

0,

2013

2015

2017

2019

2021

2023

Germany

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. 

(2) 

from 

the  Commission 

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

to 

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

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
Germany  5 

cycle analysis, PaaS (platform as a service) second hand) 
can help drive the demand for sustainable products that 
meet reparability and recyclability standards. 

Given  that  the  federal  authorities  aim  to  be  climate 
neutral  by  2045,  a  stricter  and  more  comprehensive 
regulation of green public procurement called AVV Klima 
entered  into  force  on  1 January  2022.  The  elements  it 
introduced include life-cycle costing, a list banning certain 
single-use  plastics,  encouragement  of  alternatives  to 
buying 
than 
ownership),  and  prioritisation  of  recycled  products.  The 
German government used the occasion of transposing the 
2018 waste package into national waste law to make the 
green  public  procurement  of 
recycled  products 
mandatory. 

(emphasising  genuine  benefit 

rather 

further  measures  have  been  brought  to  the 
No 
Commission’s  attention  since  the  2022  Environmental 
Implementation Review (EIR). 

The EU Ecolabel and the eco management and audit 
scheme  

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

reducing 

aimed 

at 

As of September 2024, Germany had 9 798 products out 
of 98 977 and 465 licences out of 2 983 registered in the 
EU  Ecolabel  scheme.  Germany  ranks  first  on  registered 
licences and fourth on products in Europe (7). Moreover, 
as  of  October  2024,  1 181  organisations  from  Germany 
were registered in EMAS, 66 more than in 2021 (8). 

The 2019 and 2022 EIRs suggested Germany strengthen its 
policy framework on circular economy. With the adoption 
of the national circular economy strategy, Germany made 
a big step forward.  

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, 

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. 

its 

In  December  2024,  Germany  adopted 
first 
comprehensive  national  circular  economy  strategy ( 5 ). 
With the strategy, the German government aims to reduce 
raw  material  consumption  by  examining  production  and 
consumption  over  the  entire  life  cycle  and  identifying 
ways  to  fully  harness  opportunities  for  conserving 
resources through resource efficiency and circularity in all 
phases. 

Fragmented  strategies  and  initiatives  that  address  many 
aspects  of  the  circular  economy  were  already  in  place. 
Germany’s  resource  efficiency  programme’s  second 
update  (ProgRess III (6))  included  many  initiatives  aiming 
to increase circularity in the country. The overarching goal 
of the ProgRess programme is to make the extraction and 
use of natural resources more sustainable and meet  the 
country’s  responsibility  to  future  generations  by  helping 
to secure the natural foundations of life for the long term. 
The programme aims to achieve this goal by implementing 
120  measures  along  the  entire  value  chain.  ProgRess III 
aims  to  close  material  cycles  as  much  as  possible  and 
emphasises the particular importance of product design in 
this context. 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
authorities’ 
consumption,  with  public 
European 
purchasing  power  representing  around  14 %  of  EU  GDP. 
Public  procurement  using  green  or  circular  criteria  (life-

(3) 

(4) 

(5) 

European Commission, ‘Proximity and social economy 
ecosystem’, European Commission website, https://single-
market-economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular Economy Stakeholder Platform 
(https://circulareconomy.europa.eu/platform/en/strategies). 
https://www.bmuv.de/download/nationale-
kreislaufwirtschaftsstrategie-nkws. 

(6) 

(7) 

(8) 

https://www.bmuv.de/publikation/deutsches-
ressourceneffizienzprogramm-iii-2020-bis-2023. 
European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
website, 
http://ec.europa.eu/environment/ecolabel/facts-and-
figures.html. 
European  Commission,  ‘EMAS  register’,  European  Commission 
website, 
https://webgate.ec.europa.eu/emas2/public/registration/list. 

2025 Environmental Implementation Review – Germany 

 
 
Germany  6 

2025 priority action 

• 

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

Waste management 

Turning waste into a resource is supported by: 

(i)  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; 

affect  the  overall  trend  as  there  is  still  a  small  increase 
observed,  mainly  driven  by  the  remaining  largest  waste 
categories,  namely  mixed  waste  and  recyclable  waste. 
Most  recently,  waste  generation  declined  again  across 
nearly  all  waste  categories.  Germany’s  GDP  showed  a 
steady  growth  until  2019,  but  dropped  significantly  in 
2020, most likely due to the COVID-19 outbreak. Overall, 
there  appears  to  be  a  very  small  decoupling  of  waste 
generation  from  economic  growth  throughout  2010–
2022. 

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

(ii)  fully 

implementing  EU  waste 

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

(iii)  reducing waste generation per capita and in absolute 

terms; 

(iv)  increasing  the  recycling  rates  of  waste  containing 
critical raw materials (CRMs), with a view to reducing 
dependencies and building resilient value chains, and 
in  all 
stimulating  demand  for  recycled  content 
products; 
limiting energy recovery to non-recyclable materials; 
and 

(v) 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

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

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

(which 

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

The  total  amount  of  waste  generated  in  Germany  has 
increased  over  the  last  12 years  (Figure 3).  This  trend  is 
primarily  driven  by  the  largest  waste  categories,  namely 
soils and mineral waste from construction and demolition. 
Excluding  the  major  mineral  waste  categories  does  not 

NB: Waste generation data for odd years are interpolated. 

accessed 

15 October 

nama_10_gdp, 

Sources: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table;  Eurostat,  ‘Generation  of  waste  by  waste 
category,  hazardousness  and  NACE  Rev. 2  activity’,  env_wasgen,  last 
updated 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_wasgen/default/
table?lang=en; Eurostat, ‘Population change – Demographic balance and 
crude  rates  at  national  level’,  demo_grind,  accessed  15 October  2024, 
https://ec.europa.eu/eurostat/databrowser/view/demo_gind/default/t
able?lang=en&category=demo.demo_ind. 

30 September 

22 October 

accessed 

2024, 

Critical raw materials 

Germany focuses on key products that contain a high level 
of  CRMs,  such  as  batteries  (e.g.  through  extended 
producer  responsibility  (EPR)),  electrical  and  electronic 
equipment  (collection  systems)  and  vehicles  (individual 
EPR). In addition, the newly adopted national strategy on 
circular  economy  integrates  issues  on  CRMs  through 
measures to increase the security of raw material supply 
and  raw  material  sovereignty.  In  some  federal  states, 
there are repair bonus schemes set up for electrical and 
electronical equipment that support the  sustainability of 
using products that contain CRMs. 

Construction and demolition waste 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (9) by 
the Joint Research Centre shows that preparing for reuse 

(9) 

European Commission: Joint Research Centre, Cristóbal García, J., 
Caro, D. et al., Techno-economic and environmental assessment of 
construction and demolition waste management in the European 
Union,  Publications  Office  of  the  European  Union,  Luxembourg, 

2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 

2025 Environmental Implementation Review – Germany 

 
 
 
and  recycling  operations  are  preferred  over  incineration 
and  landfilling  from  an  environmental  perspective  for 
most  of  the  different  streams  of  construction  and 
demolition  waste.  However,  the  economics  are  often 
unfavourable  for  preparing  for  reuse  and  recycling 
compared  with  incineration  and  landfilling.  If  available 
technology  were  to  be  applied,  it  is  estimated  that  the 
increase in preparing for reuse and recycling would lead to 
an  additional  33 Mt  of  greenhouse  gas  (GHG)  emission 
savings annually (more than, for example, the combined 
annual GHG emissions of Estonia, Latvia and Luxembourg). 

The  preparing  for  reuse  and  recycling  rate  of  mineral 
construction  and  demolition  waste  in  Germany  in  2022 
was  86.5 %,  compared  with  the  EU  average  of  79.8 %. 
Measures to further increase the preparing for reuse and 
recycling  rate  of  construction  and  demolition  waste 
instance 
include  separate  collection  at  source –  for 
through  digitalised  pre-demolition  audits ( 10)  (‘resource 
assessments’) – EPR and other economic instruments, and 
upstream  measures  such  as  increasing  the  recycled 
in  construction  products  and  the  circular 
content 
design (11) of construction works. 

Boosting implementation – the 2023 Waste Early 
Warning Report 

This  section  focuses  on  the  management  of  municipal 
waste ( 12 ),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste  Early  Warning  Report (13)  identifying  the  general 
trends in waste management and the Member States at 
risk of missing 2025 waste targets (see Figure 4). Germany 
is not at risk of missing the recycling targets for municipal 
waste or packaging waste. 

Germany  7 

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

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

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

Under  certain  conditions,  EU  waste  legislation  enables 
some  Member  States  to  postpone  the  deadlines  for 
reaching certain waste management targets for municipal 
and packaging waste. Member States that want to 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 

(10) 

(11) 

European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works – 
Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for buildings 
design, 
2020, 
Brussels, 
https://ec.europa.eu/docsroom/documents/39984. 

(12)  Municipal  waste  consists  of  (i)  mixed  waste  and  separately 
collected waste from households, including paper and 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. 

(13) 

2025 Environmental Implementation Review – Germany 

 
 
 
2025 targets, 11 Member States, not including Germany, 
have used this prerogative. 

https://ec.europa.eu/eurostat/databrowser/view/ENV_WASMUN/defa
ult/table. 

Germany  8 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission  is,  on  one  hand,  working  together  with  the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (14), the Packaging and 
Packaging Waste Directive (15) and the Directive on Waste 
Electrical and Electronic Equipment (16). 

Municipal waste 

Germany’s  waste  generation  rate  has  been  generally 
stable since 2010, with a slight decrease in 2022, reaching 
593 kg per capita, which is still above the EU average. The 
rate  of  preparing  for  reuse  and  recycling  of  municipal 
waste  has  stagnated  over  the  past  few  years  at  a  high 
level, reaching 69 % in 2022, which is significantly above 
the  (estimated)  EU-27  average  of  49 %  in  the  same 
year (17).  The  incineration  rate  slightly  decreased  during 
the same period, reaching 30 % in 2022.  Germany has a 
landfill rate below 1 %. 

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

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

NB:  From  reference  year  2020  onwards,  new  reporting  rules apply  for 
calculating recycled municipal waste pursuant to the targets  set out in 
Article 11.2(c–e) of Directive 2008/98/EC. The calculation points referred 
to  in  Article 6c(1)(a)  are  corrected  for  non-target  materials,  thus 
excluding material rejected from recycling facilities. Germany applied the 
new calculation rules for the first time for reference year 2020. 

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

22 October 

accessed 

Packaging waste 

Germany’s  packaging  waste  generation  has  significantly 
increased  since  2010  (Figure 7).  The  country  generated 
227 kg per capita in 2022, which is significantly above the 
estimated  European  average  of  186 kg  per  capita  in  the 
same year (18). 

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

22 October 

accessed 

(14)   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. 

(15)   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.  

(16)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 

(17) 

(18) 

equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  Directive  - 
2012/19 - EN - EUR-Lex. 
The  EU  average  might  have  been  influenced by  not  all  Member 
States  fully  applying  the  reporting  rules  for  municipal  waste  set 
out in the Waste Framework Directive as amended in 2018. 
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. 

2025 Environmental Implementation Review – Germany 

 
 
 
 
Figure 7: Packaging waste generation, 2010–2022 

Source:  Eurostat,  ‘Packaging  waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

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

NB:  There  is  a  break  in  the  series  for  paper  and  cardboard,  plastic, 
wooden, glass and aluminium packaging types in 2019. Germany applied 
the new calculation rules in accordance with Commission Implementing 
Decision 2019/665 for the first time in 2019. 

Source:  Eurostat,  ‘Packaging  waste  by  waste  management  operations’, 
env_waspac, last updated 23 October 2024, accessed 28 October 2024, 
https://ec.europa.eu/eurostat/databrowser/view/ENV_WASPAC__cust
om_842634/default/table?lang=en. 

In the past decade, the overall packaging waste recycling 
rate  was  above  65 %,  with  the  exception  of  2019,  and 
stands at 69 % in 2022. The overall recycling rate is mainly 
influenced  by  paper  and  cardboard  as  this  is  the  largest 
fraction  with  a  high  recycling  rate.  In  2019  there  was  a 
notable drop in paper and cardboard, glass, metallic and 
slightly 
plastics  packaging 
diminished  the  overall  recycling  rate  for  that  year.  This 

rates,  which 

recycling 

Germany  9 

drop is attributable to the application of new calculation 
rules (19). A comparison of the data  under the new rules 
with  a  calculation  under  the  old  rules  for  2018–2021 
indicates  an  increase  in  the  recycling  rate  from  2018–
2021 (20). 

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). 

Germany’s current national waste prevention programme 
is  the  country’s  second  prevention 
for  2021–2027 
programme (21). The new programme focuses on possible 
measures to be taken by industries, households and other 
stakeholders (22). No specific budget for implementation is 
included in the programme (23). 

Prioritised  waste  streams  are  food  and  organic  waste, 
construction  and  demolition  waste,  hazardous  waste, 
detergents,  household  and  municipal  waste,  packaging 
waste, textiles, waste electrical and electronic equipment, 
waste  batteries,  manufacturing  waste,  bulky  waste  and 
other  miscellaneous  waste.  Quantitative  targets  have 
been set for reusable beverage containers, the reduction 
of  food  waste  at  the  retail  and  consumer  levels,  the 
reduction  of  food  losses  along  production  and  supply 
chains,  and  the  continued  decrease  of  municipal  solid 
waste ( 24 ).  The  recently  adopted  German 25 the  circular 
economy aims to consolidate goals and measures relating 
to the circular economy and promote resource efficiency 
based  on  existing  raw  material  policy  strategies.  One  of 
the strategy’s strategic targets is to reduce the generation 
of municipal waste per capita by 10 % and 2 % by 2030 and 
2045, respectively. 

Policies to encourage separate collection and recycling  

through 

collected 

Residual waste and biowaste (food and garden waste) are 
mainly 
separate  door-to-door 
collection, which is supplemented with collection at civic 
amenity sites for garden waste. Door-to-door collection is 
predominantly applied for paper and cardboard (separate) 
and  for  plastics,  metals  and  composite  packaging  waste 
(commingled), 
complemented  by  drop-off  point 
collection.  Collection  of  glass  packaging  occurs  mainly 
through drop-off points and in some areas through door-
to-door  collection.  In  most  municipalities,  door-to-door 

(19) 
(20) 
(21) 
(22) 

(ETC/CE, 2022). 
(UBA, 2024). 
(BMUV, 2020). 
(BMK, 2023). 

(23) 
(24) 
(25) 

(EEA, 2023). 
(EEA, 2023). 
(BMUV, 2024). 

2025 Environmental Implementation Review – Germany 

 
 
 
 
collection or collection through drop-off points is limited 
to packaging waste. The non-packaging waste streams are 
usually  collected  at  civic  amenity  sites  or  by  private 
companies 
Furthermore,  Germany 
mandates the separate collection of packaging waste from 
non-household sources (26). 

trade). 

(scrap 

While  pay-as-you-throw  systems  are 
important  to 
improve separation at source, German municipalities are 
not  obliged  to  apply  such  systems.  Consequently,  the 
population coverage is only about 30 % and the fees are 
modulated  based  on  the  number  of  yearly  emptied 
containers or the amount of disposed residual waste (27). 
Hence, the European Commission suggested that German 
waste  management  could  benefit  from  implementing  a 
mandatory  pay-as-you-throw  system  across  the  whole 
country (28). 

The national deposit-return system in Germany was one 
of the first in Europe. Today a mandatory scheme covers 
nearly  all  single-use  drink  cans  and  bottles  made  of 
aluminium, glass and plastic (polyethylene terephthalate), 
and  previous  exemptions  (e.g.  for  some  alcoholic 
beverages and dairy products) have been removed by the 
Packaging Act (VerpackG) amendments in 2022 and 2024. 
Additional  voluntary  deposit-return  systems  are  in  place 
for certain plastic crates and some wooden packaging (29). 
Furthermore, the Packaging Act requires a deposit-return 
system  for  refillable  packaging,  requiring  sufficient 
logistics and incentive for take-back and reuse. 

Policies to discourage landfilling or incineration 

As mentioned earlier, Germany landfills less than 1 % of its 
generated  municipal  waste  (Figure 6).  While  there  is  no 
landfill tax in place, a landfill ban  has existed since 2005 
for waste with a total organic carbon content above  3 % 
(1 % for mechanically or biologically treated waste) (30). 

Germany  10 

Similarly,  Germany  does  not  impose  taxes  on  municipal 
waste 
incineration.  Nevertheless,  as  the  country’s 
incineration rate has been generally stagnant since 2015, 
the 2022 EIR suggested that introducing incineration taxes 
could  serve  as  an  incentive  to  direct  more  waste  away 
from  incineration  to  recycling (31).  However,  since  2023 
waste incineration has been eligible for national emissions 
trading  for  fuels  in  accordance  with  the  Fuel  Emission 
Allowance  Trading  Act.  Since  1 January  2024,  carbon 
dioxide (CO2) certificates must be purchased for every 1 t 
of non-biogenic CO2 emitted. In 2024, prices were set to 
EUR 45/t, and they will increase significantly in the coming 
years.  This  may  well  have  a  significant  influence  in  the 
future on the amount of waste incinerated (32). 

Germany  has  made  some  progress  when  it  comes  to 
shifting  reusable  and  recyclable  waste  away  from 
incineration,  but  more  progress  is  needed.  While  the 
amount  of  incinerated  waste  recently  decreased,  the 
share  of  municipal  waste  being  incinerated  remained 
largely  the  same.  Several  German  Länder  have  adopted 
revised  waste  management  plans  and  informed  the 
Commission  of  those  in  accordance  with  the  Waste 
framework  directive, 
including  Nordrhein-Westfalen, 
Saxony,  Lower  Saxony,  Brandenburg  and  Baden-
Württemberg. 

2025 priority actions 

• 

• 

• 

• 

through 

including 

Further shift reusable and recyclable waste away from 
economic 
incineration, 
instruments.  
Increase  the  collection  and  recycling  rate  of  waste 
electrical and electronic equipment. 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 
Ensure  the  achievement  of  the  2025  waste  targets, 
following 
the 
reports  where 
Commission 
applicable. 

the  recommendations  made  by 

in  early  warning 

(26) 
(27) 
(28) 
(29) 

(ETC/CE, 2022). 
(ETC/CE, 2022). 
(EC, 2023). 
(ETC/CE, 2022) 

(30) 
(31) 
(32) 

(ETC/CE, 2022). 
(EC, 2022). 
(UBA, 2024). 

2025 Environmental Implementation Review – Germany 

 
 
 
 
2. Biodiversity and natural capital 

Global and EU biodiversity frameworks

Germany  11 

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 ( 33 )  and  a  dashboard  of  indicators ( 34 ) 
provide  information  on  implementation  progress.  The 
recently adopted EU Nature Restoration Regulation (35) is 
the first EU-wide, comprehensive law of its kind and a key 
instrument  for  the  EU  to  deliver  on  the  global 
biodiversity targets for 2030. It lays down an overarching 
objective  at  the  EU  level  to  put  in  place  effective 
restoration measures on 20 % of EU land and sea by 2030 
and for all ecosystems in need of restoration by 2050. To 
achieve this, it sets binding targets for Member States to 
restore and maintain ecosystems, as well as an effective 
implementation 
national 
restoration plans. 

implementation 

framework 

enable 

based 

on 

to 

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

(33) 

(34) 

(35) 

Actions 

Tracker 

Strategy 

Strategy 

Dashboard 

Biodiversity 

Biodiversity 

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

page 

web 

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
line  with  the  global 
2030  biodiversity  targets. 
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 

In  December  2024,  Germany  adopted  a  new  national 
biodiversity  strategy  for  2030  (NBS  2030) 36 that  takes 
into  account  the  EU  and  global  biodiversity  targets.  It 
bundles  the  central  topics  and  goals  for  biodiversity 
conservation  in  21  fields  of  action  with  64  goals  under 
one strategic roof.  In addition to the strategy part, the 
NBS 2030 places a special focus on the implementation 
to achieve these goals. To this end, a 1st action plan lists 
around  250  concrete  measures  that  the 
federal 
government wants to implement by 2027.  

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 Germany, see 
Chapter 5. 

Nature protection and restoration – Natura 
2000 

Natura  2000 ( 37 ),  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 

36

 Nationale 

Strategie 

zur 

Biologischen 

Vielfalt 

2030, 

https://www.bmuv.de/download/die-nationale-strategie-zur-
biologischen-vielfalt-2030-nbs-2030 

(37)  Natura  2000  comprises  sites  of  community  importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as special 
protection  areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. A special area of conservation (SAC) is an SCI designated 
by a Member State. 

Environmental Implementation Review 2022 – Germany 

 
 
 
 
 
Germany  12 

protection for nature conservation, of  which  landscape 
conservation  areas 
(Landschaftsschutzgebiete)  and 
nature  parks  have  the  lowest ( 44 ).  Germany  strictly 
protects only 7.2 % of the EU’s protected areas (SCIs and 
SPAs). 

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

conservation (SACs) (38); 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 
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. 

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. 

Germany hosts 93 habitat types (39) and 195 species (40) 
covered by the Habitats Directive. The country also hosts 
populations  of  nearly  120  bird  taxa  listed  in  Annex I  to 
the Birds Directive (41). 

Nature  protection 
the 
in  Germany 
competence of the 16 Länder, and the federal authorities 
are responsible for the exclusive economic zone. 

falls  within 

In 2023, 15.4 % of the national land territory of Germany 
was covered by Natura 2000 (EU coverage: 18.6 %), with 
special protection areas (SPAs) classified under the Birds 
Directive covering 11.3 % (EU coverage: 12.8 %) and SCIs 
under  the  Habitats  Directive  covering  9.4 % 
(EU 
coverage: 14.3 %) of Germany’s territory (42). 

Considering both Natura 2000 sites and other nationally 
designated  protected  areas,  Germany  legally  protects 
38.5 %  of  its  terrestrial  area  (EU-27  coverage:  26.1 %) 
and  45.3 %  of 
its  marine  area  (EU-27  coverage: 
12.3 %) (43).  To  this  effect,  there  are  different  levels  of 

(38) 

(39) 

(40) 

(41) 

SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
European Environment Agency (EEA), ‘Number of habitats and 
species per Member State’, Article 17 dashboard, Annex I total, 
19 December 
2019, 
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’, 
Article 17 
2019, 
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  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 

19 December 

dashboard, 

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

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

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

The  Court  of  Justice  of  the  European  Union  (CJEU) 
instructed  Germany  in  a  court  ruling ( 45 )  that  the 

https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
This  counting  only  takes  into  account  bird  taxa  for  which 
information was requested. 
https://www.bfn.de/natura-2000-gebiete.  
Eurostat dataset env_bio4, terrestrial and marine protected 
area percentage for 2022 , accessed March 2025, 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en. See also the EU Biodiversity Strategy 
Dashboard 
(https://dopa.jrc.ec.europa.eu/kcbd/dashboard/#COHERENT%2
0NETWORK%20OF%20PROTECTED%20AREAS). 
See section 26 and 27 of the Federal Nature Conservation Act. 
Judgment  of  21 September  2023,  European  Commission  v 
Federal Republic of Germany, C-116/22, EU:C:2023:687. 

(42) 
(43) 

(44) 
(45) 

2025 Environmental Implementation Review – Germany 

 
 
 
remaining SAC designations and conservation measures 
must be finalised. 

In particular, the conservation objectives have not been 
set  for  88  of  the  4 606  SCIs  at  issue,  and  necessary 
conservation  measures  for  737  sites  have  not  been 
adopted, 
in  breach  of  Article 6(1)  of  the  Habitats 
Directive. 

In  addition,  several  SPAs  under  the  Birds  Directive  are 
still not legally protected under national law, and many 
SPAs  are  still  missing  conservation  measures.  These 
deficiencies are the subject of an ongoing infringement 
procedure initiated in March 2024. 

2025 priority action 

• 

the 

establishment 

Finalise 
site-specific 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 

of 

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 (46). 

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

According  to  the  report  for  2013–2018  submitted  by 
Member  States  on  the  conservation  status  of  habitats 
and species, as required under Article 17 of the Habitats 
Directive,  29.7 %  of  habitats  had  a  good  conservation 
status  in  2019  compared  with  28.1 %  in  the  previous 

Germany  13 

reporting period (2007–2012). As for protected species, 
25.6 % had a good conservation status in 2018 compared 
with  24.6 %  in  the  previous  reporting  period  (2007–
2012).  However,  less  than  10 %  of  German  protected 
grassland habitat  types  have a  favourable conservation 
status (47). Regarding birds, 61 % of the breeding species 
showed  short-term 
increasing  or  stable  population 
trends. 

Over  the  same  period,  the  share  of  habitats  with 
unfavourable  conservation  status  decreased  slightly 
from  69.8 %  to  69.2 %,  while  the  share  of  species  with 
unfavourable  conservation  status  grew  from  60.4 %  to 
63.3 %. The main pressures are agriculture and changes 
in  land  use  (both  intensification  and  abandonment) 
together with nitrogen deposition from agriculture and 
traffic sources. 

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

Figure 10: Assessments on conservation status for 
habitats for 2007–2012 and 2013–2018 reporting 
periods (% of assessments) 

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

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, 

(46) 

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, 

(47) 

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, 

2025 Environmental Implementation Review – Germany 

 
 
 
On  2 December  2021  the  Commission  decided  to  refer 
Germany  to  the  CJEU  for  failing  to  comply  with  its 
obligation  to  prevent  the  deterioration  of  two  habitat 
types: 
lowland  hay  meadows  and  mountain  hay 
meadows (48). With its judgment of 14 November 2024, 
the  CJEU  confirmed  the  Commission’s  view.  These 
habitat  types  have  significantly  diminished  in  size  or 
disappeared completely at various sites in recent years. 
The  two  habitat  types  play  a  vital  role  for  pollinating 
insects,  for  example  bees  and  butterflies,  and  are 
protected as part of the Natura 2000 network. 

The Commission has also found that the populations of 
bird species protected by the Birds Directive in Germany 
have decreased to a significant extent (49). According to 
the  data  provided  by  the  German  Federal  Agency  for 
Nature  Conservation  for  the  24-year  trend  over  1992–
2016,  Germany  lost  around  14 million  breeding  birds 
during this period. Of these,  about  4 million birds have 
disappeared from open land and around  5 million birds 
have  disappeared  from  settlement  areas.  The  losses 
mainly occurred in the first half of the reporting period. 

Figure 11: Assessments on conservation status for 
species for 2007–2012 and 2013–2018 reporting 
periods (% of assessments) 

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

December 

accessed 

2019, 

(48) 

Judgment  of  14 November  2024,  European  Commission  v 
Federal Republic of Germany, C-47/23, EU:C:2024:95. 
https://nature-art12.eionet.europa.eu/article12/. 

(49) 
(50)   National strategy for peatland protection 2022, 

https://www.bmuv.de/fileadmin/Daten_BMU/Pools/Broschuer
en/nationale_moorschutzstrategie_bf.pdf 

Germany  14 

Germany  has  one  of  the  highest  shares  of  red-listed 
species and habitat types for several classes. These still 
show a negative tendency. 

Germany is among the countries with a high percentage 
of  peatlands.  However,  less  than  5 %  of  near-natural 
peatlands remain in Germany. The conservation status of 
habitats in the continental and Atlantic zones is reported 
to be either unfavourable or bad. Peatlands contribute to 
7 % of Germany’s GHG emissions overall, but contribute 
a  much  higher  share  in  the  northern  Länder,  where 
peatlands are concentrated (50). 

Through  its  action  plan  on  nature-based  solutions  for 
climate  and  biodiversity  (Aktionsprogramm  Natürlicher 
Klimaschutz) ( 51 ),  the  federal  government  intends  to 
contribute to improving the general state of Germany’s 
ecosystems. From 2024 to 2027, a total of EUR 3.5 billion 
is  available  for  various  measures.  The  restoration  and 
rewetting of peatlands is an essential component. 

In  2022,  Germany  received  two  priority  actions  on 
conservation  objectives  and conservation  measures  for 
Natura  2000  sites,  and  on  balancing  pressures  from 
agriculture with nature protection needs. 

Germany  made  progress  with  the  priority  action  on 
establishing conservation measures. 

2025 priority actions 

•  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. 

Recovery of ecosystems 

Agricultural ecosystems 

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

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

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

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

—  reduce  by  50 %  losses  of  nutrients  from  fertilisers 
(which  will result in a  20 % reduction in the use of 

(51) 

Federal  Ministry  for  the  Environment,  Nature  Conservation, 
Nuclear Safety and Consumer Protection, Federal action plan on 
nature-based solutions for climate and biodiversity, Berlin, 2023, 
https://www.bmuv.de/fileadmin/Daten_BMU/Pools/Broschuer
en/ank_publikation_en_bf.pdf. 

2025 Environmental Implementation Review – Germany 

 
 
 
  
fertilisers)  while  ensuring 
deterioration of soil fertility; 

that 

there 

is  no 

—  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” (52), 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.  

The CAP and national CAP strategic plans that establish 
the  framework  for  the  transition  to  a  sustainable 
agriculture  are  key 
instruments  to  facilitate  and 
strengthen  the  efforts  of  European  farmers  to  protect 
large.  The 
biodiversity  and 
Commission  approved  Member  States’  CAP  strategic 
plans in 2022. CAP is the largest source of funding for the 
implementation of EU environment policy and strategic 
plans should lead to better protection of soil, water, air 
quality and biodiversity. 

the  environment  at 

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

The utilised agricultural area in Germany increased from 
16 667 300 ha  in  2012  to  16 730 700  ha  in  2015  and 
decreased to 16 594 900 ha in 2022 (53). 

regard 

to  environmental  performance, 

With 
the 
situation  of  Germany’s  agricultural  sector  varies 
depending  on  the  part  of  the  country.  Some  Länder, 
especially  in  the  north-west  and  south-east,  have  high 
livestock  density  and 
land-use,  which 
significantly  affect  ecosystems.  Diffuse  agriculture 
pollution is the most significant pressure on both surface 
waterbodies and groundwater bodies, with nitrate being 
the  worst  pollutant,  causing  failure  to  achieve  good 

intensive 

Germany  15 

chemical status in groundwater. Sales of pesticides have 
stagnated at a high level for years. The German national 
action  plan  for  the  sustainable  use  of  pesticides  is 
currently  being  revised  and  a  pesticide  reduction 
strategy is in development (54).  

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 
land.  Based  on  the  Land 
covered  by  agricultural 
Use/Cover  Area  Frame  Survey 
landscape  features 
estimates, the share of agricultural land covered by non-
productive  landscape  features  in  Germany  is  5.4 %, 
slightly below the EU average. At the EU level, landscape 
features cover 5.6 % of agricultural land. 

In 2024, the CAP basic regulations were amended (55) to 
simplify certain rules, 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. The amended regulations set out, however, 
an obligation for Member States to establish and provide 
support  for  eco-schemes  covering  practices  for  the 
maintenance of non-productive areas, such as land lying 
fallow,  and  for  the  establishment  of  new  landscape 
features on arable land. 

The recently adopted Nature Restoration Regulation (56) 
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 (57). 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 
9.83 %  of  Germany’s  land  area  is  used  for  organic 

52

(53) 

(54)

(55) 

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

food/vision-agriculture-and-food_en 
Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
2024, 
accessed 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 

5 December 

https://www.bmel.de/SharedDocs/Downloads/DE/_Landw

irtschaft/Pflanzenbau/Pflanzenschutz/zukunftsprogramm-
pflanzenschutz.pdf?__blob=publicationFile&v=5. 
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) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 
The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 

in  cropland  mineral  soils’  and 

(56) 

(57) 

2025 Environmental Implementation Review – Germany 

 
 
 
 
farming. This is lower than the EU average of 10.50 % (58). 
Although there is a moderate positive trend, Germany is 
still not contributing sufficiently to achieving the target 
of  25 %  of  the  EU’s  agricultural  land  being  used  for 
organic  farming  by  2030,  nor  is  it  on  track  to  reach  its 
(outgoing) government’s even more ambitious objective 
of  30 %  of  German  agricultural  land  being  used  for 
organic farming by 2030 (59). 

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 
• 

and 

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

practices 

address 

• 

Germany  16 

support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 

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

normal; 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 
resilience (60) 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 Germany (61). 

soil  organic 

loss  of 

carbon, 

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 

exceeding 

28 %  of  German  soils  have  a  concentration  of  nitrogen 
exceeding  50 kg/ha,  and  20 %  have  a  concentration  of 
phosphorus 
Phosphorus 
concentrations  are  particularly  high  in  the  north-west, 
while nitrogen concentrations are high in both the north-
west  and  the  south-east  of  the  country.  A  fifth  of  the 
national territory is affected by loss of soil organic carbon 

50 mg/kg. 

(58) 

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, 
2024, 
Brussels, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 

(60) 

(61) 

(59)   BMEL  -  Ökologischer  Landbau  -  Bio-Strategie  2030  –  Nationale 
Strategie 
und 
Prozent 
Lebensmittelwirtschaft bis 2030. 

ökologische 

Land- 

für 

30 

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

ASSESSMENT 

2025 Environmental Implementation Review – Germany 

 
 
in mineral soils (62), and 19 % experiences unsustainable 
soil erosion by water, wind, tillage and harvest. 

peatlands  improve  water  retention  and  quality,  store 
carbon, reduce GHG emissions and increase biodiversity. 

Germany  17 

strategy 

its  national 

sustainability 

In 
(Deutsche 
Nachhaltigkeitsstrategie),  Germany  set  itself  the  target 
of restricting daily land take to under 30 ha by 2030. Daily 
land  take  for  2019–2022  was  52 ha.  For  2022,  a  slight 
decrease  in  the  land  take  can  be  observed  compared 
with the previous year. 

Grasslands 

Grasslands  are  among  the  most  diverse  ecosystems  in 
the EU; they can contain as many as 80 different  plant 
species per square metre and are home to a large variety 
of animals, ranging from small insects, birds and rodents 
for 
large  herbivores.  Grasslands  are  essential 
to 
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. 

(U1)  or  an  unfavourable–bad 

According  to  Germany’s  Article 17  report ( 63 ),  most 
grassland  habitat  types  have  either  an  unfavourable–
inadequate 
(U2) 
conservation  status,  most  of  them  still  showing  a 
negative  trend  even  in  nature  conservation  sites.  The 
main pressure are unsustainable farming practices due to 
excessive  fertilisation  and  premature  mowing  which 
prevents 
from  seeding.  The  Commission 
launched an infringement case against Germany for the 
grassland  habitat  types  6510  and  6520  based  on 
Article 6(2)  of  the  Habitats  Directive.  The  ruling  by  the 
CJEU was announced on 14 November 2024. 

flowers 

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  GHG  emissions  from  the  EU’s  agricultural  sector. 
Restoring  peatlands  brings  multiple  benefits,  as 

(62)  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. 
https://www.bfn.de/ffh-bericht-2019. 

(63) 

According to Germany’s Article 17 report, most peatland 
habitat  types  have  either  an  unfavourable-inadequate 
(U1)  or  an  unfavourable-bad  (U2)  conservation  status, 
most  of  them  still  showing  a  negative  trend  even  in 
is 
nature  conservation  sites.  The  main  pressure 
unsustainable 
farming  practices  due  to  excessive 
fertilisation or drainage of farmland. 

2025 priority action 

• 

Implement  peatland  conservation  and  restoration 
measures and include such measures and objectives 
in the national restoration plans. 

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

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (64) 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 

(64)  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 

2025 Environmental Implementation Review – Germany 

 
 
 
 
of  favourable  conservation  status ( 65 ).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

in 
Forests  covered  32.7 %  of  Germany’s  territory 
2020 ( 66 ),  but  less  than  40 %  of  assessments  of  EU-
protected  forest  habitats  show  a  good  conservation 
status (67). German forests are affected by a combination 
of factors: exceptional heatwaves, droughts, bark beetle 
fires.  Climate  change  and 
outbreaks  and 
unsustainable 
(e.g. 
monocultures)  have  led  to  high  economic  losses  for 
foresters due to emergency woodcutting. 

forest  management  practices 

forest 

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

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

. 

Among forest disturbances contributing to loss of forest 
loss,  wildfires 
related  biodiversity 
integrity  and 

(65) 

(66) 

(67) 

(68) 

Union, 

Luxembourg, 

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. 
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 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 
San-Miguel-Ayanz, J., Durrant, T., Boca, R. et al., Forest Fires in 
Europe, Middle East and North Africa 2023, Publications Office 
of 
2024, 
Union, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC139
704. 

Accompanying 

Luxembourg, 

European 

base: 

the 

the 

Germany  18 

constitute a particular  reason for concern. In 2022, the 
EU  saw  a  record  number  (2 700)  of  wildfires  affecting 
more  than  30 ha,  which  led  to  the  destruction  of 
785 605 ha  of  forest,  the  second  highest  annual  figure 
recorded.  Recent  years  have  also  witnessed  the 
occurrence of widespread uncontrollable fires (so-called 
megafires), which are associated with loss of life and an 
enormous cost in terms of damage to the environment, 
businesses and society (over EUR 2 billion annually) and 
CO2  emissions.  Megafires  are  practically  beyond 
suppression  capacity  and  can  be  prevented  only  by  an 
integrated 
risk  management  approach.  Wildfires 
prevention is also essential to preserve resources for the 
bioeconomy. 

The 2023 fire season in Germany was relatively light after 
the extreme year of 2022; 39 fires were mapped, burning 
a total of 1 194 ha. Half of this total came from a single 
fire in June that covered over 600 ha. Most of the year’s 
total  (1 137 ha,  95 %)  occurred  on  Natura  2000  sites, 
amounting  to  0.016 %  of  the  protected  area  in  the 
country. The most  affected province (Land) in terms  of 
both  number  of  fires  and  total  burnt  area  was 
Brandenburg (68). 

The  EU  Timber  Regulation  (EUTR) ( 69 )  prohibits  the 
placing on the EU market of illegally harvested timber.  

On  29 June  2023,  the  Regulation  on  Deforestation-free 
Products  (EUDR) (70)  entered  into  force.  The  regulation 
seeks to guarantee that products in the EU that are made 
using  any  of seven  listed  commodities  have  no  links  to 
deforestation. The EUDR repeals the EUTR.(71) 

Marine ecosystems 

The  Marine  Strategy  Framework  Directive  (MSFD) 
requires Member States to achieve good environmental 
status  (GES)  for  their  marine  waters.  To  that  end, 

(69) 

(70) 

(71)  

Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down  the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 
In December 2024, the Commission proposal giving concerned 
parties additional time to prepare has been approved by the co-
legislators and the law will therefore enter into application on 30 
December 2025 for  large and medium companies and 30 June 
2026 for micro- and small enterprises. 

2025 Environmental Implementation Review – Germany 

 
 
 
 
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 
October  2024.  In  the  context  of  this  next  round  of 
reporting, 
in  accordance  with  the  MSFD  and  the 
Commission  GES  decision ( 72 ),  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 (73). Germany, 
has reported the data related to Articles 8, 9 and 10 of 
the MSFD as required by Article 17; these data are now 
under the assessment of the Commission. 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (74). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
work 
levels  of 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated programme 
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. 

Germany  19 

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

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

Germany’s  updated  programme  of  measures  scores  a 
positive level of adequacy for most descriptors (‘good’ or 
‘very  good’),  including  biodiversity  (D1)  (due  in  part  to 
targeted  measures  on  fishing),  non-indigenous  species 
(D2),  eutrophication  (D5),  sea-floor 
integrity  (D6), 
hydrographical  changes  (D7),  contaminants  (D8),  litter 
(D10) and energy (D11). 

However,  only  moderate  progress  is  noted  for  the 
commercial  fish  and  shellfish  (D3)  and  food  webs  (D4) 
descriptors, while measures addressing contaminants in 
seafood  (D9)  fall  short  of  fully  addressing  relevant 
pressures. 

Prevention and management of invasive alien 
species 

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

(72) 

(73) 

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 

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. 

(74) 

2025 Environmental Implementation Review – Germany 

 
 
 
list’), which is regularly updated (75). 

The third update of the Union list (76) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS Regulation (77) 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 (78).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 ( 79 ),  and  at 
USD 423 billion annually at the global level (80). 

The total number of IAS of Union concern in the country 
is 48. This includes 38 species recorded in the previous 
second  updated  list  of  invasive  alien  species  of  Union 
concern (2019)81 and 10 additions82.  

(75) 

(76) 

(77) 

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.  
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). 

(78)  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. 

Germany  20 

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

2025 priority actions 

• 

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

Ecosystem assessment and accounting 

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

Similarly, target 14 of the GBF (83) 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 

(80) 

(79)  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 
Biodiversity 
Summary 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 

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

(Intergovernmental 

Ecosystem 

and 

(81)  

https://www.bfn.de/sites/default/files/BfN/service/Dokumente
/skripten/skript574.pdf 

(82) 
bw.de/frontdoor/deliver/index/docId/1133/file/Schrift654.pdf  

https://bfn.bsz-

(83)  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). 

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
Germany  21 

biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (84). 

The  (EU)  No 691/2011  on  European  environmental 
economic accounts (85) 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. 

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

in  protecting  biodiversity,  including  the  EU  Business  & 
Biodiversity  Platform ( 86 ).  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. 

There  are  two  networks  of  businesses  for  biodiversity 
active  in  Germany:  Biodiversity  in  Good  Company  and 
the Global Nature Fund, which frequently work together. 
Both  are  active  members  of  the  EU  Business  & 
Biodiversity Platform. 

(84) 

European  Commission:  Joint  Research  Centre  and  EEA,  EU 
Ecosystem Assessment – Summary for policymakers, Publications 
Office  of 
Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-
/publication/81ff1498-b91d-11eb-8aca-
01aa75ed71a1/language-en. 

the  European  Union, 

(85)  Proposal for a regulation of the European Parliament and of the 
Council  amending  Regulation  (EU)  No 691/2011  as  regards 

(86) 

new 

environmental 

accounts 
economic 
introducing 
modules, COM(2022) 329 
final of  11 July  2022, 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. 

2025 Environmental Implementation Review – Germany 

 
 
 
 
Germany  22 

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 ( 87 ).  These  set  health-based  EU  air  quality 
standards ( 88 )  and  stipulate  Member  States’  national 
emission  reduction  commitments ( 89 )  for  several  air 
pollutants.  

Air  quality  in  Germany  has  improved  substantially  over 
recent  years.  Only  isolated  areas  within  two  air  quality 
zones  still 
limit  values. 
register  exceedances  of 
Nevertheless,  air  pollution  remains  a  relevant  factor 
impacting  public  health,  calling  for  sustained  efforts  to 
continue the positive trend. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (90) for Germany attribute 32 600 deaths each year (or 
312 800 years of life lost (YLL)) to fine particulate matter 
(PM2.5) ( 91 );  9 400  deaths  each  year  (or  90 500 YLL)  to 
nitrogen dioxide  (NO2) (92); and 15 200 deaths each year 
(or 146 300 YLL) to ozone (93). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Germany 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) ( 94 )  in  2024, 
Germany 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 
projections submitted under Article 10(2) of the NECD in 
2023, Germany is projected to meet its emission reduction 
commitments  for  2030  onwards  for  NOx,  NMVOC,  SO2, 
NH3 and PM2.5. 

Germany  submitted  its  updated  national  air  pollution 
control  programme  (NAPCP)  to  the  Commission  on 
21 May 2024. 

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

200%

150%

100%

50%

0%

NH₃

PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

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

2024, 

(87) 

(88) 

(89) 

(90) 

(91) 

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. 

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

(93) 

(94)  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 – Germany 

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

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
5,27%

30,59%

NOₓ

0,12%

40,76%

23,55%

9,07%

28,25%

13,59%

6,09%

6,26%

25,72%

10,75%

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
https://www.eea.europa.eu/en/topics/in-depth/air-
25 June 
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) (95) were registered 
for  NO2  in  two  air  quality  zones (96)  in  Germany,  down 
from 26 zones in 2016. Furthermore, the target values for 
ozone  concentrations  have  not  been  met  for  several  air 
quality  zones,  as  well  as  the  target  value  for  arsenic 
concentration in one air quality zone (97). 

The main reason for not meeting NOx limit values is diesel 
vehicle  traffic.  Local  diesel  access  bans  have  been 
implemented  in  a  number  of  cities,  although  some  of 
these  are  being  lifted  as  limit  values  are  being  met.  The 
federal  government  helped  cities  with  a  special 
investment  programme  of  EUR 1.5 billion  for  retrofitting 

(95)  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 

(96)  Munich metropolitan area and Essen. 
(97) 
EEA, Eionet Central Data Repository (). 

Germany  23 

buses and taxis. Further investments in rail infrastructure, 
urban  public  transport  and  e-mobility  as  part  of  the 
recovery  and  resilience  plan  (RRP)  will  also  help  to 
improve air quality. 

In  the  2022  EIR,  Germany  received  two  priority  actions. 
The first priority action was to further reduce emissions in 
the context of the NAPCP. Germany has made substantial 
progress  on  this,  as  the  latest  reported  data  shows  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, Germany has made some 
progress  in  this  regard.  Since  2019,  downward  emission 
trends  have  been  reported  for  all  main  air  pollutants. 
However,  exceedances  above  limit  values  and  target 
values  remain  for  NO2,  ozone  and  arsenic,  requiring 
further action. 

2025 priority actions 

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

• 

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

Industrial emissions 

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

(i)  protect  air,  water  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

(ii)  prevent and manage waste; 
(iii)  improve  energy  and  resource  efficiency,  including 

water; 

(iv)  contribute to decarbonisation. 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (98). 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. 

(98)  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. 

2025 Environmental Implementation Review – Germany 

 
 
 
 
The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 ( 99 ). 
In  Germany,  there  were  about  13 300 
installations  covered  by  the  IED  in  2022,  with  a  third  of 
the  waste 
them 
management sector. The other main sectors are intensive 
rearing  of  poultry  or  pigs  (23 %),  the  chemical  sector 
(14 %) and the metals sector (11 %). 

(33 %)  being 

installations 

from 

Figure 18  shows  the  damage  to  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’. Although 
Germany has the highest damage level in the EU, it comes 
17th  for  emissions  intensity,  below  the  EU  average  of 
EUR 27.5/EUR 1 000  GVA. 
industrial 
contributors to emissions to air (100) are the energy sector 
and the mineral industry for NOX, SO2 and heavy  metals 
emissions. 

The  main 

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 
https://industry.eea.europa.eu/analyse/industrial-
Portal, 
emissions-indicator. 

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity,  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 19. 

(99) 

European 

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

Emissions 

Germany  24 

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

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

Concerning  Germany  in  particular,  Figure 20  shows  the 
industrial emissions of heavy metals to water, taking into 
account the human toxicity of each metal, as well as  the 
emissions  intensity,  based  on  its  ratio  with  industrial 
activity  (expressed  in  GVA).  Germany  has  the  second 
highest emissions of heavy metals to water and is in 18th 
position  for  emissions  intensity  (below  the  EU  average 
intensity  of  0.864 kg/EUR 1 billion  GVA).  As  shown  in 
Figure 21, the main industrial contributors to emissions to 
water in Germany are the chemicals sector and the energy 
sector for heavy metals and total nitrogen,  and the pulp 
and paper industry for total organic carbon. 

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. 

(100)  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 – Germany 

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

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human Toxicity

Total nitrogen

Total organic
carbon (TOC)

Total phosphorus

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

Electricity and heat production
Ferrous metal
Fuel processing
Landfill
Non-metallic minerals
Other waste management
Refineries

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

13 September 

Data 

Germany has been subject to an infringement procedure 
for not conforming with the transposition of the IED since 
2020. This procedure is still ongoing. 

In  2022  Germany  received  priority  actions  to  continue 
large  combustion  plants 
addressing  pollution  from 
its 
lignite-firing  plants)  and  to 
(especially 
reporting to the European Pollutant Release and Transfer 
Register. The energy sector still remains among the main 
sources of industrial emissions. As regards reporting, the 
action  has  been  fulfilled,  and  Germany  submits  data  on 
time. 

improve 

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

infringements  of 

Germany  25 

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) the textiles 
industry,  (iii)  common  waste  gas  management  and 
treatment  systems 
in  the  chemical  sector  and  (iv) 
smitheries and foundries. 

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

2025 priority actions 

•  Complete the correct transposition of the 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 

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 (101)). 

The overview below of industrial plants regulated by the 
Seveso III Directive (‘Seveso establishments’) is based on 
data  reported  on  eSPIRS  (e-Seveso  Plants  Information 
Retrieval  System)  for  2022–2024 (102)  and  the  report  by 

(101)  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. 

(102)  https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 

in September 2024. 

2025 Environmental Implementation Review – Germany 

 
 
 
Germany  on  the 
Directive for 2019–2022 (103). 

implementation  of  the  Seveso III 

in  2024,  among 

In  Germany, 
the  3 961  Seveso 
establishments,  2 770  were  categorised  as  lower-tier 
establishments  and  1 191  as  upper-tier  establishments 
(UTEs),  based  on  the  quantity  of  hazardous  substances 
likely  to  be  present.  UTEs  are  subject  to  more  stringent 
requirements. Figure 22 shows the trend in the number of 
Seveso establishments. 

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

NB: LTE, lower-tier establishment. 

2022, 

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

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

According to Germany, in 2022, an EEP was required for 
1 095 UTEs; 1 165 such establishments had an EEP, which 
is more than required. However, only 659 EEPs had been 
tested over the last three years. The summary is shown in 
Figure 23. 

Germany  26 

Figure 23: Situation regarding EEPs in Germany, 2022 

2022, 

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

Information  for  the  public  referred  to  in  Annex V  to  the 
Seveso III  Directive –  especially  about  how  the  public 
concerned will be warned in case of a major accident, the 
appropriate  behaviour  in  the  event  of  a  major  accident, 
and the date of the last site visit – is permanently available 
for 95 % of the Seveso establishments in Germany. 

for  which 
Figure 24  presents  the  share  of  UTEs 
information on safety measures and requisite behaviours 
was  actively  made  available  to  the  public  in  2022  in  the 
EU-27.  This  is  an  important  provision  of  the  Seveso III 
Directive  as  the  public’s  awareness  of  this  information 
may  reduce  the  consequences  of  a  major  industrial 
accident. 

Germany is subject to an infringement procedure related 
to the transposition of the Seveso III Directive.  Germany 
has  not  correctly  transposed  the  directive  in  relation  to 
notification  requirements,  major  accident  prevention 
policy, information for the public, public consultations and 
participation  rights  in  decision-making,  and  time  limits 
regarding safety reports and emergency plans. 

(103)  As provided for by Article 21(2) of the Seveso III Directive. 

2025 Environmental Implementation Review – Germany 

 
 
 
 
Germany  27 

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). 

Measures  should  have  been  put  in  place  in  Germany  to 
ensure  a  socially  and  economically  sound  phase-out  of 
dental amalgam, 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.  Germany  will  also  need  to  ensure  that  the 
manufacture and export of mercury-containing lamps are 
prohibited  by  the  deadlines  set  out  in  the  Mercury 
Regulation. 

Noise 

The  Environmental  Noise  Directive ( 104 )  requires  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  noise.  The  designated  authorities  are 
responsible  for  making  and  approving  noise  maps  and 
action  plans  for  agglomerations,  major  roads,  major 
railways  and  major  airports.  Member  States  decide  on 
noise limits that are not set at the EU level. Nevertheless, 
the zero pollution action plan sets as a 2030 target a 30 % 
reduction  compared  with  2017  in  the  share  of  people 
chronically disturbed by transport noise. 

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

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

N.B. No data available for Greece. 

2022, 

Sources:  European  Commission:  Directorate-General  for  Environment, 
Assessment and summary of Member States’ implementation reports for 
(implementing  Directive 
Implementing  Decision 
2014/896/EU 
2012/18/EU  on  the  control  of  major  accident  hazards 
involving 
dangerous  substances),  Publications  Office  of  the  European  Union, 
https://op.europa.eu/en/publication-detail/-
Luxembourg, 
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. No data available for Greece. 

In 2022, Germany received a priority action to strengthen 
control and enforcement  to  ensure compliance with  the 
Seveso III  Directive  provisions,  especially  those  on 
information  for  the  public  and  EEPs.  Data  reported  on 
implementation  of  the  directive  for  2019–2022  show 
improvement in the number of EEPs established for UTEs 
in Germany. However, testing of those EEPs over the last 
three years is insufficient. 

2025 priority actions 

• 

• 

• 

Ensure full and correct transposition of the Seveso III 
Directive. 
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. 

(104)  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 – Germany 

 
 
 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (105). 

In Germany, environmental noise is estimated to cause at 
least  around  6 000  cases  of  ischaemic  heart  disease 
annually ( 106)  and  some  980 000  people  to  suffer  from 
disturbed sleep (107). 

Based on the latest set of information analysed, Germany 
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. 

There is an ongoing infringement procedure for Germany 
related to a lack of reporting on the strategic noise maps 
and the adoption of noise action plans. 

Germany  received  a  priority  action  in  the  2022  EIR  to 
complete  and/or 
implement  action  plans  on  noise 
management. Given that reporting under the most recent 
cycle for noise action plans was due in early 2025, these 
plans have not yet been assessed. Therefore, this priority 
action is repeated for the 2025 EIR. 

2025 priority action 

•  Complete  and  implement  action  plans  on  noise 

management. 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures on transitional waters, coastal waters and fresh 
water  (including  surface  waters  and  groundwater)  be 

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

(106)  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 
Indicators  under  the 
Industrial  Pollution  (ETC/ATNI),  Noise 
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, 

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

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

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

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

Germany  28 

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 

Directive 

The Water Framework Directive (108) is the cornerstone of 
EU  water  policy  in  the  21st  century ( 109 ).  The  Water 
other  water-related 
and 
Framework 
directives ( 110 )  form  the  basis  of  sustainable  and 
integrated  water  management  in  the  EU.  They  aim  to 
achieve  a  high  level  of  protection  of  water  resources, 
prevention  of  further  deterioration  and  restoration  to 
good status. These objectives are very important for 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. 

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

(109)  https://environment.ec.europa.eu/topics/water_en. 
(110)  These 

the  Groundwater  Directive 

include 

the 

Floods 

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

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

Drinking  Water 

Treatment 

Directive 

and 

the 

IED 

the 

the 

the 

2025 Environmental Implementation Review – Germany 

 
 
  
 
Germany  29 

reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 2025(111). 

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

Germany’s  10  river  basin  districts  count  9 744  surface 
waterbodies and 1 291 groundwater bodies. 35 % of the 
surface  waterbodies  are  heavily  modified  and  17 %  are 
artificial. 

in 

the 

show 

change 

Figures 25–28 
ecological 
status/potential and  chemical  status  of  surface  waters, 
and the quantitative and chemical status of groundwater 
in  2010,  2015  and  2021.  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 the 
ecological  status/potential  of  surface  waterbodies  has 
only slightly improved, whereas 100 %, that is, all surface 
waterbodies, do not have good chemical status, the same 
as in the second RBMPs (covering 2015–2021). 

Figure 25:  Ecological 
waterbodies in each RBMP cycle (%) 

status/potential  of 

surface 

Only  9.1 %  of  surface  waterbodies  have  good  or  better 
ecological status/potential. 

In general, diffuse nutrient pollution from agriculture and 
physical alterations to surface waterbodies for agriculture 
and flood protection purposes are identified as significant 
pressures  in  all  river  basin  districts.  The  largest  gap  in 
status is due to agricultural pollution for all surface waters 
including coastal waters. Although water abstraction is not 
identified  as  a  significant  pressure  in  all  river  basin 
districts, several studies point to emerging water scarcity 
issues, for example in eastern Germany. 

Failure to achieve good chemical status is mainly due the 
ubiquitous  persistent,  bioaccumulative  and 
toxic 
(uPBTs),  mercury  and  polybrominated 
substances 
diphenyl  ethers.  These  substances  are  mainly  emitted 
during  combustion  of  fossil  fuels  and  industrial  use,  and 
enter  surface  waters  through  atmospheric  deposition, 
which  is  the  main  pressure  on  surface  waterbodies  in 
Germany. 
If  one  excludes  uPBTs,  chemical  status 
improves,  ranging  from  59 %  of  surface  waterbodies  in 
good  chemical  status  in  the  Rhine  river  basin  district  to 
95 % in good status in the Ems river basin district. Other 
substances of concern depend on the region. Among them 
from 
are  pesticides,  perfluorooctanesulfonic  acid 
industrial  emissions,  and 
fossil 
from 
fluoranthene 
In  the  North  Rhine-Westphalia  Rhine 
combustion. 
catchment,  for  example,  perfluorooctanesulfonic  acid 
from industrial use puts pressure on surface waterbodies. 

Since  the  second  RBMPs,  the  number  of  groundwater 
bodies  has  increased  by  10 %  due  to  aggregation  and 
splitting.  This  affects  the  observed  trend  in  quantitative 
status,  which  shows  a  slight  decrease  in  groundwater 
bodies  with  good  status  (95.2 %)  compared  with  the 
second RBMPs. 

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

(111) ENV - Bibliothèque 

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
 
 
Failure  to  achieve  good  status  is  mostly  due  to  over-
abstraction, followed by damages to dependent terrestrial 
ecosystems and associated surface waters. Recent studies 
show  that  Germany 
is  experiencing  climate-change-
induced water loss from soils and vegetation and record-
low  levels  of  groundwater  bodies  throughout  different 
regions. 

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

Germany  30 

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

financing 

Floods Directive 

The chemical status of groundwater bodies has improved 
slightly,  with  67.3 %  having  good  chemical  status.  For 
is  the  pressure 
groundwater, 
reported to affect the highest percentage of groundwater 
bodies. 

‘diffuse –  agricultural’ 

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

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 identified the following priority actions. 

• 

Take  steps  to  improve  quality  and   frequency  of 
monitoring. 

•  Continue efforts to counteract nutrient pollution from 

agriculture. 

included 

Germany has made limited progress, insofar as most of the 
in  the  third  RBMPs  relate  to 
measures 
hydromorphological  alterations,  with  about  56 %  of 
surface  waterbodies  projected  to  benefit  from  such 
measures  until  2027.  In  addition,  in  83 %  of  all  surface 
waters,  measures  are  planned  to  reduce  pollution  from 
flow regulation and morphological changes. 

It  is  positive  that  climate  change  effects  have  been 
acknowledged in the first ever national water strategy and 
that  Germany  has  adopted  a  uniform  approach  to 
financing  measures,  which  will  contribute  to  the 
successful implementation of measures. 

2025 priority actions 

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

in  2024 
The  Commission  assessed  the  FRMPs,  and 
reported on both the third RBMPs and second FRMPs (first 
FRMP  reporting  was  in  March  2016)  to  the  European 
Parliament and to the Council. 

The  main  progress  resulting  from  the  assessment  of  the 
five German FRMPs from the second cycle is an improved 
national  flood  web  portal  and  a  mobile  application 
providing  up-to-date  information  on  water  and  flood 
levels,  as  well  as  a  more  uniform  approach  and  closer 
coordination  among  the  federal  states  on  flood  risk 
management. A system to assess progress is now in place. 
The 
for 
second  FRMPs  clearly  describe  criteria 
prioritisation  of  measures,  based  on  cost–benefit 
assessment.  As  regards  climate  change  effects,  all  five 
FRMPs now refer to coordination with Germany’s national 
adaptation strategy. 

2025 priority actions 

•  Consider future climate scenarios in the FRMPs. 
•  Better explain how flood hazard and risk maps were 

used in the FRMPs. 

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 

2025 Environmental Implementation Review – Germany 

 
 
 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (112), (ii) a methodology for measuring microplastics 
in drinking water (113) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (114). Member States will have to take 
into  account  when 
these  various  Commission  acts 
implementing the recast directive. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019.  The  quality  of  drinking  water  (supplied  by  large 
water  suppliers)  in  Germany  does  not  give  rise  to 
concern (115). 

From  January  2026,  the  European  quality  standards  for 
per- and polyfluoroalkyl substances in drinking water will 
apply, ensuring harmonised Member States’ reporting of 
per- and polyfluoroalkyl substances monitoring data in the 
future. 

Bathing Water Directive 

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

Figure 29  shows  that  in  2023,  out  of  the  2 291  bathing 
waters  in  Germany,  2 069  (90.3 %)  were  of  excellent 
quality, 136 (5.9 %%) were of good quality and 37 (1.6 %) 
were  of  sufficient  quality,  while  7  (0.3 %)  were  of  poor 
quality ( 116 ).  Detailed  information  is  available  on  the 
German  dedicated  website ( 117 )  and  through  an 
interactive map viewer from the EEA (118). 

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

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

(113)  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, 

(114)  OJ L, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 
OJ L, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 

2024/369, 

Germany  31 

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

The analysis of Germany’s RBMPs has identified nutrients 
important  pressure  on 
from  agriculture  as  an 

the  Commission  web  page  on  all  six  delegated  acts  for  more 
information 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
In summary, the compliance for all parameter groups in Germany 
was at least 99.64 % in 2017, 99.51 % in 2018 and 99.61 % in 2019. 

(115) 

(116)  Forty-two bathing waters (1.8 %) were not classified. 
(117)  https://www.umweltbundesamt.de/wasserqualitaet-in-

badegewaessern.  

(118)  EEA, ‘State of bathing waters in 2023’, EEA website, last updated 
2023), 

28 May 
https://www.eea.europa.eu/en/analysis/maps-and-charts/state-
of-bathing-waters-in-2023. 
(119)  https://eur-lex.europa.eu/legal-

(8 June 

2024 

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

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

2025 Environmental Implementation Review – Germany 

 
 
 
groundwater /  surface  waters  that  is  affecting  these 
waters’ good status and as one of the main factors in not 
meeting the Water Framework Directive objectives. 

In  2022,  Germany  received  a  priority  action  on  tackling 
nutrient pollution, especially from agriculture, through the 
implementation of the Nitrates Directive. Since the report 
on the implementation of the Nitrates Directive covering 
2020–2023 will be available in 2025, the 2022 EIR priority 
action cannot be assessed and is repeated. 

2025 priority action 

•  Tackle  nutrient  pollution,  especially  nitrates  from 
implementation  of  the 

agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the effects of untreated urban waste water. It therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  waste  water  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
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  Germany,  the  compliance  rate  was  99.9 %  in 
2020.  Only  five  agglomerations,  generating  56 593 
population  equivalent  of  urban  waste  water,  are  not 
compliant with the requirements of the directive. 

(121)  Communication 

to 

from 

the  Commission 

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

31.12.2008, 

(OJ 

Germany  32 

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

Source:  European  Commission,  12th  UWWTD  Implementation  Report, 
implementation  - 
2024,  12th  technical  assessment  of  UWWTD 
Publications Office of the EU. 

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

Chemicals 

The EU seeks to ensure that chemicals are produced and 
used  in  a  way  that  minimises  any  significant  adverse 
effects on human health and the environment. In October 
2020, the Commission published its chemicals strategy for 
sustainability  towards  a  toxic-free  environment ( 121 ), 
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 ( 122 )  provides  a  baseline 
protection for human health and the environment. It also 

https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

(122)  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, 
https://eur-lex.europa.eu/legal-
30/12/2006, 

p. 1), 

2025 Environmental Implementation Review – Germany 

 
 
 
 
ensures  stability  and  predictability 
operating in the internal market. 

for  businesses 

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 ( 123 )  on  the 
implementation 
these 
regulations ( 124 ).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably  in  the  area  of 
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. 

of 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (125) 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 (126). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (127).  The  new  hazard 

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. 
(123)  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, 

(124) 

the 

European 

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

Luxembourg, 

(127)  Regulation (EU) 2024/2865 of the European Parliament and of the 
Council  of  23  October  2024  amending  Regulation  (EC)  No 

Germany  33 

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 (128).  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  both  the 
REACH  and  CLP  Regulations  in  Germany  lies  with  the 
Länder authorities (129). Each of the 16 Länder has its own 
hierarchy of authorities and the respective responsibilities 
vary between the federal states. 

fully 

Germany  has  drawn  up  and 
implemented 
enforcement  strategies  for  both  the  REACH  and  CLP 
Regulations (130).  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  absence  of  new  country-specific  data  on 
enforcement since 2022. 

In Germany, resources were considered proportionate to 
REACH  and  CLP  enforcement ( 131 ) 
in  the  previous 
reporting period. 

In  2020,  Germany  participated  in  an  EU-coordinated 
enforcement  project  on  products  sold  online,  called  the 

1272/2008 on classification, labelling and packaging of substances 
and  mixtures  (Text  with  EEA  relevance),  OJ  L,  2024/2865, 
20.11.2024, p.1 (Regulation - EU - 2024/2865 - EN - EUR-Lex) 
(128)  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. 

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

Luxembourg, 

Union, 

2020, 

(130)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 76, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details.  

Luxembourg, 

Union, 

2020, 

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

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – Germany 

 
 
REACH-EN-FORCE (REF)-8 project (132). The project report 
was not released until November 2021, so it could not be 
taken into account in the previous EIR. 

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

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

Germany  34 

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

Germany’s  participation 
the  REF-8coordinated 
in 
enforcement project was above the EU average, which is 
rather low because of the lack of involvement of certain 
large Member States. 

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

In  2022,  Germany  received  a  priority  action  related  to 
upgrading  administrative  capacities  in  implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of non-compliance. 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 

•  Upgrade 

the 

capacities 

in 
administrative 
implementation and enforcement to move towards a 
policy of zero tolerance of non-compliance. 
Increase customs checks and checks of products sold 
online  with  regard  to  compliance  with  chemicals 
legislation.

• 

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

Helsinki, 

articles 

online, 

2021, 

sold 

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

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
Germany  35 

4. Climate action 

increasing  targets  under  the  effort  sharing  regulation; 
and  (iii)  a  revised  regulation  for  Land  Use,  Land  Use 
Change  and  Forestry ( 134).  The  package  has  been  fully 
adopted,  and 
the  Member  States  have  been 
implementing the legislation. 

The  key  strategic  document  at  country  level  is  the 
National Energy and Climate Plan (NECP) (135). Germany 
submitted its final plan in August 2024 after the deadline 
set  by the regulation on the  Governance of the Energy 
Union and Climate Action(136). The European Commission 
assessed the final plan and the extent to which Germany 
has followed the recommendations for the draft version. 
The findings from the assessment are: 

• 

• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease by 41% in 2030 compared to 2005 which is 
way below the of 50%. 
The latest projections show a gap to the  Land Use, 
Land-use  change  and  Forestry  (LULUCF)  target, 
meaning that current levels of removals have been 
insufficient.  

•  Germany  is  in  line  with  its  target  for  the  share  of 
renewable energy and targets for energy efficiency. 

To minimise the impacts of climate policies on vulnerable 
people and sectors, Germany is using the Just Transition 
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 

the  EU  has  demonstrated 

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 
its 
this  backdrop, 
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 in law, 
and  the  European  Commission  recommended  a  new 
intermediate  climate  target  of  a  90 %  reduction  in 
emissions  by  2040. 
In  2024,  the  Member  States 
submitted updated national energy and climate plans for 
2021–2030,  reflecting  the  increased  ambition  of  the 
revised EU legislation. In 2024, the European Commission 
also  released, 
jointly  with  the  EEA,  the  first-ever 
European climate risk assessment. 

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 % (133). However, the EU 
and 
its  Member  States  need  to  step  up  their 
implementation  efforts  and  accelerate  emissions 
reduction to stay on track to reach their targets of a 55 % 
reduction  in  net  GHG  emissions  by  2030  and  climate 
neutrality  by  2050.  Between  1990  and  2022,  net  GHG 
emissions of Germany decreased by 41%, making it one 
of the countries with an above-average decrease. 

the  green 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
(i) 
speed  up 
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) 

transition. 

includes 

It 

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

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

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

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

(136)   Article  14  of  regulation  2018/1999  on  the  Governance  of  the 

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

Energy Union and Climate Action 

2025 Environmental Implementation Review – Germany 

 
 
 
 
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 (137) and, from 2024, maritime transport also. 

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

The  emissions  under  the  ETS  decreased  by  42%  from 
2005 to 2023. 

came 

installations 

In  2023,  63 %  of  the  greenhouse  gases  emitted  by 
Germany’s  ETS 
from  power 
generation,  significantly  more  than  the  EU  average 
(57 %). Of the total emissions from all industry sectors, 
about  31 %  came  from  the  metals  industry,  22 %  from 
cement  and lime production, 18 % from refineries, and 
22 %  from  the  chemical  industry.  Another  17 %  came 
from other industries. Since 2019, the power sector has 
registered  a  higher  reduction  (24 %)  than  the  industry 
sectors  (14 %).  Since  2013,  greenhouse  gas  emissions 
have declined by 48 % in power generation and by 16 % 
in  the  industry  sectors.  Nearly  all  of  this  decline  in  the 
industry sectors has occurred since 2019. 

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 ( 138 ).  Member  States  should 
have  notified  full  transposition  the  provisions  of  the 
revised  EU  ETS  directive  related  to  the  new  ETS2  into 
national law by 30 June 2024. 

Germany  did  not  communicate  full  transposition  into 
national law by this deadline. The Commission therefore 
opened an infringement procedure against Germany on 
25 July 2024, for failing to fully transpose the provisions 
into national law. 

Germany has  since  notified  transposition  of  the  relevant 
provisions  of  the  ETS2  Directive  to  the  Commission.  The 
monitoring and reporting requirements and the obligation 
to  hold  a  permit  to  carry  out  activities  under  ETS2 
commenced on 1 January 2025. 

Germany  36 

The Commission also opened an infringement procedure 
against Germany on 25 January 2024, for failing to fully 
transpose  previous  revisions  of  the  ETS  directives ( 139) 
into  national  law.  Germany  has  since  notified  full 
transpositions of the  abovementioned directives to the 
Commission. 

Effort sharing 

The  Effort  Sharing  Regulation (ESR) ( 140 )  covers  GHG 
emissions  from  domestic  transport  (excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture,  small 
industry  and  waste.  Emissions  from  these  sectors 
account for around 60 % of the EU’s domestic emissions. 
The  regulation  sets  the  EU-wide  target  to  reduce 
emissions  from  the  effort  sharing  sectors  by  40 %  by 
2030 compared to 2005 levels. This overall target for the 
EU  translates  to  binding  national  emission  reduction 
targets  for  each  Member  State.  Germany‘s  target  is 
– 50%. 

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

limits 

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

Based  on  historical  emissions  and  the  most  updated 
implement  new 
projections  Germany  will  need  to 
measures and/or use available flexibilities to achieve its 
2030 ESR target. 

Projected gap is 9.2 percentage points to the 2030 target. 

The largest contributor is the domestic transport sector, 
which accounted for 37 % of all effort sharing emissions 
in 2022. Transport emissions have decreased by just 5 % 
since 2005. 

Continued  effort  is  crucial  to  achieve  the  shift  to  zero-
emission  transport  in  Germany.  Cars  are  used  for  over 
89 % of the distances travelled (above the EU average of 
85 %). In 2022, battery electric vehicles made up 2 % of 
Germany’s  car  passenger  fleet,  a  significantly  higher 
share  than  the  EU  average  (1.2 %),  but  the  continued 
increase in this share is challenged by the cuts to financial 
incentives. In 2023, Germany had about 125 000 publicly 
accessible  charging  points,  one  for  every  15  e-vehicles 
(against  the  EU  average  of  1:10).  Freight  transport  by 
road  is  slightly  below  the  EU  average  (72 %,  EU:  75 %), 
with a higher share of inland waterways and rail. 53 % of 
the  railway  network  is  electrified  (EU  average:  56 %). 

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

(138)  Directive (EU) 2023/959. 

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

- EUR-Lex 

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

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
Improving  the  quality  and  service  of  rail  operations 
would  help  stimulate  demand  for  public  transport  and 
ease road congestion. 

available projections show a gap to target  of  6.6 Mt  of 
CO2  equivalent  in  2030.  Therefore,  Germany  needs  to 
apply additional measures to reach its 2030 target. 

Germany  37 

Buildings accounted for 30 % of effort sharing emissions 
and  have  decreased  by  28 %  since  2005.  Nevertheless, 
Germany  needs  to  step  up  its  efforts  in  the  residential 
sector to achieve a meaningful contribution to its 2030 
reduction  target  for  energy  consumption  in  buildings. 
Residential  final  energy  consumption 
increased  by 
4.12 % between 2018 and 2022, while the national long 
term renovation strategy aims to reduce primary energy 
consumption  in  buildings  by  39 %  between  2018  and 
2030.  The  share  of  renewables  in  heating  and  cooling 
(17.5 %)  is  relatively  low  compared  to  the  EU  average 
(25 %). 

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. 

That  is  not  the  case  for  Germany  anymore.  Germany’s 
LULUCF sector has had increasing emissions since 2020, 
a  worrying  trend.  The  rewetting  of  peatlands  gives  a 
prospect  of  reversing  the  trend  of  falling  net  carbon 
removals. 

Germany‘s target for 2030 is to enhance land removals 
by additional – 3.8 Mt of CO2 equivalent compared to the 
yearly  average  of  the  period  2016–2018.  The  latest 

Adaptation to climate change 

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

Germany  has  one  out  of  three  regions  identified  as  a 
hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions. (141) 

Germany’s  climate  change  risks  include  a  particularly 
high  risk  of  flooding  (including  coastal  floods),  of  heat 
waves and droughts, all with potentially high economic 
impacts.  Germany  has  made  significant  progress  on 
climate  adaptation,  particularly  on  assessing  and 
monitoring  risks  and  impacts.  Germany  has  a  share  of 
55%  insurance  coverage  of  private  properties  against 
natural disaster risks.  

Germany  adopted  its  national  adaptation  strategy  in 
2008  and  adaptation  plan  in  2011.  It  revised  both 
documents recently in 2024.  The new strategy requires 
the  federal  state  and  municipal  governments  to 
implement climate adaptation strategies. 

European  Commission  identified  five  priority  actions 
under the heading Climate Action in the 2022 edition (142) 
of the review. 

There  is  some  progress  in  accelerating  grid  expansion. 
National legislation was amended in 2023 to enable the 
accelerated  expansion  of  the  electricity  networks. 
Nevertheless,  Germany  requires  further  grid  expansion 
and 
transmission  and 
distribution level to enable the integration of additional 
renewable energy capacity and to reduce the curtailment 
of renewable energy. 

reinforcements,  both  at 

Germany managed to strongly increase both the amount 
of wind capacity installed in 2023 and (even  more) the 
number of projects receiving permits. Germany wants to 
achieve 30 GW in total offshore wind. Total capacity of 
offshore wind was 8 GW in 2022. 

Germany ranks fifth in the world in the patenting of high-
value inventions in solar PV. In connection to this, the EU 
having the highest share of the global market for clean 
energy technologies is notably driven by Germany. 

is  some  progress 

There 
in  sustainable  transport 
infrastructure,  but  the  number  of  publicly  accessible 

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

(142)  EUR-Lex - 52022SC0265 - EN - EUR-Lex 

European Climate Risk Assessment (europa.eu) 

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
 
Germany  38 

charging  points  and  the  share  of  electrified  railways 
remain under the EU average. 

• 

The German PV sector still occupies a strong position in 
some  segments  of  the  value  chain.  Germany  hosts  the 
only solar-grade polysilicon supplier in Europe. Germany 
is  currently  the  country  with  the  highest  installed 
manufacturing  electrolysis 
in  polymer 
electrolyte membrane and alkaline in Europe. 

capacity, 

ority actions 

2025 
Implement all polices and measures that are needed 
to  achieve  targets  laid  down  in  the  Effort  Sharing 
Regulation (ESR) and the Land use, land-use change 
and  forestry  (LULUCF)  Regulation.  More  detailed 
priority actions are set out in the assessment of the 
final National Energy and Climate Plan (NECP)(143). 

(143)   National energy and climate plans 

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
 
 
 
Germany  39 

Part II: Enabling framework – implementation tools

5. Financing 

The  EU  budget  supports  climate  investment  in  Germany 
with  significant  amounts  in  2021–2027,  with  revenues 
from the ETS also feeding into the national budget. During 
2020–2022, Germany’s revenues from auctioning reached 
EUR 14.8 billion in total, with 100 % of it spent on climate 
and energy. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 80.2 billion per year in 
Germany. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 60.2 billion per year; thus, there is 
a gap of EUR 20 billion per year. 

Most  of  the  environmental  investment  gap  is  linked  to 
tackling  pollution  (EUR 9.4 billion  per  year),  followed  by 
circular economy (EUR 6.2 billion per year) and the water 
objective (EUR 3.7 billion per year). 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
Recovery  and  Resilience  Facility  (RRF)  EUR 275.7 billion 
and the CAP EUR 145.9 billion (144). 

In  Germany,  the  EU  cohesion  policy  (considering  the  EU 
contribution amount) provides EUR 6.1 billion for climate 
action in 2021–2027 (with 54 % of this via the ERDF), with 

a  further  EUR 130 million  from  European  Maritime, 
Fisheries and Aquaculture Fund (145). 

The RRF contributes to  climate finance in  Germany with 
EUR 13.2 billion  up  to  2026,  representing  47 %  of  its 
national RRP (146). 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 14.1 billion was assigned 
to Germany in the reference period (147). 

National financing, including EU emissions trading 
system revenues 

to 

amounted 

EUR 2.7 billion 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
budgets, 
in  2020, 
EUR 5.3 billion  in  2021  and  EUR 6.8 billion  in  2022  in 
Germany,  totalling  EUR 14.8 billion  in  the  three-year 
period,  with  100 %  of  these  revenues  spent  on  climate 
action projects. All revenues go to a fund for climate and 
energy projects, which is additionally co-funded from the 
general budget (148). 

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 (149). 

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (150). 

therefore, 

and, 

Environmental financing and investments 

This  section  describes  Germany’s 
investment  needs, 
current  financing  and  gaps  as  they  relate  to  the  four 

(144)  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, 

(145)  See 

the 

Cohesion 

Open 

Data 

Platform 

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

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

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

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

Luxembourg, 

Union, 

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

Luxembourg, 

Union, 

(150)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

(147)  A 

list  of 

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

financed  projects 

the  EIB 

support of the environment are accounted for via the tracking. 

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (151). 

European  Maritime  Fisheries  and 
Aquaculture Fund 

Other MFF sources 
RRF (d) (2021–2026) 

105 

2 642.4 (c) 
4 899.5 

Germany  40 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient to enable Germany 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 80.2 billion  per  year  (in  2022 
prices). 

Almost  half  of  this,  EUR 42 billion,  constitutes  a  circular 
economy  investment  potential  for  Germany  that  can  be 
utilised in the key systems related to the circular economy 
(e.g.  mobility, 
the  built  environment). 
Investment needs for the water objective are estimated to 
be  EUR 19.4 billion  per  year,  followed  by  pollution 
prevention  and  control  (EUR 13.4 billion  per  year)  and 
biodiversity and ecosystems (EUR 5.7 billion per year). 

food  and 

Current investment 

(a) 

(b) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations  in  EU  amount  excluding  national  co-financing,  based 
on the tracking in the Common Provisions Regulation (CPR, 2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its  publication  date.  Note  that  Germany  is  not  eligible  for  the 
Cohesion 
information: 
and 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

Source 

Fund. 

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.    

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual EUR 60.2 billion in Germany from EU and national 
sources combined (in 2022 prices). 

(c) 

(d) 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 14.8 billion  for  Germany  in  total,  during  2021–2027 
(or EUR 2.1 billion per year). 

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

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development 

Allocations 
2 887.1 (a) 
2 415.5 
0.0 
471.6  
9 184.4 (b) 
5 751.2 
3 433.3 

(151)  Research,  development  and  innovation  is  accounted  for  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.  

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

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. Data source: European Commission.   

Germany,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
instrument  for  the  environment  (LIFE) 
the  financial 
programme ( 152 ) 
(EUR 5.4 billion),  Horizon  Europe 
(EUR 95.5 billion) ( 153 ),  the  Connecting  Europe  Facility 
(EUR 33.7 billion) ( 154 )  and  funds  that  can  be  mobilised 
through the InvestEU programme (155). 

(47 %  of 

Germany’s  RRP  provides  EUR 13.17 billion  for  climate 
action 
total),  with  an  additional 
EUR 0.02 billion  (0.1 %  of  the  total)  contribution  to  the 
environmental objectives. 

the 

(154)  The  Connecting  Europe  Facility 

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

(Transport)  also 

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

2025 Environmental Implementation Review – Germany 

 
 
 
Germany  41 

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

The  EIB  provided  around  EUR 5 billion  in  environment-
related financial contributions to Germany  from 2021 to 
mid  2024,  most  of  which  (EUR 3.7 billion)  was  linked  to 
sustainable  energy,  transport  and  industrial  projects, 
which  provides  significant  co-benefits  to  reducing  air 
pollution,  environmental  noise  and  other  pollution. 
Around another EUR 1 billion concerned water projects. 

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 Germany, the 
total national environmental protection expenditure was 
EUR 79.9 billion  in  2020  and  EUR 83.1 billion  in  2021, 
representing 2.3 % of GDP. 

Of  the  total  environmental  expenditure,  the  national 
(investment)  on  environmental 
capital  expenditure 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Germany,  the  national 
0.4 %  of  the  EU’s  GDP. 
reached 
environmental 
EUR 14.5 billion  in  2020  and  EUR 14.4 billion  in  2021, 
representing around 0.4 % of GDP. 

investment 

protection 

Splitting  by  institutional  sector,  16.6 %  of  Germany’s 
national  environmental  protection  investment  (capital 
expenditure) comes from the general government budget, 
with  63.4 %  coming 
from  specialist  private-sector 
producers (of environmental protection services, such as 
waste and water companies) and  20 % from the general 
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 % 
specialist  private-sector 
producers and 22 % from the general business sector (156). 

from 

Germany’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 60.2 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funds  (including  EIB  funds)  reaches  5.5 %,  with  around 
94 % national financing. The total public financing (EU plus 
national public) represents 21 % of the total. 

The gap 

To meet its four environmental objectives beyond climate 
change, the additional investment need over the current 
levels  (i.e.  the  gap)  reaches  an  estimated  EUR 20 billion 
per year in  Germany, representing around 0.52 % of the 
national GDP, being lower than the EU average (0.77 %). 

Source: Analyis of Directorate-General for Environment. 

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

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

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Investment gap per year  

% of GDP 

 % of 
total 

Million 
EUR 
(2022 
prices) 

9 444 

47.2 

0.24 

6 177 

30.9 

0.16 

3 746 

18.7 

0.10 

638 

3.2 

0.02 

Total 

20 004 

100.0 

0.52 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

(156)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – Germany 

 
 
 
Germany  42 

additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

According to the latest (2023) NAPCP review report (160), 
Germany complied with ammonia reduction requirements 
in 2020 and 2021, and it is not at risk of non-compliance 
with  ammonia  concerning  the  NECD’s  2030  emission 
reduction  commitments,  based  on  the  policies  and 
measures  in  its  NAPCP  that  take  into  account  climate, 
energy and CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

Germany’s  investment  needs  in  circular  economy  and 
waste reach EUR 41.7 billion per year (including baseline 
investments).  Most  of  this,  around  EUR 38.2 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 3.6 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 (161). 

Current investments 

Circular economy investments across the economy reach 
around  EUR 32.4 billion  per  year  in  Germany  in  2021-
2027,  with  a  further  EUR 3.2 billion  provided  for  waste 
management that does not constitute circular economy. 

Around 0.2 % of the combined financing for circularity and 
waste  comes  from  the  EU  MFF,  with  no  additional 
contribution from the RRF. EIB loans identified in support 
of circularity and waste represent 0.1 % of the total. The 

control,  Germany’s 
In  pollution  prevention  and 
investment needs are estimated to reach EUR 13.4 billion 
per  year  (including  baseline  investments)  in  2021–2027. 
Most  of  this,  EUR 10.2.7 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 5.9 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air ( 157 ).  Industrial  site  remediation 
requires  an  estimated  EUR 700 million  per  year. 
Protection from radiation (nuclear site decommissioning, 
nuclear  waste)  costs  around  EUR 1.5 billion  per  year. 
Microplastics pollution and the chemicals strategy require 
around EUR 400–500 million per year (each) (158). 

Current investments 

investment 

The  current 
levels  supporting  pollution 
prevention  and  control  reach  an  estimated  EUR 4 billion 
per year in Germany in 2021–2027. Most of the financing 
concerns clean air (EUR 3 billion per year). Protection from 
environmental  noise  receives  around  EUR 871 million 
(each) per year, with a further EUR 245 million a year for 
the  chemicals  strategy,  EUR 212 million  for  radiation 
industrial  site 
protection  and  EUR 212 million 
remediation (159). 

for 

In Germany, the EU MFF provides an estimated 11.2 % of 
the clean air financing (mostly via cohesion policy), with a 
further  16.8 %  from  the  RRF,  adding  up  to  28 %  of  the 
total.  EIB  financing  contributes  12.6 %  and  national 
sources reach 59.4 %. 

The gap 

To meet its environmental objectives concerning pollution 
prevention and control (towards zero pollution), Germany 
needs  to  provide  an  additional  EUR 9.4 billion  per  year 
(0.24 % of GDP), mostly related to clean air. The adequate 
implementation  of  the  NECP  with  the 
investments 
included  for  sustainable  energy  and  transport  would 
in  many  Member  States 
largely  deliver  this,  while 

(157)  2021 

assessment 

Phenomena 

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

Environmental 

Noise 

2023 

(158)  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). 

(159)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure  (environmental  protection  expenditure  accounts, 
Eurostat). Note that the bulk of clean air financing is provided as a 
contribution from climate (energy and transport) measures, as per 

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

Commission 

projections’, 

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

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

2025 Environmental Implementation Review – Germany 

 
 
share  of  national  sources  is  absolutely  overwhelming, 
reaching 99.7 % of the total financing (162). 

EUR 0.7 billion the other aspects of the Water Framework 
Directive (water management and protection). 

Germany  43 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular economy and waste,  Germany needs to increase 
investments  by  an  estimated 
circular  economy 
EUR 5.8 billion 
additional 
EUR 415 million  concerning  waste  management  action, 
not  belonging  to  circular  economy.  Combined,  this 
amounts to EUR 6.2 billion per year, representing 0.16 % 
of Germany’s GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 1.5 billion  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 4.3 billion constitutes further investment need to 
unlock Germany’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 19.4 billion  (in  2022  prices) 
in  Germany.  This 
comprises investment needs both for the water industry 
and for the protection and the management of water. The 
largest  part  of  the  total  annual  need,  EUR 11.3 billion, 
relates to the management of waste water (also including 
additional costs  associated with  the revised UWWTD).  A 
further  EUR 7.3 billion  is  necessary  for  drinking-water-
related  investments  and  around  EUR 693 million  for  the 
protection and management of water (163). 

Current investments 

Water  investments  in  Germany  are  estimated  to  be 
around EUR 15.6 billion per year (in 2022 prices) in 2021–
2027.  Of 
this,  EUR 8.6 billion  support  wastewater 
management,  EUR 6.3 billion  drinking  water  and  around 

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

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

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

Of  the  total  financing,  a  very  small  part,  only  0.4 %,  is 
provided by the EU MFF (mostly through cohesion policy). 
EIB  financing  constitutes  similarly  small  share  (0.9 %). 
98.8 %  of  the  water  financing  coming  from  national 
sources (164). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Germany’s water investment  gap reaches  EUR 3.7 billion 
per  year  (0.1 %  of  GDP),  with  over  half  related  to  waste 
water (EUR 2.7 billion per year). Drinking water measures 
require an additional EUR 1.1 billion per year. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems in 
Germany are estimated to be EUR 5.7 billion per year (in 
2022  prices)  in  2021–2027.  This  includes  the  following 
financing needs: 

•  Germany’s  prioritised  action 

framework ( 165 ), 
concerning the Natura 2000 areas: EUR 1.5 billion per 
year, mostly running costs; 
additional BDS costs (166): EUR 2.7 billion per year on 
top of the framework; 
sustainable 
EUR 1.5 billion per year. 

soil  management 

costs (

): 

167

• 

• 

Current investments 

The current level of biodiversity financing is estimated to 
be  EUR 5 billion  per  year  (in  2022  prices)  in  2021–2027. 
93 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

1.5 % of the total financing is estimated to come from EU 
cohesion  policy  and  24.3 %  from  CAP.  The  EU  budget 

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

Commission 

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

European 

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

European  Union, 

Luxembourg, 

the 

of 

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

5 July 

final 

of 

2025 Environmental Implementation Review – Germany 

 
 
Germany  44 

accounts for 28 % of the financing. The rest, 72.1 %, comes 
from national sources (168). 

Green budgeting practices provide increased transparency 
on the environmental implications of budgetary policies.  

In  Germany,  22.3 %  of  the  entire  CAP  budget  for  2021–
2027  is  estimated  to  contribute  to  biodiversity,  a  share 
significantly  higher  than  the  EU  average.  However,  only 
5 %  of  cohesion  policy  funds  (considering  the  EU 
contribution  amount)  in  2021–2027  are  envisaged  to 
support biodiversity (disregarding ESF+), and no RRF funds 
have  been  programmed  for  investments  in  biodiversity 
(see Figure 36). 

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

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 (170). 

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 (171). Germany did not participate in the TSI 
project. 

Nevertheless, as part of other 2024 TSI projects, Germany 
contributed to the following regional and local initiatives: 

•  Baden-Württemberg  has  been  receiving  support  for 
developing  a  transparent  and  easily  applicable 
method of climate tagging and integrating it into the 
budget cycle (172). 
The  City  of  Hamburg,  jointly  with  other  European 
cities,  has  been  developing  methodologies  to  align 
local 
sustainable 
budgeting 
development goals (173). 

processes  with 

• 

Other  regional  governments  such  as  Lower  Saxony  have 
also been piloting green budgeting practices (174). Beyond 
green  budgeting,  to 
improve  policy  outcomes  the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance ( 175),  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 63.3 billion in 
Germany  in  2022,  representing  1.6 %  of  its  GDP  (EU 
average:  2.0 %).  Energy  taxes 
largest 
component of environmental taxes, accounting for 1.36 % 
of  GDP,  which  is  lower  than  the  EU  average  of  1.6 %. 
Transport  taxes,  at  0.28 %  of  GDP,  were  under  the  EU 
average  (0.4 %),  while  data  on  taxes  on  pollution  and 
resources were not available from Germany (EU average: 

formed  the 

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

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

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 
(172)  Technical support received under the TSI project 24DE26. 
(173)  Technical support received under the TSI project 24DE01. 
(174)  Haushaltsplan 2025 ist der Startschuss für Klimacheck im 

Landeshaushalt | Nds. Ministerium für Umwelt, Energie und 
Klimaschutz 

(175)  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. 

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,  Germany’s 
investment gap is estimated to be EUR 0.6 billion per year, 
corresponding to 0.02 % 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  ( 169). 

(168)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

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

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

2023, 

(170)  European  Commission, 

reference 

framework’, 

‘European  Union  green  budgeting 
https://economy-

2022, 

2025 Environmental Implementation Review – Germany 

 
 
 
 
In  2022,  environmental  taxes 

in  Germany 
0.08 %). 
accounted for 4 % of total revenues from taxes and social 
security  contributions 
the  EU  average  of 
(under 
5.0 %) (176). 

Figure 37: Environmental taxes per Member State, 2022 

Germany  45 

During  2014–2023,  83 %  of  the  green  bonds  issued  by 
European  countries  (excluding  supranational  entities) 
served objectives in energy, buildings or transport, while 
5 % supported objectives in water, 5.1 % related to land 
use  (with  links  to  nature  and  ecosystems),  and  3.8 % 
applied  to  waste  management.  By  2023,  the  combined 
share of energy, buildings and transport had decreased to 
73 %, the shares of waste management and land use had 
increased (to 5.9 % and 8.4 %, respectively) and the share 
of water had remained around 5 %. 

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

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

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

According to a 2024 study (177), Germany applies charges 
on air emissions, solid waste disposal (landfill fee), green 
vehicle  tax  differentiation, 
levies  on  plastics  and 
aluminium  sheets  and  strips,  and  volumetric  charges  on 
water abstraction and disposal. 

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 (178). 

During  2021–2023  combined,  Germany  issued  green 
bonds worth USD 193.2 billion (EUR 163.3 billion). Of this, 
the 
in  2023  amounted  to  USD 62.4 billion 
issuance 
(EUR 13.9 billion). 

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 
the  enabling 
action  programme  objectives  and 

(176)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(177)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annex 1, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(178)  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. 

2025 Environmental Implementation Review – Germany 

 
 
 
 
conditions (179). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

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

Germany  46 

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

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (180). 

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 (181). 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  Germany,  the  energy  subsidies  were  stable  in  2015–
2021,  with  FFS  ranging  between  EUR 15 billion  and 
EUR 17 billion  per  year.  In  2022  and  2023,  energy 
subsidies  increased  overall,  and  so  did  FFS,  reaching 
EUR 41.1 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.  Germany’s 
value  reached  0.7 %,  slightly  under  the  EU  average 
(0.8 %) (182). 

(179)  Article 3(h) and 3(v) of the eighth environment action programme. 
(180)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

Union, 

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

NB: RES, renewable energy source. 

Source : analysis of Directorate-General Energy 

For  Germany,  the  2022  priority  actions  included  the 
following. 

• 

increased 

Ensure  an 
level  of  financing  for  the 
environment to cover the investment needs expected 
and to close the investment gap. 

While  the  level  of  the  environmental  investment  gap  is 
lower than average, it still reaches an estimated 0.5 % of 
GDP, and most of it is related to pollution prevention and 
control. 

2025 priority action 

•  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. 

(181)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

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

Union, 

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

2025 Environmental Implementation Review – Germany 

 
 
 
 
 
 
6. Environmental governance 

Information, public participation and access to 
justice 

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

Germany  47 

to 

(iii) 

and 

access 

justice 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making 
in 
environmental  matters.  It  is  of  crucial  importance  to 
public  authorities,  the  public  and  businesses  that 
is  shared  efficiently  and 
environmental 
effectively (183).  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 (184).  It  includes  the  right  to 
bring legal challenges (‘legal standing’) (185). 

information 

Environmental information 

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

Germany’s  performance  in  implementing  the  Inspire 
Directive is substantial and has been reviewed based on 
its 2023 country fiche (186) (see Table 3). 

(183)  The  Aarhus 

Convention 

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

and 

the 

(184)  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 

2016  2023 

Legend 

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

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

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

efforts 

Effective  coordination  and 
data sharing 

Ensure 
effective 
coordination 

sharing 

Data 
without 
obstacle 

Inspire 
indicators 

■  ■ 

■  ■ 

performance 

(i)  Conformity 
of metadata 

■  ■ 

(ii)  Conformity 
of 
spatial 
datasets 

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

(iv)  Conformity 
of 
network 
services 

■  ■ 

■  ■ 

■  ■ 

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

In 2022, Germany received a priority action on the need to 
make spatial data more widely accessible and to prioritise 
the environmental datasets. Germany has made progress 
on accessibility of spatial data, including on accessibility of 
high-value 
implementing 
datasets 
environmental legislation (187). 

spatial 

for 

2018 citizen’s guide (https://op.europa.eu/en/publication-detail/-
/publication/2b362f0a-bfe4-11e8-99ee-01aa75ed71a1/language-
en/format-PDF).  

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

(186)  European  Commission,  ‘Germany’,  Inspire  Knowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/germany_en. 

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

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

Environmental Implementation Review 2025 – Germany 

 
 
 
Public participation 

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

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (188) 
and  the  Strategic  Environmental  Assessment  (SEA) 
Directive (189). 

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 (190).  Germany has already 
taken 
to  accelerate  permit-issuing 
procedures  taking  advantage  of  the  broad  flexibilities 
legal  framework,  such  as  the 
offered  by  the  EU 
establishment  of  one-stop  shops  and  accelerated  short 
deadlines  for 
issuing  permits  for  renewable  energy 
projects. 

steps  aiming 

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 ( 191 ).  The  duration  of  each  step  in  an  EIA 
report,  public 
process 

scoping,  EIA 

(screening, 

Germany  48 

consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
Germany was able to provide information on the duration 
of  only  some stages of the EIA process. The  fragmented 
nature of the data available therefore limits the ability to 
draw general conclusions. A priority action is included for 
2025  to  provide  more  detailed  information  on  the 
different  stages  of  the  EIA  process.  Effective  use  of  EU 
procedures can positively influence the timely approval of 
activities  underpinning  the  decarbonisation  of  the 
economy on the way to net zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a support study has been published with information by 
Member State (192). 

With regard to public participation, Germany received one 
priority  action  related  to  EIA  and  SEA  in  2022:  provide 
publicly  available  information  and  statistics  on  public 
participation and contributions to EIAs/SEAs at the federal 
and Länder levels. Germany makes EIA portals available at 
the  federal  and  Länder  levels ( 193).  The  portals  provide 
information  on  projects,  including  short  summaries  and 
details  on  public  participation,  progress  made  on  the 
authorisation  procedure,  and  the  final  decision  on  the 
approval of the project (including an explanation of how 
the  reasoned  assessment,  in  particular  input  from  the 
public, was taken into account in the decision). Germany 
has  therefore  fulfilled  this  priority  action.  However, 
Germany  was  not  able  to  provide  information  on  the 
average  duration  of  all  stages  of  the  EIA  process,  and 
hence a priority action is proposed for 2025. 

Access to justice 

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

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

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

(190) 

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

Impact  Assessment 

(191)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
revised  Environmental 
(EIA)  Directive 
(2011/92/EU) as amended by 2014/52/EU), Publications Office of 
the  European  Union,  Luxembourg,  2024,  Tables 5  and  6, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
( 192 )  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 

(193)  https://www.uvp-verbund.de/startseite; 

https://www.uvp-

portal.de/de. 

2025 Environmental Implementation Review – Germany 

 
 
 
review of the decisions of public authorities and to allow 
the  correction  of  any  wrongdoing  committed  by  these 
authorities. 

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

As mentioned in the 2022 EIR, recognised environmental 
organisations  are  granted  legal  standing  in  all  cases 
explicitly  specified  in  the  Environmental  Appeals  Act 
(Umweltrechtsbehelfsgesetz). 
Federal  Nature 
Conservation  Act 
(Bundesnaturschutzgesetz)  and  a 
number  of  Länder  nature  conservation  acts  grant  legal 
standing to recognised nature conservation organisations 
in  specified  areas  of  nature  conservation (194),  providing 
further  standing  to  challenge  acts  not  mentioned  in  the 
Environmental Appeals Act. 

The 

in 

listed 

section 1,  paragraph 1  of 

However,  there  remain  some  difficulties  in  challenging 
plans or programmes. Environmental organisations have 
limited  standing  for  cases  in  this  category,  as  they  have 
access  to  justice  exclusively  with  regard  to  the  subject 
the 
matter 
Environmental Appeals Act. If plans or programmes do not 
fall within the scope of section 1, paragraph 1, no 4 of the 
Environmental Appeals Act, there is limited direct access 
to justice in the cases of this category. In principle, neither 
individuals nor NGOs have standing to challenge national 
regulatory  acts,  except  when  requesting  a  ‘preventive 
declaratory  judgment’  to  stop  an  upcoming  criminal 
sanction  or  where  an  ‘incident  review’  might  offer  the 
possibility  to  challenge  the  validity  of  the  underlying 
regulatory act, which is not an option if the regulatory act 
does not require further implementing acts. There have so 
far not been enough court judgments to set a precedent 
and there is no clear legal framework. It is therefore not 
sufficiently clear if there is effective access to justice with 
regard  to,  for  example,  the  designation  of  conservation 
areas by legislative decrees and not requiring a SEA. 

In  2022  Germany  received  priority  actions  on  access  to 
justice, in particular to (i) better inform the public about 
their access to justice rights and (ii) improve legal clarity 
on  access  to  courts  by  the  public  when  it  comes  to 
challenging  administrative  or  regulatory  decisions  and 
omissions in the planning context. Information on access 

Germany  49 

to  justice  in  environmental  matters  is  available  on  the 
websites  of  the  Federal  Ministry  for  the  Environment, 
Nature  Conservation,  Nuclear  Safety  and  Consumer 
Protection  (referring  also  to  the  European  e-Justice 
Portal ( 195 ))  and  the  Federal  Environment  Agency 
(Umweltbundesamt). Germany has therefore fulfilled the 
first  priority  action.  On  the  latter  there  has  been  no 
progress.  

2025 priority actions 

• 

• 

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. 
Provide  information  on  the  average  duration  of  all 
steps in the EIA process. 

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 (196) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is, 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

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

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

A  publication  from  the  Federal  Environment  Agency  in 
December  2021  provides  an  update  on  the  status  and 
development of environmental crimes in Germany based 
on police and court statistics (197). 

(194)  See section 64 of the Federal Nature Conservation Act. 
(195)  https://e-

justice.europa.eu/content_access_to_justice_in_environmental_
matters-300-en.do. 

(197)

(196)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 
compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 

staff 

Commission 
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

document 

working 

(https://eur-

https://www.umweltbundesamt.de/sites/default/files/medi
en/11850/publikationen/98_2023_texte_umweltdelikte_2021.p
df. 

2025 Environmental Implementation Review – Germany 

 
 
 
Between  15 May  2022  and  31 December  2024,  the 
Commission  received  72  complaints  relating  to  the 
environment in Germany, the joint third highest in the EU, 
although  in  terms  of  complaints  per  million  inhabitants 
the  amount  is  0.86  well  below  the  EU  average  of  3.2 
(figures  40  and  41).  Forty  of  these  concerned  alleged 
breaches  of  the  Nature  Directives,  with  a  focus  on 
appropriate assessments in Natura 2000 sites, while  the 
others concerned water, waste, air quality, EIA issues and 
noise. 

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  

12

10

8

6

4

2

0

T
M

Y
C

R
H

I

V F
L

L
E

T
A

E
O I
R

G
B

E
S

S
E

K
D

7
2
U
E

T
P

E
E

I

K S
S

T
I

U
L

L
P

E
B

T
L

Z
C

L
N

E
D

R
F

U
H

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

198  

The next publication from the Federal Environment Agency (UBA) 
will  provide  further  updates  on  the  status  and  development  of 
environmental crimes in Germany; a publication date has not been 
announced yet. 

Germany  50 

The  2022  EIR  recommended  that  Germany  provides 
information  to  the  public  about  compliance  monitoring 
and enforcement in environmental matters as well as on 
the outcome of administrative and criminal enforcement 
actions and the follow-up to detected breaches of cross-
compliance. 
promotion, 
monitoring and criminal and administrative enforcement, 
the 2022 priority actions are not assessed here due to lack 
of systematic information198.  

compliance 

Concerning 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203)(199) and new sectoral legislation with 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  commit  an  offence  were  also 
introduced.  Other  provisions  will  help  considerably  to 
improve  the  effectiveness  in  combating  environmental 
crime  of  all  actors  along  the  enforcement  chain.  These 
include  obligations  to  ensure  adequate  resources  and 
investigative  tools,  specialised  regular  training  and  the 
establishment  of  cooperation  mechanisms  within  and 
between Member States as well as national strategies on 
combating environmental crime. 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
crime, 
in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
facilitating  the 
will  provide  support, 
identification  and  sharing  of  good  practices.  Member 

including  by 

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

criminal 

law 

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

2025 Environmental Implementation Review – Germany 

 
 
 
 
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  Enforcement  of  Environmental 
Law ( 200),  EnviCrimeNet ( 201),  the  European  Network  of 
Prosecutors for the Environment (202) and the EU Forum of 
Judges  for  the  Environment ( 203 ).  The  European  Union 
Agency for Law Enforcement  Cooperation and European 
Union  Agency 
Justice  Cooperation 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences. 

for  Criminal 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)( 204)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (205), which will be finalised in 2025, and which 
was  supported  by  an  external  study ( 206 ),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

indicators 

in  assessing 
One  of  the  most  relevant 
implementation  and  enforcement  of  the  ELD  is  the 
number  of  environmental  damage  cases  handled  under 
the  ELD,  especially  when  this  number  is  compared  with 
the  previous  reporting  period.  Fewer  ELD  cases  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 

(200)  https://www.impel.eu/en. 
(201) 

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

project 

(202)  https://www.environmentalprosecutors.eu. 
(203)  https://www.eufje.org/index.php?lang=en. 
(204) Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage, https://eur-

Germany  51 

overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  be  compared 
with the overall number of environmental damage cases, 
some of  which  may have been handled under the other 
liability instruments. 

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

the  development  of 

In  contrast,  Germany 

The  German 
Insurance  Association  recorded  3 265 
environmental damage claims for 2010 to 2020 under its 
model  ELD  environmental  extension  to  general  liability 
policies. 
reported  60  ELD 
occurrences  to  the  Commission  for  the  first  reporting 
period  and  147  ELD  occurrences  for  the  second  one,  of 
which  12  were  handled  under 
legislation 
implementing the ELD. The remaining 135 were resolved 
under  other  national 
(relevant  sectoral 
legislation).  Germany  is  among  the  Member  States  with 
the largest decreases between the two reporting periods 
(from 60 to 12 occurrences); however, it should be noted 
that in its second report, Germany covered only a three-
year period from  26 June 2019 to  31 December 2021. In 
line  with  Article  18  (1)  ELD,  Germany  will  now  publish 
reports on ELD occurrences every 5 years, the next one in 
2027.  

legislation 

federal 

Germany  has  not  imposed  mandatory  financial  security 
for  ELD  liabilities.  Environmental  insurance  policies  that 
provide  cover  for  all  ELD  liabilities  are  available  but  are 
rarely  purchased  due  to  the  prevalence  of  the  German 
Insurance Association’s model extension for ELD liabilities 
in  general  liability  policies.  The  model  environmental 
extension to general liability policies specifically provides 
cover  for  ELD  liabilities  with  the  caveat  that  it  does  not 
provide  cover  for  environmental  damage  that  occurs  on 
an insured site. 

The  EIR  2022  recommended  that  Germany  publish 
information  on  environmental  damages  detected 

lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626 

(205)  Commission  staff  working  document  -  Evaluation  of  the 

(206) 

Environmental Liability Directive, forthcoming 2025.  
 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, 
https://op.europa.eu/en/publication-detail/-
2024, 
/publication/006d90e5-980a-11ef-a130-
01aa75ed71a1/language-en. 

2025 Environmental Implementation Review – Germany 

 
 
 
the 

improve 

(possibly  via  a  registry  or  database  on  ELD  incidents), 
promote  reporting  by  citizens  and  NGOs  to  increase 
compliance,  and 
complaint-handling 
architecture.  This  could  consist  of  a  centralised  federal 
webpage and/or the creation of a federal-level complaint-
handling  platform  to  report  environmental  damage. 
Germany  has  made  some  progress  in  improving  the 
reporting  on  ELD  occurrences.  However,  there  is  no 
information  available  about  the  progress  on  other  2022 
priority actions in relation to the ELD. Therefore, efforts to 
implement  2022  priority  actions  should  continue  along 
with the 2025 priority action. 

2025 priority action 

• 

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

The  Commission’s  2023  Compact ( 207 ) 
initiative  to 
enhance  the  administrative space  identifies  the  capacity 
to  lead  the  green  transition  as  one  of  three  key  pillars, 
along with the public administration skills agenda and the 
capacity  for  Europe’s  Digital  Decade.  Compact  also 
recognises the role of the EIR reporting tool in improving 
environmental  governance.  The  two  main  capacity-
building  opportunities  for  the  environment  provided  by 
the  European  Commission  are  the  technical  support 
instrument  (TSI) ( 208 )  and  the  TAIEX-EIR  PEER  2  PEER 
tool (209).  The  technical  assistance  available  through  the 
cohesion  policy  is  subject  to shared  management  and  is 
not dealt with in this subsection. 

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. 

Germany  52 

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

•  Digitalising monitoring of East Atlantic flyway, multi-
country project  with Denmark  and  the Netherlands, 
Federal  Ministry 
for  the  Environment,  Nature 
Conservation  and  Nuclear  Safety  (BMU),  National 
Park in Lower Saxony (2022); 

•  Climate  adaptation:  Wildfire  prevention,  response 
and  climate-related  risk  assessment,  Saxon  State 
Ministry of the Interior (2023); 

• 

•  Green budgeting, developing a transparent and easily 
applicable method of climate tagging and integrating 
it into the budget cycle, Ministry of Finance, Baden-
Württemberg  (2024); 
Tackling greenwashing risk in the German and Dutch 
sustainable investment fund market, BaFiN (2024); 
PACE –  Natural  hazard 
in  France 
(Germany),  Ministry  of  Justice,  North  Rhine  – 
Westphalia (2024); 
Sustainability 
Ministry of Finance (2024); 

local  public  finances,  Hamburg 

insurance 

in 

• 

• 

• 

•  Multi-stakeholder  advocacy  on  sustainable  finance 
and  sustainable  transition –  Stay  at  the  Danish 
Climate Partnership (2024). 
Integrated 
informs 
adaptive  management  of  coastal  wetlands,  Federal 
Ministry  for  the  Environment,  Nature  Conservation, 
Nuclear  Safety  and  Consumer  Protection  (BMUV) 
(2025). 

environmental  monitoring 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where a  delegation of  experts travels to the requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
multi-country  workshops  are  those  requested  by  the 
Commission to present new and upcoming environmental 
legislation and policy in all Member States (210). 

(207)  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). 

(208)  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). 

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

tool 
governance/environmental-implementation-review/peer-2-
peer_en). 

(210)  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  Directive  to  further 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25 September  2024);  Industrial  emissions  transposition 

2025 Environmental Implementation Review – Germany 

 
 
 
 
Germany  53 

Workshops involving Germany are as follows: 

•  Climate adaptation and blue infrastructure (31 May–

1 June 2022); 

•  Circular economy (in the Irish Midlands) (4–6 October 

• 

2022); 
Future  challenges  for  air  protection  (24 November 
2022) with the EU Czech Presidency; 

•  Making  space  for  biodiversity:  Regional  action  to 
mainstream  biodiversity  and  empower  stakeholders 
(21–23 March 2023); 

•  New aspects in the cross-border cooperation against 
environmental crime (19–20 November 2024). 

Germany was involved in two expert missions: one on best 
practices in applying Article 6(3) of the Habitats Directive 
in  Estonia  (26–27 April  2023)  and  the  other  on-air 
emissions  inventory  and  assessment  of  the  impact  of 
policies  and  measures  on  emissions  in  Lithuania  (15–
17 May 2023). 

2025 priority action 

•  Biodiversity, nature conservation and large predators: 

• 

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

•  Online  platforms:  EU  batteries,  packaging  and 
packaging waste regulation (28–29 October 2024); 

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

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 – Germany 

 
 
 
 
 
Germany  54 

Annex 

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

• 

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

Waste management   
•  Further shift reusable and recyclable waste away from incineration, including through economic 

• 
• 
• 

instruments. 
Increase the collection and recycling rate of waste electrical and electronic equipment (WEEE). 
Invest in waste prevention measures to reduce the total amount of waste generated. 
Ensure the achievement of the 2025 waste targets, following the recommendations made by the 
Commission in the Early Warning Reports where applicable. 

Biodiversity and natural capital   
Nature protection and restoration – Natura 2000   

• 

Finalise the establishment of site-specific conservation objectives and measures for all Natura 2000 
sites (including by adopting their management plans) and ensure their effective implementation. 

Recovery of species    

•  Reinforce action for habitats and species in unfavourable conservation status, for example 

through restoration measures, increased connectivity, better policy coordination and integration, 
and increased funding. 

Agricultural ecosystems 

Recovery of ecosystems  

• 

• 

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

Wetlands/peatlands 

• 

Implement  peatland  conservation  and  restoration  measures  and  include  such  measures  and 
objectives in the national restoration plans. 

Prevention and management of invasive alien species    

• 

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

Zero pollution   
Clean air   

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

requirements under the revised AAQD. 

Industrial emissions   

•  Complete the correct transposition of the IED 1.0. 
•  Reduce industrial air pollution damage and intensity. 
•  Reduce industrial releases to water and their intensity. 

2025 Environmental Implementation Review – Germany 

 
 
 
Germany  55 

•  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   

Water Framework Directive 

• 

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

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

hydropower pressures. 

•  Reduce pollution from nutrients, chemicals, metals and saline discharges. 

•  Better justify exemptions to the achievement of good status. 

• 

Improve the classification of water bodies and strengthen monitoring systems. 

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

Floods Directive  

• 

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

•  Consider future climate scenarios in FRMPs. 
•  Better explain the choice and implementation of flood prevention and protection measures 

(prioritisation, monitoring, costs of measures). 

Nitrates Directive  

• 

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

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

• 

policy of zero tolerance of non-compliance. 
Increase customs checks and checks of products sold online with regard to compliance with 
chemicals legislation. 

Climate action   

• 

Implement all polices and measures that are needed to achieve targets laid down in the Effort 
Sharing Regulation (ESR) and the Land use, land-use change and forestry (LULUCF) Regulation.  

More detailed priority actions are set out in the assessment of the final National Energy and 
Climate Plan (NECP). 

Financing   

2025 Environmental Implementation Review – Germany 

 
 
 
Germany  56 

•  Use more national funding (including by increasing taxes in favour of the environment and 

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

Environmental governance 
Information, public participation and access to justice 
Provide information on the average duration of all steps in the EIA process. 
Improve access to courts in national environmental cases by the public concerned and eliminate 
practical barriers, such as length of proceedings and excessive costs in some Member States. 

• 
• 

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

• 

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

2025 Environmental Implementation Review – Germany