COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - LUXEMBOURG 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, Luxembourg, 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) 317 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review       Country Report - LUXEMBOURG             Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 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}  
 
 
Luxembourg  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Transitioning to a circular economy ..................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 12 
Global and EU biodiversity frameworks ............................................................................................................. 12 
Nature protection and restoration – Natura 2000 ............................................................................................. 12 
Recovery of species ............................................................................................................................................ 14 
Recovery of ecosystems ..................................................................................................................................... 15 
Prevention and management of invasive alien species ...................................................................................... 20 
Ecosystem assessment and accounting ............................................................................................................. 21 
3. ZERO POLLUTION ..................................................................................................................................................... 22 
Clean air ............................................................................................................................................................. 22 
Industrial emissions ............................................................................................................................................ 23 
Major industrial accidents prevention – Seveso ................................................................................................. 25 
Mercury Regulation ............................................................................................................................................ 26 
Noise .................................................................................................................................................................. 27 
Water quality and management ........................................................................................................................ 27 
Chemicals ........................................................................................................................................................... 32 
4. CLIMATE ACTION ..................................................................................................................................................... 35 
The EU emissions trading system ....................................................................................................................... 36 
Effort sharing ..................................................................................................................................................... 36 
Land use, land-use change and forestry ............................................................................................................. 37 
Adaptation to climate change ............................................................................................................................ 37 

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

5. FINANCING ............................................................................................................................................................. 39 
Climate finance landmarks ................................................................................................................................. 39 
Environmental financing and investments ......................................................................................................... 39 
Public financial management ............................................................................................................................. 44 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 47 
Information, public participation and access to justice...................................................................................... 47 
Compliance assurance ........................................................................................................................................ 48 
EU-supported environmental capacity building ................................................................................................. 51 

ANNEX ................................................................................................................................................................. 53 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
Luxembourg  3 

Executive summary 

In May 2016, the 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  regarding 
environmental legal implementation in Luxembourg. The 
purpose  of  this  report  is  to  provide  information  on  the 
implementation  performance  and  highlight  the  most 
effective  ways  to  address  the  implementation  gaps  that 
impact  human  health  and  the  environment  and  hamper 
the  economic  development  and  competitiveness  of  the 
country.  The 
sectoral 
report 
implementation  reports  collected  or 
issued  by  the 
Commission under specific environmental legislation. 

relies  on  detailed 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  considering 
factors  such  as  the  gravity  of  the  environmental 
implementation issue in light of the impact on the quality 
of  life  of  citizens,  the  distance  to  target  and  financial 
implications. 
In  Luxembourg,  these  challenges  have 
lingered  since  the  first  environmental  implementation 
review in 2017 and require urgent action. 

Luxembourg  is  among  the  good  performers  regarding 
circular economy and waste management. However, its 
performance in specific sectors are declining. For instance, 
the circular material use rate has dropped below the EU 
average  and  more  efforts  should  be  made  to  accelerate 
the  transition  to  a  circular  economy.  More  importantly, 
Luxembourg is one of the Member States generating the 
most  waste.  While  the  country  is  not  at  risk  of  missing 
both the municipal waste reuse and recycling target and 
the  packaging  waste  recycling  target,  it  still  relies  more 
than the average Member State on incineration. Actions 
should be taken to reduce waste, targeting higher levels of 
the waste hierarchy. 

Biodiversity and nature are deteriorating in Luxembourg 
and urgent  measures are needed to  protect and restore 

habitats  and  species.  Ecosystems  suffer  from  several 
soil 
pressures,  notably  agricultural  practices  and 
artificialisation. Luxembourg should take action to achieve 
the transition to sustainable agriculture. 

Despite some progress, Luxembourg does not predict that 
it will fulfil its emission reduction commitments for several 
air pollutants. Concerns remain regarding the  quality of 
waterbodies, as all surface waterbodies and a major part 
of groundwater bodies fail to achieve good chemical and 
ecological  status.  Further  efforts  are  needed  to  reduce 
nitrate pollution where agricultural pressure is significant. 
Urban  developments  and  constructions  are  also  a 
frequent cause of modifications of water bodies. 

its  objectives 

The overall environmental investment needed to enable 
Luxembourg  to  meet 
in  the  main 
environmental  areas  is  EUR 1.7 billion  per  year,  broken 
down  as  follows:  circular  economy  (EUR 913 million), 
pollution prevention and control (EUR 217 million), water 
(EUR 464 million),  and  biodiversity  and  ecosystems 
(EUR 70 million). To meet these environmental objectives, 
going  beyond  climate  change,  the  additional  investment 
over the current level – the investment gap – reaches an 
estimated  EUR 403  million  per  year  in  Luxembourg.  This 
value  is  around  0.52%  of  the  national  gross  domestic 
product and is lower than the EU average (0.77 %). 

Globally,  Luxembourg  performs  well  in  the  area  of 
environmental governance; however, it needs to increase 
its administrative capacity to support the green transition. 

On a positive note, Luxembourg’s resource productivity is 
well above the EU average, illustrating the capacity of its 
economy  to  use  resources  more  efficiently  to  produce 
goods and services. Luxembourg has demonstrated good 
levels of collection and treatment of urban waste water. 
The  country  continues  to  properly 
implement  the 
Infrastructure  for  Spatial  Information  in  the  European 
(2), 
Community  Directive 
relevant 
environmental spatial information for good governance. 

thus  providing 

(1) 

to 

from 

the  Commission 

Communication 
the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Delivering  the 
benefits  of  EU  environmental  policies  through  a  regular 
environmental  implementation  review,  COM(2016) 316  final  of 
27 May 
http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2016%3A316%3AFIN. 

2016, 

(2) 

Directive 2007/2/EC of the European Parliament and of the 
Council of 14 March 2007, establishing an Infrastructure for 
Spatial Information in the European Community (INSPIRE), 
(OJ  L,  108,  25.4.2007),  https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:32007L0002. 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
Luxembourg  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)  (3)  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. 

Luxembourg’s  CMUR  has  declined  overall,  with  some 
increases between 2016 and 2018 and between 2021 and 
2022. In 2023, it stood at 10.2 %, below the EU average of 
11.8 % (Figure 1). 

20

15

10

5

0

2013

2015

2017

2019

2021

2023

Luxembourg

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 4.53 generated per kg of 
material consumed, resource productivity in Luxembourg 
was well above the EU average of EUR 2.23 per kg in 2023. 

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

5,0

4,0

3,0

2,0

1,0

0,0

2013

2015

2017

2019

2021

2023

Luxembourg

EU-27

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

Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated  7 
August 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/env_ac_rp/default/ta
ble?lang=en. 

December 

accessed 

2024, 

9 

(3) 

from 

the  Commission 

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

to 

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

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
Policies and measures 

In  parallel  with  European  initiatives  under  the  CEAP, 
Member States are encouraged to adopt and implement 
circular strategies at the national, regional and city levels. 
These should be tailored to each national and local reality, 
to  harness  the  proximity  economy’s (4)  potential,  while 
following  the  principles  of  a  holistic  whole-value-chain 
approach. 

Since the launch of the online European Circular Economy 
Stakeholder  Platform  in  2017 (5)  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies,  roadmaps  and  good  practices,  for  example 
alternative business models and innovative technologies. 

In February 2021, Luxembourg adopted a comprehensive 
circular economy strategy (6), which includes targets along 
products’ entire life cycle. Roadmaps will be developed for 
public  authorities’  different  domains  of  competence – 
namely  regulations  and  standards,  financial  aspects, 
knowledge creation and management – to ensure tangible 
impacts. 

for 

A review of the strategy was carried out in 2023, and its 
recommendations  are  being  analysed 
further 
implementation.  Recommendations  include  putting  in 
place a structure dedicated to the circular economy at the 
national  level;  taking  a  strategic  approach  to  action; 
introducing  measurable 
including,  and 
mobilising,  citizens  and  businesses  in  the  transition; 
scaling  up  education  efforts;  and  increasing  support  for 
pilot projects. 

indicators; 

Luxembourg  is  set  to  establish  a  consumption-based 
approach  to  calculating  its  carbon  footprint,  including 
indirect  emissions.  A  carbon  footprint  calculator  will  be 
established to raise awareness of the potential to reduce 
greenhouse  gas 
from 
(GHG)  emissions 
consumption;  this  measure  is  linked  to  the  circular 
economy because of its potential to enable the adoption 
of alternative business models and consumption patterns. 

resulting 

Green public procurement 

Public  procurement  accounts  for  a  large  proportion  of 
European 
authorities’ 
consumption,  with  public 
purchasing  power  representing  around  14 %  of  EU  GDP. 
Public  procurement  using  green  or  circular  criteria  (life-
cycle analysis, PaaS (platform as a service), second hand) 

(4) 

(5) 

(6) 

website, 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
European 
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
Schosseler, P., Tock, C. and Rasqué, P., Circular Economy Strategy 
Luxembourg, Ministry of Energy and Spatial Planning, Ministry of 
the  Environment,  Climate  and  Biodiversity,  and  Ministry  of  the 

Stakeholder 

Economy 

Platform 

Luxembourg  5 

can help drive the demand for sustainable products that 
meet  reparability  and  recyclability  standards.  A  national 
action  plan  or  strategy  for  green  public  procurement  is 
currently  not  in  place  in  Luxembourg.  Nevertheless, 
formally 
procurement 
public 
Luxembourg’s 
encourages  contracting  authorities 
tender 
procedures  to  promote  sustainable  development.  The 
country  does not  have  any  targets,  specific  measures  or 
mandatory  criteria  in  place  to  promote  green  public 
procurement.  Some  guidance  on  criteria  that  can  be 
imposed is provided in the form of references and links to 
the EU’s green public procurement website and toolkit. 

law 
to  use 

No 
further  measures  have  been  brought  to  the 
Commission’s  attention  since  the  2022  environmental 
implementation review. 

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 

In  September  2021,  Luxembourg  had  9  out  of  98 977 
products and 9 out of 2 983 licences registered under the 
EU  Ecolabel  scheme (7).  These  are  further  decreases  on 
the  already  low  levels  in  2022.  As  regards  EMAS,  in 
October  2024,  Luxembourg (8)  had  eight  registered 
organisations, one more than in October 2021. 

Luxembourg  has  been  slow  to  implement  the  priority 
actions  suggested  in  previous  reports,  and  the  2022 
actions all focused on waste-related measures. 

2025 priority actions 

•  Adopt measures to increase the circular material use 

• 

rate. 
Speed  up  the  transition  to  a  circular  economy  by 
implementing  an  updated  national  strategy  and  the 

(7) 

(8) 

2021, 

Luxembourg, 

https://economie-

Economy, 
circulaire.public.lu/en/publications/circular-strategy.html. 
European Commission, ‘EU Ecolabel facts and figures’, European 
Commission 
website, 
http://ec.europa.eu/environment/ecolabel/facts-and-
figures.html. 
European  Commission,  ‘Eco-management  and  audit  scheme 
(EMAS)’,  European  Commission  website,  November  2021, 
(https://webgate.ec.europa.eu/emas2/public/registration/list). 

2025 Environmental Implementation Review – Luxembourg 

 
 
EU framework and recommendations, in particular to 
complement it with upstream circularity measures. 

clear signs of decoupling between waste generation and 
economic growth. 

Waste management 

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

Luxembourg  6 

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

implementing  EU  waste 

— 

—  reducing waste generation per capita and in absolute 

— 

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

landfilling  of 

— 
—  and  phasing  out 
recoverable waste. 

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

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

landfilling  and 

for 

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  Luxembourg 
follows  a  small  overall  decrease  over  the  period 
considered (Figure 3). Excluding the major mineral waste 
categories alters this overall trend, revealing a moderate 
increase.  This  rise  is  mainly  attributable  to  a  significant 
increase in the generation of combustion waste from 2020 
onward.  Data  reported  for  2010–2014  are  less  reliable, 
and data collection has considerably improved since 2014. 
Due to strong variations in waste generation, there are no 

(9) 

European  Commission:  Joint  Research  Centre,  Techno-economic 
and  environmental  assessment  of  construction  and  demolition 
waste management in the European Union, Publications Office of 

15 

October 

accessed 

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  30  September  2024,  accessed  22  October  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. 

Critical raw materials 

Luxembourg’s circular  economy  strategy  emphasises the 
efficient use of CRMs across all stages of the product life 
cycle: by encouraging durable, repairable, and recyclable 
design, it reduces the need for virgin CRMs. The strategy 
also  strengthens  infrastructure  for  recycling  CRMs  from 
several  waste  streams,  including  electronic  waste  and 
construction  and  demolition  waste,  and  promotes  the 
reuse of CRM-rich products to extend their life cycle and 
reduce the extraction of new CRMs. 

In parallel, Luxembourg’s zero-waste strategy focuses on 
reducing  waste  generation  at  the  source,  particularly 
CRM-rich waste, and encourages zero-waste practices in 
industries  that  use  significant  amounts  of  CRMs  (e.g. 
electronics  and  construction). 
It  promotes  selective 
demolition practices in the construction sector to facilitate 
the  recovery  of  CRMs  from  construction  and demolition 
waste,  ensuring  that  valuable  CRM-rich  materials  are 
separated and recycled rather than sent to landfills. 

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 
and recycling operations is preferred over incineration and 
landfilling from an environmental perspective for most of 
the  individual  fractions  of  construction  and  demolition 

European 

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

Luxembourg, 

Union, 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
Luxembourg  7 

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

waste.  However,  the  economics  often  do  not  favour 
preparing  for  reuse  and  recycling  over  incineration  and 
landfilling. If available technology were to be applied, it is 
estimated  that  the  increase  in  preparing  for  reuse  and 
recycling  would  lead  to  an  additional  33 Mt  of  GHG 
emission  savings  annually  (more  than,  for  example,  the 
combined annual GHG emissions from Estonia, Latvia and 
Luxembourg). 

The  rate  of  preparing  for  reuse  and  recycling  of  mineral 
construction and demolition waste in Luxembourg in 2022 
was  94.4 %,  compared  with  the  EU  average  of  79.8 %. 
Measures to further increase that rate include facilitating 
separate  collection  at  source,  for 
instance  through 
digitalised  pre-demolition  audits (10).  Other  economic 
instruments, 
producer 
responsibility  (EPR),  and  upstream  measures  such  as 
increasing the recycled content  of construction products 
and  the  circular  design (11)  of  construction  works,  also 
help. 

extended 

example 

for 

Boosting 
Warning Report 

implementation –  the  2023  Waste  Early 

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

 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  all 
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). 
European  Commission,  Early  Warning  Report,  8  June  2023, 
https://environment.ec.europa.eu/publications/waste-early-
warning-report_en. 

(13) 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
2025  targets,  11  Member  States,  including  Luxembourg, 
have used this prerogative. 

On  22 December  2023,  Luxembourg  notified 
the 
Commission of its intention to postpone the attainment of 
the  plastic  packaging  waste  recycling  target  established 
for 2025 by the Packaging and Packaging Waste Directive. 
Attached  to  this  notification,  Luxembourg  submitted  an 
implementation plan setting out the measures necessary 
to  attain  the  target  within  a  postponed  time  frame  (i.e. 
2030 instead of 2025). At the request of the Commission 
(14),  Luxembourg  submitted  a  revised  implementation 
plan  on  21 June  2024.  According  to  the  implementation 
plan,  the  main  measures  Luxembourg  will  put  in  place 
include new packaging waste legislation, an EPR scheme 
for non-household packaging, and a deposit return system 
for  plastic  bottles.  The  Commission  found  that  the  plan 
submitted complies with the requirements set out in the 
relevant waste legislation. 

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 (15), the Packaging and 
Packaging Waste Directive (16), and the Directive on Waste 
Electrical and Electronic Equipment (17). 

In  Luxembourg,  the  national  waste  and  resource 
management  plan  (PNGDR)  has  included  the  notion  of 
resources  since  2018.  The  plan  aims  to  strengthen 
prevention  and  reuse.  It  includes  the  principles  of  the 
circular  economy  in  establishing  measures.  In  2022,  the 
Chamber  of  Deputies  passed  five  laws  known  as  the 
circular economy package, the main aims of which are to 
prevent  and  reduce  waste.  This  package 
lays  the 
foundations for the transition from waste management to 
resource  management.  The  overall  objective 
is  to 
reinforce the principles of the circular economy, following 
the  principles  of  responsible  consumption  of  natural 

(14) 

COMMISSION DECISION on the implementation plan submitted by 
Luxembourg in accordance with Article 6(1a) of Directive 94/62/EC 
accompanying  the  notification  to  postpone  the  attainment  of 
certain recycling targets set out in Article 6(1), point (g) and (i), of 
2024. 
that 
http://www.cc.cec/sg/vista/home?documentDetails&DocRef=C/
2024/1969&ComCat=SPINE. 

20  March 

Directive, 

C(2024) 

1969, 

(15)  Directive  2008/98/EC  on waste  and repealing  certain Directives, 
https://eur-lex.europa.eu/legal-

OJ 
content/EN/TXT/?uri=CELEX%3A02008L0098-20180705. 

22.11.2008, 

312 

L 

(16)  Directive  94/62/EC  on packaging  and packaging  waste,  OJ  L 365 
https://eur-lex.europa.eu/legal-

31.12.1994, 
content/EN/TXT/?uri=CELEX%3A01994L0062-20180704. 

Luxembourg  8 

resources  and  optimising  the  life  cycle  of  materials  by 
reusing  them,  preparing  them  for  reuse  or,  failing  that, 
recycling them. Most aspects of the package are covered 
by specific national laws and regulations. 

Municipal waste 

in 

the 

Municipal  waste  generation  in  Luxembourg  significantly 
increased  between  2010  and  2021  (Figure 5).  However, 
the increase in 2016 is attributable to the broadening of 
the  scope  of  municipal  waste 
reporting 
methodology. Since 2016, municipal waste generation has 
stagnated, with a decrease in 2022. In 2022, the country 
generated 721 kg per capita of municipal waste, which is 
significantly  above  the  (estimated)  EU-27  average  of 
515 kg per capita. This high amount could be partly due to 
the significant number of cross-border commuters and to 
the inclusion of municipal waste from sources other than 
households, which account for around 30 % of municipal 
waste generated (18). 

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

NB:  There  is  a  break  in  the  series  in  2016,  when  the  definition  of 
municipal waste was broadened. As of 2020, new reporting rules applied 
for calculating recycled municipal waste pursuant to the targets set out 
in  Article 11.2(c–e)  of  Directive 2008/98/EC.  Luxembourg  has  been 
applying  the  new  reporting  rules  since  2015,  but  improvements  were 
made  in  2020  and  again  in  2022  with  respect  to  the  accuracy  of  the 
average loss rates (19). 

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

22 October 

(18) 

(WEEE),  OJ 

(17)  Directive  2012/19/EU  on  waste  electrical  and  electronic 
equipment 
L  197,  24.7.2012,  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32012L0019. 
EC,  2022,  Environmental  Implementation  Review  2022  Country 
-  LUXEMBOURG,  COMMISSION  STAFF  WORKING 
Report 
DOCUMENT  No  SWD(2022)  268  final,  Directorate-General  for 
Environment, 
2022, 
https://environment.ec.europa.eu/law-and-
governance/environmental-implementation-review_en.  
(19)  MECB, 2024, Information provided during the Eionet review of the 
draft EEA country profile on waste management for Luxembourg, 
Ministry  of 
the  Environment,  Climate  and  Biodiversity, 
Gouvernement du Grand-Duché de Luxembourg. 

September 

8 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
Luxembourg  9 

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

rules since 2015 but improvements were made in 2020 and again in 2022 
with respect to the accuracy of the average loss rates (21). 

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

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

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

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

22 October 

Packaging waste 

Packaging waste generation in Luxembourg has stagnated 
since  2010  (Figure 7).  The  country  generated  209 kg  per 
capita in 2022, which is significantly above the estimated 
EU average of 186 kg per capita in the same year (20). 

Figure 7: Packaging waste generation, 2010–2022 

NB: As of reference year 2020 the rules for calculating recycled packaging 
waste  have  changed,  pursuant  to  Article  6a  of  Directive  94/62/EC. 
Luxembourg  has  been  applying  the  new  reporting  rules  already  since 
2015  but  improvements  were  made  in  2020  and  again  in  2022  with 
respect to the accuracy of the average loss rates (22). 

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. 

For 2022, the reported recycling rates are above the 2025 
targets except for plastics packaging and total packaging. 
However, all recycling rates dropped in 2022 compared to 
2021. For plastic packaging recycling, Luxembourg has to 
speed up its progress to reach the 2025 recycling target. 

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). 

NB:  As  of  reference  year  2020,  the  rules  for  calculating  recycled 
packaging  waste  had 
to  Article 6a  of 
Directive 94/62/EC.  Luxembourg  has  been  applying  the  new  reporting 

changed,  pursuant 

(20) 

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. 
(21)  MECB, 2024, Information provided during the Eionet review of the 
draft EEA country profile on waste management for Luxembourg, 

Ministry  of 
Gouvernement du Grand-Duché de Luxembourg. 

the  Environment,  Climate  and  Biodiversity, 

(22)  MECB, 2024, Information provided during the Eionet review of the 
draft EEA country profile on waste management for Luxembourg, 
Ministry  of 
the  Environment,  Climate  and  Biodiversity, 
Gouvernement du Grand-Duché de Luxembourg. 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
 
Luxembourg’s  national  waste  prevention  programme 
underwent a review in 2018 (23). At the time of writing, a 
new PNGDR was being developed, based on an evaluation 
in 2023. No budget is specified for the implementation of 
the national waste prevention programme (24). 

Priority  waste  streams  for  prevention  in  the  2016–2022 
PNGDR  were  food  and  organic  waste,  construction  and 
demolition  waste,  hazardous  waste,  household  and 
municipal  waste,  packaging  waste,  waste  electrical  and 
electronic  equipment,  manufacturing  waste,  and  other 
types  of  waste,  like  bulky  waste,  littering  waste,  waste 
from  sewage  treatment,  used  tires  and  end-of-life 
vehicles (25). 

No  indicators  have  been  adopted,  but  the  2016–2022 
PNGDR  included  quantitative  targets  for  each  priority 
waste  stream,  for  example (26)  reducing  bulky  waste  by 
20 %,  achieving  zero  littering,  reducing  the  consumption 
of 
increasing  the 
production  of  packaging  overall,  and  halving  food  waste 
by 2022. 

lightweight  plastic  bags  without 

To  achieve  the  reduction  target  for  bulky  waste, 
Luxembourg  aims  to  develop  recovery  and  restoration 
in  recycling 
systems  for  consumer  goods  deposited 
centres (27). 

Luxembourg  has  created  a  special  website  dedicated  to 
repair  and  sharing (28).  Reuse  is  integrated  in  resource 
centres (formerly called recycling centres) by an ongoing 
project (29). 
the 
implementation of repair systems, as current options lack 
financial investment. Initiatives such as ‘repair cafes’ will 
also be promoted, and repair services will be linked to job 
creation (30). 

accelerating 

is  on 

focus 

The 

The 
is 
implementation  of  prevention  measures 
highlighted  across  various  areas,  including  sustainable 

Luxembourg  10 

reuse, 

food  waste 
production  and  consumption, 
reduction, 
littering  reduction  and  awareness-raising 
campaigns.  To  promote  sustainable  consumption,  the 
Ministry  of  the  Environment,  Climate  and  Sustainable 
Development has launched the project ‘Clever Iessen’. It 
aims to encourage the use of local and seasonal products 
and  the  reduction  of  food  waste,  and  address  the 
production and distribution of food through, for example, 
implementing a deposit system for reusing containers.  It 
also raises awareness among stakeholders at all levels (31). 

Policies to encourage separate collection and recycling 

In Luxembourg, residual waste is primarily collected door 
to  door  and  to  some  extent  at  civic  amenity  sites.  The 
same  applies  to  glass  and  paper  and  cardboard,  whose 
collection  methods  are  complemented  by  ‘bring  points’. 
For biowaste, a large part of the population is covered by 
door-to-door  collection.  Glass  collection  mainly  targets 
glass packaging, but systems for collecting other glass are 
in  place  at  civic  amenity  sites.  Plastics,  metals  and 
composite  packaging  are  collected  door  to  door  by 
producer  responsibility  organisation  Valorlux,  which  has 
collected,  since  2021,  all  plastic  packaging,  increasing 
collection rates and reducing incineration. Certain plastics 
and non-packaging metals are separately collected at civic 
amenity sites. Municipalities must ensure public access to 
separate  collection  facilities  for  paper,  metal,  glass, 
plastic,  biowaste  and  packaging  waste.  Furthermore, 
Luxembourg  mandates 
the  separate  collection  of 
packaging waste from non-household sources (32). 

In Luxembourg, around 60 % of citizens are incentivised to 
sort  at  source  through  a  pay-as-you-throw  system  for 
collecting  municipal  waste,  which  is  based  on  either 
weight  or  the  volume  and/or  frequency  of  waste 
collection (33). There is still potential to expand the pay-as-

(25) 

(24) 

and 

waste 

waste, 

packaging 

(23)  Gouvernement du Grand-Duché de Luxembourg, Plan National de 
Gestion  des  Déchets  et  des  Ressources,  Ministère  du 
Développement  durable 
Infrastructures,  2018, 
et  des 
https://environnement.public.lu/dam-
assets/documents/offall_a_ressourcen/pngd/plan/PNGD.pdf.  
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/luxembourg/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/luxembourg/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/luxembourg/view. 
Environnement Public, Plan National de Gestion des Déchets et des 
Ressources,  Ministère  du  Développement  durable  et  des 
Infrastructures, Gouvernement du Grand-Duché de Luxembourg, 
2018, 
https://environnement.public.lu/dam-
assets/documents/offall_a_ressourcen/pngd/plan/PNGD.pdf. 

packaging 

packaging 

waste, 

waste, 

waste 

waste 

and 

and 

(26) 

(27) 

(30) 

and 

waste 

collecte 

séparée’, 

packaging 

https://repairandshare.lu/. 

(28) 
(29)  Gouvernement  du  Grand-Duché  de  Luxembourg,  ‘Projet  de 
règlement grand-ducal relatif à l’aménagement et à la gestion des 
centres de  ressources et  des autres  infrastructures communales 
de 
2024, 
https://legilux.public.lu/eli/dl/pr/2023/220. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/luxembourg/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/luxembourg/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/luxembourg/view. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-

packaging 

packaging 

packaging 

waste, 

waste, 

waste, 

waste, 

waste 

waste 

waste 

and 

and 

and 

(31) 

(32) 

(33) 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
you-throw system for residual waste to improve sorting at 
source and enhance recycling. 

Voluntary deposit return systems are in place, but only for 
specific  types  of  reusable  packaging (34).  A  mandatory 
deposit  return  scheme  for  packaging  could  boost  reuse 
and further increase the capture of recyclable waste (35). 

Luxembourg has no advanced fee modulation – that is, fee 
modulation  beyond  the  broad  categories  of  materials, 
such as higher fees for difficult-to-recycle types of plastic 
or combinations of materials. In addition, no packaging tax 
is applied (36). 

Policies to discourage landfilling or incineration 

is 

low 

landfill  rate 

The  country’s 
(see  Figure 6). 
Luxembourg  has  no  landfill  tax  in  place,  but  a  relatively 
high  gate  fee,  of  EUR 200/ton,  for  non-hazardous 
municipal  waste  and  a  ban  on  landfilling  untreated 
municipal  waste  and  organic  waste  with  a  total  organic 
carbon content above 5 % (37). 

Luxembourg  strongly  relies  on 
incineration  for  the 
disposal  of  mixed  municipal  waste  (see  Figure 5). 
Luxembourg  could  benefit  from  introducing  a  tax  and 
phasing out subsidies for incineration (38). 

In  2024,  the  Commission  opened  a  new  infringement 
procedure as Luxembourg did not meet the agreed target 
for the collection recycling of waste electronic and electric 
equipment (39) in 2021. 

et 

des 

Infrastructures, 

states/luxembourg/view; Environnement Public, Plan National de 
Gestion  des  Déchets  et  des  Ressources,  Le  Gouvernement  du 
Grand-Duché  de  Luxembourg,  Ministère  du  Développement 
durable 
2018, 
https://environnement.public.lu/dam-
assets/documents/offall_a_ressourcen/pngd/plan/PNGD.pdf . 
Information provided by the Ministry of the Environment, Climate 
and Biodiversity of the Luxembourg Government during the 2024 
Eionet  review  of  the  draft  EEA  country  profile  on  waste 
management for Luxembourg. 
EEA,  Early  warning  assessment  related  to  the  2025  targets  for 
municipal 
2022, 
https://www.eea.europa.eu/publications/many-eu-member-
states/early-warning-assessment-related-to; 
European 
Commission: Directorate-General for Environment, Luxembourg – 
2025 EU waste recycling targets: State of play, Publications Office 
of 
2023 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/8dd40227-0351-11ee-87ec-
01aa75ed71a1/language-en. 
Ibid. 

Luxembourg, 

packaging 

European 

waste, 

waste 

and 

the 

(34) 

(35) 

(36) 

Luxembourg  11 

together  with 

Luxembourg  has  fulfilled  its  requirement  to  update  its 
waste  management  plan (40).  It  has  made  substantial 
progress in setting up new policies to further implement 
the  waste  hierarchy.  This, 
the 
implementation of policies that were already in place, has 
contributed to the progress made in reducing the landfill 
rate,  as  well  as  slightly  increasing  the  recycling  rates  of 
municipal  waste  and  packaging  waste.  Luxembourg 
ratified  the  Hong  Kong  International  Convention  for  the 
Safe and Environmentally Sound Recycling of Ships but not 
the 
for  the  Control  and 
Management  of  Ships’  Ballast  Water  and  Sediments 
(BWM Convention). Luxembourg has made no progress on 
introducing a tax on incineration or phasing out subsidies 
for incineration. 

International  Convention 

2025 priority actions 

• 

• 

• 

• 

incineration, 

Further  shift  reusable  and  recyclable  waste  away 
from 
through  economic 
including 
instruments. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 
Introduce the deposit and return system(-s) (DRS), as 
mandated by the new Packaging and Packaging Waste 
Regulation, to capture more recyclable materials and 
improve the quality of recyclates. 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 

•  Develop  EPR  schemes  for  problematic  waste  and 

introduce fee modulation. 

(37) 

(38) 

(39) 

(40) 

2022, 

review  2022, 

SWD(2022) 268 

Environnement  Public,  Plan  National  de  Gestion  des  Déchets  et 
des  Ressources,  Ministère  du  Développement  durable  et  des 
Infrastructures, Gouvernement du Grand-Duché de Luxembourg, 
2018, 
https://environnement.public.lu/dam-
assets/documents/offall_a_ressourcen/pngd/plan/PNGD.pdf. 
Commission  Staff  Working  Document  –  Environmental 
final  of 
implementation 
8 September 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=comnat%3ASWD_2022_0267_FIN. 
European  Commission  infringement  decision  INFR(2024)2124, 
Infringement  decisions,  ‘The  Commission  calls  on  all  Member 
States to meet waste collection and recycling targets’, Juillet 25, 
Brussels, 
2024, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_24_
3228. 
Environnement Public, Plan National de Gestion des Déchets et des 
Ressources,  Ministère  du  Développement  durable  et  des 
Infrastructures, Gouvernement du Grand-Duché de Luxembourg, 
2018, 
https://environnement.public.lu/dam-
assets/documents/offall_a_ressourcen/pngd/plan/PNGD.pdf. 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
2. Biodiversity and natural capital

Luxembourg  12 

Global and EU biodiversity frameworks 

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  global  biodiversity 
framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU – as well as all Member 
States –  had  to  submit  national  biodiversity  strategies 
and  action  plans,  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 (41)  and  a  dashboard  of  indicators (42) 
provide information on implementation progress. 
The 
EU  Nature  Restoration 
Regulation (43) is the first EU-wide, comprehensive law of 
its kind and a key instrument for the EU to deliver on the 
global  biodiversity  targets  for  2030.  It  lays  down  an 
overarching  objective  at  the  EU  level  to  put  in  place 
effective  restoration  measures  on  20 %  of  EU  land  and 
sea by 2030 and for all ecosystems in need of restoration 
by  2050.  To  achieve  this,  it  sets  binding  targets  for 
Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

implementation 

adopted 

recently 

enable 

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. 

Member States’ national biodiversity strategy and action 
plans need to provide coherent frameworks for national 

(41) 

(42) 

(43) 

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

page 

web 

on 

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

Luxembourg’s  third  national  nature  protection  plan (44) 
was  adopted  by  a  governmental  Council  decision  in 
January  2023.  It  sets  18  targets  for  2030  and  118 
measurable  actions  with  a  timeline  towards  2026  and 
2030,  under 
four  pillars:  protection,  restoration, 
transformative  change  and  international  engagement. 
The plan aims to align Luxembourg’s national framework 
with the EU and global biodiversity targets. In July 2024, 
Luxembourg  also  uploaded  to  the  Convention  on 
Biological Diversity Online Reporting Tool (45) a mapping 
of national targets in relation to the global  biodiversity 
targets. 

The  EU  aimed  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 more details 
for 
financing  and 
on  biodiversity 
Luxembourg, see Chapter 5. 

investments 

Nature protection and restoration – Natura 
2000 

Natura  2000 (46),  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 

la  protection  de 

(44)  Gouvernement  du  Grand-Duché  de  Luxembourg, Plan  national 
la  nature,  Portail  de 
concernant 
l'environnement 
(emwelt.lu), 
https://environnement.public.lu/content/dam/environnement/
documents/natur/biodiversite/pnpn/pnpn-version-3.pdf. 
https://ort.cbd.int/national-targets?countries=lu. 

(45) 
(46)  Natura  2000  comprises  sites  of  community  importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as special 
protection  areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 

2025 Environmental Implementation Review – Luxembourg 

 
 
conservation (SACs) (47); 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. 

Luxembourg  13 

the  last  EIR  (as  protected  areas  represented  55.8%  in 
2021). One reason for this decrease is that some areas 
previously  reported  as  “designated  protected  areas” 
have  been  excluded  from  the  reporting  as  their  actual 
protection  effect  does  not  qualify  for  a  nationally 
designated area. 

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

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. 

types (48)  and  60 
Luxembourg  hosts  28  habitat 
species (49)  covered  by  the  Habitats  Directive.  The 
country  also  hosts  populations  of  44  bird  taxa  listed  in 
Annex I to the Birds Directive (50). 

In 2023, 27.1 % of Luxembourg’s territory was covered by 
Natura  2000  sites 
(EU  average:  18.6 %).  Special 
protection  areas  classified  under  the  Birds  Directive 
covered 16.1 % (EU average: 12.8 %) and SCIs under the 
Habitats  Directive  covered  16.0 %  (EU  average:  14.3 %) 
of the Member State’s territory. 

The  latest  assessment  of  the  SCIs  of  the  Natura  2000 
network was carried out in 2016, on the basis of the 2014 
database. At that time, the only insufficiency was related 
to  the  southern  damselfly  (Coenagrion  mercuriale). 
Luxembourg  has  designated  a  site  for  this  species 
(LU0001013).  A  final  evaluation  of  the  situation  in  the 
country will be sufficient to conclude this procedure. 

Considering both Natura 2000 sites and other nationally 
designated  protected  areas, 
legally 
protected  37.9%  of  its  terrestrial  areas  in  2022  (EU 
average: 26 %) (51), showing a significant decreased since 

Luxembourg 

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

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

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

(47) 

(48) 

(49) 

SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
total,  19 December  2019, 
Article 17  dashboard,  Annex I 
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  dashboard,  Annex II,  Annex IV  excluding  those  in 
Annex II, and Annex V excluding those in Annex II, 19 December 
2019, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/general-information-on-habitats-and-species-article-17-

(50) 

(51) 

national-summary-dashboards-archived.  This  counting  only 
takes into account species and habitats for which an assessment 
of conservation status was requested. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
Eurostat dataset env_bio4, terrestrial protected area percentage 
2025, 
for 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en. 

accessed 

March 

2022, 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
In  2022,  Luxembourg  was  assigned  a  priority  action  to 
complete  the  Natura  2000  site  designation  process, 
including  addressing  the  SACs,  and  defining  the 
conservation  objectives  and  measures  required  to 
achieve  favourable  conservation  status  for  protected 
habitats  and  species 
framework  of  site 
in  the 
management  plans  or  equivalent  instruments.  Since 
then, Luxembourg has designated all its 48 SACs within 
the  six-year  deadline.  For  each  SAC,  conservation 
measures are set out in a comprehensive management 
plan  (some  management  plans  are  shared  by  several 
SACs)  (52)  or  in  the  national  plan  for  the  protection  of 
nature  (PNPN).  All  conservation  objectives  are  set  by 
Grand-Ducal  decrees.  However,  some  conservation 
objectives of management plans should be improved to 
provide quantifiable objectives. 

2025 priority action 

• 

Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
implementation  of 
the  Nature  Restoration 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 

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 (53). 

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 

(52)  Management plans are available at www.emwelt.lu. 
(53) 

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, 

Luxembourg  14 

protection rules and rules on the conservation of habitats 
and species in order to combat these threats. 

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

According  to  Luxembourg’s  report  on  the  conservation 
status of habitats and species covered by Article 17 of the 
Habitats Directive for 2013–2018, the share of habitats 
with a good conservation status was 32.14 % in 2018 (9 
good assessments). The share of protected species with 
a  good  conservation  status  was  15 %  in  2018  (11 
assessments). 42.86 % of the forest area protected under 
the  Birds  and  Habitats  Directives  has  a  favourable 
conservation status (54) (86.0 % has a good conservation 
status).  For  birds,  65 %  of  breeding  species  showed 
short-term increasing (15 %) or stable (50 %) population 
trends. For wintering species, 50 % of species showed a 
short-term increase. 

The main pressures, as reported under Article 17 of the 
Habitats  Directive  and  Article 12  of  the  Birds  Directive, 
are (i) agriculture; (ii) development, construction and use 
of  residential,  commercial,  industrial  and  recreational 
infrastructure and areas; and (iii) natural processes and 
changes in land use. 

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

NB:  The  values  shown  for  2007–2012  and  2013–2018  are  not 
necessarily directly comparable because changes in area conservation 

(54) 

EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 
2020, 
Union, 
European 
https://op.europa.eu/en/publication-detail/-
/publication/e733191f-5c65-11eb-b487-01aa75ed71a1. 

Luxembourg, 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
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’, 
EEA  website,  19 December  2019,  accessed  December  2021, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

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

Source:  European  Commission:  Directorate-General  for  Environment, 
The  State  of  Nature  in  the  EU –  Conservation  status  and  trends  of 
species and habitats protected by the EU Nature Directives 2013–2018, 
Publications  Office  of  the  European  Union,  Luxembourg,  2021, 
https://op.europa.eu/en/publication-detail/-/publication/e733191f-
5c65-11eb-b487-01aa75ed71a1. 

With regard to habitats, the threats and risks induced by 
natural  processes  are  on  par  with  those  induced  by 
agriculture. 

to 

The country is under high pressure due to its high level of 
urbanisation  and  agriculture  activities.  The  prioritised 
action framework proposed by Luxembourg (in the  3rd 
edition  of  the  PNPN) (55)  aims  to  improve  the  current 
in  particular  by  creating  eight  steering 
situation, 
committees 
site  management  and 
communication among stakeholders. Luxembourg is also 
investing 
in 
particular setting up species monitoring. Luxembourg is 
also  planning  to  invest  in  maintaining  or  restoring  the 
favourable  status  of  grasslands  and  humid  areas,  with 
specific measures for each habitat (see the third edition 
of the PNPN). 

improving  biodiversity  monitoring, 

improve 

in 

In  2022,  Luxembourg  was  given  priority  actions  to, 
among  others,  (i)  continue  to  integrate  biodiversity 
concerns into other policies (in particular on agriculture, 
but also on fisheries, urban and infrastructure planning, 

(55)  Gouvernement  du  Grand-Duché  de  Luxembourg, Plan  national 
la  nature,  Portail  de 
(emwelt.lu), 

concernant 
l'environnement 

la  protection  de 

Luxembourg  15 

and  sustainable  tourism)  and  promote  communication 
between  players; and  (ii)  where relevant, avoid further 
habitat  fragmentation  and  take  measures  to  restore 
connectivity. No progress was reported in these actions. 

2025 priority actions 

•  Reinforce  action  for  habitats  and  species  with 
unfavourable  conservation  status  through,  for 
increased 
restoration  measures, 
example, 
connectivity,  better  policy  coordination  and 
integration, and increased funding. 
Strengthen  the  integration  of  biodiversity  actions 
into other policies, e.g. energy, agriculture, fisheries, 
forestry,  urban  and  infrastructure  planning  and 
sustainable  tourism,  and  promote  communication 
between stakeholders. 

• 

Recovery of ecosystems 

Agricultural ecosystems 

The BDS works alongside the common agricultural policy 
(CAP) to support the transition to sustainable agriculture. 
The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 
— 

reduce by 50 % the overall use of – and risk from – 
chemical pesticides; 
reduce  by  50 %  the  use  of  more  hazardous 
pesticides; 
reduce  by  50 %  losses  of nutrients  from  fertilisers 
(which will result in a 20 % reduction in the use of 
fertilisers)  while  ensuring 
is  no 
deterioration of soil fertility; 
restore  at  least  10 %  of  agricultural  area  to  have 
high-diversity landscape features; 
and increase the area under organic farming to at 
least 25 %. 

there 

that 

— 

— 

— 

— 

The “Vision for agriculture and food” (56), 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  are  key 
instruments  to  facilitate  and  strengthen  the  efforts  of 
European  farmers  to  protect  biodiversity  and  the 
environment  at 
large.  The  Commission  approved 
Member  States’  CAP  strategic  plans  in  2022  for  the 

https://environnement.public.lu/content/dam/environnement/
documents/natur/biodiversite/pnpn/pnpn-version-3.pdf. 
https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en. 

(56) 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
programming period 2023-2027. The CAP is the  largest 
source  of  funding  dedicated  to  supporting  biodiversity 
and  plays  a  significant  role 
implementing  EU 
environmental policy. Strategic plans should continue to 
support  the  protection  of  soil,  water,  air  quality  and 
biodiversity. 

in 

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

The  utilised  agricultural  area  in  Luxembourg  increased 
from  130  651  hectares  (ha)  in  2016  to  132  980  ha  in 
(57)  or, 
2023  
than  50%  of 
representing  more 
Luxembourg’s territory. 

Landscape  features  are  small  fragments  of  non-
productive  and  typically –  but  not  exclusively –  semi-
natural vegetation present in or adjacent to agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
covered  by  agricultural 
land.  Based  on  the  Land 
landscape  features 
Use/Cover  Area  Frame  Survey 
estimates, the share of agricultural land covered by non-
productive  landscape  features  in  Luxembourg  is  4 %, 
below the EU average. 

In  2024,  the  CAP  basic  regulations  were  amended (58) 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land.  These  changes 
removed the obligation for farmers benefiting from CAP 
area-related support to have a minimum share of 3–4 % 
of  non-productive  area  or  landscape  features  in  their 
farms.  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 (59) 
focuses on the restoration of agricultural ecosystems and 

Luxembourg  16 

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 (60). 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 
6.23 % of Luxembourg’s utilised agricultural land area is 
used  for  organic  farming.  This  is  lower  than  the  EU 
average of 10.50 % (61). Luxembourg is making a below-
average contribution  to achieving the target  of 25 % of 
the EU’s agricultural land being used for organic farming 
by 2030. 

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

Source:  Eurostat,  ‘Area  under  organic  farming’,  sdg_02_40,  accessed 
5 December 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/sdg_02_40/default/
table?lang=en. 

In 2022, Luxembourg was asked to step up its action on 
implementing  the  recommendations  set  out  in  its  CAP 
SP, especially in improving rural areas. The Commission 
approved Luxembourg’s CAP SP in September 2022, and 
its amendment in December 2023. Its implementation is 
now ongoing. 

(57) 

(58) 

Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 21 January 2025. These figures partially include lands 
used  by  Luxembourg’s  farmers 
in  neighbouring  countries 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 
Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
strategic plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 

(59) 

(60) 

(61) 

in  cropland  mineral  soils’  and 

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

2025 Environmental Implementation Review – Luxembourg 

 
 
 
2025 priority actions 

• 

• 

• 

• 

to 

and 

further 

Step-up  efforts 
reduce  nitrogen 
deposition,  in  particular  in  Natura  2000  sites  with 
nitrogen-sensitive species and habitats. 
Implement  eco-schemes  and  agri-environmental 
measures 
the 
environmental needs of Luxembourg. 
Implement  and  scale  up  the  uptake  of  organic 
farming practices. 
Promote  the  active  management  of  grasslands 
through extensive grazing to maintain the condition 
of these semi-natural habitats. 

practices 

address 

to 

Soil ecosystems 

Soil is an essential, finite, and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
security  and  climate 
resilience,  adaptation,  and 
mitigation. 
The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 
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 (62) 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 

(62) 

(63) 

final 

Proposal for a directive of the European Parliament and of the 
Council on soil monitoring and resilience (Soil Monitoring Law), 
COM(2023) 416 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2023%3A0416%3AFIN. 
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 

2023, 

5 July 

of 

Luxembourg  17 

loss  of 

soil  organic 

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 Luxembourg (63). 

carbon, 

The  greatest  contributor  to  Luxembourg’s  unhealthy 
soils  is  nutrient  excess,  with  31 %  of  soils  containing 
nitrogen concentrations above 50 kg/ha, or 86 % of total 
agricultural  land  area.  12 %  of  the  national  territory 
experiences  unsustainable  soil  erosion  by  water,  wind, 
tillage and harvest, representing 87 % of cropland. 

In  2022,  Luxembourg  was  assigned  a  priority  action  to 
reduce the excessive area of sealed and artificialised soil 
and remediate degraded soils and, to this end, consider 
formally  committing  to 
land  degradation  neutrality 
targets under the United Nations Convention to Combat 
Desertification  (UNCCD).  According  to  Luxembourg’s 
national report to the UNCCD, Luxembourg has not set 
an  LDN  target  yet  (64).  Therefore,  the  priority  action  is 
repeated. 

2025 priority action 

•  Reduce the excessive area of sealed and artificialised 
soil  and  remediate  degraded  areas  of  soil.  If 
appropriate, consider formally committing to targets 
for  land-degradation  neutrality  under  the  relevant 
United 
Combat 
Desertification agreement. 

Convention 

Nations 

to 

Grasslands 

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

and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
5 July 
2023, 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT%20ASSESSMENT%20REPORT_ANNEXES_SWD_2023
_417_part4.pdf. 

(64)  UNCCD,  Voluntary  LDN  targets,  accessed  on  4  March  2025, 

https://www.unccd.int/our-work/country-profiles/voluntary-
ldn-targets. 

2025 Environmental Implementation Review – Luxembourg 

 
 
Luxembourg  hosts  six  types  of  protected  grasslands, 
whose conservation status is degraded: the habitat types 
6110  and  6430  have  an  unfavourable  (inadequate) 
conservation status, while the habitat types 6210, 6230, 
6410 and 6510 (83.33 % of protected grasslands) have an 
unfavourable status.  Five of these habitat  types have a 
degrading 
and 
deterioration  of  these  types  of  habitats  are  mainly 
caused by harmful agricultural practices. 

conservation 

status. 

loss 

The 

A pilot study on the degradation of protected grasslands 
in  Luxembourg  is  currently  ongoing,  mainly  targeting 
habitat type 6510, which is the most important type of 
grassland in terms of coverage. Luxembourg authorities 
proposed  some  practical  measures  to  be  taken  to 
combat  degradation,  which  will  be  discussed  in  a 
bilateral meeting by the end of 2024. 

In  2021,  the  Commission  received  a  complaint  against 
Luxembourg related to the Habitats and Birds Directives. 
The  complaint  concerned  the  conservation  status  of  (i) 
the  grey  partridge  (Perdix  perdix)  and  other  farmland 
birds,  and  (ii)  semi-natural  grasslands (65).  Despite 
supporting  measures  taken  by  Luxembourg,  only  four 
couples  of  partridges  remain  in  the  country  and  the 
is 
conservation  status  of  semi-natural  grasslands 
worsening. In response, the authorities announced they 
would take a variety of actions to step up their efforts to 
preserve  these  species  and  habitats,  in  particular  to 
protect  and  restore  semi-natural  grasslands.  These 
actions will be monitored. 

root  causes  and  ensure 

In  2022,  Luxembourg  was  given  priority  actions  to 
urgently  adopt  binding  and  regulatory  measures  to 
the  effective 
address 
enforcement  of  measures  to  protect  and  restore  the 
habitats of the grey partridge and other farmland birds. 
Some  measures  have  been 
implemented  and 
its  efforts  to  restore 
Luxembourg  should  pursue 
grassland habitats and protect endangered species. 

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 

(65)  Habitat codes 6510, 6210, 6230, 6410 and 6430. 
(66)   Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 

Luxembourg  18 

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

Luxembourg hosts priority habitat type 7220, ‘petrifying 
springs with tufa formation (cratoneurion)’, protected in 
9  Natura  2000  sites,  and  habitat  type  7140,  ‘transition 
mires  and  quaking  bogs’,  protected  in  14  Natura  2000 
sites. The area covered by these habitat types is rather 
small (about 1 ha for 7140 and 2 ha for 7220). 

The  latest  reporting  on  Article 17  (2013–2018)  shows 
wetlands  have  degraded:  half  of  them  are  classified  as 
degraded,  with  a  stable  trend,  while  the  rest  are 
degraded with a worsening conservation status. 

These  habitats  are  facing  pressures  and  threats  from 
agriculture  and  human-induced  changes  in  the  water 
regime. Other sources of pressures and threats relate to 
the development of operation of transport systems. 

Luxembourg indicated in its pledges for the BDS target on 
status  improvements  for  species  and  habitats  that  10 
projects  were  launched  in  2022  to  limit  or  reverse  the 
negative 
impacts  of  water  overexploitation  and 
contribute to climate change adaptation. These  actions 
were not found for habitat type 7140. 

Forest ecosystems 

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

including  those  for  which  there 

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

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (66) that aims to create a comprehensive 

COM(2023)728, 

forests, 
https://ec.europa.eu/transparency/documents-
register/detail?ref=COM(2023)728&lang=en 

22 

November 

2023, 

2025 Environmental Implementation Review – Luxembourg 

 
 
forest  knowledge  base,  address  information  gaps,  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (67).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

In  Luxembourg,  forests  covered  36.5 % (68)  of  the 
territory (69) in 2020, and more than 50 % of assessments 
show these areas have a poor or bad conservation status. 
Luxembourg’s  forest  health  is  concerning,  with  only 
14.5% of trees in good health and 12.3% of dying or dead 
trees in 2023, partly due to pollution and eutrophication, 
and the situation is degrading70. 

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

Source: EEA, ‘Conservation status and trends of habitats and species’, 
EEA  website,  19 December  2019,  accessed 
January  2022, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

(67) 

(68) 

(69) 

(70) 

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 
from  the  Commission  to  the  European 
Communication 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652. 
Administration  de 
l’environnement  du  Luxembourg,  Résultats  de 
photosanytaire des forêts du Luxembourg, 2023. 

la  Nature  et  des  forêts,  Ministère  de 
l’inventaire 

Accompanying 

base: 

the 

Luxembourg  19 

Among forest disturbances contributing to loss of forest 
integrity  and 
loss,  wildfires 
related  biodiversity 
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 seen 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  carbon 
dioxide  (CO2)  emissions.  Megafires  are  practically 
beyond suppression capacity and can be prevented only 
by  an  integrated  risk  management  approach.  Wildfire 
prevention is also essential to preserve resources for the 
bioeconomy. 

The  EU  Timber  Regulation  (EUTR) (71)  prohibits  the 
placing on the EU market of illegally harvested timber.  

(EUDR) (72)  entered 

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

force 

into 

2025 priority action 

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

Prevention and management of invasive alien 
species 

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 

(71) 

(72) 

(73) 

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. 
The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
Luxembourg  20 

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

(the  IAS  Regulation)  aims  to  prevent,  minimise,  and 
mitigate  the  adverse  impacts  of  IAS  on  biodiversity.  It 
focuses action on a list of IAS of EU concern (the ‘Union 
list’), which is regularly updated (74). 

The third update of the Union list (75) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS Regulation (76) 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 
to 
EUR 116.61 billion  between  1960  and  2020 (77).  More 
recent  studies  have  put  this  cost  at  USD 28 billion  per 
increasing  to  USD 148.2 billion  by 
year  in  the  EU, 
2040 (78),  and  at  USD 423 billion  annually  at  the  global 
level (79). 

and  management) 

amounted 

The total number of IAS of Union concern in the country 
is 22. This includes 14 species recorded in the previous 
EIR (2021) and 8 new additions. Of these 8 additions, 6 
were  already  on  the  Union  concern  list  in  2021,  and  2 
were  added  later  under  Commission  Implementing 
Regulation (EU) 2022/1203. 

(74) 

(75) 

(76) 

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 

In 2022, Luxembourg was assigned priority actions on (i) 
stepping  up  the  implementation  of  the  IAS  Regulation, 
and (ii) ensuring regional cooperation with neighbouring 
Member  States  to  address  predominant  pressures. 
Luxembourg  has  taken  the  appropriate  steps  and 
complied  with  the  first  priority  action  but  should 
continue its efforts regarding the second one. 

2025 priority actions 

• 

• 

Step  up  implementation  of  the  IAS  Regulation, 
including  with  regard  to  enforcement  and  the 
capacity of inspection authorities. 
Ensure  regional  cooperation  with  neighbouring 
Member States to address predominant pressures. 
•  Ratify  the  International Convention for  the  Control 
and  Management  of  Ships'  Ballast  Water  and 
Sediments of 2004 (BWM Convention). 

management  of  the  introduction  and  spread  of  invasive  alien 
https://eur-
4.11.2014, 
L 317, 
species 
lex.europa.eu/eli/reg/2014/1143/oj/eng. 

p. 35), 

(OJ 

(77)  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. 

(79) 

(78)  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 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
Luxembourg  21 

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 (80) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (81). 
The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (82)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

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

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

Platform (83). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

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

In  2022,  Luxembourg  received  the  following  priority 
actions. 

• 

• 

Continue supporting the mapping and assessment of 
ecosystems  and  their  services,  and  ecosystem 
accounting  development, 
through  appropriate 
indicators 
integrating  ecosystem  extent, 
for 
condition  and  services  (including  some  monetary 
values)  into  national  accounts  and  the  planning  of 
management and restorative action. 
Continue  supporting  the  development  of  national 
including 
business  and  biodiversity  platforms, 
natural capital accounting systems, to monitor and 
value the impact of business on biodiversity. 

The first  priority action could  not  be assessed due to  a 
lack of data. Regarding the second priority action, there 
has  been  some  progress,  as  there  is  one  Luxembourg 
business  sustainability  network  member  of  the  EU 
Business & Biodiversity Platform. 

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

Assessment – 

Summary 

(81) 

for 

(82) 

(83) 

final 

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

11 July 

2022, 

of 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
Luxembourg  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 (84).  These  set  health-based  EU  air  quality 
standards (85)  and  stipulate  Member  States’  national 
emission  reduction  commitments (86)  for  several  air 
pollutants. 

The air quality in Luxembourg is generally good, with some 
exceptions.  The  latest  available  annual  estimates  (for 
2022)  by  the  EEA (87)  for  Luxembourg  attribute  around 
80 deaths each year (or 830 years of life lost (YLL)) to fine 
particulate  matter  (PM2.5) (88),  30  deaths  each  year  (or 
360 YLL) to nitrogen dioxide (NO2) (89) and 50 deaths each 
year (or 610 YLL) to ozone (90). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Luxembourg since 2005, while GDP growth 
has  continued  (Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (91)  in  2024, 
Luxembourg 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 

(84) 

(85) 

(86) 

(87) 

(88) 

European  Commission,  ‘Air’,  European  Commission  website, 
https://environment.ec.europa.eu/topics/air_en. 
European  Commission,  ‘EU  air  quality  standards’,  European 
website, 
Commission 
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 

projections submitted under Article 10(2) of the NECD in 
2023,  Luxembourg  is  projected  to  meet  its  emission 
reduction  commitments  for  2030  onwards  for  SO2  and 
NH3 (92), but not for NOx, NMVOC and PM2.5. 

Luxembourg submitted an updated national air pollution 
control programme (NAPCP) to the Commission on 20 July 
2023 and on 3 February 2025. 

Figure 15: Emissions trends of main pollutants /  GDP in 
Luxembourg (%), 2005–2022 

200%

150%

100%

50%

0%

NH₃

PM2.5

NMVOC

SO₂

NOₓ

GDP

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

2024, 

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

(90) 

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

(91)  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. 
In the ‘with additional measures’ scenario. 

p. 1), 

(92) 

2025 Environmental Implementation Review – Luxembourg 

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

in 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
5,44%

33,52%

NOₓ

0,00%

64,35%

31,59%

9,08%

21,84%

14,40%

3,84%

3,77%

4,17%

8,00%

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,  no  exceedances  above  the 
limit  values 
established  by  the  Ambient  Air  Quality  Directive 
(AAQD) (93) were registered in Luxembourg (94). 

Infringement procedures have been opened for Member 
States not meeting the emission reduction commitments 
for 2020–2029; this includes a procedure for Luxembourg 
for NH3 and NMVOC. 

In the 2022 EIR, Luxembourg received two priority actions. 
The first priority action was to further reduce emissions in 
the  context  of  the  NAPCP.  Luxembourg  has  made  some 
progress on this. While the latest  data show compliance 
with  the  2020–2029  emission  reduction  commitments, 
Luxembourg  is  still  projected  not  to  reach  the  emission 
reduction  commitments  for  NOx,  NMVOC  and  PM2.5  for 
2030 onwards. The second priority action was to ensure 
full compliance with EU air quality standards and maintain 

(93)  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. 
Eionet 
EEA, 
(https://cdr.eionet.europa.eu/). 

Repository 

11.6.2008, 

Central 

L 152, 

p. 1), 

Data 

(94) 

(OJ 

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

Luxembourg  23 

downward  emission  trends.  Based  on  the  latest  data, 
Luxembourg has made substantial progress in this regard. 
Full compliance has been ensured for all limit values and 
target values. Since 2019, downward emission trends have 
been reported for all main air pollutants except NMVOC, 
which requires 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: 
—  protect  air,  water,  and  soil  and  to  prevent  harmful 
effects on human health and the environment; 

—  prevent and manage waste; 
— 

improve  energy  and  resource  efficiency,  including 
water; 

—  contribute to decarbonisation. 
The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (95). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation,  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (96). 

In Luxembourg, 48 industrial installations are required to 
have a permit under the IED. In 2022, the industrial sectors 
in  Luxembourg  with  the  most  IED  installations  were  the 
production and processing of metals (25 %) and the waste 
management  (including  landfills)  (25 %),  followed  by 
intensive  rearing  of  poultry  and  pigs  (23 %),  the  mineral 
industries (6 %) and chemicals (6 %). 

Figure 17  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 

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

Emissions 

(96) 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions ‘intensity’. 

In  relation  to  air  emissions,  Luxembourg  ranks  24th  in 
terms of damage in the EU, and it comes 16th with regard 
to  the  emissions  intensity,  above  the  EU  average  of 
EUR 27.5 / EUR 1 000 GVA. 

The main industrial contributors to emissions to air (97) in 
Luxembourg are the metals sector, followed by the waste 
and energy sector as regards dioxins, as well as the metals, 
energy, and mineral sectors for mercury. 

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

Luxembourg  24 

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. 

In  Luxembourg,  the  ferrous  metal  processing  industry 
(particularly  the  processing  of  heavy  metals)  places  the 
largest burden on the environment in terms of industrial 
emissions to water (based on European Pollutant Release 
and Transfer Register data). 

Figure 19 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  the 
ratio  with 
in  GVA). 
Luxembourg has the 23rd highest amount of emissions of 
heavy metals to water and is in 21st position in terms of 
emissions  intensity  (below  the  EU  average  intensity  of 
0.864 kg per billion EUR GVA). 

industrial  activity 

(expressed 

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

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

2024, 

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

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

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

As shown in Figure 20, the main industrial contributor to 
emissions  to  water  in  Luxembourg  is  the  ferrous  metal 
sector. 

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

100%

75%

50%

25%

0%

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

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 

Heavy Metals Ecotoxicity

Heavy Metals Human
Toxicity

Ferrous metal

(97) 

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 – Luxembourg 

050100150200250300020004000 000 0001000012000140001 0001 000MTIED SELVFIATITLTNLDEFRSIEELUPTESHRHUS BEROELC PLC BGIntensity(EUR damage / thousand EUR GVA)Damage (million EUR)DamageIntensity012345 0100200300400500 00C LTIELVHRLUD EESIDEATELHUFRRONLBEC ESMTPTSES PLITBGFIIntensity (kg weighed by human toxicityfactors / billion EUR GVA)Releases (kg)ReleasesIntensity 
 
 
 
 
 
Geospatial 
https://doi.org/10.2909/cf5e54c1-be99-4426-bcad-baa26c4f27a0. 

September 

Catalogue, 

Data 

13 

2024, 

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 1–3 years, 
using  risk-based  criteria.  In  addition,  IED  enforcement 
provisions require Member States to determine effective, 
proportionate,  and  dissuasive  penalties  applicable  to 
infringements  of  IED-based  national  provisions.  In  the 
that  worst 
the  provisions 
revised  directive, 
infringements can be sanctioned by fines of at least 3% of 
the  annual  EU  turnover  of  the  legal  person.  The  revised 
IED  also  introduces  a  right  to  compensation  for  people 
whose health has been harmed by such infringements. 

set 

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. 

In 2022, Luxembourg received priority actions to address 
the pollution from metal production and processing. Some 
progress was made on this action at the time of reporting. 

2025 priority actions 

•  Reduce industrial air pollution damage and intensity. 
• 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 
Ensure  effective  public  participation  and  access  to 
justice in relation to the IED. 

• 

Luxembourg  25 

Major industrial accidents prevention – Seveso 

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

— 

substances, especially chemicals; 
limit the consequences of such accidents for human 
health and the environment; 

—  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) (98). 

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) (99)  and  the  report  by 
Luxembourg  on  the  implementation  of  the  Seveso III 
Directive for 2019–2022 (100). 

in  2024,  among 

the  16  Seveso 
In  Luxembourg, 
establishments,  8  were  categorised  as 
lower-tier 
establishments and 8 as upper-tier establishments (UTEs), 
based on the quantity of hazardous substances likely to be 
present. UTEs are subject to more stringent requirements. 
The  trend  of  the  number  of  Seveso  establishments  is 
presented in Figure 21. 

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

in 

NB: LTE, lower-tier establishment. 

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

2022, 

(98)  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. 

(99) 

https://espirs.jrc.ec.europa.eu/en/espirs/content; data extracted 
in September 2024.  

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

2025 Environmental Implementation Review – Luxembourg 

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

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs). These EEPs are essential to allow 
proper  preparation  and  effective  implementation  of  the 
actions  necessary  to  protect  the  environment  and  the 
population  should  a  major  industrial  accident  occur.  In 
Luxembourg, in 2022, an EEP was required for seven UTEs. 
That same year, six UTEs had an EEP, and each plan had 
been tested over the previous three years. A summary of 
the situation is shown in Figure 22. 

Figure 22: Situation regarding EEPs in Luxembourg, 2022 

2022, 

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

The information  for the public referred to in  Annex V to 
the Seveso III Directive is permanently available for all UTE 
establishments  in  Luxembourg  (101).  This  information 
mainly  concerns  (i)  how  the  public  concerned  will  be 
warned  in  the  event  of  a  major  accident,  (ii)  the 
appropriate  behaviour  in  the  event  of  a  major  accident 
and (iii) the date of the most recent site visit. 

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available  to  the  public  in  2022  in  all  Member  States  are 
presented in Figure 23. This provision on knowledge is an 
important  provision  of  the  Seveso III  Directive,  as 
information  may 
awareness  by  the  public  of  this 

(101)  https://seveso.public.lu/fr.html 

Luxembourg  26 

ameliorate  the  consequences  of  a  major 
accident. 

industrial 

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

NB: No data available for Greece. 

2022, 

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

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 202  
or 1 January 2027 (depending on the lamp category). 

In 2019, 21 % of dental treatments were still using dental 
amalgam, while more up-to-date information provided by 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
the  authorities  reveals  much  lower  use  in  more  recent 
years. However, measures should have been put in place 
to  ensure  a  socially  and  economically  sound  phase-out, 
including an adequate reimbursement of the alternatives 
to dental amalgam through the health insurance scheme 
and the training of dental practitioners.  The Commission 
is  monitoring  whether  the  phase-out  has  taken  place 
under  the  terms  and  conditions  of  the  regulation. 
Luxembourg 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 (102)  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 
the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment, and stress (103). 

In Luxembourg, environmental noise is estimated to cause 
at least 50 cases of ischaemic heart disease annually (104) 
and  some  25 000  people  to  suffer  from  disturbed  sleep 
(105). 

(102)  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. 

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

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

Bilthoven, 

Luxembourg  27 

latest  set  of 

Based  on  the 
Luxembourg  has  completed 
agglomerations, roads, railways, and airports. 

information  analysed, 
its  noise  mapping  of 

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

2025 priority action 

• 

Complete  and  implement  action  plans  on  noise 
management. 

Water quality and management 

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

is  managed 

Water Framework Directive 

The WFD (106) is the cornerstone of EU water policy in the 
21st  century (107).  The  WFD  and  other  water-related 
directives (108) 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 

(105)    More information on the adverse health effects of noise pollution 
at:  

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

available 

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

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

(107)  https://environment.ec.europa.eu/topics/water_en. 
(108)  These 

the  Groundwater  Directive 

the 

Floods 

include 

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

Drinking  Water 

Treatment 

Directive 

and 

the 

the 

the 

2025 Environmental Implementation Review – Luxembourg 

 
 
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 WFD establishes a procedural framework for reaching 
good  surface  water  ecological  and  chemical  status  and 
good groundwater quantitative and chemical status. This 
implies  monitoring  and  classification  of  all  waterbodies, 
assessment of pressures and impacts and identification of 
the  most  cost-effective  measures  to  achieve  the 
objectives of the directive. The directive dates from 2000 
and  set  an  initial  deadline  of  2015  for  achieving  its 
objectives, with the option to extend the deadline to the 
end of 2027. Every six years, Member States must report 
their  river  basin  management  plans  (RBMPs)  to  the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 2025 (109). 

Luxembourg  has  106  surface  waterbodies  and  6 
groundwater bodies, divided over two river basin districts 
(Rhine and Meuse). Approximately 7 % of surface waters 
are  designated  as 
‘heavily  modified’  and  none  as 
‘artificial’.  Heavily  modified  and  artificial  waterbodies 
must  reach  good  ecological  potential  rather  than  good 
ecological status, which means that all measures must be 
taken  to  mitigate  the  adverse  impact  of  the  sustainable 
human development  activities causing the waterbody to 
be  heavily  modified /  artificial,  while  not  significantly 
affecting these activities. 

It  follows  from  the  assessment  of  the  third  RBMPs  that 
there  has  been  a  deterioration 
in  the  ecological 
surface  waterbodies,  and  no 
status/potential  of 
improvement in their chemical status, compared with the 
status  reported  in  the  second  RBMPs  (covering  period 
2015–2021).  There  has  been  no  deterioration  in  the 
quantitative status  of  groundwater  bodies,  which  are  all 
reported  to  have  a  good  status,  and  there  has  been  no 
improvement in their chemical status. 

the 

show 

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

change 

in 

Luxembourg  28 

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

status/potential  of 

surface 

Since  the  second  RBMPs,  there  has  been  a  further 
deterioration in the ecological status/potential of surface 
waterbodies, as  0 % had a good (or better) status in the 
third  RBMPs.  The  apparent  deterioration  can  be  mainly 
attributed  to  improved  compliance  with  monitoring  and 
assessment methodologies. No improvement is expected 
by 2027. 

Diffuse  pollution,  point  sources  (from  industry,  urban 
waste  water  and  historical  contaminated  sites)  and 
historical anthropogenic pressures are reported as being 
equally  responsible  for  the  failures  to  achieve  good 
ecological and/or chemical status. Diffuse pollution from 
agriculture is identified as placing significant pressure on 
nearly  all  waterbodies.  Hydromorphological  pressures 
affect nearly all surface waterbodies. 

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

In the third RBMPs, the percentage of surface waterbodies 
failing  to  achieve  a  good  chemical  status  continues  to 
amount 
to  100 %.  However,  monitoring  changed 
compared with previous cycles, as new priority substances 
were monitored, and  stricter thresholds were set. 

(109)  Commission Staff Working Document – EU overview, Third river 
basin management plans, second flood hazard and risk maps and 
second flood risk management plans, Member State: Luxembourg, 
accompanying the document report from the Commission to the 
Council  and the  European  Parliament  on the  implementation  of 

the  water  framework  directive  (2000/60/ec)  and  the  floods 
directive  (2007/60/ec),  SWD(2025)  13  final  of  4  February  2025, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2025%3A35%3AFIN&qid=173874
6144581. 

2025 Environmental Implementation Review – Luxembourg 

0 20 40  0  0 100 1st2nd3rdS B chemical status for LUGoodFailing to achieve goodUnknown 
 
 
 
Luxembourg  29 

Failure to achieve a good chemical status is mostly due to 
ubiquitous  persistent  bio-accumulative  and 
toxic 
substances, which are difficult to address and often have 
transboundary sources. In Luxembourg, these are mainly 
airborne  polycyclic  aromatic  hydrocarbons  and  scrubber 
water discharges, and airborne mercury from combustion 
processes. Fluoranthene, cadmium and cypermethrin are 
the other main pollutants. 

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

Failure to achieve a good chemical status is mostly due to 
diffuse  agricultural  pollution  of  nutrients  and  pesticides. 
The main three pollutants are nitrates, and a herbicide and 
its metabolites (110). Additionally, two groundwater bodies 
failed to pass the drinking water protected area test due 
to pesticides. 

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 WFD. 

After 2027, the possibilities for applying exemptions will 
be much more limited. 

The 2022 EIR identified the following priority actions. 

the  WFD. 

•  Assess new physical modifications of waterbodies in 
line  with  Article 4(7)  of 
these 
assessments,  consider  alternative  options  and 
appropriate mitigation measures. 
Facilitate  the  implementation  of  measures  to  help 
achieve  the  WFD  objectives  and  step  up  efforts  to 
counteract pollution in waterbodies. 

In 

• 

and 

groundwater-associated 

100 % of groundwater bodies are reported to have a good 
terrestrial 
status.  However,  groundwater-dependent 
aquatic 
ecosystems 
ecosystems are not considered in the quantitative status 
assessment. Natura 2000 data show a mostly poor nature 
status,  but  the  dependence  of  this  status  on  associated 
groundwater  is  unclear.  Water  balances  are  not  used  to 
evaluate the quantitative status of groundwater bodies. 

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

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

In  this  context,  the  third  RBMPs  describe  involved  a 
detailed  process  of  measure  selection  based  on 
knowledge of pressures. The RBMPs have added a focus 
on  identifying  significant  pressures  for  morphological 
alterations  and  modifications  of  flow  regimes  through 
abstractions or regulations of the flow, including measures 
to mitigate or compensate these alterations. A particular 
example is the renaturalisation of the  river Pétrusse, co-
funded by the European Investment Bank (EIB), which will 
help  in  reducing the flood risk, increase biodiversity and 
help  the  city  of  Luxembourg’s  atmosphere  adapt  to 
climate  change.  Furthermore,  Luxembourg’s  programme 
of measures (111) includes, in addition to the measures in 
the  nitrate  action  plans,  a  list  of  voluntary  agricultural 
measures  (supported  by  the  CAP)  to  reduce  diffuse 
pollution that cover approximately 10 % of the area used 
for agriculture. Luxembourg has also included seven WFD-
eco-schemes in its CAP SP. 

2025 priority actions 

in  the  chemical  status  of 
There  was  no  change 
groundwater  bodies  between  the  second  and  third 
RBMPs, and 50 % of groundwater bodies are reported to 
have a good chemical status. 

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

(110)  For  example,  metolachlor  ethanesulfonic  acid  and  metazachlor 
ethanesulfonic  acid.  Under  the  Plant  Protection  Product 
Regulation 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex%3A32009R1107)  and  the  guidance 
document 
No 1107/2009 
(EC) 
(https://food.ec.europa.eu/system/files/2021-
10/pesticides_ppp_app-proc_guide_fate_metabolites-

Regulation 

on 

groundwtr-rev11.pdf), 
‘metabolite’  means  any  reaction  or 
breakdown product of an active substance of a plant protection 
product, formed either in organisms or in the environment. 
(111)  As  requested  by  Article 11  of  the  Water  Framework  Directive 

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

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
• 

• 

flows, 
Improve  river  continuity  and  ecological 
boosting efforts on nature-based solutions to reduce 
hydromorphological pressures. 
Ensure  periodic  reviews  of  permits  for  discharges, 
including 
abstractions  and  other  water  uses, 
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 cost 
recovery and the polluter-pays principle. 

financing 

Floods Directive 

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

The Commission also assessed the FRMPs, and will report 
in the first quarter of 2025 on both the third RBMPs and 
the second FRMPs (first FRMP reporting was  in 2016) to 
the European Parliament and to the Council. 

The  main  progress  resulting  from  the  assessment  of  the 
third FRMPs is that the objectives of these plans are more 
specific, and there is a  clear link between measures and 
objectives. For some objectives, the type of measures and 
number  of  actions  are  mentioned.  Information  is  also 
provided  on 
the  prioritisation  of  measures.  The 
responsibilities  of  authorities  with  respect  to  measures 
are now identified. Moreover, a  damage potential study 
was commissioned based on the FHRMs, which identified 
the  potential  monetary  damage.  In  addition,  specific 
funding  sources  are  included  in  the  FRMPs.  The  FRMPs 
describe  coordination  with  the  2018–2027  national 
climate  change  adaptation  strategy  and  link  measures 
between the two. 

(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, 

23.4.2024, 
http://data.europa.eu/eli/dec_impl/2024/365/oj; OJ L, 2024/367, 
http://data.europa.eu/eli/dec_impl/2024/367/oj; 
23.4.2024, 
23.4.2024, 
OJ L, 

(114)  OJ L, 

2024/369, 

Luxembourg  30 

2025 priority actions 

• 

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

consultation  and 

stakeholder 

• 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
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 
these  various  Commission  acts 
into  account  when 
implementing the recast directive. 

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

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

Bathing Water Directive 

The  Bathing  Water  Directive  requires  Member  States  to 
monitor and assess bathing water. It requires that, during 
the  bathing  season,  Member  States  disseminate  to  the 
public information on bathing water quality actively and 

http://data.europa.eu/eli/reg_del/2024/369/oj;  OJ L,  2024/368, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 
2024/370, 
23.4.2024, 
http://data.europa.eu/eli/reg_del/2024/370/oj;  OJ L,  2024/371, 
23.4.2024,  http://data.europa.eu/eli/reg_del/2024/371/oj;  see 
the  Commission  web  page  on  all  six  delegated  acts  for  more 
information, 
(https://environment.ec.europa.eu/publications/delegated-acts-
drinking-water-directive_en). 
In  summary,  the  compliance  for  all  parameter  groups 
in 
Luxembourg  was  at  least  97.96 %  in  2017,  97.83 %  in  2018  and 
98.19 % in 2019. 

(115) 

2025 Environmental Implementation Review – Luxembourg 

 
 
Luxembourg  31 

promptly. In particular, notices banning or advising against 
bathing should be rapidly and easily identifiable. 

Figure 28 shows that in 2023, out of the 17 Luxembourg’s 
bathing waters, 15 (88.2 %) were of excellent quality and 
2 (11.8 %) were of good quality. No bathing waters were 
found to be of sufficient or poor quality. 

According  to  national  data (116),  several  bathing  sites  in 
repeatedly  affected  by 
Luxembourg  have  been 
cyanobacteria contamination, and subsequently closed to 
the public, in recent years. 

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

In 2022, Luxembourg 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 could not be assessed and is repeated. 

2025 priority action 

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

• 

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

Urban Wastewater Treatment Directive 

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

In Luxembourg, the compliance rate was nearly 100 % in 
2020. 

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

Source:  European  Commission,  12th  technical  assessment  of  UWWTD 
implementation 
2024 
Publications  Office 
https://op.europa.eu/en/publication-detail/-/publication/4c97f846-
44b2-11ef-865a-01aa75ed71a1/language-en. 

EU, 

the 

of 

- 

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

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

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

(116) 

Luxembourg's 
(https://www.cyanowatch.lu/home). 

website 

on 

cyanobacteria 

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

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
The directive has been revised. The revised directive builds 
on the current acquis and 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. Luxembourg has until 31 July 2027 to incorporate 
the new directive into its national legal system. 

In  the  2019  EIR,  Luxembourg  received  three  priority 
actions.  The  first  action,  on  the  compliance  of  new 
projects with the WFD, has been fully implemented. The 
action  to  ensure  the  correct  levels  of  collection  and 
treatment  of  urban  waste  water  has  also  been  fully 
implemented. No information is available on the action on 
clarifying  the  method  used  by  Luxembourg  for  the 
prioritisation  of  measures,  including  the  assessment  of 
costs and benefits in relation to FRMPs. 

The  priority  actions  from  2022  are  considered  to  have 
been fully implemented. 

Luxembourg  32 

Deal. 

The  EU’s  chemicals  legislation (119)  provides  a  baseline 
protection for human health and the environment. It also 
for  businesses 
ensures  stability  and  predictability 
operating in the internal market. 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  Registration,  Evaluation, 
the  enforcement  of 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (120)  on  the 
implementation 
these 
regulations (121).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
law  enforcement.  Recorded 
notably 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because: (i) enforcement authorities  are becoming more 
effective in detecting non-compliant products/companies; 
and (ii) more non-compliant products are being placed on 
the EU market. 

in  the  area  of 

of 

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 (118), 
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 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (122) 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 (123). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 

(118)  Communication 

to 

from 

the  Commission 

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

31.12.2008, 

(OJ 

(119)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 

p. 1), 

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. 
(120)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
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, 

(121) 

the 

European 

(122)  European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  REACH  and  CLP 
Enforcement: EU level enforcement indicators, Publications Office 
of 
2021, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/e5c3e461-0f85-11ec-9151-01aa75ed71a1/. 
(123)  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, 

2025 Environmental Implementation Review – Luxembourg 

 
 
(published  on  20 November  2024)  (124).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (125).  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. 

In  Luxembourg,  responsibility  for  checking  compliance 
with  the  REACH  and  CLP  Regulations  rests  with  the 
following authorities (126): 

• 
• 
• 
• 
• 

• 

the customs and excise administration; 
the labour and mining inspectorate; 
the health directorate; 
the water management administration; 
Institute  of  Standardisation, 
the 
Accreditation,  Safety  and  Quality  of  Products  and 
Services; 
the environmental administration. 

Luxembourg 

implemented 
Luxembourg  has  devised  and 
enforcement  strategies  for  both  the  REACH  and  CLP 
Regulations (127). 

fully 

in 
The  Member  States’  reporting  exercise  set  out 
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  2022,  two  full-time  equivalents  were  allocated  to 
REACH and CLP Regulation enforcement (128). 

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

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

(125)  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. 

(126)  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. 70, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

(127)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 

Luxembourg  33 

REACH-EN-FORCE  (REF-8)  project (129).  The  report  was 
adopted in November 2021, so it could not be taken into 
account in the previous EIR. 

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

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

the  non-compliance 

Union, 

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, 

2020, 

(128)  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. 

Luxembourg, 

Union, 

p. 75, 

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

Helsinki, 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Luxembourg 

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

Luxembourg  34 

participation 

coordinated 
Luxembourg’s 
enforcement  project  (REF-8)  was  well  above  the  EU 
average. 

the 

in 

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

In 2022, Luxembourg received a priority action related to 
upgrading its administrative capacities in implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance to instances of non-compliance. In the absence 
of reporting since 2022, no progress has been shown and 
this priority action remains valid in 2025. 

2025 priority actions 

•  Upgrade 

the 

capacities 

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

• 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
Luxembourg  35 

4. Climate action

The impacts of climate change have continued to increase 
in recent years, inflicting damage and suffering in the EU 
and around the world. Globally, 2023 was the hottest year 
on  record,  while  Europe  has  been  warming  twice  as 
quickly  as  the  global  average  and  is  now  the  fastest-
warming  continent.  The  frequency  and  severity  of 
extreme  climate  events  are  also  increasing.  Against  this 
backdrop, the EU has demonstrated its determination to 
implement  the  European  Green  Deal  and  to  become 
climate neutral and resilient by 2050, ensuring sustainable 
competitiveness  and  supporting  EU  industry  in  the  net-
zero  transition.  The  European  Climate  Law  is  the  EU’s 
response  to  the  need  for  action.  It  sets  the  objective  of 
achieving climate neutrality by 2050 and a midterm target 
of a reduction in GHG emissions of at least 55 % by 2030 
and outlines the adaptation efforts necessary to adjust to 
climate  change’s  present  and  future  impacts.  Almost  all 
the  ‘Fit  for  55’  proposals  set  out  in  the  European  Green 
law,  and  the  European 
in 
Deal  have  been  agreed 
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 % (130). 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 
Luxembourg  decreased  by  41 %,  making  it  one  of  the 
countries with an above-average decrease. 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
speed up the green transition. It includes (i) strengthening 
and expanding the EU emissions trading system (ETS), with 
the  creation  of  a  new,  second,  ETS  for  transport  and 
buildings together with a dedicated Social Climate Fund to 
help  citizens  during  the  transition;  (ii)  increasing  targets 
under  the  Effort  Sharing  Regulation;  and  (iii)  a  revised 
for  Land  Use,  Land  Use  Change  and 
Regulation 

Forestry (131). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

Energy 

and  Climate  Plan 

The  key  strategic  document  at  the  country  level  is  the 
(NECP) (132). 
National 
Luxembourg submitted its final plan in July 2024 after the 
deadline set by the Regulation on the Governance of the 
Energy  Union  and  Climate  Action  (133).  The  European 
Commission  assessed  the  final  plan  and  the  extent  to 
which Luxembourg has followed the recommendations for 
the draft version. The findings from the assessment are: 

• 

• 

• 

• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease  by  56%  in  2030  compared  to  2005,  and 
Luxembourg will meet its target of 50%. 
Luxembourg  is  in  line  with  its  Land  Use,  Land-Used 
Change and Forestry (LULUCF) target.  
Luxembourg is in line with its target for the share of 
renewable energy. 
There  are  still  gaps  in  energy  efficiency  targets  that 
must be closed. 

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

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

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 

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

(131)  A  full  overview  of  the  Fit  for  55  package  is  available  at 
https://commission.europa.eu/strategy-and-policy/priorities-
2019-2024/european-green-deal/delivering-european-green-
deal/fit-55-delivering-proposals_en. 

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

(133)  Article  14  of  Regulation  2018/1999  on  the  Governance  of  the 

Energy Union and Climate Action. 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
biggest carbon market, covering around 40 % of the EU’s 
total GHG emissions from electricity and heat generation, 
the  manufacturing  industry,  aviation  within  Europe (134) 
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 t of CO2 equivalent (eq)), 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 61 % from 2005 
to 2023. 

In 2023, 43 % of the GHGs emitted by Luxembourg’s ETS 
installations came from cement and lime production, 39 % 
came  from  the  metals  industry,  and  12 %  from  other 
industries. Between 2013 and 2023, GHG emissions from 
the  metals  industry  decreased  by  22 %,  while  in  ‘other 
industries’ (glass production), they declined by 62 %. With 
emissions broadly stable between 2013 and 2022, cement 
and lime production saw a steep decline in 2023, by 36 %. 
In 2023, power generation accounted for only 6 % of GHG 
emissions (EU average: 57 %), following big reductions in 
2014–2016. 

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 (135).  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.  Luxembourg  did  not 
communicate  full  transposition  into  national  law  by  this 
deadline.  The  Commission 
therefore  opened  an 
infringement  procedure (136)  against  Luxembourg  on 
25 July  2024  for  failing  to  fully  transpose  the  provisions 
into national law. 

also 

Commission 

The 
infringement 
procedures (137) against  Luxembourg on 25 January 2024 
for  failing  to  fully  transpose  previous  revisions  of  ETS 
Directive (138)  into  national  law.  Luxembourg  has  since 

opened 

Luxembourg  36 

notified  full  transpositions  of  the  abovementioned 
directives to the Commission and the case was closed in 
October 2024. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation  (ESR) (139)  covers  GHG 
emissions 
(excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture,  small 
industry, and waste. Emissions from these sectors account 
for  around  60 %  of  the  EU’s  domestic  emissions.  The 
regulation  sets  the  EU-wide  target  to  reduce  emissions 
from the effort sharing sectors by 40 % by 2030 compared 
to 2005 levels. This overall target for the EU translates to 
binding  national  emission  reduction  targets  for  each 
Member State. Luxembourg‘s target is – 50 %. 

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

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

Based  on  historical  emissions  and  the  most  updated 
projections Luxembourg is on track to achieve its 2030 ESR 
target. 

Projected  emission  reduction  is  5.6  percentage  points 
above the 2030 target. 

is  taking  off,  and 

Transport  is  the  dominant  effort  sharing  sector  and 
accounted for 60 % of all effort sharing emissions in 2022. 
Transport emissions have decreased by 42 % since 2005, 
but  emissions  per  capita  or  per  kilometre  remain  the 
highest in the EU. Luxembourg’s transition to sustainable 
transport 
it  must  keep  up  the 
momentum. In 2023, 5.6 % of its car passenger fleet were 
battery electric vehicles, one of the highest shares in the 
EU  (EU  average  is  1.2 %).  In  2023,  it  had  2  120  publicly 
accessible  charging  points,  providing  one  charging  point 
for every 13 e-vehicles (EU average 1:10). 97 % of its rail 
network is electrified – the highest share in the EU – but 
only  4 %  and  7 %  of  passenger  and  freight  transport, 

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

Norway, Iceland, Switzerland, and the United Kingdom. 

(135)  Directive 

(EU)  2023/959  amending  Directive  2003/87/EC 
establishing  a  system  for  greenhouse  gas  emission  allowance 
trading within the Union and Decision (EU) 2015/1814 concerning 
the establishment and operation of a market stability reserve for 
the  Union  greenhouse  gas  emission  trading  system,  OJ  L  130, 
16.5.2023, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG. 
(136)  European Commission infringement decision INFR(2024)0194. 
(137)  European  Commission  infringement  decisions  INFR(2024)0088 

and INFR(2024)0087. 

(138)  Directive 

(EU)  2023/959  amending  Directive  2003/87/EC 
establishing  a  system  for  greenhouse  gas  emission  allowance 
trading within the Union and Decision (EU) 2015/1814 concerning 

the establishment and operation of a market stability reserve for 
the  Union  greenhouse  gas  emission  trading  system,  OJ  L  130, 
16.5.2023, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG; 
and  Directive  (EU)  2023/958  amending  Directive  2003/87/EC  as 
regards  aviation’s  contribution  to  the  Union’s  economy-wide 
emission reduction target and the appropriate implementation of 
a global market-based measure, OJ L 130, 16.5.2023, https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023L0958. 

(139)  Regulation  (EU)  2018/842  on  binding  annual  greenhouse  gas 
emission  reductions  by  Member  States  from  2021  to  2030 
contributing  to  climate  action  to  meet  commitments  under  the 
Paris Agreement and amending Regulation (EU) No 525/2013, OJ 
L 156, 19.6.2018, https://eur-lex.europa.eu/eli/reg/2018/842. 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
respectively,  is  by  rail.  Roads  are  used  for  86 %  of 
passenger and freight transport. 

Adaptation to climate change 

Luxembourg  37 

The buildings sector accounted for 20 % of effort sharing 
emissions  and  it  is  a  concern  for  Luxembourg.  Although 
emissions have decreased by 15 % since 2005, the general 
trend  is  stagnating.  From  2016  to  2021,  emissions  were 
higher than in 2015. Residential final energy consumption 
has remained stable since 2015, while the national Long 
Term  Renovation  Strategy  envisages  a  reduction 
in 
building energy consumption of 36 % by 2030. 

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

Land use, land-use change and forestry 

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

Luxembourg  has  seen  a  comparatively  large  increase  in 
net LULUCF removals since 2018. 

Luxembourg‘s target in 2030 is to enhance land removals 
by additional −27 kt (kiloton) of CO2 equivalent compared 
to the yearly average of the period 2016–2018. The latest 
available projections show a surplus to target of −40 kt of 
CO2 equivalent in 2030. Therefore, Luxembourg is on track 
to meet its 2030 target. 

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

Luxembourg  has  no  regions  identified  as  a  hotspots  of 
climate risks most affected by climate change (140). 

Climate  change  affects  many  sectors  in  Luxembourg, 
including  agriculture,  forestry,  water  management  and 
health. Climate hazards may give rise to floods, droughts, 
and  heatwaves,  with  adverse  effects  on  health  and 
changes in the vegetation period, impacting wheat crops, 
winegrowing,  and  other  sectors.  In  the  last  few  years 
droughts,  heatwaves,  and  the  spread  of  bark  beetle, 
exacerbated by climate change, have caused the damage 
or  destruction  of  about  two  thirds  of  forests 
in 
Luxembourg (141). Luxembourg’s climate protection gap is 
low. 

Luxembourg  has  relatively  well-developed  institutional 
arrangements 
for  climate  adaptation.  Luxembourg 
adopted its national climate  adaptation law in 2020 and 
has  national  adaptation  strategy  (for  2018–2023)  and 
plan. A new national adaptation strategy  is being drawn 
up  in  Luxembourg  and  will  be  submitted  for  public 
consultation  and  participation 
in  early  2025.  These 
documents  cover  all  relevant  climate  risks  and  links  its 
vulnerabilities  and  risks  with  actions.  Luxembourg  is 
currently  updating  the  strategy  and  plan  in  line  with  its 
climate law, and sets binding requirements for planning, 
implementing  and  governing  adaptation  measures. 
Stakeholders  are  involved  locally  via  the  climate  and 
nature pacts. 

European  Commission  identified  three  priority  actions 
regarding climate action in the 2022 edition of the review. 
There is no progress in traffic congestion, and it remains 
an issue. The share of public transport on total passenger 
transport  has  decreased  by  0.2  percentage  points 
compared  to  2019  and  there  is  no  visible  progress  in 
recent  years.  But 
invest 
EUR 1.7 billion in public transportation during the period 
2024–2027 (142),  which 
is  promising  for  the  future 
development.  Luxembourg  is  making  progress  towards 
electrification of passenger car fleet and railway network. 

Luxembourg  plans 

to 

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

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

(141)  Gouvernement  du  Grand-Duché  de  Luxembourg  (2023),  The 
results of the 2023 phytosanitary inventory of forests - Nature and 
Forest Administration. 
Les priorités « Mobilité et Travaux publics » d’ici 2027 | Chambre 
des députés du grand-duché de Luxembourg. 

(142) 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
 
2025 priority action 

• 

Implementing  all  polices  and  measures  that  are 
needed  to  achieve  targets  laid  down  in  the  Effort 
Sharing Regulation (ESR) and the Land Use and Land-

Use Change and Forestry (LULUCF) Regulation. More 
detailed priority actions are set out in the assessment 
of the final National Energy and Climate Plan (NECP) 
(143). 

Luxembourg  38 

(143)  European  Commission,  National  energy  and  climate  plans. 
https://commission.europa.eu/energy-climate-

Available 
change-environment/implementation-eu-countries/energy-and-

at 

climate-governance-and-reporting/national-energy-and-climate-
plans_en. 

 Environmental Implementation Review 2022 – Luxembourg 

 
 
 
 
 
 
 
Luxembourg  39 

Part II: Enabling framework – implementation tools 

5. Financing

investment 

supports  climate 

The  EU  budget 
in 
Luxembourg with significant amounts in 2021–2027, with 
revenues  from  the  ETS  also  feeding  into  the  national 
budget. During 2020–2022, Luxembourg’s revenues from 
auctioning  reached  EUR 56 million  in  total,  with  73 %  of 
that spent on climate and energy. 
In  addition,  the  annual  investment  needed  to  meet  its 
in  the  areas  of  pollution 
environmental  objectives 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR  1.7 billion per year in 
Luxembourg. 
These  four  environmental  areas  currently  receive  total 
funding of around EUR 1.3 billion per year; thus, there is a 
gap of around EUR 0.4 billion per year. 
gap, 
environmental 
Of 
EUR 200 million  concerns  pollution  prevention  and 
control,  EUR 125 million  water  and  circular  economy 
(each). 

investment 

annual 

the 

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 
CAP EUR 145.9 billion (144). 

In  Luxembourg,  the  EU  cohesion  policy  (considering  EU 
contribution  amounts)  provides  EUR 17.8 million  for 
climate  action  in  2021–2027  (with  one-third  via  the 
ERDF) (145). 

(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). 

(147)  A 

list 

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

projects 

by 

of 

the 

EIB 

The  recovery  and  resilience  facility  (RFF)  contributes  to 
climate finance in Luxembourg with EUR 0.06 billion up to 
2026, representing 68.8 % of the RRP (146). 

The EIB provided EUR 109.9 billion of 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 27.2 million 
was assigned to Luxembourg in the reference period (147). 

National financing, including EU emissions trading 
system revenues 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feeds  directly  into  national 
budgets,  amounted  to  EUR  17 million  in  2020,  EUR 
in 
in  2021  and  EUR  31 million 
8.1 million 
Luxembourg,  totalling  EUR  56 million  in  the  three-year 
period. In Luxembourg, these revenues are not earmarked 
(148). 

in  2022, 

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

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (149). 

therefore, 

and, 

Environmental financing and investments 

This  section  describes  Luxembourg’s  investment  needs, 
current  financing,  and  gaps  as  they  relate  to  the  four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (150). 

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

Luxembourg, 

Union, 

(149) 

(150)  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. 

 Environmental Implementation Report 2022 – Luxembourg 

 
 
The environment overall 

Investment needs 

investment  needs  to  be 
The  overall  environmental 
sufficient to enable Luxembourg 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 1.7 billion per year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 0.9 billion per year, can be attributed to the need to 
support  circular  economy;  the  needs  are  around 
EUR 464 million  for  water,  EUR 217 million  for  pollution 
prevention  and  control,  and  EUR  70 million 
for 
biodiversity and ecosystems (in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
in  Luxembourg  from  EU  and 
annual  EUR 1.3 billion 
national sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 1 198.2 million for Luxembourg in total during 2021–
2027 (or EUR 17 million per year). 

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

Instrument 

Cohesion policy 
ERDF 
Just Transition Fund 
CAP 
European  Agricultural  Guarantee 
Fund 
European  Agricultural  Fund  for  Rural 
Development 
European  Maritime,  Fisheries  and 
Aquaculture Fund 
Other MFF 

RRF (d) (2021–2026) 

Allocations 
4.8 (a) 
2.2 
2.7 
66.2 (b) 
42.6 

23.6 

0.0 

48.1 (c) 

27.8 

(a) 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its publication date.  Note that Luxembourg is not eligible for the 
information: 
and 
Cohesion 

further 

Source 

Fund. 

Luxembourg  40 

https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

(b) 

(c) 

(d) 

Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 

6.12.2021, 

Annex XI, 

L 435 

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

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

instrument  for  the 

Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

Luxembourg, in addition to receiving EU funds earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
the  financial 
instrument  for  the  environment  (LIFE) 
programme (151)  (EUR 5.4 billion),  Horizon  Europe (152) 
(EUR 95.5 billion),  the  Connecting  Europe  Facility (153) 
(EUR 33.7 billion) and funds that can be mobilised through 
the InvestEU programme (154). 

Luxembourg’s  RRP  supports  climate  objectives  through 
funding  of  EUR 0.06 billion  (68.8 %  of  total),  with  an 
additional  EUR 3.6 million 
for  the 
environment. 

(4.4 %  of  total) 

The  EIB  provided  around  EUR 9 million  in  environment-
related financial contributions to Luxembourg from 2021 
to mid 2024, related to 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 Luxembourg, 
the  total  national  environmental  protection  expenditure 
was EUR 609 million in 2020 and EUR 674 million in 2021, 
representing around 0.9 % of GDP. 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 

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

(153)  The  Connecting  Europe  Facility  Transport  part  also  includes 
EUR 11.3 billion  transferred  from  the  Cohesion  Fund,  of  which 
30 % will be made available, on a competitive basis, to all Member 

States  eligible  for  the  Cohesion  Fund.  The  remaining  70 %  will 
respect the national envelopes until 31 December 2023. 

(154)  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 – Luxembourg 

 
 
 
 
 
EUR 59.9 billion in 2021 in the EU-27, representing around 
0.4 %  of  the  EU’s  GDP.  In  Luxembourg,  the  national 
environmental  protection  investment  data  were  not 
available for 2020 and 2021. 

Splitting  by  institutional  sector,  13 %  of  Luxembourg’s 
national  environmental  protection  investment  (capital 
expenditure) comes from the general government budget, 
with 87 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies).  Data  for  the  business  sector,  whose 
environmental  activities  are  usually  ancillary  to  its  main 
activities,  was  not  available.  At  the  EU  level,  38 %  of 
from 
environmental  protection 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (155). 

investment  comes 

from 

for 

total 

environmental 
financing 
Luxembourg’s 
investment reaches an estimated EUR 1.3 billion per year 
(in 2022 prices), including EU funding and national public 
and national private expenditure. Of the total, the share 
of EU fund (including EIB funds) reaches 2 %, with around 
98 % national financing. The total public financing (EU plus 
national public) represents 14 % 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  403 million 
per  year  in  Luxembourg,  representing  around    0.52%  of 
the  national  GDP,  being  lower  than  the  EU  average 
(0.77 %). 

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

(155)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 
env_ac_epea, 
https://ec.europa.eu/eurostat/statistics-
explained/index.php?title=Environmental_protection_expenditur
e_accounts. 

Luxembourg  41 

Source: Analysis of Directorate-General for Environment. 

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

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

Environmental 
objective 

Investment gap per year 

of 

% 
total 

% 
GDP 

of 

Million 
EUR 
(2022 
prices) 

Pollution  prevention 
and control 
Circular economy and 
waste 
Water  management 
and water industries 
Biodiversity 
ecosystems 
Total 

and 

201 

125 

125 

— 

403 

 49.9 

0.3 

 30.9 

0.2 

 31.0 

0.2 

— 

— 

100.0 

0.5 

NB:  For  biodiversity  and  ecosystems,  no  significant  gap  is  observed, 
based  on  currently  available  data,  with  data  consistency  to  be  further 
assessed. 

Source: Analysis of Directorate-General for Environment. 

Pollution prevention and control 

Investment needs 

In  pollution  prevention  and  control,  Luxembourg’s 
investment needs are estimated to reach EUR 217 million 
per  year  (including  baseline  investments)  in  2021–2027. 
Most  of  this,  EUR 184 million,  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 119 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (156).  Industrial  site  remediation 
year. 
requires  an  estimated  EUR 14 million  per 

(156)  2021 

Phenomena 

project 
(https://op.europa.eu/en/publication-detail/-
/publication/f4cd7465-a95d-11eb-9585-01aa75ed71a1)  and  the 

assessment 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
Microplastics pollution and the chemicals strategy require 
around EUR 8–10 million per year (each) (157). 

Circular economy and waste 

Luxembourg  42 

Current investments 

investment 

levels  supporting  pollution 
The  current 
prevention and control reach an estimated EUR 16 million 
per  year  in  Luxembourg  in  2021–2027.  Most  of  the 
financing  concerns  clean  air  (EUR 11 million  per  year). 
Protection  from  environmental  noise  receives  around 
EUR 2 million per year, and chemicals 5 million per year. 

In Luxembourg, the EU MFF provides an estimated 31 % of 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further 18 % from the RRF, adding up to 49 % of the total. 
National sources provide 51 % (158). 

The gap 

needs 

provide 

To meet its environmental objectives concerning pollution 
(towards  zero  pollution), 
prevention  and  control 
Luxembourg 
additional 
an 
to 
EUR 201 million per year (0.26 % of GDP), mostly related 
to  clean  air  and  noise.  The  adequate  implementation  of 
the  NECP  with  the  investments  included  for  sustainable 
energy  and  transport  would  largely  deliver  this,  while  in 
many  Member  States  additional  measures  and 
investments may be required to comply with the ammonia 
reduction requirements. 

According  to  the  latest  NAPCP  review  report (159)  and 
Luxembourg’s  2024  emission  inventory,  Luxembourg  did 
not comply with ammonia reduction requirements in 2020 
but  complied  in  2021  and  2022.  Luxembourg  will  need 
additional  measures  to  meet  the  NECD’S  2030  emission 
reduction  commitments  for  ammonia,  based  on  the 
policies and measures in its NAPCP that take into account 
climate, energy and CAP plans and financing baselines. 

2023 

Commission’s 
implementation 
(https://environment.ec.europa.eu/system/files/2023-
03/COM_2023_139_1_EN_ACT_part1_v3.pdf). 

Environmental 

Noise 

Directive 
report 

(157)  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. 

(158)  Through  the  tracking  of  EU  funds,  EIB  projects  and  national 
expenditure (EPEA accounts, Eurostat). Note that the bulk of clean 
air  financing  is  provided  as  a  contribution  from  climate  (energy 
and  transport)  measures,  as  per  the  tracking  schemes  in  the 
Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
tracking: 
Annex  VI.  Further 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 

information  on  clean  air 

Investment needs 

of 

this, 

investments).  Most 

Luxembourg’s investment needs in circular economy and 
waste  reach  an  EUR 913 million  per  year  (including 
baseline 
around 
EUR 855 million  per  year,  relates  to  circular  economy 
measures  in  the  mobility,  food  and  built  environment 
systems, with a further EUR 59 million necessary for waste 
management  (municipal  and  packaging  waste),  covering 
waste 
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 (160). 

treatment, 

collection, 

biowaste 

Current investments 

Circular economy investments across the economy reach 
around EUR 739 million per year in Luxembourg in 2021-
2027,  with  a  further  EUR 50 million  provided  for  waste 
management that does not constitute circular economy. 

Around 0.1 % of this combined financing for circularity and 
waste  comes  from  the  EU  MFF,  with  no  further 
contribution from the RRF. The share of national sources 
is absolutely overwhelming, reaching 99.9 % of the total 
financing (161). 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Luxembourg  needs  to 
increase  circular  economy  investments  by  an  estimated 
EUR 116 million per year, with an additional EUR 8 million 
concerning  waste  management  action,  not  belonging  to 
circular 
to 
EUR 125 million  per  year, 
representing  0.16 %  of 
Luxembourg’s GDP. 

economy.  Combined, 

amounts 

this 

Of  the  circular  economy  gap,  EUR 30 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 

(159)  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. 

(160)  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. 

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

2025 Environmental Implementation Review – Luxembourg 

 
 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 86 million constitutes further investment need to 
unlock Luxembourg’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 464 million  (in  2022  prices)  in  Luxembourg.  This 
comprises investment needs both for the water industry 
and for the protection and the management of water. Of 
the  total  annual  need,  EUR 246 million,  relates  to  the 
management  of  waste  water  (also  including  additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 122 million  is  necessary  for  drinking-water-related 
investments and around EUR 94 million for the protection 
and management of water (162). 

Current investments 

Water  investments  in  Luxembourg  are  estimated  to  be 
around EUR 339 million per year (in 2022 prices) in 2021–
2027.  Of  this,  EUR 234 million  supports  waste  water 
management, EUR 105 million drinking water and around 
EUR 1 million  the  other  aspects  of  the  WFD  (water 
management and protection). 

Of  the  total  financing,  0.2 %  is  provided  by  the  EU  MFF 
(mostly through cohesion policy), with no further support 
from the RRF. EIB financing is around 0.4 % of the total, 
while the bulk of financing comes from national sources 
(99.4 %) (163). 

The gap 

To meet the various environmental targets under the WFD 
and the Floods Directive, Luxembourg’s water investment 
gap  reaches  EUR 125 million  per  year  (0.16 %  of  GDP), 
linked  to  wastewater  measures. 
with  EUR 13 million 
Drinking water measures require an additional 18 million 
per  year  and  the  other  aspects  of  the  WFD  around 
94 million per year over the existing levels of financing. 

(162)  See  European  Commission,  ‘Estimating  investment  needs  and 
financing capacities for water-related investment in EU Member 
States’, 
2020, 
2  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. 

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

European 

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

Commission 

Luxembourg  43 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 70 million per year (in 2022 prices) in 
Luxembourg  in  2021–2027.  This  includes  the  following 
financing needs: 

• 

• 

• 

framework (164), 
Luxembourg’s  prioritised  action 
concerning the Natura 2000 areas: EUR 59 million per 
year, mostly running costs; 
additional  BDS (165)  costs:  there  may  be  additional 
costs, while the annual costs of the strategy are lower 
than  those  associated  with  the  prioritised  action 
framework; 
sustainable 
EUR 10.7 million per year. 

management (166) 

costs: 

soil 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 118 million per year (in 2022 prices) in 2021–2027. 
97 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

Out  of  the  total  biodiversity  financing,  no  financing  is 
estimated  to  come  from  EU  cohesion  policy,  2.7 %  from 
CAP,  0.5 %  from  Horizon  Europe  and  around  0.2 %  from 
LIFE.  The  EU  MFF  altogether  accounts  for  8.2 %  of  the 
financing  and  the  RRF  for  0.7 %,  adding  up  to  a  total  of 
8.9 %  from  the  EU  budget.  The  rest,  91 %,  comes  from 
national sources (167). 

Luxembourg  is  the  Member  State  with  the  third-highest 
share  of  biodiversity  financing  programmed  under  the 
RRF: 7.3 %. Luxembourg has also envisaged 19.4 % of CAP 
funds in 2021–2027 period to support biodiversity (above 
the  EU  average  of  18.6 %).  However,  no  cohesion  policy 
in 
funds  have  been  programmed  for 
biodiversity  in  Luxembourg  (while  the  EU  average  is 
5.9 %). 

investments 

(165)  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 

(166)  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. 
in 
biodiversity 

(167)  Based 

tracking 

budget 

5 July 

final 

the 

EU 

on 

of 

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

2025 Environmental Implementation Review – Luxembourg 

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

budgeting in 2021 (170), in which Luxembourg participated 
and  identified  possible  improvements  to  its  tagging 
methodology. 

Luxembourg  44 

Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (171)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 1.02 billion in 
Luxembourg in 2023, representing 1.28 % of its GDP (EU 
average:  2.03 %).  Energy  taxes  formed  the 
largest 
component of environmental taxes, accounting for 1.18 % 
of  GDP,  which  is  lower  than  the  EU  average  of  1.58 %. 
Transport  taxes,  at  0.09 %  of  GDP,  were  under  the  EU 
average  (0.36 %),  as  were  taxes  on  pollution  and 
resources,  at  0.01 %  (EU  average:  0.08 %).  In  2022, 
environmental taxes in  Luxembourg accounted for 3.2 % 
from  taxes  and  social  security 
of  total  revenues 
contributions (under the EU average of 5.0 %) (172). 

Figure 36: Environmental taxes per Member State, 2022 

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, based on the 
available  data,  no  significant  investment  gap  can  be 
observed in the case of Luxembourg. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
including  Luxembourg,  already  use  green 
States, 
budgeting  tools  for 
identifying  and  tracking  green 
expenditures  and/or  revenues  (168).  Green  budgeting 
practices  provide 
the 
environmental implications of budgetary policies. 

transparency  on 

increased 

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 (169). 

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

(168)  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, 

(169)  European  Commission, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

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

The  European  Green  Deal  emphasises  the  role  of  well-
designed  tax  reforms  (e.g.  shifts  from  taxing  labour  to 

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

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

(171)  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. 

(172)  Eurostat,  ‘Environmental  taxes  statistics –  detailed  analysis’, 
2024, 

September 

Eurostat 
https://ec.europa.eu/eurostat/statistics-
explained/index.php?oldid=651046. 

website, 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
 
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 (173),  Luxembourg  applies  a 
hunting and fishing tax, and a volumetric charge on water 
abstraction and water disposal. 

Green bonds and sustainable bonds 

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

During  2021–2023  combined,  Luxembourg  issued  green 
bonds worth USD 11.5 billion (EUR 9.8 billion). Of this, the 
to  USD 0.8 billion 
amounted 
2023 
issuance 
(EUR 0.7 billion) (174). 

in 

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

issuances)  were 

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

issued  by 

Luxembourg  45 

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

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

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies (EHSs), in particular fossil fuel subsidies (FFS), is 
a further step towards achieving the eighth environmental 
action  programme  objectives  and 
the  enabling 
conditions (175). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

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

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 103 billion in 2023 from EUR 57 billion in 
2020. From 2021 to 2023, there was a marked increase in 
annual FFS of 72 % in the EU (176). 

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 (177). 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 Luxembourg, the energy subsidies were stable between 
2015 and 2021, with FFS amounting to EUR 0.1–0.2 billion 
per  year.  In  2022  and  2023,  energy  subsidies  increased 

(173)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
Annexes 1  and  2,  https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
en. 

(174)  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. 

(175)  Article 3(h) and 3(v) of the eighth environmental action plan. 
(176)  European Commission, 2025, “2024 Report on Energy Subsidies in 

the European Union”, COM(2025), . 

(177)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
significantly  overall,  and 
EUR 0.3 billion in 2022 and EUR 0.5 billion in 2023. 

so  did  FFS, 

reaching 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden. Luxembourg’s 
value reached 0.4 %, under the EU average (0.8 %) (178). 

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

Luxembourg  46 

Source: analysis of the Directorate-General for Energy. 
In  the  2022  EIR,  Luxembourg  received  the  following 
recommendations. 

•  Draw  up  an  environmental  financing  strategy  to 
maximise  opportunities  for  closing  environmental 
implementation  gaps, 
increasing 
environmental taxes. 
Tackle  the  main  environmental  challenges  affecting 
the  country  through  appropriate  funding,  including 
through the mobilisation of investments and the use 
of EU funds. 

including  by 

• 

Overall,  Luxembourg  has  a  similar  environmental 
investment  gap  to  that  in  2022  (around  0.5 %  of  GDP), 
which is lower than the EU average, and is to a significant 
extent related to pollution prevention and control. In light 
of  an  existing  investment  gap  overall,  which  requires 
further  actions,  the  second  recommendation  from  2022 
has been reformulated below. 

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. 

NB: RES, renewable energy source. 

(178)  European Commission, 2025, “2024 Report on Energy Subsidies in 
COM(2025), 

European 

Union”, 

the 

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

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
Luxembourg  47 

6. Environmental governance 

Information, public participation and access to 
justice 

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

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
shared  efficiently  and  effectively (179).  Public 
is 
participation  allows  authorities  to  make  decisions  that 
take public concerns into account. Access to justice is a set 
of  guarantees  that  allows  citizens  and  NGOs  to  use 
national courts to protect the environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
authorities (180).  It 
legal 
includes  the  right  to  bring 
challenges (‘legal standing’) (181). 

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. 

Luxembourg’s  performance  in  implementing  the  Inspire 
Directive is substantial and has been reviewed based on its 
2023 country fiche (182) (see Table 3). 

(179)  The 

Aarhus 

Convention 

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

and 

the 

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

2016 

2023 

Legend 

Effective 
sharing 

coordination  and  data 

Ensure  effective 
coordination 

Data 
without obstacle 

sharing 

■ 

■ 

■ 

■ 

Inspire performance indicators 

(i)  Conformity  of 
metadata 

(ii)  Conformity  of 
spatial datasets  

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

(iv)  Conformity  of 
network services 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

■ 

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

Source:  European  Commission,  ‘Luxembourg’,  Inspire   nowledge  Base, 
https://knowledge-base.inspire.ec.europa.eu/luxembourg_en. 

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 

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

(181)  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. 

(182)  European  Commission,  ‘Luxembourg’,  Inspire   nowledge  Base, 

(https://knowledge-base.inspire.ec.europa.eu/luxembourg_en). 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
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 (183) 
and  the  Strategic  Environmental  Assessment 
(SEA) 
Directive (184). 

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 (185).  Luxembourg is yet to 
take  steps  aiming  to  accelerate  permitting-issuing 
procedures  taking  advantages  of  the  broad  flexibilities 
offered  by  the  EU 
legal  framework,  such  as  the 
establishment  of  one  stop  shop  and  accelerated  short 
deadlines  for 
issuing  permits  for  renewable  energy 
projects. 

(screening, 

scoping,  EIA 

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 (186).  The  duration  of  each  step  in  an  EIA 
process 
report,  public 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
The available data for Luxembourg shows that the average 
duration  for  some  steps  (screening,  scoping,  EIA  report, 
public  consultation,  reasoned  conclusion)  of  the  EIA 
process in the country is faster than the EU average (187). 
Effective use of EU procedures can positively influence the 
timely 
the 
decarbonisation of the economy on the way to net zero by 
2050. 

activities  underpinning 

approval  of 

(183)  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. 

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

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

2022, 

(186)  European  Commission:  Directorate-General  for  Environment, 
Collection of information and data on the implementation of the 
(EIA)  Directive 
revised  Environmental 

Impact  Assessment 

Luxembourg  48 

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 (188). 

Access to justice 

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

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

As outlined in the 2022 EIR, both individuals with a legal 
legitimate  interest  and  recognised  environmental  NGOs 
have standing to challenge environmental administrative 
decisions. 

Information on access to justice in environmental matters 
is accessible via government sites (189). 

In the 2022 EIR, Luxembourg received  priority actions to 
ensure  that  standing 
is  not  conditional  on  prior 
participation  in  environmental  cases.  It  appears  that 
standing  is  no  longer  conditional  on  prior  participation; 
therefore, the priority action is not repeated. 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 

(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/. 
(187)  Details  are  not  available  regarding  the  average  duration  for  all 
steps  of  the  procedure.  Therefore,  we  could  not  assess  the 
average duration of the entire EIA procedure. 

(188)  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 

(189)  Portals 

providing 

information 
and 

on 
sustainable 

the 

environment 
development 

(www.emwelt.lu) 
(www.developpement-durable-
infrastructures.public.lu/fr/index.html). 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
undertaken by public authorities to ensure that industries, 
farmers,  and  others  fulfil  their  obligations  to  protect 
water,  air,  and  nature,  to  manage  waste (190)  and  to 
remedy any environmental damage. It includes measures 
such  as  (i)  compliance  promotion;  (ii)  compliance 
monitoring  (i.e. 
inspections  and  other  checks);  (iii) 
enforcement,  that  is,  steps  taken  to  stop  breaches,  and 
impose  sanctions;  and  (iv)  ensuring  damage  prevention 
and remediation in line with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

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

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

As mentioned in the 2022 EIR, no centralised database or 
statistics on environmental crimes and their outcomes are 
available.  Luxembourg  police  continue  to  report  limited 
statistics specifically targeting environmental crimes, but 
they are not broken down by specific environmental crime 
types. The 2023 activity report from Luxembourg’s police 
website (191)  still  does  not  isolate  environmental  crimes, 
though  it  does  provide  general  crime  statistics  across 
various  categories,  such  as  property,  violent  crime  and 
other 
infractions.  Nonetheless,  Luxembourg’s  police 
continue to allocate specialised teams to investigate these 
offences,  particularly  within  departments  addressing 
economic  and  financial  crimes,  which  include  some 
environmental violations. 

The  2022  EIR  recommended  that  Luxembourg  (i)  better 
the  public  about  compliance  promotion, 
inform 
monitoring  and  enforcement; 
(ii)  provide  more 
information  on  how  professionals  dealing  with 
environmental  crime  work  together;  and  (iii)  publish 
information on the outcomes of enforcement actions and 
on the follow-up of detected cross-compliance breaches 
on nitrates and nature. However, such actions concerning 
compliance  promotion,  monitoring,  and  criminal  and 

(190)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 
compliance  and  governance  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
Commission 
(https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

document 

working 

staff 

Luxembourg  49 

administrative enforcement are not assessed in this report 
due to the lack of systematic information. 

The new EU Environmental Crime Directive 

(ECD) 

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 
(Directive (EU) 
2024/1203) (192) 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 
in  place  and  more  systematic 
measures  are  put 
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 
to  combat  environmental  crime  more 
measures 
effectively,  in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 

including  by 

(191)  https://police.public.lu/en/publications/2024/rapport-

activites.html. 

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

law, 

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

criminal 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
Luxembourg  50 

some  of  which  may  have  been  handled  under  the  other 
liability instruments. 

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

the  development  of 

From  1 May  2013  to  31 December  2021,  Luxembourg 
reported  two  occurrences  of  environmental  damage 
under  the  ELD (water damage), whereas in the previous 
reporting  period  no  environmental  damage  occurrences 
were reported under the ELD. 

liabilities.  Environmental 

Luxembourg  has  not  introduced  mandatory  financial 
insurance 
security  for  ELD 
policies that provide cover for all on-site and off-site ELD 
liabilities including other environmental damage as well as 
pollution  are  widely  available 
form  of  the 
environmental extensions to general liability policies. Such 
extensions generally only provide cover for ELD liabilities 
if  such  liabilities  overlap  with  requirements  under  other 
national  environmental  legislation  to  remediate  off-site 
land/soil pollution from a sudden and accidental incident 
on the insured’s site. The extensions rarely provide cover 
for remediating biodiversity damage under the ELD. 

in  a 

for  environmental 

The  2022  EIR  recommended  that  Luxembourg  improve 
liabilities,  and 
financial  security 
improve  ELD  guidance  and/or  the  collection  and/or 
publication  of  information  on  environmental  damage. 
Luxembourg  has  made  some  progress 
improving 
financial  security;  however,  no  information  is  available 
about  its  progress  on  other  priority  actions.  Efforts  to 
implement the 2022 priority actions should continue along 
with those for the 2025 priority actions. 

in 

2025 priority action 

• 

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

(198)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

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

enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 
Law (193),  EnviCrimeNet (194),  the  European  Network  of 
Prosecutors for the Environment (195) and the EU Forum of 
Judges  of  the  Environment (196).  The  European  Union 
Agency for Law Enforcement  Cooperation and European 
Justice  Cooperation 
Union  Agency 
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)  (197)  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 
for  better 
tool  and  a  key  enabler 
cross-cutting 
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 (198), which will be  finalised in 2025, and which 
was  supported  by  an  external  study (199),  containing, 
among other things, evidence, views,  reports, and other 
relevant information gathered from different stakeholder 
groups, including Member States. 

indicators 

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

(193)  https://www.impel.eu/en. 
(194) 

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 

(195)  https://www.environmentalprosecutors.eu/. 
(196)  https://www.eufje.org/index.php?lang=en. 
(197)  Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage (https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626). 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
 
Luxembourg  51 

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 (200) 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 
the  European 
for 
Commission  are  the  TSI (201)  and  TAIEX-EIR  PEER  2  PEER 
tool (202).  The  technical  assistance  available  through  the 
cohesion  policy  is  subject  to shared  management  and  is 
not dealt with in this subsection. 

the  environment  provided  by 

The Commission’s technical support instrument 

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

The Commission’s TSI had annual calls in 2021, 2022, 2023, 
2024 and 2025, with projects implemented the following 
year. In 2024, Luxembourg participated for the first time 
in a multi-country TSI project related to the environment, 
identifying  financial  solutions  to 
which  focused  on 
mobilise  resources  for  the  implementation  of  the  GBF, 
through  the  preparation  of  national  biodiversity  finance 
plans, 
the 
the  Ministry  of 
Environment, Climate and Sustainable Development. 

the  beneficiary  was 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
multi-country  workshops  are  those  requested  by  the 
European  Commission  to  present  new  and  upcoming 
in  all  Member 
legislation  and  policy 
environmental 
States (203). 

Workshops involving Luxembourg are as follows: 

•  Online  platforms:  EU  Batteries,  Packaging  and 
Packaging Waste Regulation (28-29 October 2024); 
•  Delivery  of  advisory  services  for  businesses  to  go 

• 

• 

circular (13 April 2023); 
Future  challenges  in  the  air  protection  in  Europe 
(24 November 2022) with the Czechia EU presidency; 
Eco-management  and  audit  scheme  (EMAS)  (28–
30 September 2022), hosted by Luxembourg. 

improve  environmental  governance, 

In 2022, Luxembourg received a priority action to continue 
to 
in  particular 
administrative  capacity  and  coordination  at  the  national 
level. There are no available data showing progress in this 
regard; therefore, the priority action is repeated. 

2025 priority action 

• 

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

(200)  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). 

(201)  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). 

tool 

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

PEER 
governance/environmental-implementation-review/peer-2-
peer_en). TAIEX: Technical Assistance and Information Exchange. 
(203)  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: 
further 
implementation  of  the  NEC  Directive  to 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25 September  2024);  Industrial  emissions  transposition 
and implementation of the revised directive (12 September 2024); 
Noise:  progress  towards  meeting  Member  States’  noise  limit 
values and EU reduction targets (5 June 2024); Best practice use 
of  environmental  footprint  methods  on  the  EU  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:  permitting  granting 
processes (13 June 2022). NB: The first flagship workshop on zero 
pollution for air, water and soil took place on 9 February 2022. 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
 
 
 
Luxembourg  52 

Annex

2025 priority actions 
Circular economy 

•  Adopt measures to increase the circular material use rate.  
• 

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 electronic and electric equipment (WEEE).  
Introduce  the  deposit  and  return  system(-s)  (DRS),  as  mandated  by  the  new  Packaging  and  Packaging  Waste 
Regulation, to capture more recyclable materials and improve the quality of recyclates.  
Invest in waste prevention measures to reduce the total amount of waste generated.  

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

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000 

• 

Ensure the effective implementation of Natura 2000 management plans and sufficient administrative capacity and 
financing  both  for  Natura  2000  and  the  implementation  of  the  Nature  Restoration  Regulation.  Ensure 
implementation of Prioritised Actions Framework 2021-2027 (PAFs). 

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

• 

• 

• 

• 
• 

measures, increased connectivity, better policy coordination and integration, and increased funding.  
Strengthen the integration of biodiversity actions into other policies, e.g. energy, agriculture, fisheries, forestry, 
urban and infrastructure planning and sustainable tourism, and promote communication between stakeholders. 

Recovery of ecosystems 

Step-up  efforts  to  further  reduce  nitrogen  deposition,  in particular  in  Natura  2000  sites  with  nitrogen-sensitive 
species and habitats. 
Implement eco-schemes and agri-environmental measures and practices to address the environmental needs of 
Luxembourg. 
Implement and scale up the uptake of organic farming practices. 
Promote the active management of grasslands through extensive grazing to maintain the condition of these semi-
natural habitats. 

•  Reduce the  excessive area  of sealed  and artificialised soil  and remediate degraded areas of soil. If appropriate, 
consider  formally  committing  to  targets  for  land-degradation  neutrality  under  the  relevant  United  Nations 
Convention to Combat Desertification agreement. 

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

Habitats Directive to recover. 

Prevention and management of invasive alien species  

• 

Step up implementation of the IAS Regulation, including with regard to enforcement and the capacity of inspection 
authorities. 
Ensure regional cooperation with neighbouring Member States to address predominant pressures. 

• 
•  Ratify the International Convention for the Control and Management of Ships' Ballast Water and Sediments of 2004 

(B M Convention). 

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Luxembourg  53 

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 

•  Reduce industrial air pollution damage and intensity.  
• 

Engage  with  industry  and  environmental  NGOs  to  ensure  proper  contribution  to  and  implementation  of  BAT 
conclusions and ensure timely updates to permits following the publication of BAT conclusions.  
Ensure effective public participation and access to justice in relation to the IED. 

• 

• 

• 

• 

Complete and implement action plans on noise management.  

Noise 

Water quality and management 

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

Improve the classification of water bodies and strengthen monitoring systems.  

•  Reduce pollution from nutrients, chemicals, metals and saline discharges.  
•  Better justify exemptions to the achievement of good status.  
• 
•  Develop more robust programmes of measures, tackle obstacles identified in the implementation of measures and 
ensure adequate financing for implementation, including through better use of cost recovery and the polluter-pays 
principle.  
FRMPs should provide details on how the FHRMs were used in the choice of measures and how to consider pluvial 
flooding.  
Consider future climate scenarios in the FRMPs.  

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

• 

monitoring, costs of measures).  
Improve public consultation and stakeholder involvement. 
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 for non-compliance.  
Increase customs checks and checks of products sold online with regard to compliance with chemicals legislation.  

• 

Climate action 

• 

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

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

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

Environmental governance 

2025 Environmental Implementation Review – Luxembourg 

 
 
 
Luxembourg  54 

• 

• 

Encourage  the  use  of  training  programmes  provided  by  the  Commission  (or  developed  at  the  national  level) 
covering the ELD and its interaction with the other national liability-related instruments, to ensure more efficient 
ELD  implementation,  improve  the  expertise  of  the  competent  authorities  and  raise  awareness  among  all 
stakeholder groups.  
Improve  overall  national  environmental  governance,  in  particular  administrative  capacity  to  support  the  green 
transition and coordination at the local level. 

2025 Environmental Implementation Review – Luxembourg