COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025 Country Report - FINLAND 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, Finland, 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) 308 final  COMMISSION STAFF WORKING DOCUMENT Environmental Implementation Review 2025        Country Report - FINLAND                 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) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Finland | 2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 5 
Transitioning to a circular economy ..................................................................................................................... 5 
Waste management ............................................................................................................................................. 7 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 13 
Global and EU biodiversity frameworks ............................................................................................................. 13 
Nature protection and restoration – Natura 2000 ............................................................................................. 13 
Recovery of species ............................................................................................................................................ 15 
Recovery of ecosystems ..................................................................................................................................... 16 
Prevention and management of invasive alien species ...................................................................................... 21 
Ecosystem assessment and accounting ............................................................................................................. 22 
3. ZERO POLLUTION ..................................................................................................................................................... 24 
Clean air ............................................................................................................................................................. 24 
Industrial emissions ............................................................................................................................................ 25 
Major industrial accidents prevention – Seveso ................................................................................................. 27 
Mercury Regulation ............................................................................................................................................ 28 
Noise .................................................................................................................................................................. 29 
Water quality and management ........................................................................................................................ 29 
Chemicals ........................................................................................................................................................... 33 
4. CLIMATE ACTION ..................................................................................................................................................... 37 
The EU emissions trading system ....................................................................................................................... 38 
Effort sharing ..................................................................................................................................................... 38 
Land use, land-use change and forestry ............................................................................................................. 39 
Adaptation to climate change ............................................................................................................................ 39 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 41 

5. FINANCING ............................................................................................................................................................. 41 
Climate finance landmarks ................................................................................................................................. 41 
Environmental financing and investments ......................................................................................................... 42 
Public financial management ............................................................................................................................. 46 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 49 
Information, public participation and access to justice...................................................................................... 49 
Compliance assurance ........................................................................................................................................ 51 
EU-supported environmental capacity building ................................................................................................. 54 

2025 Environmental Implementation Review – Finland 

 
 
 
Finland | 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 
in  Finland.  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 

implementation 

legal 

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

Finland on this point. 

Waste  management  in  Finland  remains  a  field  where 
improvement through economic instruments is necessary 
to curb the rate of landfilling of waste streams other than 
municipal waste. Economic instruments are also necessary 
to  direct  recyclables  away  from  waste  incineration  and 
towards the higher steps of the waste hierarchy. Finally, in 
line with the waste hierarchy, Finland needs to introduce 
new  policies  to  promote  waste  prevention  and  make 
product  reuse  and  waste  recycling  more  economically 
attractive. 

is  EUR 8.7 billion,  broken  down  as 

The  overall  environmental  investment  need  to  enable 
Finland to meet its objectives in the main environmental 
areas 
follows: 
biodiversity  and  ecosystems  (EUR 5 billion),  pollution 
prevention and control (EUR 1.7 billion), circular economy 
(EUR 1.5 billion)  and  water  (EUR 0.4 billion).  The  current 
in  Finland  stands  at  an  estimated 
investment  gap 
EUR 13 million  per 
four 
environmental  objectives  beyond  climate  change,  the 
additional investment need over the current levels – the 
investment gap – reaches an estimated EUR 6.2 billion per 
year  in  Finland,  representing  around  2.32 %  of  the 
national  GDP,  which  is  higher  than  the  EU  average 
(0.77 %). 

year.  To  meet 

these 

Regarding  biodiversity,  the  situation  has  worsened 
according to the latest reporting period (2013-2018):  67 % 
of  habitats  were  assessed  as  having  poor  and  bad 
conservation  statuses  (35%  and  32%,  respectively). 
Likewise, as for protected species, 47 % were assessed as 
having poor and bad conservation statuses (34% and 13%, 
respectively).  Moreover,  assessments  show  that  nearly 
90 %  of  Finland's  forest  habitats  have  bad  or  poor 
resulting 
statuses. Agricultural 
eutrophication continue to increase. Forestry is the most 
reported pressure on Natura 2000 sites. 

intensification 

and 

Regarding water quality, decisive measures are needed to 
address  diffuse  pollution  from  agriculture,  mainly  in  the 
form  of  phosphates,  mercury  and  polybrominated 
diphenyl ethers. Moreover, in Finland, periodic reviews of 
controls  over  water  uses  do  not  comply  with  the 
requirements of the Water Framework Directive. In 2024, 
the  Commission  started  an  infringement  case  against 

(1) 

from 

the  Commission 

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

to 

Regarding  environmental  governance,  Finland  needs  to 
improve  the  data  available  to  assess  the  level  of  public 
participation 
in  decision-making  processes.  Finally, 
Finland should make spatial data more widely accessible 
and 
the 
implementation of the Inspire Directive. 

environmental 

prioritise 

datasets 

in 

On  the  positive  side,  air  quality  in  Finland  is  generally 
good, with some exceptions (e.g. arsenic). The emissions 
of  several  air  pollutants  have  decreased  significantly  in 
Finland since 2005, while GDP growth has continued. The 
quality of drinking water in Finland does not give rise to 
concern, the compliance rate for all parameter groups is 
above 99%. 

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

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
 
Finland | 4 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial  systems  by  reducing  input  materials,  keeping 
products and materials in the loop for longer and reducing 
waste generation, thus decoupling economic growth from 
resource 
circular  economy  has 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
action plan (CEAP) (2) going through the legislative process 
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. 

The rate has been slowly increasing in Finland since 2016 
but  dropped  down  to  2.4 %  in  2023,  against  the  EU 
average of 11.8 %. This makes Finland the country with the 
third lowest use of circular materials in the EU (Figure 1), 
ahead of Ireland and Romania. 

15

10

5

0

2013

2015

2017

2019

2021

2023

Finland

EU-27

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

10 December 

2024, 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
can help to minimise negative impacts on the environment 
and reduce dependency on volatile raw material markets. 
In  2023,  Finland  generated  EUR 0.97  per  kg  of  material, 
against the EU average of EUR 2.23 per kg (Figure 2). 

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

2,5

2,0

1,5

1,0

0,5

0,0

2013

2015

2017

2019

2021

2023

Finland

EU-27

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

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

10 December 

accessed 

2024, 

(2) 

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 – Finland 

 
 
 
 
Policies and measures 

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

Since the launch of the online European Circular Economy 
Stakeholder  Platform  in  2017 (4)  national,  regional  and 
local  authorities  have  used  the  platform  to  share  their 
strategies,  roadmaps  and  good  practices,  for  example 
alternative business models and innovative technologies. 
In 2019  Finland updated its 2016  national  roadmap to a 
circular economy (5) to extend the timeline to 2025. 

is  guided  by  the 

In  addition, 
its  strategic 
in  2021,  Finland  adopted 
programme to promote a circular economy, with a vision 
to  have  the  country’s  economic  success  founded  on  a 
carbon-neutral  circular  economy  society  by  2035.  The 
vision 
following  objectives:  the 
consumption  of  non-renewable  natural  resources  will 
decrease,  and  the  sustainable  use  of  renewable  natural 
resources  may  increase  to  the  extent  that  the  total 
consumption of primary raw materials in Finland in 2035 
does  not  exceed  that  of  2015.  The  productivity  of 
resources  will  double  by  2035  from  what  it  was  in  2015 
and the CMUR will double by 2035. 

Finland’s Circular Economy Green Deal (6) is in its starting 
phase. It builds on parallel research work done on circular 
economy  scenarios 
involves 
organisations  voluntarily  committing  to  reduce  their 
natural  resource  use,  setting  goals  and  taking  action  to 
promote a low-carbon circular economy. 

the  country  and 

for 

As  for  sectoral  strategies,  in  2022  Finland  updated  its 
plastic roadmap for Finland (7) to be an extensive national 
programme  aiming  for  a  breakthrough  in  the  circular 
economy regarding plastics by 2030. 

The Finnish national recovery and resilience plan (RRP) (8) 
includes some circular-economy-related activities, mainly 
linked to increased investments in the reuse and recycling 
of  key  materials  and  industrial  side  streams,  the  built 

Finland  5 

international  growth.  The 
environment  sector  and 
cohesion  policy  programme  ‘Innovation  and  skills  in 
Finland  2021–2027’  includes  a  specific  objective  for 
promoting  the  transition  to  a  circular  and  resource-
efficient economy. The programme will support  private–
public research, development and innovation cooperation 
and high-value circular economy businesses, aiming at the 
sustainable use of natural resources. 

Some cities and regions in Finland have been active in the 
EU’s circular cities and regions initiative and plan to make 
a  voluntary  commitment  under  the  Circular  Economy 
Green Deal. 

The Commission started infringement proceedings against 
Finland for failure to transpose fully the Single-Use Plastics 
Directive (9) into its national laws (10). 

Green public procurement 

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

The first public procurement  strategy in Finland was put 
forward in 2020, with 27 objectives in categories such as 
innovative, social, ecological and financial. A new strategy 
for 2024–2027 was adopted with renewed focus areas (11). 

The  main  approaches  of  the  environmental  focus  area, 
one of eight focus areas of the strategy, are (i) developing 
legislative  proposals  to  account  for  the  environmental 
impact of procurement; (ii) encouraging environmentally 
responsible procurement and voluntary commitments to 
advance  sustainable  development  principles  in  public 
procurement;  (iii)  updating  guides  on  the  responsible 
procurement  of  foodstuff  (in  line  with  the  farm-to-fork 
strategy);  and 
low-carbon  public 
launching  a 
procurement  development  programme  with  pioneer 
organisations.  The  strategy  does  not  establish  product-
specific  rules,  but  it  has  developed  criteria  on,  for 
example, food and catering as well as green deals (12). To 

(iv) 

(3) 

(4) 

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). 
(5)  Ministry of the Environment, ‘Strategic programme to promote a 
circular  economy’,  https://ym.fi/en/strategic-programme-to-
promote-a-circular-
economy#:~:text=The%20programme,leader%20in%20the%20cir
cular%20economy. 

Stakeholder 

Economy 

Platform 

(6)  Ministry  of  the  Environment,  ‘Circular  Economy  Green  Deal’, 

https://ym.fi/en/circular-economy-green-deal. 

(8) 

(9) 

and 

resilience 

(7)  Ministry  of  the  Environment,  ‘Plastics  roadmap  for  Finland – 
Reduce,  refuse,  recycle  and  replace’,  https://ym.fi/en/plastics-
roadmap-for-finland. 
Finnish Government, Sustainable growth programme for Finland – 
2021, 
Recovery 
https://julkaisut.valtioneuvosto.fi/handle/10024/163363.  
Directive  (EU)  2019/904  of  the  European  Parliament  and  of  the 
Council of 5 June 2019 on the reduction of the impact of certain 
plastic  products on the  environment  (OJ  L 155,  12.6.2019,  p. 1), 
https://eur-lex.europa.eu/eli/dir/2019/904/oj. 
INFR(2022)0078. 
https://vm.fi/hankinta-suomi. 
https://ym.fi/green-deal-sopimukset. 

(10) 
(11) 
(12) 

Helsinki, 

plan, 

2025 Environmental Implementation Review – Finland 

 
 
ensure successful implementation and the achievement of 
the strategy’s objectives, public procurement units will be 
supported by members of the KEINO Competence Centre 
for Sustainable and Innovative Public Procurement. 

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 
the 
scheme 
management 
environmental impacts of organisations. 

reducing 

aimed 

at 

As of September 2024, Finland had 2 402 products out of 
98 977, and 11 licences out of 2 983 registered in the EU 
Ecolabel scheme, showing significant take-up of products 
(with  paints  and  varnishes  being  the  dominant  product 
group) but low take-up of licences (13). Since the last two 
reports in 2019 and 2022, the number of licences under 
the  EU  Ecolabel  in  Finland  has  decreased.  In  addition  to 
the EU Ecolabel registrations, Finland had 2 869 products 
and services awarded the Nordic Swan  Ecolabel, a  more 
common  and  widespread  ecolabel  in  certain  Nordic 
countries, as of October 2024. This only includes products 
where  the  certifying  country 
itself.  Five 
organisations in Finland are currently registered in EMAS, 
one more than in October 2021 (14). 

is  Finland 

The  CMUR  of  Finland  has  decreased  by  3 percentage 
points in 2023. This represents a step back from the 2022 
priority action to take measures to increase the rate. 

While  Finland’s  circular  economy  policy  framework  is 
being 
further 
measures to decrease material consumption are needed. 

implementation  and 

strengthened, 

2025 priority action 

•  Adopt measures to increase the circular material use 

rate. 

Waste management 

Turning waste into a resource is supported by: 

(i)  addressing  the  full  life  cycle  of  products,  from 
conception to end of life, by setting requirements on 
the design of products to ensure that they are more 

Finland  6 

sustainable; 

(ii)  fully 

implementing  EU  waste 

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

(iii)  reducing waste generation per capita and in absolute 

terms; 

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

(v)  limiting energy recovery to non-recyclable materials; 

and 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

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

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

(which 

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

The total amount of waste generated in Finland increased 
between  2012  and  2018  and  has  decreased  since 
(Figure 3).  This  trend  is  primarily  driven  by  the  largest 
waste category, other mineral waste (which is part of the 
mineral  waste  category  and  is  mainly  generated  in  the 
mining  and  quarrying  sector).  When  excluding  mineral 
waste, waste generation shows a strong decreasing trend, 
mainly  driven  by  the  drop  in  the  recyclable  wood  waste 
category, which in 2014 was redefined as a byproduct and 
now  excludes  the  majority  of  wood  waste  from  waste 
statistics.  Finland’s  GDP  is  quite  steady  with  a  small 
increasing trend, but dropped slightly in 2019, most likely 
due  to  the  COVID-19  outbreak.  Due  to  the  strong 
variations  in  waste  generation,  no  clear  indications  of 
decoupling  between  economic  growth  and  waste 
generation can be seen. 

(13) 

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

(14) 

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

2025 Environmental Implementation Review – Finland 

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

accessed 

15 October 

nama_10_gdp, 

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

30 September 

22 October 

accessed 

2024, 

Critical raw materials  

The national waste plan, which was published in 2022 and 
covers up to 2027, includes policy recommendations for 
improving  the  circularity  of  minerals (15).  The  current 
minerals  strategy  dates  back  to  2011  and  therefore 
Finland  is  also  working  on  updating  it.  The  circularity 
aspect of metals and minerals will be taken into account 
in the updated strategy (16). 

Construction and demolition waste  

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (17) 
by  the  Joint  Research  Centre  shows  that  preparing  for 
reuse  and  recycling  operations  are  preferred  over 
landfilling  from  an  environmental 
incineration  and 
perspective  for  most  of  the  different  streams  of 
construction  and  demolition  waste.  However,  the 
economics are often unfavourable for preparing for reuse 
and recycling compared with incineration and landfilling. 
If available technology were to be applied, it is estimated 

Finland  7 

that  the  increase  in  preparing  for  reuse  and  recycling 
would  lead  to  an  additional  33 Mt  of  greenhouse  gas 
(GHG) emission savings annually (more than, for example, 
the combined annual GHG emissions of Estonia, Latvia and 
Luxembourg). 

The  preparing  for  reuse  and  recycling  rate  of  mineral 
construction  and  demolition  waste  in  Finland  is  61.6 %, 
compared  with  the  EU  average  of  79.8 %.  Measures  to 
further increase the preparing for reuse and recycling rate 
of  construction  and  demolition  waste  include  separate 
collection at source, for instance through digitalised pre-
demolition audits (18) (‘resource assessments’); extended 
producer  responsibility 
(EPR)  and  other  economic 
instruments;  and  upstream  measures  such  as  increasing 
the  recycled  content  in  construction  products  and  the 
circular design (19) of construction works. 

Under  Finnish 
law,  the  holder  of  construction  and 
demolition waste must organise separate collection for (at 
least)  concrete,  brick,  mineral  slabs  and  ceramic  waste. 
Separate collection is also required for asphalt, bitumen, 
roofing felt, gypsum waste, untreated wood, metal, glass, 
plastic,  paper  and  cardboard,  mineral  wool  insulation 
waste, and soil and stone waste. 

Boosting implementation – the 2023 Waste Early 
Warning Report 

This  section  focuses  on  the  management  of  municipal 
waste (20),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste  Early  Warning  Report (21)  identifying  the  general 
trends in waste management and the Member States at 
risk of missing 2025 waste targets (see Figure 4). Finland is 
in the category of countries at risk of missing the municipal 
waste target but not the packaging waste target. 

last  decade,  Finland  has  made  considerable 
In  the 
progress  in  diverting  waste  from  landfilling,  but  this  has 
resulted in a significant increase in the incineration rate, 
while  recycling  has  increased  less.  Significantly  more 

(15) 

(16) 
(17) 

(18) 

(in 

https://julkaisut.valtioneuvosto.fi/handle/10024/163978 
Finnish only). 
http://projects.gtk.fi/minerals_strategy/index.html. 
European Commission: Joint Research Centre, Cristobal Garcia, J., 
Caro,  D.,  Foster,  G.  et  al.,  Techno-economic  and  environmental 
assessment of construction and demolition waste management in 
the  European  Union,  Publications  Office  of  the  European  Union, 
2024, 
Luxembourg, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 
European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works – 
Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-

(19) 

/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. 

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

(21) 

2025 Environmental Implementation Review – Finland 

 
 
 
efforts are required to meet the 2025 targets mentioned 
above for preparing for reuse and recycling. 

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

Finland  8 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts  to  improve  their  recycling  performance.  The 
Commission  is,  on  one  hand,  working  together  with  the 
national  authorities  and  stakeholders  to  speed  up  the 
implementation  of  measures  necessary  to  meet  the 
targets,  including  through  dedicated  financing.  On  the 
other  hand,  the  Commission  is  pursuing  enforcement 
actions against those Member States that, based on data 
submitted to the Commission, do not achieve the targets 
of the Waste Framework Directive (22), the Packaging and 
Packaging Waste Directive (23) and the Directive on Waste 
Electrical and Electronic Equipment (24). 

the  Ministry  of 

In  summer  2024, 

Further to the Waste Early Warning Report, the Ministry 
of  the  Environment  in  Finland  launched  a  process  with 
stakeholders  to 
identify  the  best  ways  to  promote 
the 
recycling. 
Environment  also  launched  a  comprehensive  reform  of 
waste  legislation  (the  Circular  Economy  Act).  The  aim  of 
the reform is to make the circular economy more efficient, 
and  additional  measures  to  promote  recycling  will  be 
assessed and implemented in connection with the project. 
The efficiency of the circular economy is expected to also 
have a positive impact on the recycling rate of municipal 
waste. 

Municipal waste 

Municipal  waste  generation  has  significantly  increased 
over  the  past  decade  but  dropped  in  2022.  In  2022, 
Finland  generated  522 kg  per  capita  of  municipal  waste, 
which  is  very  close  to  the  estimated  EU-27  average  of 
513 kg per capita (Figure 5). 

treatment 

type.  The  share  of 

In Finland, incineration with energy recovery is the main 
waste 
incineration 
significantly  increased  since  2010  and  stands  at  56 %  in 
2022.  Landfilling  accounts  for  less  than  1 %  of  waste 
treatment.  Finland  has  made  considerable  progress  in 
diverting waste from landfilling and this has resulted in a 
significant  increase  in  the  incineration  rate  but  the 
recycling rates have increased less (Figure 5). The recycling 
rate increased from 33 % in 2010 to 43 % in 2022, which is 
slightly  below  the  estimated  EU27  average  of  49 % 
(Figure 6). 

Finland has also reported data showing compliance with 
the  preparing  for  reuse  and  recycling  target  of  55 %  for 
2025, as laid down in the Waste Framework Directive. The 
difference between these (provisional) data, following the 

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

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

  Member States at risk of missing both targets 

  Outside coverage 

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

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

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

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

-  EN 

2025 Environmental Implementation Review – Finland 

 
 
 
reporting  obligation  of  the  Waste  Framework  Directive, 
and  the  data  shown  in  Figure 5  (voluntary  reporting)  is 
below 1 percentage point for the preparing for reuse and 
recycling rate for both 2021 and 2022. 

Figure 5:  Municipal  waste  management 
(including preparing for reuse), 2010–2022 

recycling 

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

22 October 

accessed 

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

NB: From reference year 2020, new reporting rules apply for calculating 
recycled  municipal  waste  pursuant  to  the  targets 
in 
Article 11.2(c–e) of Directive 2008/98/EC. 

laid  down 

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

22 October 

accessed 

Packaging waste 

Finland  9 

in  2022 (25).  Some  changes 

in 
160 kg  per  capita 
consumption habits due to the  COVID-19 outbreak have 
taken place. The volume of generated packaging waste is 
still significantly below the estimated European average of 
186 kg per capita in 2022 (26). 

Finland’s overall packaging waste recycling rate as well as 
the recycling rates for all materials steadily increased until 
2019.  In  2022,  the  reported  recycling  rate  for  total 
packaging waste was 60 %. This is mainly driven by paper 
and  cardboard  and  plastics  packaging,  as  these  are  the 
largest packaging waste categories. It is, however, highly 
likely  that  the  reported  recycling  rate  for  paper  and 
cardboard  packaging  is  overestimated,  since  it  has  been 
exceeding 100 % for several years. The recycling rate for 
plastics  packaging  is  still  rather  low,  although  it  has 
increased over time. Since the reference year 2020, it has 
been mandatory to report steel and aluminium packaging 
separately.  The  reported  recycling  rate  of  aluminium 
packaging  is  above  the  2025  target,  while  the  recycling 
rate  of  steel  packaging  needs  to  increase  to  meet  the 
target for 2025. 

Figure 7: Packaging waste generation, 2010–2022 

NB:  From  reference  year  2020,  the  rules  for  calculating  recycled 
to  Article 6a  of 
packaging  waste  have 
Directive 94/62/EC. Finland has reported packaging and packaging waste 
using  the  new  calculation  rules  from  reference  year  2020,  which  has 
affected all materials’ recycling rates except those of metals. 

changed,  pursuant 

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

Policies to encourage waste prevention 

Finland’s packaging waste generation per capita stagnated 
between  2010  and  2019  but  increased  significantly  to 

Waste  management  plans  and  waste  prevention 
programmes are instrumental to the full implementation 

(25) 

If repaired wooden packaging is included, waste generation was 
169 kg per capita, 170 kg per capita and x kg per capita in 2020, 
2021 and 2022, respectively (SYKE, 2024). 

(26) 

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

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
Finland  10 

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). 

Finland has a national waste management plan (NWMP) 
and a national waste prevention programme (NWPP). The 
NWPP  is  integrated  into  the  2022–2027  NWMP,  ‘From 
recycling to circular economy’, and the waste prevention 
targets  are  linked  to  the  general  waste  management 
targets (27). In addition to the NWMP, a specific roadmap 
to  reduce  food  waste  in  the  food  supply  chain  was 
established  in  2020 (28).  The  NWMP  and  NWPP  are 
complemented by Finland’s plastics roadmap, one of the 
main  objectives  of  which 
is  to  avoid  unnecessary 
consumption of plastics and promote the reuse of plastics. 

In the NWPP, the priority waste streams are electrical and 
electronic  waste,  construction  waste,  municipal  waste, 
biodegradable  waste,  packaging  waste  and  single-use 
plastics (29). Each priority stream has its own quantitative 
targets,  but  most  of  the  targets  relate  to  waste 
management. The quantitative waste prevention target is 
to halve food waste generation by 2030. A set of indicators 
is  proposed  to  monitor  the  NWPP,  mainly  on  waste 
generation for different waste streams and on preparation 
for  reuse.  There 
for  the 
implementation of the NWPP. However, the NWMP and 
its measures are binding on the administrative branches. 
In addition, a separate budget has been set aside for the 
circular  economy  programme  that  complements  the 
waste plan. 

is  no  budget  specified 

Finland  intends  to  evaluate  the  NWMP,  including  the 
NWPP, at its midpoint by providing an extensive interim 
report  in  2024–2025,  and  at  its  end  in  2027.  Regional 
cooperation groups are asked annually about the progress 
of  the  NWMP’s  and  the  NWPP’s  measures.  The 
information of the interim report will be made public. 

Policies to encourage separate collection and recycling 

Finland has a mandatory door-to-door separate collection 
system  for  packaging  waste  at  household  properties 
consisting  of  at  least  five  apartments  located  in  built-up 
areas  with  more  than  200  inhabitants,  and  a  system  of 
drop-off points in rural areas. The system does not cover 
non-packaging  categories  (except  small  metal  items). 
There  is  a  mandatory  door-to-door  separate  collection 
system  for  biowaste  for  townhouses  or  apartment 
buildings  with  at  least  five  apartments.  In  addition, 

is 

incentivised  through  allowing  a 

mandatory  door-to-door  collection  of  biowaste  at 
household properties located in population centres with 
more  than  10 000  inhabitants  starts  in  2024.  Home 
composting 
less 
frequent  emptying  schedule  for  residual  waste,  which 
reduces  waste  management  fees  for  households  when 
registering  for  home  composting  and  ensuring  the 
compost fulfils specific requirements. Separate collection 
is  supported  by  regular  campaigns  for  sorting  biowaste 
and  home  composting (30).  Textile  waste  and  reusable 
clothes  are  collected  at  civic  amenity  sites  and  drop-off 
points.  In  addition,  Finland  has  a  wide  coverage  of 
separate  collection  for  non-packaging  paper  waste, 
covered by the EPR scheme for printed paper. 

Businesses  and  public  administration  located  in  urban 
areas must organise the separate collection of biowaste if 
the  operation  generates  at  least  10 kg  per  week.  The 
sorting  at  source  of  packaging  waste  originating  from 
companies  became  mandatory  in  2022.  Producers  are 
obliged to organise the reception of separately collected 
non-household  packaging  waste.  EPR  for  packaging  has 
been implemented since 1998. Separate collection of non-
household packaging waste has been mandatory in urban 
areas from 2022. 

In  Finland,  EPR  applies  to  all  packaging.  Advanced  fee 
modulation has been required by law since 2023 and fees 
have  to  be  determined  based  on  the  recyclability  and 
reusability of the packaging, taking into consideration the 
presence of harmful substances or other properties that 
may harm the recycling system. For beverage packaging, 
Finland uses a voluntary deposit-return system, covering 
nearly all aluminium cans, glass bottles and plastic bottles. 
This  system  achieves  very  high  return  rates  (87–94 %). 
Producers  are  incentivised  to  participate  in  this  system 
through  a  tax  exemption,  an  exemption  from  some  of 
their  EPR  obligations,  and  an  excise  duty  for  beverage 
containers outside the deposit-return system. 

Recent  legislative changes require that Finland’s existing 
door-to-door separate collection system be extended to a 
larger part of the population, and that the EPR scheme for 
packaging also cover online sales and imports. In addition, 
the number of drop-off points for plastic packaging had to 
be doubled compared with the requirements set in 2014, 
that is, with the level of other packaging material drop-off 
points.  These  drop-off  points  serve  residents  in  sparsely 
populated areas who do not have door-to-door collection. 

On  the  international  level,  Finland  has  not  ratified  the 
Hong  Kong  International  Convention  for  the  Safe  and 
Environmentally Sound Recycling of Ships. 

(27) 

(28) 

EEA,  Waste  Prevention  Country  Profile –  Finland,  Copenhagen, 
https://www.eea.europa.eu/themes/waste/waste-
2023, 
prevention/countries/2023-waste-prevention-country-fact-
sheets/finland_waste_prevention_2023/view. 
https://ruokahavikkitiekartta.fi/. 

(29) 

(30) 

https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/1639
79/YM_2022_14.pdf?sequence=1&isAllowed=y. 
https://www.xn--biojte-eua.info/. 

2025 Environmental Implementation Review – Finland 

 
 
Finland  11 

Policies to discourage landfilling or incineration 

Finland  has  a  landfill  tax  in  place  and  a  landfill  ban  on 
biodegradable and other organic waste, limited to a total 
organic  carbon  content  above  10 %.  The  landfill  tax  is 
EUR 70/t,  which  is  considerably  higher  than  the  EU 
average. The landfill tax has been unchanged since 2016. 
Finland has no tax on waste incineration. 

Finland is subject to an infringement procedure for  poor 
application  of  the  Waste  Electrical  and  Electronic 
Equipment Directive and the Waste Framework Directive 
due  to  non-attainment  of  the  targets  provided  therein. 
Indeed,  Finland  failed  to  meet  the  50 %  target  for 
preparing for reuse and recycling of municipal waste (e.g. 
paper,  metal,  plastic  and  glass)  for  2020.  Furthermore, 
Finland  failed  to  collect  sufficient  waste  electrical  and 
electronic equipment separately and therefore missed the 
EU  collection  target  of  65 %  of  the  average  weight  of 
electrical and electronic equipment placed on the market 
in the three preceding years. 

Regarding  the  priority  actions  delivered  in  the  2022  EIR, 
there has been some progress on the recommendation to 

improve  recycling  rates,  as  Finland  has  revised  the 
separate  collection  system  for  packaging  waste  and 
biowaste.  However,  the  recommendation  for  the  Åland 
Islands to adopt a waste plan has not been fulfilled. There 
implementing  economic 
has  been  no  progress  on 
instruments  aiming  at  curbing  the  rate  of  landfilling  of 
waste  streams  other 
than  municipal  waste  and 
channelling those revenues towards measures to manage 
waste at higher levels in the waste hierarchy. 

2025 priority actions 

• 

• 

• 

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

2025 Environmental Implementation Review – Finland 

 
 
 
Finland  12 

2. Biodiversity and natural capital 

Global and EU biodiversity frameworks 

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

The EU biodiversity strategy for 2030 (BDS) aims to put 
EU  biodiversity  on  a  path  to  recovery  by  2030.  It  sets 
quantified targets intended to protect and restore nature 
and manage ecosystems in a sustainable manner, as well 
as  measures 
and 
commitments  to  support  global  biodiversity.  A  BDS 
actions  tracker (31)  and  a  dashboard  of  indicators (32) 
provide information on implementation progress. 

implementation 

enable 

to 

The BDS is the main instrument used by the EU to deliver 
on  its  obligations  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. 

recently 

adopted 

EU  Nature  Restoration 
The 
Regulation (33) 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 

(31) 

(32) 

(33) 

Actions 

Tracker 

Strategy 

Strategy 

Dashboard 

Biodiversity 

Biodiversity 

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

page 

web 

Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

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

In 

Finland  is  in  the  process  of  updating  its  NBSAP (34).  In 
August  2024,  Finland  uploaded  to  the  Convention  on 
Biological  Diversity’s  online  reporting  tool (35)  a  draft 
national  goal  and  23  national  biodiversity  targets, 
pending official Finnish government decision on a revised 
NBSAP. 

The EU aims to allocate to biodiversity objectives at least 
7.5 % of annual spending under the EU budget in 2024, 
rising to 10 % in 2026 and 2027. 

For details on biodiversity financing and investments  in 
Finland, see Chapter 5. 

Nature protection and restoration – Natura 
2000 

Natura  2000 (36),  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 

(34)  Ministry of the Environment, ‘Finland’s biodiversity policy’, 

ministry website, https://ym.fi/en/national-biodiversity-policy. 
https://ort.cbd.int/national-targets?countries=fi. 

(35) 
(36)  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 8 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. A special area of conservation (SAC) is an SCI designated 
by a Member State. 

2025 Environmental Implementation Review – Finland 

 
 
 
Finland  13 

Figure 8: Natura 2000 terrestrial protected area 
coverage per Member State, 2023 

conservation (SACs) (37); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

Setting up a complete and coherent network of Natura 
2000 sites 

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

the 

these 

requires 

commitments 

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

Finland  hosts  68  habitat  types (38)  and  128  species (39) 
covered by the Habitats Directive. The country also hosts 
populations of 81 bird taxa listed in Annex I to the Birds 
Directive (40). 

In 2023 (41), approximately 12.6 % of the terrestrial area 
of  Finland  was  covered  by  the  Natura  2000  network – 
well  below  the  EU  average  of  18.6 %  (see  Figure 8). 
special  protection  areas  (SPAs),  designated  under  the 
Birds Directive, account  for  7.3 % of Finland’s territory, 
while  SCIs,  designated  under  the  Habitats  Directive, 
cover 12.5 % of the area. This represents a slight increase 
in  the  area  of  land  under  protection  compared  with 
previous  years  as  part  of  Finland’s  ongoing  efforts  to 
align with EU biodiversity goals. 

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 
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. 

In  the  2022  EIR,  Finland  received  priority  actions  to 
complete the Natura 2000 network, especially for marine 
sites. Finland has made some progress in this respect, but 
it  still  needs  to  speed  up  the  necessary  conservation 
measures, as they are yet to be defined for some sites, 
including the Åland Islands. 

(37) 

(38) 

(39) 

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’, 
2019, 
Article 17 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 

19 December 

dashboard, 

(40) 

(41) 

dashboard, 

19 December 

EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-
specieshttps://www.eea.europa.eu/themes/biodiversity/
state-of-nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-
species. 
EEA, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/natura-2000-barometer-dashboards. 

Barometer’, 

‘Natura 

22 May 

2018, 

2000 

2025 Environmental Implementation Review – Finland 

 
 
 
Finland  14 

13.21 %.  The  main  pressures identified  for  habitats  are 
forestry,  mixed-source  pollution,  agriculture,  and 
development  and  construction.  Unknown  pressures 
including pressures from outside Finland also rank high 
for  habitats  and  are  the  main  pressures  for  species, 
which are also strongly affected by forestry and natural 
processes. 

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

Figure 9: Assessments of conservation status of habitats 
for the 2007–2012 and 2013–2018 reporting periods 

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

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

December 

accessed 

2019, 

2025 priority actions 
• 

the 

establishment 

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

of 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
Habitats Directive, a quarter of species in the EU were of 
good conservation status as of 2018 (42). 

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

According  to  Finland’s  report  for  2013–2018  on  the 
conservation  status  of  habitats  and  species  required 
under  Article 17  of  the  Habitats  Directive,  31.87 %  of 
habitats  were  assessed  as  having  good  conservation 
status  in  2018,  lower  than  the  33.70 %  reported  in  the 
previous reporting period (2007–2012). As for protected 
species,  45.28 %  were  assessed  as  having  good 
conservation status in 2018, also lower than the 46.00 % 
reported  in  2007–2012.  Only  11.76 %  of  the  forest 
habitats  of  community  interest  in  Finland  show  a 
favourable  conservation  status (43).  Regarding  birds, 
26 %  of  the  breeding  species  showed  short-term 
increasing  or  stable  population  trends.  Finland  has  the 
increasing  wintering 
reported 
in 
highest 
populations in the short term (50 %). 

trend 

Between  the  same  reporting  periods,  the  share  of 
habitats  with  bad  conservation  status  increased  from 
26.09 %  to  31.87 %  and  the  share  of  species  with  bad 
conservation  status  also  increased  from  11.33 %  to 

(42) 

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, 

(43) 

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

2025 Environmental Implementation Review – Finland 

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

that forestry practices take fully into account the need to 
protect  and  restore  the  conservation  status  of  forest 
habitats  and  species.  Limited  progress  is  noted  on  all 
these actions; hence the priority actions are reiterated in 
this report. 

Finland  15 

2025 priority actions 
• 

• 

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.   
Enhance  efforts  to  collect  reliable  data  on  the 
conservation status of habitats and species as well 
as  their  occurrence  at  site  level.  In  view  of  this, 
consider  the  creation  of  a  body  in  charge  of 
monitoring  and  reporting,  to  ensure  that  data  are 
not provided only ad hoc on a contract basis. 

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

Recovery of ecosystems 

Agricultural ecosystems 

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

December 

accessed 

2019, 

Finland  needs  to  ensure  that  species  and  habitats  of 
community  interest  are  maintained  at  or  restored  to 
favourable  conservation  status  across  their  natural 
ranges.  Finland  has  nature  protection  and  restoration 
programmes,  namely  the  METSO  programme 
for 
financing  forest  biodiversity  measures  and  the  HELMI 
programme focusing mainly on mires, wetlands, coastal 
habitats and semi-natural grasslands. The SOTKA project 
is  also  designed  to  improve  the  status  of  waterfowl. 
Considering the increasing number of negative trends in 
the  conservation  status  of  habitats  and  species,  it  is 
important  that  Finland  pursue  such  actions  with 
consistent ambition over time. 

fully 

In  the  2022  EIR,  Finland  received  priority  actions,  inter 
alia, to (i) finalise Natura 2000 objectives and measures; 
(ii) 
into  the 
integrate  biodiversity  concerns 
implementation  of  other  policies;  (iii)  ensure  the 
regulatory framework applicable in Finland for protected 
species  is  fully  in  line  with  the  requirements  of  the 
Nature  Directives;  (iv)  step  up  action  on  implementing 
the  priority  actions  set  out 
in  Finland’s  common 
agricultural  policy  (CAP)  strategic  plan  (SP),  especially 
with  regard  to  improving  rural  areas;  (v)  step  up  the 
implementation  of  the  EU  Invasive  Alien  Species  (IAS) 
Regulation; and (vi) pursue and scale up efforts to ensure 

(44) 
agriculture-food/vision-agriculture-and-food_en  

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

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

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

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

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

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

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

— 

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

The “Vision for agriculture and food” (44), 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. 

2025 Environmental Implementation Review – Finland 

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

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

The utilised agricultural area in Finland decreased from 
2 285 200 ha in 2012 to 2 274 500 ha in 2016, and further 
decreased to 2 266 400 ha in 2022. 

‘share  of  agricultural 

Landscape features are fragments of non-productive and 
typically – but not exclusively – semi-natural vegetation 
present in or adjacent to agricultural land. They provide 
ecosystem  services  and  support  for  biodiversity.  The 
indicator 
land  covered  with 
landscape  features’  is  the  ratio  between  the  area 
covered by landscape features and the area covered by 
agricultural  land.  Based  on  the  Land  Use/Cover  Area 
Frame Survey landscape features estimates, the share of 
agricultural  land  covered  by  non-productive  landscape 
features in Finland is 7.6 %, above the EU average. At the 
EU  level,  landscape  features cover  5.6 %  of  agricultural 
land. 

In 2024, the CAP basic regulations were amended (45) to 
simplify certain rules, inter alia, the standards for good 
agricultural  and  environmental  conditions  (GAECs)  of 
land. These changes removed the obligation for farmers 
benefiting  from  CAP  area-related  support  to  have  a 
minimum  share  of  3–4 %  of  non-productive  areas  or 
landscape  features 
in  their  farms.  The  amended 
regulations do not remove the obligation under GAEC 8 
to  maintain  existing  landscape  features  but  set  out  an 
obligation  for  Member  States  to  establish  and  provide 
support  for  eco-schemes  covering  practices  for  the 
maintenance of non-productive areas, such as land lying 

(45) 

(46) 

Regulation (EU) 2024/1468 of the European Parliament and of 
the  Council  of  14 May  2024  amending  Regulations  (EU) 
2021/2115 and (EU) 2021/2116 as regards good agricultural and 
environmental  condition  standards,  schemes  for  climate, 
environment  and  animal  welfare,  amendment  of  the  CAP 
Strategic Plans, review of the CAP strategic plans and exemptions 
from  controls  and  penalties  (OJ  L,  2024/1468,  24.5.2024), 
http://data.europa.eu/eli/reg/2024/1468/oj. 
Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj. 

Finland  16 

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

The recently adopted Nature Restoration Regulation (46) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level in 
at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (47). 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 11, it is estimated that 
14.98 % of Finland’s utilised agricultural land area is used 
for organic farming. This is among the best rates in the 
EU  and  higher  than  the  EU  average  of  10.50 % (48). 
Finland  is  contributing  more  than  the  EU  average  to 
achieving the target of 25 % of the EU’s agricultural land 
being used for organic farming by 2030. 

Figure 11:  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  Finland 
received  a  priority  action  on 
implementing  the  measures  set  out  in  its  CAP  SP, 
especially  with  regard  improving  rural  areas.  Since 

(47) 

(48) 

in  cropland  mineral  soils’  and 

The  three  indicators  are  ‘grassland  butterfly  index’,  ‘stock  of 
organic  carbon 
‘share  of 
agricultural land with high-diversity landscape features’. 
This is based on the latest available information from Eurostat, 
which 
is  currently  under  review;  European  Commission, 
Agriculture biologique au sein de l’union européenne, factsheet, 
Brussels, 
2024, 
https://agriculture.ec.europa.eu/document/download/c67458e
d-ec50-4762-ae68-341763ab93c2_fr?filename=factsheet-
organic-farning_fr.pdf&prefLang=en. 

2025 Environmental Implementation Review – Finland 

 
 
 
challenges remain in implementing these measures, the 
priority action is reiterated in this report. 

2025 priority actions 

• 

• 

• 

to 

and 

address 

practices 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
environmental needs of Finland. 
Ensure  sustainable  management  of  forests,  i.a.  by 
adopting the National Forest Programme post-2020 
and consider the conservation objectives of Natura 
2000  forest  sites  when  developing  the  National 
Forest Management Plan. 
Implement  peatland  conservation  and  restoration 
measures and include such measures and objectives 
in the national restoration plans. 

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 (49) 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 

(49) 

(50) 

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

2023, 

5 July 

final 

of 

Finland  17 

to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU  Soil Observatory, points to 
the following soil degradation issues in Finland (50). 

soil  organic 

loss  of 

carbon, 

The  greatest  contributor  to  Finland’s  unhealthy  soils  is 
peatland  degradation,  affecting  7 %  of  the  national 
territory.  19 %  of  the  affected  area  is  agricultural  land. 
6 % of Finland’s total land area is also at high or very high 
susceptibility  to  topsoil  compaction,  particularly  along 
the southern border of the country. 

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. 

In  Finland,  there  are  significant  areas  of  semi-natural 
grasslands, including several types listed in Annex I to the 
Habitats  Directive.  Grasslands  are  among  the  most 
threatened  habitat  types  in  Finland,  primarily  due  to 
changes in agricultural practices, such as abandonment, 
intensification  and  the  conversion  of  grasslands  to 
forestry. Protecting these habitats and their biodiversity 
requires active management, such as periodic grazing or 
mowing, to maintain their ecological value. 

In the latest report (covering 2013–2018) in accordance 
with  Article 17,  the  conservation  status  of  all  grassland 
habitats in the boreal biogeographical region in Finland 
was  unfavourable  to  bad,  except  for  one  habitat  type 
that  was  ranked  as  unfavourable  to 
inadequate 
(hydrophilous tall herb fringe communities of plains and 

the European Parliament and of the Council on soil monitoring 
and  resilience  (Soil  Monitoring  Law),  SWD(2023) 417  final  of 
2023, 
5 July 
https://environment.ec.europa.eu/system/files/2023-
07/IMPACT 
REPORT_ANNEXES_SWD_2023_417_part4.pdf. 

ASSESSMENT 

2025 Environmental Implementation Review – Finland 

 
 
 
 
of the montane to alpine levels) (51). The main pressures 
and threats for grassland habitats identified in the report 
include  agriculture,  natural  processes, 
forestry, 
development,  mixed-source  pollution  and  invasive  and 
problematic species. 

Baltic Sea, which is affected by eutrophication at a level 
of 97 %. Damage is caused when peatlands are drained 
for agriculture and tree planting, with peat extracted for 
fuel or horticulture. 

Finland  18 

Wetlands/peatlands 

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

In  Finland,  wetlands  and  peatlands  include  several 
habitat types listed in Annex I to the Habitats Directive. 
According  to  the  latest  report  (covering  2013–2018)  in 
accordance  with  Article 17,  the  conservation  status  of 
most of these habitats is unfavourable (52). The primary 
pressures and threats identified in the report for wetland 
and  peatland  habitats  in  Finland  include  agriculture, 
forestry, resource extraction, human-induced changes in 
regimes,  mixed-source  pollution,  natural 
water 
processes, 
and 
infrastructure development (including transport system 
expansion). 

production 

activities 

energy 

and 

Peatland 

Peatlands are unique and rare ecosystems that, despite 
only covering around 3-4% of the planet’s land surface, 
contain up to one-third of the world’s soil carbon, which 
is  twice  the  amount  of  carbon  as  found  in  the world’s 
forests. 
sustainable 
restoration 
management is highly important to both combat climate 
change  and  preserve  biodiversity.  Living  peatlands  not 
only  sequester  carbon  dioxide  (CO2)  but  also  provide  a 
healthy habitat for valuable species and remove nitrates 
from polluted agricultural run-off through denitriﬁcation. 
Peatland loss also means biodiversity loss, more floods 
and  droughts,  degraded  drinking  water  for 
local 
communities  and  eutrophication  of  open  waters.  This 
last  impact  should  be  avoided,  especially  around  the 

Forest ecosystems 

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

including  those  for  which  there 

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

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

forest  habitats,  approximately  14 %  of  EU 
For 
favourable 
biogeographical  assessments 
conservation  status (53).  The  share  of  forested  areas  in 
the  EU  with  a  bad  conservation  status  increased  from 
26 % in 2012 to 31 % in 2018. 

show  a 

In 2020, forests covered 73.7 % of Finland’s territory (54), 
and  assessments  show  that  nearly  90 %  of  its  forest 

(51) 

(52) 

(53) 

nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Grasslands&country=IE&region=. 
https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Bogs%2C+mires+%26+fens&country=FI&region=. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  2013–2018,  Publications  Office  of  the 

(54) 

Union, 

Luxembourg, 

European 
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.  

2020, 

2025 Environmental Implementation Review – Finland 

 
 
habitats  have  a  bad  or  poor  status (55).  In  Finland, 
203 000 ha is covered by primary forests (56). 

The  EU  Timber  Regulation  (EUTR) (57)  prohibits  the 
placing on the EU market of illegally harvested timber.  

Finland  19 

Figure 12:  Conservation  status  of  forests  protected 
under  the  Habitats  Directive  per  Member  State  (%  of 
assessments), 2013–2018 

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

. 

Among forest disturbances contributing to loss of forest 
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  witnessed  the 
occurrence of widespread uncontrollable fires (so-called 
megafires), which are associated with loss of life and an 
enormous cost in terms of damage to the environment, 
businesses and society (over EUR 2 billion annually) and 
carbon dioxide (CO2) emissions. Megafires are practically 
beyond suppression capacity and can be prevented only 
by  an  integrated  risk  management  approach.  Wildfires 
prevention is also essential to preserve resources for the 
bioeconomy. 

(EUDR) (58)  entered 

On  29 June  2023,  the  Regulation  on  Deforestation-free 
(59).  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 

In  the  2022  EIR,  Finland  received  priority  actions  to 
pursue  and  scale  up  efforts  to  ensure  that  forestry 
practices  take  fully  into  consideration  the  need  to 
protect  and  restore  the  conservation  status  of  forest 
habitats  and  species.  Despite  some  progress  made 
through  conservation  programmes,  significant  gaps 
remain in achieving robust protection and restoration of 
forest  habitats  and  species.  To  effectively  reverse 
biodiversity  loss,  greater  investment  and  coordinated 
actions  are  necessary  to  scale  up  these  efforts  and 
address ongoing challenges in forestry management. 

Marine ecosystems 

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

Since the 2022 EIR report, no additional data regarding 
Member  States’  set  of  GES  characteristics  for  each 
descriptor 
in  the  MSFD  have  become  available. 
Nevertheless, Member States had to report updates by 
October 2024. In the context of this round of reporting, 
in accordance with the MSFD and the Commission GES 
decision (60), Member States must include as part of their 
set  of  GES  characteristics  any  threshold  values  for  the 
descriptors in the MSFD that may have been established 
in  cooperation  with  other  Member  States  at  the  EU  or 

(55) 

(56) 

(57) 

https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Forests&country=FI&region=; 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-
summary-dashboards-archived. 
European Commission: Joint Research Centre, Mapping and 
assessment of primary and old-growth forests in Europe, 
Publications Office of the European Union, Luxembourg, 2021, 
p. 13, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC124
671. 
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  on  Deforestation-free  products 
Commission 

-  European 

(58) 

(60) 

(59)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 
Commission Decision (EU) 2017/848 of 17 May 2017 laying down 
criteria  and  methodological  standards  on  good  environmental 
status  of  marine  waters  and  specifications  and  standardised 
methods for monitoring and assessment, and repealing Decision 
(OJ  L 125,  18.5.2017,  p. 43),  https://eur-
2010/477/EU 
lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv%3AOJ.L_.2017.125.01.0043.01.EN
G&toc=OJ%3AL%3A2017%3A125%3ATOC. 

2025 Environmental Implementation Review – Finland 

 
 
 
level (61).  In 

late  December  2024,  Finland 
regional 
reported  the  data  related  to  Articles 8,  9  and  10  as 
required by Article 17 of the MSFD, which are now under 
assessment by the Commission. 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (62). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
work 
levels  of 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated programmes 
of measures, which are required under Article 13 of the 
MSFD and  which  must  be updated every  six years. The 
Commission has assessed Member States’ programmes 
of measures. 

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

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

(61) 

(62) 

(63) 

Communication  from  the  Commission  of  11 March  2024 – 
Commission notice on the threshold values set under the Marine 
Strategy  Framework  Directive  (Directive  2008/56/EC)  and 
Commission  Decision  (EU)  2017/848  (OJ  C,  C/2024/2078, 
11.3.2024), 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=OJ:C_202402078. 
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 
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 
Implementing  Regulations  (EU) 
amended  by  Commission 

Finland  20 

Finland’s  updated  programme  of  measures  shows  an 
overall good level of adequacy, although some remaining 
gaps can be noted. 

On biodiversity (D1), Finland introduced new measures 
to  reduce  species  disturbance,  particularly  for  seabirds 
and  marine  mammals  affected  by  by-catch.  New 
measures on eutrophication (D5) aim to reduce nitrogen 
and phosphorus input, while underwater noise (D11) is 
addressed  quite  comprehensively  through  well-defined 
measures including practical actions like speed limits and 
technological innovations. 

However,  measures  addressing  the  pressures  of  non-
indigenous  species  and  contaminants  in  seafood,  in 
particular, could be strengthened. 

In  the  EIR  2022  Finland  was  given  a  priority  action  to 
implement  the  recommendations  of  Member  States 
related to Articles 8, 9 and 10 of the MSFD. Finland has 
made  some  progress.  As  stated  above,  Finland  has 
reported data related to Articles 8, 9 and 10 as required 
the  MSFD.  Cooperation  with 
by  Article 17  of 
neighbouring  countries 
is  still  relevant  to  address 
predominant pressures. 

Prevention and management of invasive alien 
species 

Invasive  alien  species  (IAS)  are  a  major  cause  of 
biodiversity  loss  in  the  EU.  Besides  inflicting  direct  and 
indirect damage on nature and the economy, some IAS 
also carry and spread infectious diseases, posing a threat 
to  humans  and  wildlife.  Regulation  (EU)  No 1143/2014 
(the  IAS  Regulation)  aims  to  prevent,  minimise  and 
mitigate  the  adverse  impacts  of  IAS  on  biodiversity.  It 
focuses action on a list of IAS of EU concern (the ‘Union 
list’), which is regularly updated (63). 

The third update of the Union list (64) entered into force 
on 2 August 2022. The fourth update is in preparation. 

The IAS Regulation (65) 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 

2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update  the  list  of  invasive  alien  species  of  Union  concern  (OJ 
L 186,  13.7.2022,  p. 10),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203. 
Regulation (EU) No 1143/2014 of the European Parliament and 
of  the  Council  of  22 October  2014  on  the  prevention  and 
management  of  the  introduction  and  spread  of  invasive  alien 
species (OJ L 317, 4.11.2014, p. 35). 

(64) 

(65) 

2025 Environmental Implementation Review – Finland 

 
 
 
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 
including  through  eradication  and 
managing  them, 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (66).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (67),  and  at 
USD 423 billion annually at the global level (68). 

There are 18 IAS of Union concern in Finland, 7 of which 
are  not  encountered  in  the  wild  and  1  of  which  is 
uncertain (establishment unknown). In addition to these 
18  species,  there  are  another  6  that  have  been 
encountered only sporadically. 

The 18 species include 13 recorded in the previous EIR 
(2022)  and  5  new  additions.  Of  these  new  additions,  2 
were  already  on  the  Union  concern  list  in  2021,  and  3 
were  added  later  under  Commission  Implementing 
Regulation (EU) 2022/1203. 

(66)  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. 

(67)  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 – 

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

(Intergovernmental 

Ecosystem 

and 

(68) 

Finland  21 

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

In the 2022 EIR Finland was given a priority action to step 
up the implementation of the IAS Regulation. Finland has 
made some progress in that respect, in the form of the 
sixth national management plan to address the IAS and 
the latest updated national Act on IAS enforceable from 
January 2025. The implementation and control of IAS is 
recorded at the national level (69). Despite these actions, 
it  is  advised  to  take  further  measures  as  mentioned  in 
this report. 

2025 priority actions 

• 

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

Ecosystem assessment and accounting 

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

Similarly, target 14 of the GBF (70) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 

https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 
https://vieraslajit.fi. 

(69) 
(70)  Decision 15/4 adopted by the Conference of the Parties to the 
Convention  on  Biological  Diversity:  Kunming–Montreal  global 
framework 
biodiversity 
(https://www.cbd.int/doc/decisions/cop-15/cop-15-dec-04-
en.pdf). 

2025 Environmental Implementation Review – Finland 

 
 
 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (71). 

The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (72)  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. 

the  Finnish  ecosystem 

in  the  Esmeralda 
Finland  has  actively  participated 
project,  which  continues 
the  ecosystem  service 
assessment  work  previously  done  by  an  Economics  of 
Ecosystems  and  Biodiversity  study  for  Finland (73),  and 
has  developed 
services 
indicators –  a  national  framework  that  integrates  the 
International  Classification  of  Ecosystem 
Common 
Services and the cascade model. The Finnish biodiversity 
internet portal (74) aims to synthesise knowledge on the 
status  of  biodiversity  and  ecosystem  services,  and  to 
serve  as  the  national  resource  for  information  on  the 
Nagoya Protocol on genetic resources and the Cartagena 
Protocol on biosafety. 

increasing  number  of  platforms,  networks  and 
An 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (75). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 

(71) 

(72) 

for 

Summary 

Assessment – 

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. 
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. 

11 July 

2022, 

final 

of 

Finland  22 

assessments  among  businesses  and  financial  services 
providers. 

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

There  is  one  Finnish  sustainability  business  network 
member of the EU Business & Biodiversity Platform. 

Currently  there  is  no  official  mandate  for  ecosystem 
accounting in Finland. Methodological development for 
piloting  ecosystem  and  water  accounting  has  been  a 
bottom-up  process.  The  Eurostat  initiative  to  update 
Regulation  (EU)  No 691/2011  and  the  System  of 
Environmental–Economic 
Ecosystem 
Accounting are expected to increase demand for natural 
ecosystem  accounting  from  the  policy  side  in  Finland. 
Finland  has  developed  multiple  frameworks  and  has 
done  multiple  academic  exercises  in  natural  capital 
accounting, but there are no official accounts published 
so far. 

Accounting – 

Some  possible  challenges  for  the  development  and 
implementation of ecosystem accounts in Finland are (i) 
the  lack  of  a  mandate;  (ii)  the  difficulty  of  finding 
scientists, 
common 
between 
economists 
current 
statisticians; 
impossibility of data-based quantification of freshwater 
assets due to fully or partially missing data; and (iv) the 
necessity of refining the marine condition account. 

language 
and 

natural 
(iii) 

the 

In 2022, Finland received priority actions on developing 
harmonised  ecosystem  classification  and  ecosystem 
accounts;  progress  cannot  be  assessed  due  to  lack  of 
data. 

(73) 

(74) 
(75) 

Helsinki, 

Jäppinen, J.-P. and Heliölä, J. (eds), Towards a Sustainable  and 
Genuinely Green Economy – The value and social significance of 
ecosystem services in Finland (TEEB for Finland), Ministry of the 
Environment, 
2015, 
https://julkaisut.valtioneuvosto.fi/handle/10138/152815. 
https://biodiversity.fi. 
The  EU  Business  &  Biodiversity  Platform  (https://green-
business.ec.europa.eu/business-and-biodiversity_en)  aims  to 
promote  the  business  case  for  biodiversity  to  businesses  and 
financial institutions through workshops, seminars, reports and 
a cross-media communication strategy. 

2025 Environmental Implementation Review – Finland 

 
 
Finland  23 

3. Zero pollution

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

Finland  submitted  its  updated  national  air  pollution 
control programme (NAPCP) to the Commission on 1 June 
2023. 

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

200%

150%

100%

50%

0%

NH₃

PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

Source: EEA, ‘National air pollutant emissions data viewer 2005–2022’, 
25 June 2024, https://www.eea.europa.eu/en/topics/in-depth/air-
pollution/national-air-pollutant-emissions-data-viewer-2005-2022. 

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

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

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (79)  for  Finland  attribute  70  deaths  each  year  (or 
640 years  of  life  lost  (YLL))  to  fine  particulate  matter 
(PM2.5) (80), 50 deaths each year (or  510 YLL) to nitrogen 
dioxide (NO2) (81) and 440 deaths each year (or 4 100 YLL) 
to ozone (82). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly in Finland since 2005, while GDP growth has 
continued  (see  Figure 15).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (83)  in  2024, 
Finland has met its emission reduction commitments for 
2020–2029  for  air  pollutants  NOx,  non-methane  volatile 

(76) 

(77) 

(78) 

(79) 

(80) 

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

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

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

(82) 

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

p. 1), 

2025 Environmental Implementation Review – Finland 

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

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

Finland  24 

data, Finland has made some progress in this regard. Since 
2019, downward emission trends have been reported for 
all  main  pollutants.  However,  exceedances  above  target 
values remain for arsenic, requiring further action. 

2025 priority actions 

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

• 

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

Industrial emissions 

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

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

effects on human health and the environment; 

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

water; 

The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (86). 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 (87).  

industrial 

In  Finland,  around  1 370 
installations  are 
required  to  have  a  permit  based  on  the  IED,  with  the 
majority  of  them  in  the  waste  management  sector, 
including landfills (25 %). The other main sectors are the 
energy  sector  (23 %),  followed  by  intensive  rearing  of 
poultry and pigs (21 %) and the production and processing 
of metals (9 %). 

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 
shows  the  ratio  between  the  damage  and  the  industrial 

(OJ  L 334, 
(integrated  pollution  prevention  and  control) 
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 

(87) 

59,84%

12,26%

(iv) contribute to decarbonisation. 

PM2.5
PM2.5
0,92%

18,02%

NOₓ

0,00%

36,52%

17,11%

22,51%

1,42%

2,69%

18,89%

9,82%

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

2024, 

In  2023,  no  exceedances  above  the 
limit  values 
established  by  the  Ambient  Air  Quality  Directive 
(AAQD) (84)  were  registered  in  Finland.  However,  the 
target  values  for  arsenic  concentrations  have  not  been 
met in two air quality zones (85). 

In the 2022 EIR, Finland received two priority actions. The 
first was to further reduce emissions in the context of the 
NAPCP. Finland has made substantial progress on this as 
the  latest  reported  data  show  that  the  2020–2029 
emission reduction commitments have been met and that 
the  emission  reduction  commitments  for  2030  onwards 
are  projected  to  be  reached.  The  second  action  was  to 
ensure full compliance with EU air quality standards and 
maintain downward emission trends. Based on the latest 

(84)  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/). 

11.6.2008, 

Repository 

Central 

L 152, 

p. 1), 

Data 

(85) 

(OJ 

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

2025 Environmental Implementation Review – Finland 

 
 
 
Finland  25 

activity  (expressed  in  gross  value  added  (GVA)),  which 
gives an indication of the emissions ‘intensity’. Finland has 
relatively low damage (11th lowest damage in the EU), and 
is  below  the  EU  average  of  EUR 27.5/EUR 1 000  GVA  for 
emissions  intensity  (6th  lowest  emission  intensity  in  the 
EU). The  main industrial contributors to emissions to air 
(88) are the energy sector (including refineries, gasification 
etc.) and the metal sector. 

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

account  the  human  toxicity  of  each  metal,  as  well  as 
emissions  intensity,  based  on  its  ratio  with  industrial 
activity (expressed in GVA). Finland has the fourth highest 
amount  of  emissions  of  heavy  metals  to  water  and  is  in 
first position for emissions intensity (above the EU average 
of 0.864 kg/EUR 1 billion GVA). 

As shown in Figure 20, the main industrial contributors to 
emissions  to  water  in  Finland  are  the  pulp,  paper  and 
wood  sector  in  general  and  the  metal  sector  for  heavy 
metals. 

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

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average  in  the  EU,  they  appear  to  be  decoupled  from 
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 

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

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

Concerning  Finland  in  particular,  Figure 19  shows  the 
industrial emissions of heavy metals to water, taking into 

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

Figure 20:  Relative  releases  to  water  from  industry  in 
Finland (%), 2022 
100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human Toxicity

Total nitrogen

Total organic
carbon (TOC)

Total phosphorus

Chemicals
Extractive industry
Landfill
Other manufacturing
Refineries

Electricity and heat production
Ferrous metal
Non-ferrous metal
Pulp, paper and wood

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

13 September 

Data 

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

(88) 
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 – Finland 

 
 
 
 
 
 
 
 
 
Finland  26 

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

infringements  of 

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

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

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  the  2022  EIR,  the  Commission  gave  Finland  a  priority 
action  to  review  permits  to  comply  with  newly  adopted 
BAT conclusions; strengthen monitoring and enforcement 
to ensure compliance with BAT conclusions; and address 
challenges  in  complying  with  the  recently  adopted  BAT 
conclusions. There are no data available to assess progress 
on this priority action. 

2025 priority actions 

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

• 

intensity. 
Engage  with  industry  and  environmental  NGOs  to 
ensure proper contribution to and implementation of 
BAT conclusions and ensure timely updates to permits 
following the publication of BAT conclusions. 

• 

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

Major industrial accidents prevention – Seveso 

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

(i)  control  major-accident  hazards  involving  dangerous 

substances, especially chemicals; 

(ii)  limit  the  consequences  of  such  accidents  for  human 

health and the environment; 

(iii) continuously improve the prevention of, preparedness 

for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive (89)). 

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 (90)  and  the  report  by 
Finland on the implementation of the Seveso III Directive 
for 2019–2022 (91). 

In 2024, of the 334 Seveso establishments in Finland, 188 
are  categorised  as  lower-tier  establishments  and  146  as 
upper-tier establishments (UTEs) based on the quantity of 
hazardous substances likely to be present. The  UTEs are 
subject to more stringent requirements. The change in the 
in 
number  of  Seveso  establishments 
Figure 21. 

is  presented 

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

400

300

200

100

0

187

138

181

140

188

146

2018

2022

2024

UTE

LTE

NB: LTE, lower-tier establishment. 

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

(89)  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. 

(90) 

(91) 

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

2025 Environmental Implementation Review – Finland 

 
 
 
Finland  27 

2022, 

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

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs). These EEPs are essential to allow 
proper  preparation  and  effective  implementation  of  the 
actions  necessary  to  protect  the  environment  and  the 
population  should  a  major  industrial  accident  occur. 
According to Finland, in 2022, EEPs were required for 140 
UTEs.  Out  of them, 139 had EEPs and 137 of these EEPs 
had been tested  in  the last three years. The summary is 
shown in Figure 22. 

Figure 22: Situation regarding EEPs in Finland, 2022 

2022, 

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

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

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in the EU-27 in 2022 are presented 
in Figure 23. This provision on knowledge is an important 

provision of the Seveso III Directive, as awareness by the 
public  of 
the 
consequences of a major industrial accident. 

information  may  ameliorate 

this 

Figure 23: Share of UTEs for which information on safety 
measures and requisite behaviours were 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 
involving 
2012/18/EU  on  the  control  of  major  accident  hazards 
dangerous  substances),  Publications  Office  of  the  European  Union, 
Luxembourg, 
https://op.europa.eu/en/publication-detail/-
/publication/94d57d74-735b-11ec-9136-01aa75ed71a1/language-
en/format-PDF/source-search;  eSPIRS  data,  extractions  from  2022  and 
2024;  Analysis  and  summary  of  Member  States'  reports  on 
implementation  of  Directive  2012/18/EU  on  the  control  of  major 
accident hazards involving dangerous substances according to the format 
established  by  Commission  Implementing  Decision  2014/896/EU  - 
Publications  Office  of  the  EU,  https://op.europa.eu/en/publication-
detail/-/publication/9bd73087-e9b8-11ef-b5e9-
01aa75ed71a1/language-en. 

In July 2022, the Commission started an infringement case 
against  Finland  for  not  having  correctly  transposed  the 
directive’s  requirements  on  (i)  Seveso  establishment 
safety  reports;  (ii)  granting  NGOs  the  right  to  get 
information  on  the  establishments  in  question  and  the 
dangerous  substances  used;  and  (iii)  the  information 
in  the  establishments. 
underpinning  the 
Finland  has  notified  the  Commission  of  the  national 
transposition measures that should remedy the breaches 
identified.  The  Commission  is  currently  assessing  the 
Finnish notification and may take further action, if needed. 

inspections 

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 

2025 Environmental Implementation Review – Finland 

 
 
 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

Measures  should  have  been  put  in  place  in  Finland  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  of dental amalgam 
has  taken  place  under  the  terms  and  conditions  of  the 
regulation.  Finland  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 (92) 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 (93). 

(92)  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. 

(94) 

(93)  WHO,  Environmental  Noise  Guidelines  for  the  European  Region, 
Copenhagen, 
2018, 
https://www.who.int/europe/publications/i/item/978928905356
3. 
These figures are an estimation by the EEA based on: (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022; (ii) 
European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Indicators  under  the 
Industrial  Pollution  (ETC/ATNI),  Noise 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 

Finland  28 

In  Finland,  environmental  noise  is  estimated  to  cause  at 
least  around  190  cases  of 
ischaemic  heart  disease 
annually (94)  and  some  27 000  people  to  suffer  from 
disturbed sleep(95). 

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

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

2025 priority action 

•  Complete  and  implement  action  plans  on  noise 

management. 

Water quality and management 

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

Water Framework Directive 

The Water Framework Directive (96) is the cornerstone of 
EU  water  policy (97).  This  and  other  water-related 
directives (98) 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 

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, 

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

(96) 

(97) 
(98) 

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 
https://environment.ec.europa.eu/topics/water_en. 
These 
(https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32006L0118), 
the  Environmental  Quality  Standards  Directive  (https://eur-
Directive 
lex.europa.eu/eli/dir/2008/105/oj), 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32007L0060), the Bathing Water 

the  Groundwater  Directive 

include 

Floods 

the 

2025 Environmental Implementation Review – Finland 

 
 
  
 
Finland  29 

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

status/potential  of 

surface 

Lack of progress since the second RBMP is mainly due to 
diffuse  pollution  from  agriculture  and  forestry  that  has 
remained high. Furthermore, Finland also faces challenges 
in addressing hydromorphological alterations. 

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

further  deterioration  and  restoration  to  good  status. 
These  objectives  are  very 
important  for  the  EU’s 
competitiveness,  strategic  autonomy  and  security,  yet 
have become even more challenging in the face of climate 
change affecting our precious water resources. 

The Water Framework Directive establishes a procedural 
framework for reaching good surface water ecological and 
chemical  status  and  good  groundwater  quantitative  and 
chemical status. This implies monitoring and classification 
of all waterbodies, assessment  of pressures and impacts 
and identification of the most cost-effective measures to 
achieve the objectives of the directive. The directive dates 
from 2000 and set an initial deadline of 2015 for achieving 
its objectives, with the option to extend the deadline to 
the  end  of  2027.  Every  six  years,  Member  States  must 
report their river basin management plans (RBMPs) to the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 202599. 

Finland’s  eight  river  basin  districts  count  6 876  surface 
waterbodies and 3 918 groundwater bodies. Only 2 % are 
highly  modified  waterbodies  and  0.6 %  are  artificial 
waterbodies. 

in 

the 

show 

change 

Figures 24–27 
ecological 
status/potential and of chemical status of surface waters, 
and the quantitative and chemical status of groundwater 
in  2010,  2015  and  2021.  Heavily  modified  water  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  RBMP  that 
74.6 %  of  surface  waterbodies  in  Finland  are  in  good  or 
better  ecological  status/potential,  which  is  only  a  slight 
increase compared with the second RBMP. On the other 
hand, 100 % of surface waterbodies are failing to achieve 
good  chemical  status,  compared  with  about  50 %  in  the 
second RBMP. 

the 

Treatment 

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

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

Drinking  Water 

Directive 

the 

the 

(in 

from 

ethers 

diphenyl 

transport) 

long-range 

and 
100 % 

Failure to achieve good status is largely due to mercury (in 
50 %  of  waterbodies,  mainly  through  atmospheric 
to 
deposition 
polybrominated 
of 
waterbodies).  A  few  other  substances,  including  nickel, 
cadmium,  polycyclic  aromatic  hydrocarbons,  tributyltin 
and  perfluorooctane sulphonate, are also causing failure 
to  achieve  good  status,  but  in  a  small  proportion  of 
waterbodies. The significant deterioration compared with 
the second RBMP may be (in part) explained by improved 
monitoring  and  assessment 
the 
inclusion/assessment  of  polybrominated  diphenyl  ethers 
in  biota,  which  provides  a  more  accurate  picture  of  the 
chemical status. 

techniques  and 

(https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32008L0056) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010L0075). 

and 

the 

IED 

99 

https://webgate.ec.europa.eu/circabc-

ewpp/ui/group/c04f478b-d4dc-44f9-a211-
087c01165b2c/library/faada4be-9fc3-4a48-b972-
f71e356019d5?p=1&n=10&sort=modified_DESC    

2025 Environmental Implementation Review – Finland 

0%20%40% 0% 0%100%1st2nd3rdS B chemical status for FIGoodFailing to achieve goodUnknown 
 
 
 
Figure 26: Quantitative status of groundwater bodies  in 
each RBMP cycle (%) 

conservation;  remediating  contaminated  land;  reducing 
road and rail transport run-off; and maintaining reservoirs. 

Finland  30 

In  2024,  the  Commission  started  an  infringement  case 
against  Finland  for  incorrect  transposition  of  the  Water 
Framework  Directive (100).  Indeed,  in  Finland,  periodic 
reviews do not fully conform  to the requirements of the 
control  measures  for  different  types  of  water  use  as  set 
out in the Water Framework Directive. 

2025 priority actions 

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

• 

• 

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

•  Reduce  pollution  from  nutrients,  chemicals,  metals 

and saline discharges. 

•  Better justify exemptions to the achievement of good 

• 

status. 
Improve  the  classification  of  water  bodies  and 
strengthen monitoring systems. 

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

financing 

Floods Directive 

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

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

The  second  FRMPs  have  improved  insofar  as  they  set  a 
time  frame  for  their  objectives  and  a  clear  connection 
between objectives and measures. 

2025 priority actions 

• 

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

All  groundwater  bodies,  except  for  two,  are  in  good 
quantitative  status.  Water  quantity  is  not  a  problem  for 
recharging groundwater bodies. 

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

Pollutants affecting groundwater bodies include chloride, 
nitrates,  pesticides,  solvents  (e.g.  trichloroethylene), 
polycyclic  aromatic  hydrocarbon  compounds  (derived 
from  burning  fossil  fuels,  waste  or  other  organic 
substances)  and  methyl  tert-butyl  ether  (a  gasoline 
additive). There still is a small percentage of groundwater 
bodies with unknown chemical status. 

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

In  this  context,  a  positive  note  is  that  the  third  RBMP 
provides  both  mandatory  and  additional  measures, 
prioritised on the basis of cost-effectiveness assessment, 
aimed at reducing nutrient pollution from agriculture and 
forestry;  reducing  untreated  sewage  release;  restoring 
biodiversity, including fish migration routes; soil moisture 

(100) 

INFR(2024)2196. 

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
 
•  Better  explain  the  choice  and  implementation  of 
protection  measures 
and 

flood 
(prioritisation, monitoring, costs of measures). 

prevention 

Drinking Water Directive 

The  objectives  of  the  Drinking  Water  Directive  are  to 
protect human health by ensuring the quality intended for 
human  consumption  and  to  improve  access  to  drinking 
water. 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (101), (ii) a methodology for measuring microplastics 
in drinking water (102) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (103). 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  Finland  does  not  give  rise  to 
concern (104). 

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

Bathing Water Directive 

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

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

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

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

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

(103)  OJ L, 

2024/369, 

Finland  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  304  Finnish 
bathing waters, 265 (87.2 %) were of excellent quality, 21 
were  of  good  quality  (6.9 %)  and  9  were  of  sufficient 
quality (3 %), while 5 bathing waters were found to be of 
poor quality (1.6 %). 

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

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

in  2023,  briefing 
2024, 

Copenhagen, 

Nitrates Directive 

The  Nitrates  Directive (105)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

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

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 Finland 
was at least 99.56 % in 2017, 99.63 % in 2018 and 99.58 % in 2019. 

(104) 

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

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

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
a good supply of drinking water. Nevertheless, excessive 
fertilisation remains a problem in many parts of the EU. 

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

Finland  32 

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

important  pressure 

The  report  on  the 
Directive covering 2020–2023 will be available in 2025. 

implementation  of  the  Nitrates 

2025 priority action 

• 

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

Urban Wastewater Treatment Directive 

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

Overall, in Finland, the compliance rate was 97 % in 2020. 
Seven  agglomerations,  generating  191 700  population 
equivalent of urban waste water, did not comply with the 
requirements of the directive. 

Source:  European  Commission:  Directorate-General  for  Environment, 
Fribourg-Blanc,  B.,  Dhuygelaere,  N.,  Berland,  J.  and  Imbert,  F.,  12th 
technical  assessment  of  UWWTD  implementation  –  Final  version, 
Publications 
2024, 
the 
https://data.europa.eu/doi/10.2779/318637 

European 

Union, 

Office 

of 

The directive has been revised (106). The revised directive 
builds  on  the  current  acquis  to  strengthen  existing 
treatment 
standards  and  establish  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.  Finland  has  until  31 July  2027  to  transpose  the 
new directive into its national legal system. 

In  the  2022  EIR,  the  Commission  gave  Finland  a  priority 
action to complete the implementation of the UWWTD for 
all  agglomerations  by  building  up 
the  necessary 
infrastructure.  However,  despite  some  progress  made, 
Finland has not fully implemented the UWWTD. 

2025 priority action 

• 

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

Chemicals 

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 (107), 

(106)  Directive (EU) 2024/3019 of the European Parliament and of the 
Council  of  27 November  2024  concerning  urban  wastewater 
treatment 
12.12.2024), 
http://data.europa.eu/eli/dir/2024/3019/oj. 

2024/3019, 

(OJ 

L, 

(107)  Communication 

the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  Chemicals 

the  Commission 

from 

to 

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
which  led  to  some  systemic  changes  in  EU  chemicals 
legislation. The strategy is part of the EU’s zero pollution 
ambition –  a  key  commitment  of  the  European  Green 
Deal. 

The  EU’s  chemicals  legislation (108)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (109)  on  the 
implementation 
these 
regulations (110).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably  in  the  area  of 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because: (i) enforcement authorities  are becoming more 
effective in detecting non-compliant products/companies; 
and (ii) more non-compliant products are being placed on 
the EU market. 

of 

In August 2021, the Commission published a measurable 
assessment  of the enforcement (111) 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 

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

(108)  Namely,  Regulation 

(EC)  No 1907/2006  of  the  European 
Parliament  and  of  the  Council  of  18 December  2006  concerning 
the  registration,  evaluation,  authorisation  and  restriction  of 
chemicals  (REACH),  establishing  a  European  Chemicals  Agency, 
amending Directive 1999/45/EC and repealing Council Regulation 
(EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as 
well as Council Directive 76/769/EEC and Commission Directives 
91/155/EEC,  93/67/EEC,  93/105/EC  and  2000/21/EC  (OJ  L 396, 
30/12/2006, 
https://eur-lex.europa.eu/legal-
content/en/TXT/?uri=CELEX%3A32006R1907; and Regulation (EC) 
No 1272/2008 of the European Parliament and of the Council of 
16 December  2008  on  classification,  labelling  and  packaging  of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
No 1907/2006 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 

p. 1), 

Finland  33 

new entries have been added to Annex XVII to the REACH 
Regulation (112). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (113).  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 (114).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

Responsibility  for  checking  compliance  with  the  REACH 
Regulation in Finland lies with the following authorities: 

• 

Finnish Safety and Chemicals Agency (also responsible 
for CLP Regulation compliance), 

•  Occupational  Safety  and  Health  Administration 

(under the Regional State Administrative Agencies), 

•  Centres  for  Economic  Development,  Transport  and 

the Environment, 
Finnish Customs, 
Finnish Defence Forces, 
Finnish Medicines Agency. 

• 
• 
• 

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

(110) 

the 

European 

(111)  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/. 
(112)  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, 

(113)  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) 

(114)  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. 

2025 Environmental Implementation Review – Finland 

 
 
Finland has drawn up and fully implemented enforcement 
strategies for both the REACH and CLP Regulations (115). 

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

Finland  34 

The  Member  States’  reporting  exercise  set  out 
in 
Article 117 of the REACH Regulation and Article 46 of the 
CLP Regulation is conducted every five years. The results 
of  the  coming  one  are  expected  in  2025,  hence  the 
absence  of  new  country-specific  data  on  enforcement 
since 2022. 

In  2022,  in  Finland,  seven  staff-years  were  allocated  for 
both  REACH  and  CLP  Regulations  (and  other  chemicals 
regulations  and  market  surveillance),  as  were  6–7  staff-
in  customs  authorities  for  REACH  Regulation 
years 
checks (116).  There  were  nearly  7 000  REACH  checks  in 
2019 alone, and more than 33 000 in the entire reporting 
period.  Most  REACH  checks  are  proactive  (inspections) 
rather  than  reactive  (i.e.  investigations  in  response  to 
complaints, accidents and referrals). The high rate of non-
compliance  cases  found  during  these  checks  should  be 
emphasised (117). 

in  an  EU-coordinated 
In  2020,  Finland  participated 
enforcement  project  on  products  sold  online,  called  the 
REACH-EN-FORCE (REF)-8 project (118). The project report 
was released in November 2021, so it could not be taken 
into account in the previous EIR. 

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

(115)  European Commission, Technical assistance to review the existing 

(117)  European Commission, Technical assistance to review the existing 

Member States reporting questionnaire under Articles 117(1) of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European Union, Luxembourg, 2020, p. 76, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

(116)  European Commission, Technical assistance to review the existing 

Member States reporting questionnaire under Articles 117(1) of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European Union, Luxembourg, 2020, p. 75, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Member States reporting questionnaire under Articles 117(1) of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European Union, Luxembourg, 2020, pp. 87–88, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

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

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – Finland 

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

Finland  35 

Finland is therefore encouraged to further engage in the 
activities  of 
European  Chemicals  Agency’s 
Enforcement  Forum  for  Exchange  of  Information  on 
Enforcement. 

the 

In 2022, Finland received a priority action related to the 
upgrade of administrative capacities for the implementation 
and enforcement of the REACH and CLP Regulations. In the 
absence of formal reporting since 2022, no progress has 
been  assessed,  hence  this  priority  action  is  reiterated  in 
this report. 

2025 priority actions 

• 

• 

Finland’s  participation 
coordinated 
in 
enforcement project was around the EU average, which is 
rather low because of the lack of involvement of certain 
large Member States. 

the  REF-8 

•  Upgrade 

the 

capacities 

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

including 

in 

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
 
Malta  36 

4. Climate action 

its  determination 

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

first-ever  European 

climate 

the 

Over the last three decades, since 1990, the EU has 
achieved steady decreases in its emissions, reaching 
a  running  total  in  2022  of  – 32.5 % (119).  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  Finland  increased  by  4%, 
making it one of the countries with a net increase. 

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 
regulation  for  Land  Use,  Land  Use  Change  and 
Forestry (120).  The  package  has  been  fully  adopted, 
and the Member States have been implementing the 
legislation. 

The  key  strategic  document  at  country  level  is  the 
National  Energy  and  Climate  Plan  (NECP) (121). 
Finland submitted its updated plan  in June 2024 in 
line with the deadline set by the Regulation on the 
Governance  of  the  Energy  Union  and  Climate 
Action122.  The  European  Commission  assessed  the 
plan  and  the  extent  to  which  Finland  has  followed 
the  recommendations  for  the  draft  version.  The 
findings from the assessment are: 

• 

• 

• 

• 

Emissions  under  the  Effort  Sharing  Regulation 
will decrease by 45% in 2030 compared to 2005, 
and Finland will have to use flexibilities to meet 
its target of 50%. 
The  latest  projections  show  a  gap  to  the  Land 
Use,  Land-Use  Change  and  Forestry  (LULUCF) 
Regulation  target,  meaning  that  current  levels 
of removals have been insufficient.  
Finland is in line with its target for the share of 
renewable energy. 
Finland did not provide its energy consumption 
contribution, and thus it is not possible to assess 
its progress. 

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

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

(120)  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. 

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

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

the Energy Union and Climate Action. 

 Environmental Implementation Review 2022 – Malta 

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

the industry sectors. This has resulted in an overall 
reduction of 51 % since 2013. 

Finland  37 

 On  25 January  2024,  the  Commission  started  an 
infringement case against Finland for failing to fully 
transpose  previous  revisions  of  ETS  directive (124) 
into national law. Finland has since notified partial 
transposition of either one or both revisions to the 
the  absence  of  a  complete 
Commission. 
transposition,  the  Commission  may  decide  to  take 
the case further. 

In 

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 (125).  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. 
Finland did not communicate full transposition into 
national law by this deadline. For this reason, on 25 
July  2024,  the  Commission  opened  infringement 
proceedings against Finland. 

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

The  monitoring 

and 

Effort sharing 

The Effort Sharing Regulation (ESR) (126) covers GHG 
emissions  from  domestic  transport  (excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture, 
small  industry  and  waste.  Emissions  from  these 
sectors  account  for  around  60 %  of  the  EU’s 
domestic emissions. The regulation sets the EU-wide 
target  to  reduce  emissions  from  the  effort  sharing 
sectors  by  40 %  by  2030  compared  to  2005  levels. 
This  overall  target  for  the  EU  translates  to  binding 
for  each 
national  emission  reduction  targets 
Member State. Finland‘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. 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG 
emissions cost-effectively across all Member States. 
It  is  the  world’s  biggest  carbon  market,  covering 
around  40%  of  the  EU’s  total  GHG  emissions  from 
electricity  and  heat  generation,  the  manufacturing 
industry,  aviation  within  Europe (123)  and,  from 
2024, maritime transport also. 

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

The emissions under the ETS decreased by 54% from 
2005 to 2023. 

In  2023,  32 %  of  greenhouse  gases  emitted  by 
Finland’s  ETS 
from  power 
installations  came 
generation, less than the EU average (57 %). Of the 
total emissions from all industry sectors, the metals 
industry emitted 43 %, refineries 26 %, and cement 
and lime production 10 %. 20 % of emissions came 
from other industries. Between 2019 and 2023, the 
power generation sector reduced emissions by 57 %, 
while  the  industry  sectors  decreased  emissions  by 
13 %.  Since  2013,  greenhouse  gas  emissions  have 
declined by 74 % in power generation and by 17 % in 

(123)  Flights between the EU Member States including 

departing flights to Norway, Iceland, Switzerland and the 
United Kingdom. 

(124)  Directive  (EU)  2023/959  (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32023L0959)  and  Directive 
(EU) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32023L0958). 

2023/958 

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

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

2025 Environmental Implementation Review – Finland 

 
 
 
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  Finland  is  on  track  to  achieve  its  2030 
ESR target. Nevertheless, excess of emissions in the 
LULUCF  sector  automatically  reduces  ESR  annual 
in  2021–2025 (127).  Based  on 
emission 
available  data,  Finland  may  struggle  to  stay  within 
these limits each year in this period. 

limits 

Projected gap is 4.8 percentage points to the 2030 
target. 

The  largest  contributor  is  the  domestic  transport 
sector, which accounted for 36 % of all effort sharing 
emissions in 2022. 

Finland’s shift to sustainable transport is taking off 
but  has  not  yet  gained  full  momentum.  In  2022, 
battery electric vehicles accounted for 1.3 % (same 
as  the  EU  average)  of  Finland’s  passenger  vehicle 
fleet.  Its  9  000  publicly  accessible  charging  points 
provided one charging point for every 16 e-vehicles, 
below  the  EU  average  of  1:10.  Passenger  cars 
accounted  for  87 %  of  the  distances  travelled  by 
passengers (above the EU average of 85 %). Freight 
is  predominantly  transported  by  road,  with  roads 
accounting for 73 % of tonnes transported (close to 
the EU average of 75 %). At 27 %, rail is used more 
for transporting freight than the EU average (17 %). 
57 % of the rail network is electrified which is close 
to EU average of 56 %. 

Finland has good-quality building stock overall and 
the lowest building emissions (per floor area) in the 
EU.  Building  accounted  for  16 %  of  effort  sharing 
emissions. 

Finland  38 

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

Land use, land-use change and forestry 

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

Finland’s net  removals  have decreased  since  2015, 
resulting  in  worryingly  large  net  emissions  in  2021 
and 2022. 

Finland‘s target in 2030 is to enhance land removals 
by  an  additional  – 2.9  Mt  of  CO2  equivalent 
compared to the yearly average of the period 2016–
2018. The latest projections show a gap to target of 
1.2 Mt of CO2 equivalent in 2030. Therefore, Finland 
needs to apply additional measures to reach its 2030 
target. 

Adaptation to climate change 

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

(127)  See  Article 9(2)  of  Effort  Sharing  Regulation,  Regulation 
(EU) 
(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2018.156.01.0026.01.
ENG).https://eur-lex.europa.eu/legal-

2018/842 

content/EN/TXT/?uri=uriserv:OJ.L_.2018.156.01.00
26.01.ENG 

2025 Environmental Implementation Review – Finland 

 
 
 
Finland has one out of three regions identified as a 
hotspots  of  climate  risks  most  affected  by  climate 
change – low-lying coastal regions (128). 

and 

risks 

vulnerabilities 

Finland  adopted  its  national adaptation  strategy  in 
2005 and in 2022 adopted the climate act and a new 
national  adaptation  plan  for  2030.  The  new 
assessment  of 
is 
comprehensive  and  covers  all  major  sources  of 
climate  risk,  including  floods,  drought,  heatwaves 
and  forest  fires.  Finland  is  taking  a  multitiered 
approach  to  climate  adaptation,  involving  a  broad 
range  of  policymakers  and  stakeholders,  and 
harnessing  scientific  and  technological  advances. 
The  national  strategy  for  climate  adaptation  spans 
sectors such as flood and drought risk management, 
healthcare, social welfare and transportation. Water 
management  requires  particular  attention,  as 
floods,  heat  and  drought  can  disrupt  energy 
production.  There  is  no  notable  climate  protection 
gap in Finland. 

Finland  received  five  priority  actions  regarding 
climate  action  in  the  2022  EIR.  Finland  has  made 
significant progress towards the 2030 EU targets for 
energy  efficiency.  Finland’s  grid  development 
continues  to  be  driven  by  the  need  to  further 
strengthen  the  weak  connections  with  the  rest  of 
the  Nordic  synchronous  system  and  connect  the 

(128)  EEA, European Climate Risk Assessment, Publications Office 
2024, 

European  Union, 

Luxembourg, 

the 

of 

Finland  39 

production of renewables in the region. The first EU 
list  of  projects  of  common  interest  (PCIs)  and 
projects  of  mutual  interest  (PMIs)  include  two 
connections to Sweden and one to Estonia. On the 
other hand, Finland needs to increase its efforts in 
electrification of transport. There is some progress, 
but the share of electric car fleet or electrified rails 
remains on average. 

Finland’s  share  of  renewable  energy  sources  is 
growing  steadily,  and  Finland  will  likely  achieve  its 
target. Finland also has made significant progress in 
the 
in 
deployment of renewables. 

to  accelerate 

implementing 

reforms 

None of the reported measures include any further 
updates  or  additions  to  sustainability  criteria  of 
biomass  beyond  what  is  already  in  place  from 
previous reporting obligations. 

2025 priority actions 

• 

Implement  all  polices  and  measures  that  are 
needed  to  achieve  targets  laid  down  in  the 
Effort  Sharing  Regulation  (ESR)  and  the  Land 
Use  and  Land-Use  Change  and  Forestry 
(LULUCF)  Regulation.  More  detailed  priority 
actions are set out in the assessment of the final 
National Energy and Climate Plan (NECP)(129).  

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

(129)   National energy and climate plans. 

2025 Environmental Implementation Review – Finland 

 
 
Finland  40 

Part II: Enabling framework – implementation tools 

5. Financing 

The  EU  budget  supports  climate  investment  in  Finland 
with  significant  amounts  in  the  2021–2027  period,  with 
revenues  from  the  ETS  also  feeding  into  the  national 
budget.  During  2020–2022,  Finland’s  revenues  from 
auctioning reached EUR 1 141 million in total, with all of it 
spent on climate and energy. 

In  addition,  the  annual  investment  needed  to  meet  its 
environmental  objectives 
in  the  areas  of  pollution 
prevention and control, the circular economy and waste, 
water protection and management, and biodiversity and 
ecosystems is estimated to be EUR 8.7 billion per year in 
Finland. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 2.5 billion per year; thus, there is a 
gap of EUR 6.2 billion per year. 

the 

annual 

gap, 
environmental 
Of 
EUR 4.7 billion  concerns  biodiversity  and  ecosystems, 
0.9 billion  pollution  prevention  and  control,  0.5 billion 
circular economy and 0.2 billion the water objective. 

investment 

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 (130). 

In  Finland,  the  EU  cohesion  policy  (considering  the  EU 
contribution  amount)  provides  EUR 816 million 
for 
climate action in 2021–2027 (with around  a third  of this 

via  the  ERDF),  with  a  further  EUR 39 million  from  the 
European Maritime, Fisheries and Aquaculture Fund (131). 

The  RFF  contributes  to  climate  finance  in  Finland  with 
EUR 1.02 billion  up  to  2026,  representing  52.3 %  of  the 
RRP (132). 

(EIB)  provided 
Investment  Bank 
The  European 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid  2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 2.1 billion was assigned to 
Finland in the reference period (133). 

National financing, including EU emissions trading 
system revenues 

to  EUR 221 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
in  2020, 
budgets,  amounted 
EUR 409 million  in  2021  and  EUR 511 million  in  2022  in 
Finland,  totalling  EUR 1 141 million  in  the  three-year 
period.  In  Finland,  revenues  are  not  earmarked  and  the 
national spending on climate and energy totals more than 
100 %  of  auctioning  revenues.  Only  a  part  of  actual 
spending  has  been  reported,  in  some  years  covering 
specific projects and in other years covering up to 100 % 
of revenues, even though this funding cannot be directly 
linked to the auctioning revenues (134). 

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

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (135). 

therefore, 

and, 

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

European  Union, 

Luxembourg, 

2024, 

(131)  See 

the 

Cohesion 

Open 

Data 

Platform 

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

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

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

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

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

(134)  European  Commission:  Directorate-General 

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

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

2025 Environmental Implementation Review – Finland 

 
 
 
Environmental financing and investments 

This section describes Finland’s investment needs, current 
financing  and  gaps  as 
four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (136). 

relate 

they 

the 

to 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient  to  enable  Finland  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 8.7 billion per year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 5 billion  per  year,  can  be  attributed  to  the  need  to 
support  biodiversity  and  ecosystems,  with  a  further 
EUR 1.7 billion  needed  for  pollution  prevention  and 
control,  EUR 1.5 billion  for  the  circular  economy  and 
EUR 0.4 billion for water (in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 2.5 billion  in  Finland  from  EU  and  national 
sources combined (in 2022 prices). 

(c) 

(d) 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 2.1 billion for Finland in total, during 2021–2027 (or 
EUR 296.9 million per year). 

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

Instrument 

Cohesion policy 
ERDF 
Just Transition Fund 

CAP 
European 
Guarantee Fund 

Agricultural 

Allocations 

259.6 (a) 
185.2 
74.4  
1 158.3 (b) 
530.2 
628.2 

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

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

Finland  41 

European  Agricultural  Fund 
for Rural Development 

European 
Maritime, 
Fisheries  and  Aquaculture 
Fund 

Other MFF 

RRF (d) (2021–2026) 

29.3 

631.1 (c) 

501.9 

(a) 

(b) 

Fund. 

Source 

further 

European  Commission,  2021-2027  cohesion  policy  (planned) 
allocations in EU amount excluding national co-financing, based on 
the  tracking  in  the  Common  Provisions  Regulation  (CPR,  2021) 
Annex I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its  publication  date.  Note  that  Finland  is  not  eligible  for  the 
information: 
and 
Cohesion 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data  
Regulation (EU) 2021/2115 of the European Parliament and of the 
Council  of  2 December  2021  establishing  rules  on  support  for 
strategic  plans  to  be  drawn  up  by  Member  States  under  the 
common agricultural policy (CAP strategic plans) and financed by 
the  European  Agricultural  Guarantee  Fund  (EAGF)  and  by  the 
European  Agricultural  Fund  for  Rural  Development  (EAFRD)  and 
repealing Regulations (EU) No 1305/2013 and (EU) No 1307/2013 
(OJ 
https://eur-
p. 1), 
lex.europa.eu/eli/reg/2021/2115. 
Note that 2021-2027 combines factual data for 2021 and 2022 and 
expenditure  under  the  relevant  specific  objectives  (SOs)  of  the 
CAP strategic plans from 2023, using the EU biodiversity tracking 
methodology  (https://commission.europa.eu/system/files/2023-
06/Biodiversity%20tracking%20methodology%20for%20each%20
programme%202023.pdf). Source: European Commission.  
Space  Fund,  Horizon  Europe,  financial 
environment and the Connecting Europe Facility. 
Outside  the  MFF.  Note  that  the  RRF  applies  a  similar 
environmental tracking scheme (set in the RRF Regulation, Annex 
VI)  as  the  EU’s  cohesion  policy.  RRF  dataset  version  used:  July 
2024, prior to 2025 revisions. Data source: European Commission. 

instrument  for  the 

6.12.2021, 

Annex XI, 

L 435 

Finland,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
instrument  for  the  environment  (LIFE) 
the  financial 
(EUR 5.4 billion) (137),  Horizon 
programme 
Europe 
(EUR 95.5 billion) (138),  the  Connecting  Europe  Facility 
(EUR 33.7 billion) (139)  and  funds  that  can  be  mobilised 
through the InvestEU programme (140). 

Finland’s RRP supports climate objectives through funding 
of  EUR 1.02 billion  (52.3 %  of  total),  with  an  additional 
EUR 0.01 billion (0.5 % of total) for the environment. 

(139)  The  Connecting  Europe  Facility 

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

(Transport)  also 

(140)  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 – Finland 

 
 
 
Finland  42 

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

The EIB provided around EUR 588 million in environment-
related financial contributions to Finland from 2021 to mid 
2024,  most  of  which,  EUR 440 million  (75 %),  was  in  the 
area  of  sustainable  energy,  transport  and  industrial 
projects,  which  provides  significant  co-benefits  to 
reducing  air  pollution,  environmental  noise  and  other 
pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2 % of EU-27 GDP. In Finland, the 
total national environmental protection expenditure was 
EUR 4.1 billion 
in  2021, 
representing 1.7 % and 1.9 % of GDP, respectively. 

in  2020  and  EUR 4.8 billion 

Of  the  total  environmental  expenditure,  the  national 
(investment)  on  environmental 
capital  expenditure 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
In  Finland,  the  national 
0.4 %  of  the  EU’s  GDP. 
reached 
environmental 
EUR 561 million in 2020, rising to EUR 806 million in 2021, 
representing around 0.2–0.3 % of GDP. 

investment 

protection 

Broken  down  by  institutional  sector,  4 %  of  Finland’s 
national  environmental  protection  investment  (capital 
expenditure) comes from the general government budget, 
with 60 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  36 %  from  the  general  business 
sector,  whose  environmental  activities  are  usually 
ancillary  to  its  main  activities.  At  the  EU  level,  38 %  of 
from 
environmental  protection 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (141). 

investment  comes 

from 

Finland’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 2.5 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funds  (including  EIB  funds)  reaches  22 %,  with  around 
78 % national financing. The total public financing (EU plus 
national public) represents 25 % 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 6.2 billion 
per  year  in  Finland,  representing  around  2.32 %  of  the 
national GDP, being higher than the EU average (0.77 %). 

Source: Analysis of Directorate-General for Environment. 

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

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

Environmental 
objective 

Investment gap per year  

Million 
EUR (2022 
prices) 

 % of 
total 

% of GDP 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

871 

14.1 

0.33 

454 

7.3 

0.17 

198 

3.2 

0.07 

4 669 

75.4 

1.75 

Total 

6 191 

100.0 

2.32 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In pollution prevention and control, Finland’s investment 
needs  are  estimated  to  reach  EUR 1.7 billion  per  year 

(141)  Eurostat, 

’Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

 2025 Environmental Implementation Review – Finland 

 
 
 
to 

reduce 

(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 1.4 billion,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
reach 
needs 
EUR 400 million per year, most of which is delivered by the 
(same) sustainable energy and transport investments that 
also  benefit  clean  air (142).  Industrial  site  remediation 
year. 
requires  an  estimated  EUR 49 million  per 
Microplastics pollution and the chemicals strategy require 
around EUR 30–40 million per year (each) (143). 

environmental 

noise 

Current investments 

investment 

The  current 
levels  supporting  pollution 
prevention and control reach an estimated EUR 306 billion 
per  year  in  Finland  in  2021–2027.  Most  of  the  financing 
concerns clean air  (EUR 170 million per year). Protection 
from environmental noise receives around EUR 30 million 
per  year,  with  a 
for  site 
remediation. 

further  EUR 34 million 

In Finland, the EU MFF provides an estimated 11.4 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further  15.7 % from the RRF, adding up to 27.1 % of the 
total.  EIB  financing  contributes  19.4 %  and  national 
sources reach 54 % (144). 

The gap 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  Finland 
needs  to  provide  an  additional  EUR 1.4 billion  per  year 
(0.33 % of GDP), mostly related to clean air and noise. The 
adequate  implementation  of  the  national  climate  and 
energy  plan  (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. 

(142)  2021 

assessment 

Phenomena 

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

Environmental 

Noise 

2023 

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

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

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

Finland  43 

According to the latest (2023) NAPCP review report (145), 
Finland complied with ammonia reduction requirements 
in 2020 and 2021, while it is at low risk of non-compliance 
with  ammonia  concerning  the  NECD’s  2030  emission 
reduction  commitments,  based  on  the  policies  and 
measures  in  its  NAPCP  that  take  into  account  climate, 
energy and CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

Finland’s  investment  needs  in  the  circular  economy  and 
waste  reach  EUR 1.5 billion  per  year  (including  baseline 
investments).  Most  of  this,  around  EUR 1.1 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
for  waste  management 
EUR 0.4 million  necessary 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (146). 

Current investments 

Circular economy investments across the economy reach 
around EUR 722 million per year in Finland in 2021-2027, 
with  a  further  EUR 299 million  provided  for  waste 
management that does not constitute circular economy. 

Around 1.8 % of this combined financing for circularity and 
waste comes from the EU MFF, with a further 1.8 % from 
the  RRF,  adding  up  to  3.6 %  of  the  total.  EIB  loans 
identified  in  support  of  circularity  and  waste  represent 
1.9 % of the total. The share of national sources reaches 
95 % of the total financing (147). 

https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(145)  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.  

(146)  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. 

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

 2025 Environmental Implementation Review – Finland 

 
 
The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Finland  needs  to  increase 
investments  by  an  estimated 
circular  economy 
EUR 397 million 
additional 
EUR 56 million concerning waste management action, not 
belonging to circular economy. Combined, this amounts to 
EUR 454 million per year, representing 0.17 % of Finland’s 
GDP. 

year,  with 

per 

an 

Of  the  circular  economy  gap,  EUR 104 million  relates  to 
recent  initiatives,  such  as  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and EUR 293 million constitutes further investment need 
to unlock Finland’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 443 million (in 2022 prices) in Finland. This comprises 
investment needs both for the water industry and for the 
protection and the management of water. The largest part 
of  the  total  annual  need,  EUR 338 million,  relates  to  the 
management  of  wastewater  (also  including  additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 12 million  is  necessary  for  drinking-water-related 
investments and around EUR 84 million for the protection 
and management of water (148). 

Current investments 

Water investments in Finland are estimated to be around 
EUR 245 million per year (in 2022 prices) in 2021–2027. Of 
this,  EUR 194 million supports wastewater  management, 
EUR 4 million  drinking  water  and  around  EUR 43 million 
the  other  aspects  of  the  Water  Framework  Directive 
(water management and protection). 

Of  the  total  financing,  3.1 %  is  provided  by  the  EU  MFF 
(mostly  through  cohesion  policy),  with  a  further  0.2 % 

(148)  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. 

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

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

frameworks’, 

Commission 

European 

Finland  44 

from  the  RRF,  reaching  3.3 %  combined.  The  bulk  of 
financing comes from national sources (96.7 %) (149). 

The gap 

To  meet  the  various  environmental  targets  under  the 
Water  Framework  Directive  and  the  Floods  Directive, 
Finland’s  water  investment  gap  reaches  EUR 198 million 
per  year  (0.07 %  of  GDP),  with  most  of  it  related  to 
wastewater  (EUR 144 million  per  year).  Drinking  water 
measures require an additional EUR 8 million per year and 
the  other  aspects  of  the  Water  Framework  Directive 
around EUR 42 million per year over the existing levels of 
financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 5.1 billion per year (in 2022 prices) in 
Finland 
includes  the  following 
financing needs: 

in  2021–2027.  This 

• 

• 

• 

action 

prioritised 

framework (150), 
Finland’s 
concerning the Natura 2000 areas: EUR 862.4 million 
per year, mostly running costs; 
additional BDS costs (151): EUR 2.8 billion on top of the 
framework; 
sustainable  soil  strategy  management  costs (152): 
EUR 1.4 billion per year. 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 384 million per year (in 2022 prices) in 2021–2027. 
81.7 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

0.2 % of the total financing is estimated to come from EU 
cohesion  policy,  40 %  from  CAP,  10 %  from  Horizon 
Europe  and  around  3.9 %  from  LIFE.  The  EU  MFF 
altogether accounts for 56 % of the financing and the RRF 

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

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

European  Union, 

Luxembourg, 

the 

of 

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

5 July 

final 

of 

 2025 Environmental Implementation Review – Finland 

 
 
Finland  45 

tools  for  identifying  and  tracking  green  expenditures 
and/or revenues (154). Green budgeting practices provide 
increased transparency on the environmental implications 
of budgetary policies.  

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (155).  

To help Member States develop national green budgeting 
and  thereby  improve  policy  coherence  and  support  the 
green  transition,  the  Commission  facilitated  a  Technical 
Support Instrument (TSI) project on green budgeting from 
2021 to 2024 (156), in which Finland participated.  

Beyond green budgeting, to improve policy outcomes the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (157)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 6.5 billion in 
Finland in 2022, representing 2.4 % of its GDP (EU average: 
2.0 %).  Energy  taxes  formed  the  largest  component  of 
environmental taxes, accounting for 1.8 % of GDP, which 
is slightly higher than the EU average of 1.6 %. Transport 
taxes, at 0.6 % of GDP, were above the EU average (0.4 %), 
as  were  taxes  on  pollution  and  resources,  at  0.02 %  (EU 
average: 0.08 %). In 2022, environmental taxes in Finland 
accounted  for  5.7 %  of  total  revenues  from  taxes  and 

for 0.3 %, adding up to a total of 57 % from the EU budget. 
The rest, 43 %, comes from national sources (153). 

Finland has planned to invest 19.4 % of its CAP funding for 
2021–2027  in  biodiversity  support  measures.  However, 
Finland is among the EU countries with the lowest share 
of  cohesion  policy  funds  dedicated  to  biodiversity:  just 
1.3 %  over  2021–2027  (disregarding  ESF+)  (EU  average: 
5.9 %). Finland has also planned to invest a relatively low 
share of RRF funds in biodiversity: 0.4 %, lower than the 
EU average (1.6 %). 

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

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Finland’s 
investment gap is estimated to be around EUR 4.7 billion 
per year, corresponding to 1.75 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 
States,  including  Finland,  already  use  green  budgeting 

(153)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

(155)  European  Commission, 

(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. 

(154)  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, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

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

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

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

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

 2025 Environmental Implementation Review – Finland 

 
 
 
 
 
social  security  contributions  (above  the  EU  average  of 
5.0 %) (158). 

Figure 36: Environmental taxes per Member State, 2022 

Finland  46 

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

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

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

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

to  a  2024  study (159),  Finland  applies 
According 
environmental taxes used to discourage environmentally 
harmful activities and behaviours in the fields of packaging 
and waste. 

Green bonds and sustainable bonds 

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

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

During 2021–2023 combined, Finland issued green bonds 
worth USD 16.7 billion (EUR 14.2 billion) via Munifin (160). 
Of this, the issuance in 2023 amounted to USD 7.8 billion 
(EUR 7.2 billion) (161). 

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 

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 
the  enabling 
action  programme  objectives  and 
conditions (162). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

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

(160)  https://www.kuntarahoitus.fi/en/. 
(161)  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. 

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

 2025 Environmental Implementation Review – Finland 

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

As  a  direct  consequence,  annual  FFS  in  the  EU  have 
increased to EUR 109 billion in 2023 from EUR 57 billion in 
2020.  From  2021  to  2023,  there  has  been  a  marked 
increase in annual FFS of 72 % in the EU (163). 

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 (164). 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  Finland,  energy  subsidies  have  shown  increases  since 
2016, especially from 2019. FFS, however, have remained 
relatively stable, ranging between EUR 1.0–1.3 billion per 
year (amounting to EUR 1.1 billion in 2023). 

As a share of GDP, fossil FFS in 2022 ranged from 1.8 % in 
Croatia  to  less  than  0.1 %  in  Denmark  and  Sweden. 
Finland’s  value  reached  0.4 %,  under  the  EU  average 
(0.8 %) (165). 

Finland  47 

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

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 

In  the  2022  EIR,  Finland  received  the  following  priority 
actions: (i) draw up an environmental financing strategy to 
maximise  opportunities 
for  closing  environmental 
implementation  gaps,  bringing  together  all  relevant 
administrative levels; and (ii) ensure an increased level of 
financing  for  the  environment  to  cover  the  investment 
needs  for  all  environmental  objectives  and  to  close  the 
investment  gaps.  Finland  has  made  no  progress  in  this 
respect,  as  the  same  environmental  investment  gap 
(around 2.3 % of GDP) remains. 

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. 

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

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

Union, 

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

Union, 

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

(164)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

 2025 Environmental Implementation Review – Finland 

 
 
 
 
 
 
Finland  48 

6. Environmental governance 

Information, public participation and access to 
justice 

Table  3:  Finland  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 (166).  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 (167).  It 
legal 
includes  the  right  to  bring 
challenges (‘legal standing’) (168). 

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 
information  between  public 
environmental  spatial 
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. 

in 

implementing  the 

Finland’s  performance 
Inspire 
Directive  has  been  reviewed  based  on  its  2023  country 
fiche (169)  (see  Table 3).   More  efforts  are  needed  to  (i) 
make  the  data  more  widely  accessible  and  (ii)  prioritise 
environmental  datasets  in  implementation,  especially 
identified  as  high-value  spatial  datasets  for 
those 
legislation (170).  Finland 
implementing  environmental 
already  received  a  priority  action  in  2022  in  this  regard, 
which is repeated in 2025. 

(166)  The  Aarhus 

Convention 

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

and 

the 

(167)  These  guarantees  are  explained  in  the  European  Commission’s 
2017  notice  on  access  to  justice  in  environmental  matters 
(https://eur-lex.europa.eu/legal-
content/EN/ALL/?uri=CELEX:52017XC0818(02))  and  a  related 

2016  2023 

Legend 

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

addressed 

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

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

efforts 

Effective  coordination  and 
data sharing 

Ensure 
effective 
coordination  

sharing 

Data 
without 
obstacle  

Inspire 
indicators 

■  ■ 

■  ■ 

performance 

(i)  Conformity 
of metadata  

■  ■ 

(ii)  Conformity 
of 
spatial 
datasets 

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

(iv)  Conformity 
of 
network 
services 

■  ■  

■   ■  

■  ■ 

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

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

(168)  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. 

(169)  European  Commission, 

‘Finland’, 

Inspire  Knowledge  Base, 

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

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

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

2025 Environmental Implementation Review – Finland 

 
 
 
 
assessment procedure. Such consultation also provides an 
opportunity for public authorities and project promoters 
to  engage  with  the  public  actively  and  meaningfully  by 
making information on the likely significant effects widely 
available. If carried out with due diligence and taking into 
consideration  useful  public  input,  this  process  leads  to 
better-informed decision-making and can promote public 
acceptance.  Making 
increases 
stakeholder  involvement,  thus  lessening  resistance  and 
preventing (or minimising) litigation. On the other hand, it 
is paramount that the procedure is effective. 

information  available 

involvement  and 
This  section  examines  how  public 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (171) 
and  the  Strategic  Environmental  Assessment 
(SEA) 
Directive (172). 

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

steps  aiming 

The average speed in the EU for issuing permits involving 
an  EIA  procedure 
is  20.6 months,  with  a  minimum 
duration  of  11.4 months  and  a  maximum  duration  of 
75.7 months (174).  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 Finland do not cover all the steps of 
the  EIA  to  draw  overall  conclusions;  however,  for  the 

scoping,  EIA 

(screening, 

Finland  49 

screening, scoping and EIA report phases, Finland showed 
a  shorter-than-average  time  duration  for  all  three. 
Effective use of EU procedures can positively influence the 
timely 
the 
decarbonization of the economy on the way to net zero by 
2050. 

activities  underpinning 

approval  of 

Reforms are ongoing in Finland to speed up permit-issuing 
processes and to establish one single authority to monitor 
progress  and  the  coordination  of  the  permit  process, 
including submissions. 

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 (175). 

Finland is committed to facilitating public participation in 
the  EIA  and  SEA  procedures.  The  Centres  for  Economic 
Development,  Transport  and  the  Environment  are  the 
competent EIA authorities. There is a central data source 
for all open and closed EIA procedures in Finland (176). To 
facilitate  participation,  a  video  and  a  leaflet  explaining 
what  an  EIA  is  and  how  to  participate  in  it  has  been 
produced  for  the  public (177).  A  service  design  working 
group  for  the  Centres  for  Economic  Development, 
Transport  and  the  Environment  looked  at  options  for 
improving the public participation process, although it is 
unclear when and how these will be put into practice. 

Not enough data are available to assess the level of public 
participation in decision-making processes related to the 
EIA or SEA Directives. Individual EIA projects may receive 
a large amount of feedback from the public, but no data 
are available on the general level of participation. 

There has been an open infringement case against Finland 
since  2019  for  failure  to  correctly  transpose  the  EIA 
Directive into its national laws (178). 

(171)  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. 

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

(175)   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 
(176)  https://www.ymparisto.fi/yva-hankkeet?n5=1; 

https://www.suomi.fi/palvelut/ymparistovaikutusten-
arviointimenettely-elinkeino-liikenne-ja-
ymparistokeskus/99980420-f076-4636-a752-d16ae39e5e16. 

(173)  Commission Staff Working Document  (SWD/2022/0149 final), 18 

(177)  https://www.ymparisto.fi/fi-

May 2022, EUR-Lex - 52022SC0149 - EN - EUR-Lex 

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

Impact  Assessment 

FI/Asiointi_luvat_ja_ymparistovaikutusten_arviointi/Ymparistova
ikutusten_arviointi; 
https://www.ely-
keskus.fi/documents/10191/40025628/YVA-
kuulemisen_palvelumuotoilu.pdf/b3b909a0-6449-4be8-bb22-
d5036f4c53e1. 
INFR(2019)2290. 

(178) 

2025 Environmental Implementation Review – Finland 

 
 
Access to justice 

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

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

As mentioned in the 2022 EIR, both individuals and NGOs 
have  recourse  to  seek  judicial  review  of  administrative 
decisions.  With  a  few  exceptions,  there  are  no  specific 
provisions  on  legal  standing  during  the  administrative 
procedure, that is, NGOs can generally participate through 
public  consultation  in  decision-making  procedures  that 
include public consultation. 

In most cases, the right to appeal for environmental plans 
and  programmes  is  to  be  determined  by  the  special 
provisions on access to justice in different environmental 
acts. Under these special provisions, access to justice also 
covers  the  standing  of  NGOs.  In  cases  where  no  such 
special  provisions  on  the  right  to  appeal  exist,  the 
provisions  of  the  Administrative  Judicial  Procedure  Act 
(plans and programmes adopted by the state authorities) 
or the Local Government Act on Municipal Appeal (plans 
and programmes adopted at the municipal level)  will be 
applied. In light of the national case law, access to national 
courts in environmental matters is guaranteed. 

In the 2022 EIR, Finland received two priority actions on 
public participation (to consider further improvements to 
the tools available for public  participation in light  of the 
service design working group’s recommendations, and to 
monitor  levels  of  public  participation  to  assess  whether 
Finland’s ambitions for improved public engagement are 
being met). Some progress has been recorded one these; 
however, a priority action is delivered in this report on the 
gathering and publication of relevant data. Finally, Finland 
also received two priority actions on access to justice (to 
improve  access  to  courts  by  the  public  concerned  for 
administrative or regulatory planning decisions on water, 
nature  and  air  quality,  and  to  better  inform  the  public 

(179)  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 

Finland  50 

using the relevant Commission eJustice Portal factsheets 
about their access to justice rights). Substantial progress 
has been measured on these. 

2025 priority actions 

• 

for 

spatial  datasets 

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

• 

• 

Compliance assurance 

Environmental  compliance  assurance  covers  all  work 
undertaken by public authorities to ensure that industries, 
farmers and others fulfil their obligations to protect water, 
air and nature, to manage waste (179) and to remedy any 
environmental  damage.  It  includes  measures  such  as  (i) 
compliance  promotion,  (ii)  compliance  monitoring  (i.e. 
inspections  and  other  checks),  (iii)  enforcement,  that  is 
steps taken to stop breaches and impose sanctions, and 
(iv) ensuring damage prevention and remediation in line 
with the polluter-pays principle. 

Compliance promotion, monitoring and enforcement 

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

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

staff 

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

document 

working 

(https://eur-

2025 Environmental Implementation Review – Finland 

 
 
Finland  51 

Figure 39: EU complaints 15 May 2022-31 December 2024 

Environmental crimes are monitored by the government’s 
Finnish  Environmental  Crime  Monitoring  Group,  which 
publishes annual reports (180). Based on the findings of the 
2023 report (181), the following needs to be emphasised: 
smoothness of mutual cooperation between supervisory 
and  criminal  investigation  authorities,  prevention  and 
detection  of  criminal  offences,  confiscation  of  criminal 
proceeds, informing the public, and implementation of the 
environmental  crime  prevention  strategy  and  the  action 
plan.  The  fight  against  environmental  crime  is  tackled 
through an environmental crime prevention strategy and 
an operational action plan. 

to 

As mentioned in the 2022 EIR, Finland adopted an updated 
national strategy for preventing environmental offences in 
2020 (182),  covering  2020–2026.  It  aims  to  ensure  the 
sharing  of  good  practices  and  facilitate  cooperation 
between  authorities  working  on  environmental  crime 
prevention; 
coordinate  budgetary  and  other 
supervision;  to  continue  the  implementation  of  joint 
education  on  environmental  offences;  to  develop  joint 
training  materials; 
statistical 
information;  to  take  the  need  to  combat  environmental 
offences into account in international legislative projects; 
to influence attitudes in order to prevent environmental 
in 
offences 
international 
enhance 
interaction between national actors and those operating 
in  international  networks.  A  joint  executive  board  of 
relevant  stakeholders  appointed  by  the  Ministry  of  the 
Environment  manages  the  implementation  of  practical 
measures.  

in  advance;  and  to  follow  the  trends 

further  develop 

environmental 

crime 

and 

to 

Source: DG Environment complaints data. 

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

Between  15  May  2022  and  31  December  2024,  the 
Commission  received  31  complaints  relating  to  the 
environment in Finland. In terms of complaints per million 
inhabitants, that is 5.53, meaning that Finland is the fifth 
highest-ranking  among  Member  States  on  this  point 
(figures  39  and  40).  Out  of  those  31  complaints,  21 
concerned alleged breaches of nature directives, while a 
small proportion is related to waste, water, and air quality 
issues.  

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

The 2022 EIR recommended that Finland (i) better inform 
the public about  compliance  promotion, monitoring and 
enforcement,  providing  clear  and  well-signposted 
information for citizens on how to report environmental 
complaints  or  infringements;  and  (ii)  take  forward  the 
commitments  set  out 
in  the  national  strategy  on 
environmental  crime,  including  on  developing  better 
statistics.  Some  progress  has  been  made  on  the  first 
recommendation, as the Commission has been informed 
that the action plan under the 2020 national strategy for 
preventing  environmental  offences  has  been  updated 

(180)  https://poliisi.fi/en/environmental-and-animal-offences. 
(181)

e4b14e402fae/Ymparistorikoskatsaus-2023-
EN.pdf?t=1710405865615. 

https://poliisi.fi/documents/25235045/28576016/Ymparisto

(182)  https://ym.fi/en/environmental-offences. 

rikoskatsaus-2023-EN.pdf/2a007b15-5131-001f-1d4c-

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
twice, in 2022 and 2024. The second priority action cannot 
be assessed due to lack of relevant information. 

The new EU Environmental Crime Directive 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD)  (Directive  (EU) 
2024/1203/EU)183  and  new  sectoral 
legislation  with 
stronger 
compliance  monitoring, 
enforcement  and  penalties.  Issues  important  for  the 
transposition and the implementation of the relevant new 
instruments are highlighted below. A detailed assessment 
of these topics will be included in the next EIR once more 
implementation  measures  are  put  in  place  and  more 
systematic information is available. 

provisions 

on 

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

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures 
to  combat  environmental  crime  more 
effectively,  through  training,  coordination,  cooperation 
and  strategic  approaches.  In  Finland,  a  working  group 
consisting of relevant ministries and stakeholders was set 
up  in  May  2024  to  support  the  transposition  work.  The 

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

law, 

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

criminal 

(184)  https://www.impel.eu/en. 
(185) 

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 

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

Finland  52 

Commission will provide support, including by facilitating 
the identification and sharing of good practices. Member 
States are expected to ensure the necessary resources and 
specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 
Law (184),  EnviCrimeNet (185),  the  European  Network  of 
Prosecutors for the Environment (186) and the EU Forum of 
Judges  for  the  Environment (187).  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)188  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate the ELD. Following the legal obligation, the ELD 
has undergone the second evaluation (189), which will be 
finalised in 2025, and which was supported by an external 
study190, 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 

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

(189)   Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

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

2025 Environmental Implementation Review – Finland 

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

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

the  development  of 

From 1 May 2013 to 31 December 2019, Finland reported 
one occurrence of an imminent  threat of environmental 
(water  damage)  and  two  occurrences  of 
damage 
environmental damage under the ELD (one occurrence of 
water  and  biodiversity  damage  and  one  of  biodiversity 
damage). In the previous reporting period, there were two 
confirmed environmental damage occurrences under the 
ELD  (one  case  for  biodiversity  damage  and  one  for 
land/soil and water damage). For comparison, the Finnish 
Environment 
Institute  studied  627  occurrences  of 
environmental damage between 2013 and 2019 in detail 
and concluded that only three of them were plausible ELD 
occurrences. 

Finland  has  not  introduced  mandatory  financial  security 
for  ELD  liabilities  and  the  demand  for  such  voluntary 
instruments  remains 
low.  Stand-alone  environmental 
insurance  policies  that  provide  cover  for  remediating 
gradual  as  well  as  sudden  and  accidental  pollution, 
including on-site and off-site remediation, may sometimes 
provide  coverage  for  ELD 
liabilities.  Environmental 
extensions to general liability policies are widely available 
and  mostly  provide  cover  only  for  remediating  off-site 
pollution  from  a  sudden  and  accidental  incident  on  an 
insured  site.  These  extensions  provide  cover  for  ELD 
liabilities 
and 
compensatory  remediation  for  water  and  biodiversity 
damage as well as land damage. Environmental extensions 
to property policies are also available  that  are similar to 
debris removal clauses but offer broader cover; however, 
they  do  not  cover  complementary  or  compensatory 
remediation under the ELD. 

including  primary, 

complementary 

Finland  53 

2025 priority action 

• 

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

EU-supported environmental capacity building 

initiative 

The  Commission’s  2023  Compact (191) 
to 
enhance  the  administrative  space  identifies  the  capacity 
to  lead  the  green  transition  as  one  of  three  key  pillars, 
along with the public administration skills agenda and the 
capacity  for  Europe’s  Digital  Decade.  Compact  also 
recognises the role of the EIR reporting tool in improving 
environmental  governance.  The  two  main  capacity-
building  opportunities  for  the  environment  provided  by 
the European Commission are the TSI (192) and the TAIEX-
EIR  PEER  2  PEER  tool (193).  The  technical  assistance 
available through the cohesion policy is subject to shared 
management and is not dealt with in this subsection. 

The Commission’s Technical Support Instrument   

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

The TSI had annual calls in 2022, 2023,2024 and 2025 with 
projects implemented in the respective following year (the 
year in brackets indicated below is the call year): 

•  Do  no  significant  harm  (DNSH)  guidelines  for  
implementing  the  Green  transition  in  Finland  (from 
national  DNSH-guidelines  to  implementing  the  EU 
taxonomy), Ministry of the Environment (2022) 

•  Accelerating  permitting 

for 

renewable  energy, 

• 

• 

Ministry of the Environment (2023) 
Industrial  ecosystems,  Regional  Council  of  Lapland 
(2023) 
ESG  risk  management  framework  for  the  financial 
sector, Finanssivalvonta (FIN-FSA) (2023) 
•  GreenREFORM EU, Ministry of Finance (2024) 
• 

Support  for  the  Preparation  of  Social  Climate  Plans, 
Ministry of the Environment (2024) 
Support  for  assessment  of  Environmentally  Harmful 
Subsidies  (EHS)  and  for  the  preparation  of  national 

• 

(191)  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). 

(192)  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). 

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

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

tool 

2025 Environmental Implementation Review – Finland 

 
 
• 

• 

finance  plans 

in  Belgium,  Finland, 
biodiversity 
Luxembourg  and  Netherlands,  Ministry  of  the  the 
Environment (2024) 
ProdTool - NPB 2.0: Micro-Data Analysis Tool 2.0 for 
studies  at  National 
comparative  productivity 
Productivity Boards (2025) 
-  Enhancing  Finland's  capacity  to  anticipate  and 
analyse  multidimensional 
implications  of  new 
technologies and to implement EU Recommendation 
on enhancing research security (2025) 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

States’ 

among  Member 

In 2017, the Commission launched the TAIEX-EIR PEER 2 
PEER  tool (194),  which  aims  to  facilitate  peer-to-peer 
environmental 
learning 
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 (195) are those 
requested  by  the  European  Commission  to  present  new 
and upcoming environmental legislation and policy in all 
Member States. 

Workshops involving Finland are as follows: 

•  Climate adaptation and blue infrastructure (31 May–

1 June 2022); 

Finland  54 

• 

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

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

•  Decentralised  biowaste  recycling 

in  Austria  (9–

10 October 2023); 

•  Biodiversity, nature conservation and large predators: 

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

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

In  the  2022  EIR,  Finland  received  a  priority  action  to 
continue  building  administrative  capacity  to  support  the 
green  transition,  in  particular  in  the  fields  of  circular 
economy,  governance  and  public  administration,  and 
finance  including  access  to  finance.  Finland  has  made 
some progress in that respect, but the situation still needs 
improvement.  For  that  reason  the  priority  action  is 
reiterated below. 

2025 priority action 

• 

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

(194)  https://ec.europa.eu/environment/eir/p2p/index_en.htm. 
(195)   Flagship multi-country workshops projects in the reporting period 
are: Recast Drinking  Water Directive (3 April 2025); Environmental 
compliance  and  governance  (18  March  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety:  awareness raising of emerging risks linked 
with climate change and decarbonation (12 December 2024); Air 
quality: 
implementation  of  the  NEC  Directive  to  further 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25  September  2024);  Industrial  emissions  transposition 
and implementation of the revised Directive (12 September 2024); 
Noise progress towards meeting Member States’ noise limit values 
and  EU  reduction  targets  (5  June  2024);  Best  practice  use  of 
environmental  footprint  methods  on  the  EU  market  (30  May 

2024);  Sustainable  finance  (9  November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13  June  2023);  Advisory 
service  for    businesses  to  go  circular  (24  April  2023);  Digital 
product  passport  implementation  (6  December  2022);  Public 
involvement  in  planning  and  approval  of  renewable  energy 
projects  (17  November  2022);  Environmental  compliance  and 
governance  (14  November  2022); Biowaste  management  (19-20 
September 2022); Renewable energy projects: permitting granting 
processes  (13 June 2022). N.B. the first flagship workshop on Zero 
Pollution for Air, Water and Soil, took place 9 February 2022. 

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
 
Finland  55 

Annex 

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

• 

• 
• 
• 

• 

• 

• 

• 

• 

• 

• 

 Adopt measures to increase the circular material use. 

Waste management 

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

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000 

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

Recovery of species  

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.   
Enhance efforts to collect reliable data on the conservation status of habitats and species as well as their 
occurrence at site level. In view of this, consider the creation of a body in charge of monitoring and reporting, to 
ensure that data are not provided only ad hoc on a contract basis 

Recovery of ecosystems 
Implement eco-schemes and agri-environmental measures and practices to address the environmental needs of 
Finland. 
Ensure sustainable management of forests, i.a. by adopting the National Forest Programme post-2020 and 
consider the conservation objectives of Natura 2000 forest sites when developing the National Forest 
Management Plan. 
Implement peatland conservation and restoration measures and include such measures and objectives in the 
national restoration plans. 

Prevention and management of invasive alien species  
Step up implementation of the IAS Regulation, including with regard to enforcement and capacity of inspection 
authorities. 

Zero pollution 
Clean air 

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

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

Industrial emissions 

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

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

• 

• 

Complete and implement action plans on noise management. 

Noise 

2025 Environmental Implementation Review – Finland 

 
 
 
 
 
 
 
 
Finland  56 

Water Framework Directive 

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. 

•  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 

Improve the classification of water bodies and strengthen monitoring systems. 

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

Floods Directive  
• 

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

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

monitoring, costs of measures). 

Nitrates Directive  
• 

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

Urban Wastewater Treatment Directive  
• 

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

Chemicals 

•  Upgrade the administrative capacities in implementation and enforcement to move towards a policy of zero 

• 

• 

• 

tolerance of non-compliance. 
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement of the European 
Chemicals Agency, including in the coordinated enforcement projects, called REF projects. 
Increase customs checks and checks of products sold online with regard to compliance with chemicals legislation. 
Climate action 
Implement all polices and measures that are needed to achieve targets laid down in the Effort Sharing Regulation 
(ESR) and the Land Use and Land-Use Change and Forestry (LULUCF) Regulation. More detailed priority actions 
are set out in the assessment of the final National Energy and Climate Plan (NECP).  

Financing 

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

Information, public participation and access to justice  

Environmental governance 

• 

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

• 
• 

Compliance assurance  

• 

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

2025 Environmental Implementation Review – Finland 

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

EU-supported environmental capacity building 

• 

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

Finland  57 

2025 Environmental Implementation Review – Finland