COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - THE NETHERLANDS 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, Netherlands, 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) 319 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review       Country Report - THE NETHERLANDS               Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security   {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 325 final} - {SWD(2025) 326 final}  
 
 
Contents 

EXECUTIVE SUMMARY ........................................................................................................................................... 2 

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ............................................................................................................. 4 
Transitioning to a circular economy ..................................................................................................................... 4 
Waste management ............................................................................................................................................. 6 
2. BIODIVERSITY AND NATURAL CAPITAL ........................................................................................................................... 12 
Global and EU biodiversity frameworks ............................................................................................................. 12 
Nature protection and restoration – Natura 2000 ............................................................................................. 13 
Recovery of species ............................................................................................................................................ 14 
Recovery of ecosystems ..................................................................................................................................... 16 
Prevention and management of invasive alien species ...................................................................................... 22 
Ecosystem assessment and accounting ............................................................................................................. 23 
3. ZERO POLLUTION ..................................................................................................................................................... 26 
Clean air ............................................................................................................................................................. 26 
Industrial emissions ............................................................................................................................................ 27 
Major industrial accidents prevention – Seveso ................................................................................................. 29 
Mercury Regulation ............................................................................................................................................ 31 
Noise .................................................................................................................................................................. 31 
Water quality and management ........................................................................................................................ 31 
Chemicals ........................................................................................................................................................... 36 
4. CLIMATE ACTION ..................................................................................................................................................... 39 
The EU emissions trading system ....................................................................................................................... 39 
Effort sharing ..................................................................................................................................................... 40 
Land use, land-use change and forestry ............................................................................................................. 41 
Adaptation to climate change ............................................................................................................................ 41 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 42 

5. FINANCING ............................................................................................................................................................. 42 
Climate finance landmarks ................................................................................................................................. 42 
Environmental financing and investments ......................................................................................................... 42 
Public financial management ............................................................................................................................. 47 
6. ENVIRONMENTAL GOVERNANCE ................................................................................................................................. 51 
Information, public participation and access to justice...................................................................................... 51 
Compliance assurance ........................................................................................................................................ 54 
EU-supported environmental capacity building ................................................................................................. 56 

EN 

  EN 

 
 
 
 
 
The Netherlands  2 

Executive summary 

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

environmental 

regarding 

The  main  challenges  set  out  below  have  been  selected 
from  Part I  of  this  report,  ‘Thematic  areas’,  considering 
factors  such  as  the  gravity  of  the  environmental 
implementation issue in light of the impact on the quality 
of  life  of  citizens,  the  distance  to  target  and  financial 
implications. 

The Netherlands is one of the EU’s best performers on the 
circular  economy  as  regards  resource  productivity, 
secondary material use and waste management. It is not 
considered at risk of missing the municipal and packaging 
waste targets. However, further progress could be made 
by  introducing  new  economic  instruments  to  prevent 
waste  by  avoiding  the 
incineration  of  reusable  or 
recyclable waste and by making reuse and recycling more 
economically attractive. 

The  Netherlands  did  not  submit  its  national  biodiversity 
strategy and action plan and therefore did not respect its 
international  commitment  as  regards  the  Kunming–
Montreal  global  biodiversity 
framework.  Protecting 
biodiversity  presents  major  challenges,  since  over  three 
quarters  of  protected  habitats  and  species  still  have  an 
unfavourable  conservation  status.  One  main  reason  for 
the  deterioration  of  habitats is  the  continued  significant 
pressure  from  agriculture,  in  particular  due  to  nitrogen 
deposition affecting many sensitive habitats, from bogs to 
forests,  and  changes  in  the  water  regime  (drainage). 
Furthermore,  the  situation  for  forested  areas  protected 
under the Nature Directives is severe, as more than half of 
assessments show a bad conservation status. At the same 

(1) 

from 

the  Commission 

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

to 

time, the share of habitats with a bad conservation status 
has increased to 53.85 % and the share of species with a 
bad  conservation  status  has  decreased  to  38.75 %.  The 
main pressures are agriculture, human-induced changes in 
water regime and natural succession. 

The  analysis  of  river  basin  management  plans  of  the 
Netherlands has identified  nutrients from agriculture as 
an  important  pressure  on  groundwaters  and  surface 
waters, impacting their good status, and therefore as one 
of  the  main  factors  in  their  failure  to  meet  the  Water 
Framework  Directive  objectives.  It  is  estimated  that 
4.44 % of utilised agricultural land area in the Netherlands 
is used for organic farming. This is the fifth-worst result in 
the  EU,  and  substantially  lower  than  the  EU  average  of 
10.50 %.  The  Netherlands  is  not  sufficiently  contributing 
to  achieving  the  target  of  using  25 %  of  the  EU’s 
agricultural  land  for  organic  farming  by  2030.  The  main 
contributor to emissions to water in the Netherlands is the 
waste  management  sector;  emissions  from  this  sector 
include heavy metals, nitrogen, total organic carbon and 
phosphorus.  Urban  waste  water  collected 
in  the 
Netherlands is being properly treated (100 %) as required 
by EU law. 

The overall environmental investment needed to enable 
the  Netherlands  to  meet  its  objectives  in  the  main 
environmental  areas  is  EUR 4.1 billion  per  year,  broken 
down  as  follows:  circular  economy  (EUR 1.5 billion), 
pollution  prevention  and  control  (EUR 2.3 billion),  and 
water (EUR 1.0 billion). To meet environmental objectives 
beyond climate change, the additional investment needed 
over the current level – the investment gap – per year in 
the Netherlands represents around 0.4 % of the national 
gross domestic product, being lower than the EU average 
(0.77 %). 

and 

regard 

impact 

assessment 

to  environmental  governance, 

With 
the 
Netherlands needs to ensure that relevant information on 
environmental 
strategic 
environmental  assessment  procedures  (including  on 
opportunities 
for  public  participation  and  on  the 
publication of final decisions) is electronically accessible, 
and  provide  information  on  the  average  duration  of  all 
steps in the environmental impact assessment process. On 
a  positive  note,  the  Netherlands  continues  to  properly 
implement  the  Inspire  Directive,  and  ensures  access  to 
courts  in  national  environmental  cases  by  the  public 
concerned through eliminating practical barriers, such as 
excessive costs. 

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

2025 Environmental Implementation Review – The Netherlands 

 
 
The Netherlands  3 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
The Netherlands  4 

Part I: Thematic areas 

1. Circular economy and waste management 

Transitioning to a circular economy 

Advancing the transition to a circular economy in the EU 
will reduce the environmental and climate impact of our 
industrial  systems  by  reducing  input  materials,  keeping 
products and materials in the loop for longer and reducing 
waste generation, thus decoupling economic growth from 
circular  economy  has 
resource 
considerable  potential  to  increase  competitiveness  and 
job creation and will also promote innovation and provide 
access to new markets. With the 2020 circular  economy 
in  place  or 
action  plan  (CEAP) (2)  measures  either 
legislatively advanced, EU Member States will now have to 
focus on a swift and effective implementation. 

consumption.  A 

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

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

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

The circular use of material in the Netherlands was 30.6 % 
in  2023.  Despite  a  slight  decrease  in  2016–2019,  the 
country’s  rate  is  the  highest  in  the  EU,  against  the  EU 
average of 11.8 % (Figure 1). 

Figure 1: CMUR (%), 2013–2023 

40

30

20

10

0

2013

2015

2017

2019

2021

2023

Netherlands

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. 
As shown in Figure 2, with EUR 5.46 generated per kg of 
material  consumed  in  2023,  the  Netherlands’  resource 
productivity is well above the EU average of EUR 2.23 per 
kg, and is the highest in Europe. 

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

6,0

4,0

2,0

0,0

2013

2015

2017

2019

2021

2023

Netherlands

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, 
accessed 
https://ec.europa.eu/eurostat/databrowser/product/view/env_ac_rp. 

9 December 

2024, 

(2) 

Communication 
the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee  and  the  Committee  of  the  Regions –  A  new  circular 

the  Commission 

from 

to 

economy action plan for a cleaner and more competitive Europe, 
COM(2020) 98 
https://eur-
lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:52020DC0098. 

11 March 

2020, 

final 

of 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
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  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  2023,  the  Netherlands  put  in  place  the  2023–2030 
national programme for circular economy (5), following up 
on  the  broader  2016  programme  on  a  fully  circular 
economy by 2050 (6), under which the country’s objective 
was to achieve a 50 % reduction in the use of primary raw 
materials by 2030. 

To achieve the ambitious objectives from 2016, the 2023–
2030  programme  introduces  measures  to  improve  the 
economy of raw materials, with a focus on the reduction 
and  substitution  of  raw  materials,  the  extension  of 
product  lifetimes,  high-grade  processing  and  circular 
design. Dedicated initiatives have been developed for the 
more impactful product groups, namely some consumer 
goods,  plastics,  construction  products  and  certain 
manufacturing practices. 

Supporting  measures  are  also 
initiatives 
behaviour change and education. 

introduced,  such  as 
for  circular  entrepreneurship,  consumer 

The Netherlands’ regions and cities are particularly active 
in promoting the transition to a circular economy. 

In  2024,  a  new  infringement  case  was  opened  by  the 
Commission, as in 2021 the Netherlands did not achieve 
the  agreed  collection  recycling  rate  for  waste  electronic 
and electric equipment (INFR(2024)2125). 

Green public procurement 

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

(3) 

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  Infrastructure  and  Water  Management,  National 
2023, 

Stakeholder 

Programme 

2023–2030, 

Economy 

Economy 

Platform 

Circular 

(4) 

The Netherlands  5 

help drive the demand for sustainable products that meet 
reparability and recyclability standards. 

The Netherlands has a long tradition of sustainable public 
procurement  (SPP)  policy.  However,  an  evaluation  has 
shown broad support  for  green public procurement, but 
still too little structural uptake. 

To address this and significantly boost the impact of public 
procurement, a new national plan on SPP was adopted in 
2021. This plan aims to create more political commitment, 
activate key decision-makers in organisations and create 
more  impact  in  key  sectors.  The  Sustainable  Public 
Procurement  Manifesto  (2022–2025)  was  signed  by  all 
Dutch  ministries,  a  third  of  Dutch  provinces,  50 
municipalities  and  all  Dutch  regional  water  authorities, 
among  others.  It  covers  social  return,  diversity  and 
inclusion,  international  supply  chain  responsibility,  the 
environment  and  biodiversity,  the  circular  economy  and 
climate. 

For  circular  procurement  specifically,  a  number  of 
activities are relevant. The Netherlands has so far set up 
around  30  so-called  buyer  groups  to  leverage  collective 
procurement  power  in  a  relevant  sector  and  provide  a 
platform for sharing knowledge and learning experiences. 
Specifically  for  infrastructure,  extensive  transition  paths 
have been worked out as part of the climate-neutral and 
circular  infrastructure  programme.  These  are  supported 
by buyer groups for the procurement angle. The national 
buyer group for ICT has been linked to the Circular and Fair 
ICT Pact, initiated by the Netherlands, together with seven 
other countries. 

increasing  number  of  circular  procurement  best 
An 
practices  are  shared as  part of  a  free  online  SPP  criteria 
tool. The Netherlands promotes the use of internal carbon 
pricing, especially in the infrastructure sector. In addition, 
a  growing  number  of  organisations  use  the  Dutch  CO2 
Performance Ladder, which provides both a procurement 
tool and a plan–do–check–act management system. This 
approach  speeds  up  carbon  emission  reduction 
in 
companies  and  governments  certified  on  this  ladder, 
including  (at  the  higher  levels)  emissions  resulting  from 
procurement.  This  provides  a  powerful  impetus  for 
circular procurement. 

To  boost  political  support  for  sustainable  (and  circular) 
procurement, a new political manifesto is being drawn up 
that focuses on boosting SPP, and providing support and 

https://www.government.nl/documents/reports/2023/09/27/na
tional-circular-economy-programme-2023-2030. 

(6)  Ministry  of  Infrastructure  and  Water  Management,  National 
2016, 

Agreement 
the 
https://www.government.nl/documents/discussion-
documents/2017/01/24/national-agreement-on-the-circular-
economy. 

Economy, 

Circular 

on 

2025 Environmental Implementation Review – The Netherlands 

 
 
creating  a  stronger  foundation  for  SPP,  within  signatory 
organisations. 

— 

limiting energy recovery to non-recyclable materials; 
and 

—  phasing  out  landfilling  of  recyclable  or  recoverable 

The EU Ecolabel and the eco-management and audit 
scheme 

waste. 

The Netherlands  6 

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

reducing 

aimed 

at 

As  of  September  2024,  the  Netherlands  had  2 019 
products  out  of  98 977  and  106  licences  out  of  2 983 
registered in the EU Ecolabel scheme , which is an increase 
from  previous  years (7).  One  organisation  from  the 
Netherlands is currently registered in EMAS, the same as 
in October 2021 (8). 

While  no  circular-economy-specific  priority  actions  were 
suggested in the 2022 report, the Netherlands has made 
progress  on  priority  actions  suggested  for  the  circular 
economy in previous reports. The country has introduced 
a wide-ranging and comprehensive policy framework and 
has successfully included local and regional authorities in 
the process. 

Waste management 

Turning waste into a resource is supported by: 

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

implementing  EU  waste 

— 

—  reducing waste generation per capita and in absolute 

— 

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

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

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

(which 

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

The total amount of waste generated in the Netherlands 
was  increasing  until  2018,  when  it  began  to  decrease 
significantly  (Figure 3).  This  trend  is  primarily  driven  by 
dredging spoils included in the mineral waste categories. 
Without those, the overall waste generation trend would 
stabilise,  and  from  2020  onward  a  slight  decoupling  of 
total  waste  generation  from  economic  growth  could  be 
observed. 

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 
2024, 
income)’, 
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, 

(7) 

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

(8) 

As of October 2024. European Commission, ‘Eco-management and 
audit scheme (EMAS)’, European Commission website, November 
2021, 
http://ec.europa.eu/environment/emas/emas_registrations/stati
stics_graphs_en.htm. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
Critical raw materials 

The  national  circular  material  plan  (NCEP) (9)  will  come 
into force in 2025. It focuses on waste management and 
minimum  standards  for  the  quality  and  methods  of 
recycling of critical raw materials from waste streams. 

Construction and demolition waste 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (10) 
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 
individual  fractions  of 
construction  and  demolition  waste.  However,  the 
economics  are  often  not  right  to  favour  preparing  for 
reuse  and  recycling  over  incineration  and  landfilling.  If 
available  technology  were  to  be  applied,  it  is  estimated 
that  the  increase  in  preparing  for  reuse  and  recycling 
would lead to an additional 33 Mt of GHG emission savings 
annually  (more  than,  for  example,  the  combined  annual 
GHG emissions from Estonia, Latvia and Luxembourg). 

The rate of recycling and preparation for reuse of mineral 
construction and demolition waste in the Netherlands in 
2022 was high, at 99.3 % compared with the EU average 
of 79.8 %. Construction and demolition waste is collected 
separately  at  construction  sites.  In  the  Netherlands,  the 
vast  majority  of  building  and  construction  waste  is 
recycled. The national policy targets separate raw material 
with minimal requirements for recycling with the aim  of 
ensuring recycling higher up the value chain. 

Boosting 
Warning Report 

implementation –  the  2023  Waste  Early 

This  section  focuses  on  the  management  of  municipal 
waste (11),  for  which  EU  law  sets  mandatory  recycling 
targets.  In  June  2023,  the  Commission  published  the 
Waste  Early  Warning  Report (12)  identifying  the  general 
trends in waste management and the Member States at 
risk  of  missing  2025  waste  targets  (see  Figure 4).  The 
Netherlands is not at risk of missing the municipal  waste 
target or the packaging waste target. 

The Netherlands  7 

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

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

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

 Member States at risk of missing both targets 

 Outside coverage 

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

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

(9) 

(10) 

https://www.rijksoverheid.nl/onderwerpen/circulaire-
economie/nederland-circulair-in-2050. 
European Commission: Joint Research Centre, Techno-economic 
and environmental assessment of construction and demolition 
waste management in the European Union, Publications Office of 
the European Union, Luxembourg, 2024, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC1354
70. 

(11)  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. 

(12) 

2025 Environmental Implementation Review – The Netherlands 

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

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 (13), the Packaging and 
Packaging Waste Directive (14) and the Directive on Waste 
Electrical and Electronic Equipment (15). 

Municipal waste 

Municipal waste generation in the Netherlands decreased 
between 2010 and 2022 (Figure 5). In 2022, the  country 
generated 473 kg of municipal waste per capita, which is 
significantly below the estimated EU-27 average of 513 kg 
per capita. 

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

NB:  As  of  the  reference  year  2020,  new  reporting  rules  applied  for 
calculating recycling of municipal waste pursuant to the targets set out 
in Article 11.2(c–e) of Directive 2008/98/EC. However, it is unclear based 
on  the  information  available  whether  these  new  reporting  rules  have 
been implemented in the Netherlands yet. 

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

22 October 

accessed 

The Netherlands  8 

years (Figure 6), while at the same time the incineration 
rate  has  decreased  (see  Figure 5).  In  2022,  the  rate  of 
preparing  for  reuse  and  recycling  was  58 %,  which  is 
slightly above the estimated EU-27 average of 49 % in the 
incineration  rate  decreased  by  8 
same  year.  The 
percentage  points  to  41 %  in  2022.  The  landfill  rate 
remained  below  2 %  throughout  the  time 
frame 
considered (Figure 6). 

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

NB: Note that the data slightly differ from the data reported by the Dutch 
authorities  to  show  compliance  with  the  preparing  for  reuse  and 
recycling  target  of  55 %  to  be  met  by  2025,  as  set  out  in  the  Waste 
Framework Directive. The Netherlands reported a (provisional) preparing 
for  reuse  and  recycling  rate  in  response  to  the  target  that  was  in  the 
range of 1–5 percentage points below the (voluntary) data shown in the 
figure  for  the  reference  year  2022.  These  data  are  still  awaiting  final 
validation by Eurostat. 

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 

Packaging  waste  generation  in  the  Netherlands  has 
stagnated  since  2010  (Figure 7).  The  country  generated 
169 kg  per  capita  in  2022,  which  is  slightly  below  the 
estimated  EU  average  of  186 kg  per  capita  in  the  same 
year (16).  The  higher  amounts  of  wooden  packaging  in 
2015–2017 can be explained by a change in the reporting 
method for repaired wooden packaging in 2015 and again 
in 2018. 

The rate of preparing for reuse and recycling of municipal 
waste in the Netherlands has increased slightly in recent 

(13) 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. 
(14)  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. 

(15)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment  (WEEE)  (OJ  L 197,  24.7.2012,  p. 38),  Directive  - 
2012/19 - EN - EUR-Lex. 
The  EU  average  might  have  been  influenced by  not  all  Member 
States fully  applying  the  reporting  rules for  packaging  waste  set 
out in Commission Implementing Decision (EU) 2019/665. 

(16) 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
Figure 7: Packaging waste generation, 2010–2022 

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

The Netherlands  9 

NB:  As  of  the  reference  year  2020,  the  Netherlands  applied  the  new 
calculation  rules  for  calculating  recycled  packaging  waste  pursuant  to 
Article 6c of Directive 94/62/EC. 

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. 

The  country’s  overall  packaging  waste  recycling  rate,  as 
well as the recycling rates for paper/cardboard and glass 
packaging,  were  already  above  the  2025  target  in  2010 
(Figure 8). The overall recycling rate has stagnated, and in 
2022  was  75 %.  The  overall  recycling  rate  is  mainly 
influenced by paper and cardboard, as this constitutes the 
largest  share  of  recyclable  waste.  In  2020,  the  recycling 
rates dropped for all materials, which slightly reduced the 
overall  recycling  rate  and  can  be  attributed  to  the 
application  of  the  new  calculation  points.  The  trend  for 
wooden packaging recycling  shows a  significant  increase 
from 2014 to 2018, when it began to decrease.  This was 
due  to  the  introduction  of  wooden  packaging  to  the 
measurements  in  the  reference  year  2015.  From  2020 
onwards, it was mandatory to report steel and aluminium 
packaging separately. The recycling rates of both fractions 
exceeded the 2025 target. 

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

In  2023  and  2024,  significant  attention  was  paid  to  the 
functioning  of  the  packaging  collection  system.  Since 
2022, the deposit refund system for packaging waste has 
covered small plastic bottles and beverage cans (deposit 
of  EUR 0.15/piece),  with  a  national  collection  target  of 
90 % for plastic bottles (higher than the EU target of 65%). 
The  national  targets  were  not  achieved  in  2022,  with  a 
68 % collection rate reported. This has resulted, over the 
last three years, in EUR 370 million in deposits not being 
reimbursed.  The  Human  Environment  and  Transport 
Inspectorate  announced  five  penalties  with  a  potential 
maximum 
improve 
compliance (17). 

EUR 140 million 

sum  of 

to 

Policies to encourage waste prevention 

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

In the Netherlands, the management of waste, including 
packaging waste, is organised at the national level through 
the  Central  Environmental  Law  (Wet  Milieubeheer) (18) 
and  the  Dutch  Law  on  Packaging  Waste (19).  Both  the 
Dutch  national  waste  prevention  plan  and  the  national 
waste  management  plan  (NWMP)  were  updated  to 
accommodate the Waste Framework Directive, amended 
in  2018.  The  NWMP  also  includes  national  targets  for 

(17) 

(18) 

https://www.ilent.nl/actueel/nieuws/2024/07/12/inleveren-
plastic-flesjes-moet-aantrekkelijker-5-lasten-onder-dwangsom-
voor-verpact. 
European  Environment  Agency  (EEA),  Early  warning  assessment 
related to the 2025 targets for municipal and packaging waste – 
2022, 
Netherlands, 

https://www.eea.europa.eu/publications/many-eu-member-
states/early-warning-assessment-related-to. 

(19)  Ministerie  van  Infrastructuur  en  Waterstaat,  ‘Besluit  beheer 
verpakkingen  2014’,  Overheid.nl  website,  2021,  accessed 
16 December 
2024, 
https://wetten.overheid.nl/BWBR0035711/2021-07-03.  

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
packaging waste. Additionally, an action plan is in place to 
implement a circular economy by 2050 (20). 

to a circular economy by 2050, with a goal of reducing the 
use of primary raw materials by 50 % by 2030. 

The Netherlands  10 

The  Ministry  of  Infrastructure  and  Water  Management 
adopted  the  second  amendment  to  the  2017–2029 
NWMP,  entitled  ‘Smarter  use  of  raw  materials’  (2017–
2029 Landelijk afvalbeheerplan (LAP3) (21)). In 2022, it was 
decided  that  the  validity  of  LAP3  would  be  extended  by 
two years, until the end of 2025. LAP3 will be followed by 
a circular materials plan in 2025. The NWMP covers both 
household  and 
industrial  waste  and  has  dedicated 
sections  for  targeted  waste  streams  (e.g.  biowaste, 
textiles, paper and cardboard). The plan provides a set of 
measures  to  be  implemented  by  the  municipalities  to 
improve separate household waste collection. The NWMP 
is  complemented  by  sectoral  plans  including  minimum 
standards for and information on cross-border transport 
covering 85 waste streams (Sectorplannen LAP 3, 2021). In 
addition, regarding packaging waste, the NWMP refers to 
the  2014  Packaging  Management  Decree  and  the 
packaging  management  regulations,  alongside  sectoral 
plan 41,  which  encompasses the  packaging  policy  (LAP3, 
2021). 

The Netherlands’ national waste prevention programme is 
a stand-alone document (22). Waste prevention measures 
are included in the NCEP published in 2016 and updated 
in  2023.  The  updated  NCEP  focuses  on  sustainable 
production  and  consumption  practices,  along  with 
product reusability and repairability. The programme has 
three overarching strategic objectives: 

— 

— 

— 

reducing  the  utilisation  of  raw  materials  within 
existing supply chains; 
transitioning  away 
materials and non-sustainable resources; 
driving  innovation  in  production  methods  and 
circular product design. 

fuels,  critical 

fossil 

from 

In  the  NCEP,  priority  waste  streams  are  food  waste, 
construction and demolition waste, hazardous waste and 
critical  raw  materials,  packaging  waste,  electrical  waste 
(including  batteries)  and  bulky  waste.  The  document 
outlines  waste  prevention  measures,  such  as  extended 
producer responsibility (EPR), circular design and circular 
purchasing, as well as measures to increase reuse. 

Monitoring  of  the  programme’s  implementation  will  be 
conducted by the Netherlands Environmental Assessment 
Agency in collaboration with seven other institutions (23), 
as part of the government’s monitoring of the  transition 

(20) 

(21) 

(22)

https://www.government.nl/documents/reports/2023/09/27/na
tional-circular-economy-programme-2023-2030. 
https://lap3.nl/sectorplannen/ 
https://lap3.nl/sectorplannen/sectorplannen/verpakkingen/ 

https://www.rijksoverheid.nl/documenten/rapporten/2021/

02/18/afvalpreventieprogramma-nederland. 

EPR schemes have been implemented in the Netherlands 
for  various  product  groups  (electric  and  electronic 
equipment,  batteries,  scrap  vehicles,  packaging  and  car 
tyres).  An  EPR  scheme  for  textiles  was  implemented  in 
2023, and the government is exploring options for  other 
product chains. 

Policies to encourage separate collection and recycling 

The Dutch municipalities design their own separate waste 
collection  systems  through  municipal  ordinances.  For 
residual  waste  and  biowaste,  door-to-door  collection  is 
applied  throughout  the  whole  country.  By 
law,  all 
municipalities  should  do  their  best  to  collect  biowaste 
from  all  households,  and  around  90 %  of  Dutch 
households are served by biowaste collection services (24). 
Regarding  the  collection  of  other  recyclable  materials, 
larger  cities  favour  collection  points  and  municipal 
container parks, while smaller towns prefer door-to-door 
collection.  Some  materials  are  frequently  collected 
commingled,  for  example  plastics,  metals  and  beverage 
cartons;  plastics  and  beverage  cartons;  or  glass  and 
metals. 

Only about 41 % of the Dutch households are incentivised 
to  sort  their  waste  at  the  source  through  a  pay-as-you-
throw  system.  These  systems  are  mainly  based  on  the 
volume and/or frequency of waste collection. The success 
of  separate  collection  for  certain  materials  is  fading, 
posing a challenge for meeting the EU waste targets in the 
future.  The  Dutch  authorities  aim  to  enhance  separate 
collection systems, especially for high-rise buildings. 

Policies to discourage landfilling or incineration 

A landfill ban has been in place in the Netherlands since 
1995 for, among others, combustible and biodegradable 
waste (waste with a total organic carbon content of > 5 %), 
thus  practically  banning  landfilling  of  mixed  municipal 
waste. In 2018, this ban was extended to additional waste 
streams (25). 

The  Netherlands  strongly  relies  on  incineration  for  the 
disposal of mixed municipal waste. The Dutch disposal tax 
(EUR 39/t in 2024) is equal for landfilling and incineration 
and adjusted annually. This tax is levied on all Dutch waste, 
including  waste  that  is  exported  for  these  purposes  and 
outputs  from  mechanical  biological  treatment  or  sorting 

(23) 

https://www.pbl.nl/publicaties/werkprogramma-monitoring-en-
sturing-ce-2023-2024. 

(24)  National  Institute  for  Public  Health and  the  Environment;  Dutch 
Ministry  of  Infrastructure  and  Water  Management,  information 
provided during the Eionet review of the draft country profile on 
2024. 
waste  management 
https://www.rivm.nl/en 
https://wetten.overheid.nl/BWBR0009094/2024-01-01. 

Netherlands, 

the 

(25) 

for 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
The Netherlands  11 

2025 priority actions 

• 

•  Further shift reusable and recyclable waste away from 
incineration, including through economic instruments. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 

• 

•  Extend  a  pay-as-you-throw  system  to  all  households, 
and fully introduce the cost-coverage rules as part of 
extended producer responsibility for packaging. 

plants going to incineration (26). Overall, this disposal tax 
is  close  to  the  EU  average  of  landfill  taxes  across  those 
Member States applying such taxes (EUR 39–46/t). 

including  economic 

In the 2022 EIR, the Netherlands had two priority actions. 
With regard to the first objective, ‘to introduce new policy 
instruments, 
instruments,  to  (i) 
promote  waste  prevention  and  (ii)  make  preparing  for 
waste reuse and recycling more economically attractive’, 
the  Netherlands  made  significant  progress  with  the 
comprehensive NCEP. 

Regarding  the  second  objective,  ‘shift  reusable  and 
recyclable  waste  away  from  incineration  with  energy 
recovery’,  there  has  been  no  downward  trend  in  the 
volumes of waste sent for incineration. 

(26) 

https://iplo.nl/thema/bodem/nieuws-bodem/2023/tarief-
afvalstoffenbelasting-per-1-januari-

2024/#:~:text=2024%3A%20%E2%82%AC%2039%2C23%20per,%
E2%82%AC%2033%2C15%20per%20ton 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
2. Biodiversity and natural capital

Global and EU biodiversity frameworks

The Netherlands  12 

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 (27)  and  a  dashboard  of  indicators (28) 
provide  information  on  implementation  progress.  The 
recently adopted EU Nature Restoration Regulation (29) is 
the first EU-wide, comprehensive law of its kind and a key 
instrument  for  the  EU  to  deliver  on  the  global 
biodiversity targets for 2030. It lays down an overarching 
objective  at  the  EU  level  to  put  in  place  effective 
restoration measures on 20% of EU land and sea by 2030 
and for all ecosystems in need of restoration by 2050. To 
achieve this, it sets binding targets for Member States to 
restore and maintain ecosystems, as well as an effective 
implementation 
national 
restoration plans. 

implementation 

framework 

enable 

based 

on 

to 

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

Member  States’  NBSAPs  need  to  provide  coherent 
frameworks  for  national  delivery  on  the  global  and  EU 
2030  biodiversity  targets. 
line  with  the  global 
obligations,  NBSAPs  should  also  include  a  biodiversity 
financing  plan  and  a  capacity-building  plan,  based  on 

In 

(27) 

(28) 

(29) 

Actions 

Tracker 

Strategy 

Biodiversity 

Biodiversity 

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

Dashboard 

Strategy 

needs  assessments,  as  well  as  an  overview  of  the 
national indicators used to measure progress. 

In 2020, the Netherlands launched a national programme 
for strengthening biodiversity (30) that builds on the BDS 
and strives to achieve 100 % of the objectives of the Birds 
and  Habitats  Directives  by  2050.  It  identifies  goals  for 
2030 that are reflected in more than 100 measures, each 
with  corresponding 
indicators,  priorities,  deadlines, 
verification  means,  tools  and  responsible  entities.  The 
Netherlands  has  not  yet  submitted  to  the  CBD  an 
updated NBSAP or national targets aligned with the GBF. 
This  programme  was  launched  under  the  previous 
government  and,  inter  alia,  builds  on  the  national 
programme  for  rural  areas  (Nationaal  Programma 
Landelijk Gebied), and aims to improve nature, soil and 
water  quality  and  combat  climate  change.  The  new 
government that came into office in 2024 has scrapped 
the  national  programme  for  rural  areas  and  cut  the 
budget  for  environmental  measures  in  rural  areas  by 
80 %. It is unclear at this stage whether and by when the 
programme  will  be 
the 
environmental targets. 

to  achieve 

replaced 

The Dutch government did not submit a NBSAP and did 
thus not respect its international commitment as regards 
the GBF.  

The EU aims to allocate to biodiversity objectives at least 
7.5 % of annual spending under the EU budget in 2024, 
in  2026  and  2027.  For  details  on 
rising  to  10 % 
the 
biodiversity 
Netherlands, see Chapter 5. 

financing  and 

investments 

in 

2025 priority action 

• 

Submit  to  the  CBD  an  updated  NBSAP  or  national 
targets  following  the  adoption  of  the  Kunming-
Montreal Global Biodiversity Framework. 

see  also 
http://data.europa.eu/eli/reg/2024/1991/oj; 
Commission 
the 
on 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 

page 

web 

the 
law 

(30)

https://www.rijksoverheid.nl/documenten/kamerstukken/
2020/10/16/kamerbrief-programma-versterken-biodiversiteit. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
Nature protection and restoration – Natura 
2000 

Natura  2000 (31),  the  largest  coordinated  network  of 
protected areas in the world, is key to the achievement 
of  the  objectives  set  out  in  the  Birds  and  Habitats 
Directives. These objectives are to ensure the long-term 
protection,  conservation  and  survival  of  Europe’s  most 
valuable  and  threatened  species  and  habitats  and  the 
ecosystems  they  underpin.  Key  milestones  towards 
meeting  the  objectives  of  the  Birds  and  Habitats 
Directives  are  (i)  the  setting  up  of  a  complete  and 
coherent  Natura  2000  network;  (ii)  the  designation  of 
sites of community importance (SCIs) as special areas of 
conservation (SACs) (32); and (iii) effective management 
of  all  Natura  2000  sites  through  the  setting  of  site-
specific conservation objectives and measures. 

Setting up a complete and coherent network of Natura 
2000 sites 

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

the 

these 

requires 

commitments 

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

The  Netherlands  hosts  52  habitat  types (33)  and  80 
species (34)  covered  by  the  Habitats  Directive.  The 
country  also  hosts  populations  of  70  bird  taxa  listed  in 
the Birds Directive Annex I (35). 

In  2023,  14.7 %  of  the  national  land  area  of  the 
Netherlands  was  covered  by  Natura  2000  sites  (EU 

The Netherlands  13 

coverage:  18.6 %),  with  special  protection  areas  (SPAs) 
classified under the Birds Directive covering  12.8 % (EU 
coverage: 12.8 %) and SCIs and SACs under the Habitats 
Directive covering 8.3 % and 9.9 %, respectively (totalling 
10.06 %)  (EU  coverage:  14.3 %)  of  the  Netherlands’ 
territory. The coverage of the Dutch marine part of the 
North Sea by Natura 2000 sites is 16 456 km2 (26 % of the 
Dutch marine area) (EU coverage: 10.7 %) (36). 

The  latest  assessment  of  the  SCIs  in  the  Natura  2000 
network shows that there are potential insufficiencies in 
designation (even though there is no need to designate 
additional  sites),  as  some  habitats  and  species  do  not 
appear  in  the  designation  decrees  for  some  sites.  The 
amendment  decree  covering  100  SACs  has  been 
published, yet its adoption has been pending since 2018 
due  to  several  ongoing  appeal  cases.  In  addition,  the 
coverage  by  the  network  of  three  species  should  be 
ensured by adding them to the  standard data forms of 
the relevant sites. As regards SPAs, while good progress 
has  been  made  (with  a  new  site  designated  on 
8 December 2021), the classification of one marine site is 
still pending. Furthermore, a number of terrestrial SPAs 
are not designated for breeding populations of meadow 
bird  species  that  are  present  in  high  numbers  on  the 
sites,  such  as  the  black-tailed  godwit.  In  light  of  the 
infringement 
birds 
(INFR(2024)4014), launched in July 2024, additional SPAs 
would  need  to  be  classified  for  (breeding)  populations. 
Therefore,  the  Netherlands  still  has  to  complete  its 
Natura  2000  network,  in  particular  its  marine  network 
and its SPA network. 

on  meadow 

procedure 

Considering  both  Natura  2000  and  other  nationally 
designated  protected  areas,  the  Netherlands  legally 
protects  22.7 %  of  its  terrestrial  areas  (EU-27  average: 
26.1 %)  and  26.8 %  of  marine  areas  (EU-27  average: 
12.3 %). It strictly protects 1 % of terrestrial and marine 
areas (37). 

Noteworthy is the transformation of Millingerwaard, an 
area  that is located in the Natura 2000 site Rijntakken. 
This  public–private  partnership  project  successfully 

(32) 

(31)  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 7 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17  dashboard,  Annex I 
total,  19 December  2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
2019, 
Article 17 

19 December 

dashboard, 

(34) 

(33) 

(35) 

(36) 

(37) 

11 May 

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,  ‘Winter  population  trends’,  Article 12  dashboard,  last 
updated 
2023, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
https://dopa.jrc.ec.europa.eu/kcbd/EUBDS2030-
dashboard/?version=1. 
Eurostat dataset env_bio4, protected area percentage for 2022, 
2025, 
accessed 
https://ec.europa.eu/eurostat/databrowser/view/env_bio4/def
ault/table?lang=en. 

March 

2025 Environmental Implementation Review – The Netherlands 

 
 
reconciled  the  different  interests  of  all  parties  to  allow 
the conversion of intensively farmed land for large-scale 
nature  development  to  provide  protection  for  citizens 
that need to be evacuated frequently due to the flooding 
of the nearby river Waal. The project was selected as a 
finalist for the coveted Natura 2000 Award in 2024, and 
is  regarded  as  an  excellent  practical  example  of  the 
benefits of the Natura 2000 network (38). 

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

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

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

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

The  six-year  deadline  set  by  the  Habitats  Directive  to 
designate  SCI  as  SAC  and  establish  appropriate 
conservation  objectives  and  measures  has  expired  for 
two sites in the Netherlands. 

(38) 

(39) 

https://environment.ec.europa.eu/news/transformation-
millingerwaard-intensive-agriculture-and-clay-extraction-
natural-flood-protection-2024-03-14_en. 
EEA, State of Nature in the EU: Results from reporting under the 
Nature  Directives  (2013–2018),  Publications  Office  of  the 

The Netherlands  14 

Overall, three SCIs have not yet been designated as SACs. 
Definitive site-specific conservation objectives have been 
established  for  all  sites,  except  for  those  where 
designation  is  still  pending.  Two  of  them  already  have 
draft  objectives,  while  for  the  third  site  where  the  six-
year deadline has not yet expired there are no objectives 
yet. 

2025 priority actions 

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

the  Nature 

of 

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

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 (39). 

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. 

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

Luxembourg, 

Union, 

2020, 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
The Netherlands  15 

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

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2025, 
https://www.eea.europa.eu/en/analysis/maps-and-
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

February 

accessed 

2019, 

in 

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. 

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

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  2019–2024, 
for 
submission  in  July  2025.  Figures 10  and  11  show  the 
latest available data on conservation status. 

is  due 

The  results  of  reports  under  Article 17  of  the  Habitats 
Directive and Article 12 of the Birds Directive on progress 
towards  maintaining  or  restoring 
favourable 
conservation  status  of  species  and  habitats  are  key  to 
measuring the performance of Member States. 

the 

According to the report submitted by the Netherlands on 
the conservation status of habitats and species covered 
by  the  Article 17  of  the  Habitats  Directive  for  2013–
2018 (40),  the  share  of  assessments  for  habitats  with  a 
good conservation status in 2018 is more than the 3.85 % 
reported  during  the  previous  reporting  period  (2007–
2012).  As  regards  protected  species,  the  share  of 
assessments  of  good  conservation  status  in  2018  was 
26.25 %, more than the 22.78 % reported in the previous 
reporting period.  The shares of assessments  of poor or 
bad  conservation  status  in  2018  were  39 %  and  30 %, 
respectively (5 % are unknown), and are mostly wetland 
dependant.  Of  the  forest  habitats  protected  under  the 
EU  Nature  Directives,  none  have  a 
favourable 
conservation status. As far as birds are concerned, 58 % 
of the breeding species showed short-term increasing or 
stable population trends (for key wintering species, this 
figure was 62 %). 

At  the  same  time,  the  share  of  habitats  with  a  bad 
conservation  status  has  increased  to  53.85 %,  and  the 
share  of  assessments  for  species  of  bad  conservation 
status has decreased to 38.75 %. The main pressures are 
agriculture, human-induced changes in water regime and 
natural succession (41). 

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2025, 
https://www.eea.europa.eu/en/analysis/maps-and-

February 

accessed 

2019, 

in 

(40) 

(41) 

https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/conservation-status-and-trends. 
The  Netherlands  indicates  that  the  pressures  under  ‘natural 
processes’  is  mainly  due  to  ‘natural  succession’;  this  exerts 
pressures because succession is accelerated due to high nitrogen 
deposition.  The  country  also  indicates  that  ‘human-induced 

changes  to  the  water  regime’  relate  to  abstraction  from 
groundwater,  surface  water  or  mixed  water,  as  well  as 
agricultural  activities  generating  diffuse  pollution  to  surface 
water or groundwater. In addition, the Netherlands states that 
invasive  species  and  climate  change,  although  not  in  the  top 
three pressures, are also very relevant, because they are hard to 
deal with. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
charts/conservation-status-and-trends-article-17-national-summary-
dashboards-archived. 

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. 

The Netherlands made minor progress in improving the 
conservation  status  of  habitats  and  species,  and  as  a 
result  the  percentage  of  Annex I  habitat  types  with  a 
favourable  status  tripled  (from  two  types  to  six  types) 
compared  with  the  previous  reporting  period  under 
Article 17. With a total of 88 % of habitat types without a 
favourable  conservation  status,  the  Netherlands  is  still 
very  far  behind.  At  the  same  time,  while  there  was  a 
considerable decrease in the percentage of species with 
a bad status, dropping from over 50 % to below 39 %, the 
trend  for  habitats  was  the  opposite,  as  the  percentage 
with a bad status increased from 46 % to 54 %. One main 
reason for the deterioration of habitats is the continued 
very  significant  pressure  from  agriculture  leading,  for 
instance, to acidification and/or overfertilisation. In 2019 
alone,  80 %  of  unused  nitrogen  (equal  to  419 million 
kilograms) leached to the environment (42). In particular, 
excessive nitrogen deposition is affecting many sensitive 
habitats  protected  under  the  directive,  from  bogs  to 
forests (43),  as  well  as  changes  in  the  water  regime 
(drainage  and/or  pollution).  In  the  case  of  birds,  the 
Article 12 report indicates a minimal 1 % improvement in 
species  with  an  increasing  population  trend,  while  the 
population of 5 % more species is decreasing. This is in 
particular  of  major  concern 
for  meadow  birds, 
dependent on the agricultural landscape, and for which 
the Netherlands is a key breeding and wintering area. By 
2020, the breeding population of the flagship species and 
national  bird,  the  black-tailed  godwit,  had  dropped  by 
50 % since 2001. An EU pilot investigation was launched 
in 2017 on the decline of meadow birds and the alleged 
insufficiency of the measures taken. According to a 2021 
report by the Dutch Court of Audit, the decline has still 
not been halted despite measures being put in place and 
eight times more budget being made available to reverse 
the birds’ continued declining population trend (44). The 
Court of Audit’s report points to a major weakness: most 
measures are financial in nature and based on voluntary 
uptake  by  farmers.  This  means  that  the  measures 
implemented are not necessarily the best. On this basis 

(42) 

(43) 

(44) 

https://longreads.cbs.nl/nederland-in-cijfers-2021/hoeveel-
stikstof-produceert-de-veehouderij/. 
Scientific  reports  show  that  17  habitat  types  are  ‘sensitive’  to 
nitrogen and 28 habitat types are considered ’very sensitive’ to 
nitrogen (Wamelink, W., van Dobben, H., van der Zee, F. et al., 
Overzicht  van  kritische  depositiewaarden  voor 
stikstof, 
toegepast  op  habitattypen  en  leefgebieden  van  Natura  2000, 
2023, 
Wageningen 
https://edepot.wur.nl/633179). 
Partly as result of the Water Framework Directive, and related 
directives, such as the Nitrates Directive, water quality improved 

University 

Research, 

& 

The Netherlands  16 

and  based  on  the  latest  scientific  insights  on  meadow 
birds’ species in the Netherlands, notably the continuing 
decline  of  meadow  bird  populations,  the  Commission 
decided  to  open  an  infringement  procedure  on  24 July 
2024, based on Articles 2, 3 and 4 of the Birds Directive. 

In  2022  the  Commission  also  started  an  infringement 
case concerning the Netherlands' failure to comply with 
its  obligations  under  the  Habitats  Directive  to  monitor 
bycatch of harbour porpoises by fishing vessels.45 

2025 priority action 

•  Reinforce  action  for  habitats  and  species  with 
for 
increased 
and 

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

restoration  measures, 

coordination 

through, 

Recovery of ecosystems 

Agricultural ecosystems 

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

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”(46), 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. 

significantly, as did biodiversity in the water; see H2O, ‘Eindelijk 
goed  nieuws  over  biodiversiteit:  diversiteit  watergebonden 
toe’,  H2O  website,  23 August  2021, 
insecten  neemt 
https://www.h2owaternetwerk.nl/h2o-actueel/eindelijk-goed-
nieuws-over-biodiversiteit-diversiteit-watergebonden-insecten-
neemt-toe. 
INFR(2021)4062. 

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

food/vision-agriculture-and-food_en. 

(45)  
(46) 

2025 Environmental Implementation Review – The Netherlands 

 
 
The Netherlands  17 

In  2024,  the  CAP  basic  regulations  were  amended (48) 
regarding, inter alia, the standards for good agricultural 
and  environmental  condition  of  land.  These  changes 
removed the obligation for farmers benefiting from CAP 
area-related support to have a minimum share of 3–4 % 
of  non-productive  area  or  landscape  features  in  their 
farms.  The  amended  regulations  do  not  remove  the 
obligation  under  the  GAEC  8  to  maintain  existing 
landscape features and  set out, however, an obligation 
for Member States to establish and provide support for 
eco-schemes covering practices for the maintenance of 
non-productive areas, such as land lying fallow, and for 
the establishment of new landscape features on arable 
land. 

The  recently  adopted  Nature  Restoration  Regulation 
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 (49). 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  the  Figure  12,  it  is  estimated 
that 4.44 % of the Netherlands’ agricultural land area is 
used for organic farming. This is the fifth worst result in 
the  EU  and  substantially  lower  than  the  EU  average  of 
10.50 % (50).  The  Netherlands 
is  not  sufficiently 
contributing to achieving the target of 25 % of the EU’s 
agricultural land being used for organic farming by 2030. 

To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective.  

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

indicators 

certain  CAP 

focus  on 
result 
While 
interventions favouring sustainable agriculture practices 
that  regenerate  ecosystems,  the 
impact  of  these 
measures  is  difficult  to  be  assessed  ex  ante.  The  eco-
schemes,  agri-environmental  measures  and  climate 
commitments, as well as investments related to natural 
resources  and  biodiversity,  are  voluntary  for  farmers. 
However, at the level of Member States, at least 25 % of 
the funding allocation provided for must be reserved for 
each calendar year from 2023 to 2027 for eco-schemes. 

The  utilised  agricultural  area 
in  the  Netherlands 
increased from 1 841 600 ha  in 2012 to 1 845 750 ha in 
2015 and decreased to 1 804 370 ha in 2022 (47). 

Landscape  features  are  small  fragments  of  non-
productive  and  typically –  but  not  exclusively –  semi-
natural vegetation present in or adjacent to agricultural 
land.  They  provide  ecosystem  services  and  support  for 
biodiversity.  The  indicator  ‘share  of  agricultural  land 
covered  with  landscape  features’  is  the  ratio  between 
the  area  covered  by  landscape  features  and  the  area 
land.  Based  on  the  Land 
covered  by  agricultural 
Use/Cover  Area  Frame  Survey 
landscape  features 
estimates, the share of agricultural land covered by non-
productive  landscape  features  in  the  Netherlands  is 
7.2 %, above the EU average. At the EU level, landscape 
features cover 5.6 % of agricultural land. 

(47) 

(48) 

5 December 

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

(49) 

(50) 

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 – The Netherlands 

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

The Netherlands  18 

—  taking action for ecosystem restoration. 

The  proposed  directive  on  soil  monitoring  and 
resilience (51) 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. 

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. 

to 

further 

2025 priority actions 
• 
Step-up  efforts 
reduce  nitrogen 
deposition,  in  particular  in  Natura  2000  sites  with 
nitrogen-sensitive species and habitats. 
Implement  eco-schemes  and  agri-environmental 
measures 
the 
environmental needs of the Netherlands. 
Implement  and  scale  up  the  uptake  of  organic 
farming practices. 

practices 

address 

and 

to 

• 

• 

Soil ecosystems 

Soil is an essential, finite and extremely fragile resource. 
Its  increasing  degradation  poses  a  threat  to  EU  food 
resilience,  adaptation  and 
security  and  climate 
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; 

(51) 

(52) 

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 

Degradation  of  soil  ecosystems  encompasses  several 
aspects. The proposed directive requires Member States 
to  assess  soil  health  according  to  a  set  of  common 
indicators  and  to  define  the  necessary  regeneration 
measures. The area of soil that is sealed is an important 
factor in monitoring land-use change and represents an 
important pressure on nature and biodiversity. Other soil 
issues  related  to  land degradation  are  soil  erosion,  soil 
compaction, 
soil 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the 
the 
soil  degradation 
following 
Netherlands (52). 

soil  organic 

loss  of 

carbon, 

issues 

in 

national 

The greatest contributor to the Netherlands’ unhealthy 
soils is excessive nutrient concentrations, which impacts 
roughly 88 % of the total agricultural area, with 69 % of 
phosphorus 
the 
concentrations  above  50 mg/kg  and  63 %  containing 
nitrogen  concentrations  above  50 kg/ha.  16%  of  the 
national  territory  also  experiences  unsustainable  soil 
erosion by water, wind, tillage and harvest, representing 
63 % of the Netherlands’ cropland area. 

containing 

territory 

Grasslands 

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

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 – The Netherlands 

 
 
 
The Netherlands  19 

The  Netherlands  hosts  seven  freshwater  habitat  types 
covered  by  the  Habitats  Directive  and  seven  habitat 
types  belonging  to  the  group  ‘bogs,  mires  and  fens’. 
According  to  the  most  recent  report  produced 
in 
accordance with Article 17 of the Habitats Directive, only 
1 (out of the 14) of these habitat types has a favourable 
in  the  Netherlands.  The  main 
conservation  status 
pressures  and  threats 
identified  by  the  report  to 
freshwater  habitat  types  are  agriculture  (generating 
pollution), invasive alien species (IAS) or human-induced 
changes  in  the  water  regime  (water  abstraction);  five 
freshwater  habitat  types  are  considered  sensitive  to 
nitrogen  deposition.  For  bogs,  mires  and  fens,  the 
pressures and threats are human-induced changes in the 
water  regime  (water  abstraction),  mixed-source  air 
pollution,  natural  processes  or  agriculture.  All  bogs, 
mires  and  fens  are  considered  sensitive  to  nitrogen 
deposition. 

Forest ecosystems 

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

including  those  for  which  there 

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

In  2023,  the  Commission  proposed  a  new  forest 
monitoring law (55) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 

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

making  them  one  of  Europe’s  most  threatened 
ecosystems.  Extensively  managed  grasslands  include 
meadows, mountain pastures, dry calcareous grasslands 
and steppic grasslands. 

According  to  the  latest  reports,  all  (eight)  Annex I 
grassland habitat types present in the Netherlands have 
an unfavourable conservation status and only a quarter 
have  a  positive  status (53).  This  is  mainly  due  to  a 
combination of different pressures and threats, such as 
agriculture 
pollution, 
application of fertiliser), human-induced changes in the 
water regime, abandonment of grassland management, 
or  natural  processes 
(vegetation  succession).  All 
grassland habitat types are considered sensitive or very 
sensitive 
nitrogen 
to 
deposition (54). 

generating 

excessive) 

(activities 

(impacts 

air 

of 

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 of the habitats 
directive. Drained peatlands under intensive agricultural 
use  constitute  only  3 %  of  the  EU’s  utilised  agricultural 
area. At the same time, they are responsible for 25 % of 
the  greenhouse  gas  (GHG)  emissions  from  the  EU’s 
agricultural  sector.  Restoring  peatlands  brings  multiple 
benefits,  as  peatlands  improve  water  retention  and 
quality,  store  carbon,  reduce  GHG  emissions  and 
increase biodiversity. 

(53) 

nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Grasslands&country=NL&region=. 
(54) 
https://wetten.overheid.nl/BWBR0036751/2021-07-01. 
(55)   Proposal for a Regulation of the European Parliament and of the 
Council  on  a  monitoring  framework  for  resilient  European 
2023, 
forests, 

COM(2023)728, 

November 

22 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
The Netherlands  20 

territory in  2020 (59).  The  situation  of  forest  habitats 
protected  under  the  Habitats  Directive  is  particularly 
worrying,  as  100 %  have  a  bad  or  poor  status (60).  The 
report  under  the  directive  indicates  that  this  is  mainly 
due  to  agriculture,  non-native  species,  removal  of 
dead/dying trees or changes in the water regime. 

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

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

. 

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

forests. 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (56).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

Contamination  can  severely  reduce  soil  quality  and 
threaten human health and the environment. The latest 
available estimates based on information from Member 
States (57)  indicate  that  potentially  polluting  activities 
have  taken  or  are  still  taking  place  on  approximately 
2.8 million  sites  in  the  EU.  At  the  EU  level,  650 000  of 
these sites have been registered in national or regional 
inventories.  65 500  contaminated  sites  have  already 
been  remediated.  The  Netherlands  has  registered  181 
sites  with  either  current  or  past  potentially  polluting 
activities  and  has  already  remediated  or  applied 
aftercare measures to 83 of these. 

Soil organic matter plays an important role in the carbon 
cycle and in climate change. Soils are the second largest 
carbon sink in the world after oceans. 

As  regards  capacity  building  on  this 
issue,  the 
Netherlands  attended  a  Technical  Assistance  and 
Information  Exchange  Environmental  Implementation 
Review (TAIEX-EIR) PEER 2 PEER workshop on sustainable 
urban development on 26–27 March 2019 in Belgium. In 
addition,  a  TAIEX-EIR  PEER  2  PEER  workshop  on 
maintaining and enhancing ecosystem services in urban 
regions  was  carried  out  on  4–5 July  2019 
in  the 
Netherlands. 

Forests are important carbon sinks and conserving them 
is vital if the EU is to achieve climate neutrality by 2050. 

Of  the  27 %  of  EU  forest  area  protected  under  the 
Habitats Directive, fewer than 15 % of assessments result 
in  favourable  conservation  status (58).  The  percentage 
identifying  habitats  with  a  bad  conservation  status 
increased from 27 % to 31 %  in the EU, compared  with 
2015.  In  the  Netherlands,  forests  covered  11 %  of 

(56) 

(57) 

(58) 

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. 
European Commission: Joint Research Centre, Status of Local 
Soil Contamination in Europe: Revision of the indicator ‘Progress 
in the management contaminated sites in Europe’, Publications 
Office of the European Union, Luxembourg, 2018, 
https://publications.jrc.ec.europa.eu/repository/handle/JRC107
508. 
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. 

(59) 

(60) 

(61) 

the 

base: 

Accompanying 

EEA, forest information system for Europe, ‘Countries – FISE 
country factsheets’, forest information system for Europe 
website, https://forest.eea.europa.eu/countries. 
Commission staff working document – Stakeholder consultation 
and 
document 
evidence 
Communication 
from  the  Commission  to  the  European 
Parliament,  the  Council,  the  European  Economic  and  Social 
Committee and the Committee of the Regions – New EU forest 
strategy  for  2030,  SWD(2021) 652  final  of  16 July  2021, 
https://eur-lex.europa.eu/legal-
content/NL/TXT/?uri=CELEX:52021SC0652.https://ec.europa.eu
/environment/pdf/forests/swd_forest_strategy.pdf 
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. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
(EUDR) (62)  entered 

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

force 

into 

2025 priority actions 

• 

• 

Improve conservation status of forests by promoting 
sustainable 
forest  management  and  ensuring 
compliance  with  the  Habitats  Directive  before 
granting/renewing permits for forest logging. 
Implement  peatland  conservation  and  restoration 
measures and include such measures and objectives 
in the national restoration plans. 

•  Bring  levels  of  nitrogen  deposition (64)  under  the 
critical  threshold  to  allow  forest  habitat  types 
protected  under 
to 
recover.ion51 

the  Habitats  Directive 

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,  and  these  are  being  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
reporting, 
in  accordance  with  the  MSFD  and  the 
Commission  GES  decision (65),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold  values  for  the  descriptors  in  the  MSFD  that 

The Netherlands  21 

may  have  been  established  in  cooperation  with  other 
Member States at the EU or regional level (66). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (67). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
levels  of 
work 
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 14: Level of adequacy of the Netherlands’ 
updated programme of measures under Article 13 of 
the MSFD (2022 reporting exercise) 

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

The  Netherlands’  updated  programme  of  measures 
shows varying levels of adequacy across descriptors. 

(62) 

Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(63)   The law will apply to large and medium-sized companies starting 
on  December  30,  2025,  and  to  micro  and  small  enterprises 
starting on June 30, 2026. 
https://wetten.overheid.nl/BWBR0036751/2021-07-01. 
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 

(64) 
(65) 

(66) 

(67) 

methods for monitoring and assessment, and repealing Decision 
2010/477/EU 
(OJ  L 125,  18.5.2017,  p. 43),  https://eur-
lex.europa.eu/eli/dec/2017/848/oj/eng. 
Communication from  the  Commission –  Commission  notice  on 
the threshold values set under the Marine Strategy Framework 
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. 
Communication from  the  Commission –  Commission notice  on 
recommendations on the 2020 updated reports for Article 11 of 
the  Marine  Strategy  Framework  Directive  (2008/56/EC)  (OJ  C, 
10.5.2023), 
C/2023/2203, 
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
for  eutrophication 

Notable  progress  was  achieved  for  sea-floor  integrity 
(D6)  and  hydrographical  changes  (D7),  while  gaps 
remained  unaddressed 
(D5), 
contaminants  (D8)  and,  in  particular,  food  webs  (D4). 
Except for biodiversity (D1), sea-floor integrity (D6) and 
marine litter (D10), no new measures were put in place. 
Therefore, progress depended solely on measures arising 
from other legislative and policy frameworks. 

For D4, while the Netherlands stated that GES would be 
achieved  through  the  implementation  of  D1  and  D6 
is  a  need  for  descriptor-specific 
measures,  there 
insufficiently 
measures,  as  key  pressures  remain 
covered. 

2025 priority action: 

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

Prevention and management of 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 
IAS 
Regulation) aims to prevent, minimise and mitigate the 
adverse impacts of IAS on biodiversity. It focuses action 
on a list of IAS of EU concern (the ‘Union list’), which is 
regularly updated (69). 

(EU)  No 1143/2014 

(the 

(68) 
(69) 

(70) 

(71) 

In accordance with Article 17 of Directive 2008/56/EC. 
Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016 adopting a list of  invasive alien species of Union concern 
pursuant  to  Regulation  (EU)  No 1143/2014  of  the  European 
Parliament  and  of  the  Council  (OJ  L 189,  14.7.2016,  p. 4),  as 
amended  by  Commission 
Implementing  Regulations  (EU) 
2017/1263,  (EU)  2019/1262  and  (EU)  2022/1203,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN. 
Commission Implementing Regulation (EU) 2022/1203 of 12 July 
2022  amending  Implementing  Regulation  (EU)  2016/1141  to 
update  the  list  of  invasive  alien  species  of  Union  concern  (OJ 
L 186,  13.7.2022,  p. 10),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32022R1203. 
Regulation (EU) No 1143/2014 of the European Parliament and 
of  the  Council  of  22 October  2014  on  the  prevention  and 
management  of  the  introduction  and  spread  of  invasive  alien 
species (OJ L 317, 4.11.2014, p. 35). 

The Netherlands  22 

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

The IAS  Regulation (71) currently lists 88 species subject 
to  restrictions  on  keeping,  importing,  selling,  breeding, 
growing  and  releasing  into  the  environment.  Member 
States are required to take measures to (i) prevent the 
introduction of IAS, (ii) ensure early detection and rapid 
eradication  of  IAS  and  (iii)  manage  species  that  are 
already widespread on their territory. 

This  aligns  with  target 6  of  the  GBF  to  reduce  the 
introduction of IAS by at least 50 % by 2030 and minimise 
their impact. 

Preventing  the  introduction  and  spread  of  IAS,  and 
managing  them, 
including  through  eradication  and 
control,  can  result  in  a  substantial  cost  saving.  Studies 
estimate  that  the  total  cost  of  IAS  in  Europe  (damages 
and  management)  amounted  to  EUR 116.61 billion 
between  1960  and  2020 (72).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (73),  and  at 
USD 423 billion annually at the global level (74). 

The BDS aims to manage recognised IAS and decrease the 
number of ‘red list’ species they threaten by 50 %. 

According to a report (75) on the review of the application 
of the IAS Regulation for 2015–2018, the implementation 
of the IAS Regulation is already starting to deliver on its 
objectives,  such  as  creating  a  coherent  framework  for 
addressing IAS at the EU level and increased awareness 
of the problem of IAS, including among the public. At the 
same time, the above report identified some challenges 
and areas for improvement. Given that the deadlines for 
implementing  the  various  obligations  of  the 
IAS 
Regulation applied gradually between July 2016 and July 
2019,  it  is  premature  to  draw  conclusions  on  several 
aspects of the implementation of the IAS Regulation. 

The total number of IAS of Union concern in the country 
is 59. This includes 37 species recorded in the previous 

(72)  Haubrock, P. J., Turbelin, A. J., Cuthbert, R. N. et al., ‘Economic 
costs of invasive alien species across Europe’, NeoBiota, Vol. 63, 
2021, pp. 153–190. 

(74) 

and 

Ecosystem 

(Intergovernmental 

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

(73)  Henry, M., Leung, B., Cuthbert, R. N. et al., ‘Unveiling the hidden 
economic  toll  of  biological  invasions  in  the  European  Union’, 
Environmental Sciences Europe, Vol. 35, No 1, 2023, p. 43. 
Platform 
IPBES 
Biodiversity 
Summary 
Policymakers – 
https://www.ipbes.net/document-library-catalogue/summary-
policymakers-invasive-alien-species-assessment. 
Report  from  the  Commission  to  the  European  Parliament  and 
the Council on the review of the application of Regulation (EU) 
No 1143/2014 of the European Parliament and of the Council of 
22 October  2014  on  the  prevention  and  management  of  the 
species, 
invasive 
introduction 
COM(2021) 628 
final  of  13 October  2021,  https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A52021DC0628. 

spread  of 

alien 

and 

(75) 

2025 Environmental Implementation Review – The Netherlands 

 
 
EIR  (2021)  and  22  additions.  Of  these  22  additions,  12 
were already on the Union concern list in 2021, and 10 
were  added  later  under  Commission  Implementing 
Regulation (EU) 2022/1203. 

For the distribution of IAS of EU concern, see Figure 15. 

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

2025 priority actions 

• 

• 

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

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 (76) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 

The Netherlands  23 

biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (77). 

The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (78)  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 Dutch Atlas of Natural Capital was launched in 2015. 
All  content  has  now  been  translated  into  English.  To 
improve  the  quality  of  data,  the  Netherlands  natural 
capital  model  was  developed  based  on  a  national  land 
cover and ecosystem units map. The model consists of a 
set  of  input  maps,  a  simulation  tool  and  output  maps, 
which  define  the  relationship  between  the  ecosystems 
and the services they provide. The services are simulated 
at a 100 m and a 10 m grid scale. The applicability of the 
maps was tested in various pilots studies, in cooperation 
with various stakeholders. For communication purposes, 
a brochure on the Dutch Atlas of Natural Capital has been 
developed. 

In  2016,  the  TEEB  City  project  delivered  a  tool  that 
calculates  the  monetary  value  of  green  areas  in  cities. 
The  tool  has  been  further  developed  into  a  high-
resolution  map-based 
the  Green  Benefits 
tool – 
Planner – to analyse and predict the benefits (and costs) 
of different scenarios for green infrastructure in an urban 
environment (79),  which  is  being  implemented  in  green 
infrastructure planning in a growing number of cities. The 
Netherlands 
Agency 
conducted an extensive programme from 2014 to 2016 
involving conceptual analysis, cross-sectoral evaluations 
and case studies, all focusing on the application of  The 
Economics  of  Ecosystems  and  Biodiversity  model  in 
practice.  After  successful  pilots  (phase I) 
in  some 
municipalities  and  provinces,  the  Central  Bureau  for 
Statistics,  together  with  Wageningen  University  & 
Research, developed a national natural capital account in 

Environmental 

Assessment 

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

Assessment – 

Summary 

(77) 

for 

/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, 
https://eur-
COM(2022) 329 
lex.europa.eu/legal-content/EN/TXT/?uri=COM:2022:329:FIN. 
https://atlasnatuurlijkkapitaal.nl/groene-baten-planner. 

11 July 

2022, 

final 

of 

(78) 

(79) 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
2018, building on the System of Environmental Economic 
Accounting (SEEA) – Experimental Ecosystem Accounting 
and MAES frameworks. This account was the first of its 
kind  in  the  Netherlands,  and  was  updated  in  2021. 
Further  work  is  under  way  to  improve  and  extend  this 
account, to test its applicability to national and regional 
planning  and  to  populate  indicators  in  the  national 
Monitor of Well-being and the Sustainable Development 
Goals. 

In  2016,  an  international  conference  on  natural  capital 
(‘Let’s  talk  business!’)  took  place  in  The  Hague.  In 
addition,  the  Wealth  Accounting  and  the  Valuation  of 
Ecosystem Services policy forums in 2016 and 2017 took 
place in The Hague. 

In 2018, a national guide was published on accounting for 
in 
impacts  on  ecosystems  and  ecosystem  services 
societal cost–benefit analyses. 

The  Netherlands  has  provided  up-to-date  information 
and  progress  has  been  recorded  since  January  2016 
is  based  on  27 
(Figure 16).  This  assessment 
implementation  questions  and  is  updated  every  six 
months. 

Figure 16: Esmeralda MAES barometer, January 2016–
March 2021 

Source:  European  Commission:  Joint  Research  Centre,  Publications 
2021, 
Office 
https://data.europa.eu/doi/10.2760/846428, p. 80. 

Luxembourg, 

European 

Union, 

the 

of 

Figure 17: SEEA – Ecosystem Accounting barometer, 
September 2021 

NB: The Mapping and Assessment for Integrated Ecosystem Accounting 
uses  the  SEEA –  Experimental  Ecosystem  Accounting  as  the 
for  ecosystem  accounting.  The  SEEA – 
methodological  basis 

The Netherlands  24 

integrated  and 
Experimental  Ecosystem  Accounting 
comprehensive  statistical  framework  that  is  based  on  five  core 
accounts: ecosystem extent, ecosystem condition, ecosystem services 
and monetary ecosystem assets. 

is  an 

Source: Mapping and Assessment for Integrated Ecosystem Accounting 
(EU Horizon 2020 project) portal, 2022. 

level  of  expertise 

The  Netherlands  has  a  high 
in 
ecosystem  accounting.  This  is  reflected  in  the  high 
number of accounts published. The extent and condition 
accounts are available at the regional and national levels. 
A wide variety of ecosystem services are incorporated in 
the  Netherlands’  accounts  on  (i)  ecosystem  assets,  (ii) 
biophysical assets and (iii) monetary supply and use for 
ecosystem services. These accounts were set up in 2013, 
2018 and 2020, thus enabling trend analyses. On specific 
issues,  accounts  are  published  on  carbon  and 
biodiversity, and a marine account at the national level is 
being developed. 

revision  process 

The Netherlands faces difficulties similar to those often 
highlighted in international meetings, for example during 
the  SEEA –  Ecosystem 
for 
the 
Accounting  guidelines.  It  is  actively  trying  to  engage 
policymakers  and  other  stakeholders  in  the  accounting 
process  and  looking  for  relevant  key  indicators  and 
information on the usage of the accounts. Their marine 
and biodiversity accounts need further development and 
still have some data gaps. 

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (77). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

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

An  important  line  of  action  has  been  to  stimulate 
business and financial institutions to account for natural 
capital 
in  their 
impacts,  dependencies  and  risks 
operations,  in  order  to  fulfil  their  corporate  social 
responsibilities  and  to  develop  innovative  and  more 
sustainable  services  and  supply  chains.  From  2017 
onwards, a government-funded ‘societal natural capital 
programme’  was  set  up  and  implemented  by  CSR 
facilitate 
Netherlands 
businesses  in  different  economic  sectors  to  respond  to 
these  challenges.  Moreover,  the  development  of 
cooperation  on  protocols,  tools  and  data  for  natural 
capital and biodiversity accounting in the financial sector 
has  been  strongly  supported.  To  this  end,  the  Dutch 
government  has  also  invested in improving the quality, 

stimulate  and 

inspire, 

to 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
The Netherlands  25 

usability and number of certified data in the Ecosystem 
Services  Valuation  Database (80)  (or  The  Economics  of 
Ecosystems and Biodiversity database). 

The MAIA project can facilitate the exchange of methods 
and knowledge between members and the Netherlands 
is eager to support other partners. Other specific needs 
improved  data  viewer  for 
include  developing  an 

interested  stakeholders  who  are  unable  to  use  the  GIS 
datasets. 

Three  Dutch  organisations  are  members  of  the  EU 
Business  &  Biodiversity  Platform,  one  business 
sustainability  network  and  two  business-linked  public 
authorities. 

(80) 

https://www.esvd.info/. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
The Netherlands  26 

3. Zero pollution 

Clean air

EU  clean  air  policies  and  legislation  have  successfully 
reduced  emissions  of  key  air  pollutants  and  significantly 
improved  air  quality,  which  is  now  moving  towards  the 
levels  recommended  by  the  World  Health  Organization 
(WHO).  This  has  resulted  in  clear  health  benefits  and 
reduced adverse impacts on ecosystems and biodiversity. 
However, to achieve the WHO-recommended levels, more 
efforts  are  needed,  including  full  compliance  with  EU 
legislation.  To  guide  these  efforts,  the  EU  zero  pollution 
action plan sets targets for 2030 relative to 2005. These 
are to reduce the health impacts of air pollution by 55 % 
and  to  reduce  the  EU  ecosystems  threatened  by  air 
pollution by 25 %. 

The EU has developed a comprehensive suite of air quality 
policies (81).  These  set  health-based  EU  air  quality 
standards (82)  and  stipulate  Member  States’  national 
emission  reduction  commitments (83)  for  several  air 
pollutants. 

The air quality in the Netherlands is generally good with 
some exceptions. 

The  latest  available  annual  estimates  (for  2021)  by  the 
European  Environment  Agency (84)  for  the  Netherlands 
attribute 5 700 deaths each  year (or 59 000 years of life 
lost  (YLL))  to  fine  particulate  matter  (PM2.5) (85);  1 800 
deaths  each  year  (or  18 300  YLL)  to  nitrogen  dioxide 
(NO2) (86);  and  430  deaths  each  year  (or  4 700  YLL)  to 
ozone (87). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly  in  the  Netherlands  since  2005,  while  GDP 
growth  has  continued  (see  Figure 18).  According  to  the 
inventories submitted under Article 10(2) of the National 
Emission Reduction Commitments Directive (NECD) (88) in 
2024,  the  Netherlands  met 
its  emission  reduction 
commitments  for  2020–2029  for  air  pollutants  nitrogen 

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

The  Netherlands  submitted  its  updated  national  air 
pollution control programme (NAPCP) to the Commission 
on 5 December 2023. 

Figure 18: Emission trends of main pollutants / GDP in 
the Netherlands (%), 2005–2022 

200%

150%

100%

50%

0%

NH₃

PM2.5

NMVOC

SO₂

NOₓ

GDP

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

2024, 

(81) 

(82) 

(83) 

(84) 

(85) 

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. 

(86)  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. 

(87) 

(88)  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 – The Netherlands 

 
 
 
Figure 19: PM2.5 and NOx emissions by sector in the 
Netherlands (%), 2022 

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
3,51%

23,31%

NOₓ

0,15%

56,47%

33,56%

6,40%

34,23%

10,30%

1,81%

3,59%

10,03%

16,64%

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) (89) were registered in the Netherlands (90). 

In  the  2022  EIR,  the  Netherlands  received  two  priority 
actions.  The  first  priority  action  was  to  further  reduce 
emissions in the context of the NAPCP. The Netherlands 
has  made  substantial  progress  on  this,  as  the  latest 
reported  data  show  that  the  2020–2029  emission 
reduction commitments have been met, and the emission 
reduction commitments for 2030 onwards are projected 
to be reached. The second priority action was to ensure 
full compliance with EU air quality standards and maintain 
downward emission trends. Based on the latest data, the 
Netherlands  has 
fulfilled  this  priority  action.  Full 
compliance has been ensured for all limit values and target 
values.  Additionally,  since  2019,  downward  emission 
trends have been reported for all main pollutants. 

(89)  Directive  2008/50/EU  of  the  European  Parliament  and  of  the 
Council of 21 May 2008 on ambient air quality and cleaner air for 
Europe 
https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0050. 
Eionet 
EEA, 
(https://cdr.eionet.europa.eu/). 

Repository 

11.6.2008, 

Central 

L 152, 

p. 1), 

Data 

(90) 

(OJ 

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

The Netherlands  27 

2025 priority actions 

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

of air pollutants. 

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

Industrial emissions 

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

—  prevent and manage waste; 
— 

improve  energy  and  resource  efficiency,  including 
water; 

—  contribute to decarbonisation. 
The  cornerstone  of  the  policy  is the  Industrial  Emissions 
Directive (IED), which was revised in 2024 (91). The revision 
improves the directive’s contribution to the zero pollution 
objective. It has a strong focus on innovation, and builds 
solid  links  between  depollution,  decarbonisation  and 
circularity, making it a key regulatory tool to accompany 
the green transformation of EU industry by 2050. 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (92).In  the  Netherlands,  about  4 400  installations 
were covered by the IED in 2022, with more than half of 
them  (61 %)  being  installations  for  intensive  rearing  of 
poultry  or  pigs.  The  other  main  sectors  covered  are  the 
waste  management  sector  (21 %),  the  food  and  drink 
industry  (6 %),  the  chemical  sector  (4 %)  and  the  metals 
sector (3 %). 

Figure 20  shows  the  damage  to  health  and 
the 
environment due to the main industrial air pollutants. As 
this  depends  on,  among  other  factors,  the  size  of  the 
industrial  sector  in  each  Member  State,  the  figure  also 
shows  the  ratio  between  the  damage  and  the  industrial 
activity  (expressed  in  gross  value  added  (GVA)),  which 
gives  an  indication  of  the  emissions  ‘intensity’.  The 
Netherlands has the eighth highest damage in the EU and 
comes  10th  for  the  emissions  intensity,  below  the  EU 
average of EUR 27.5/EUR 1 000 GVA. The main industrial 

emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. 
EEA, 
Portal, 
Industrial 
European 
https://industry.eea.europa.eu/, 2022 being the baseline year for 
all reports. 

Emissions 

(92) 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
The Netherlands  28 

contributors  to  emissions  to  air  (93)  are  the  energy  and 
chemicals  sector  for  NOX  emissions,  the  energy-refining 
sector for SO2 and the metals sector for heavy metals. 

Figure 20: Industrial air pollution damage and intensity 
per Member State, 2021 

below  the  EU  average  intensity  of  0.864 kg  /billion  EUR 
GVA).  As  shown 
industrial 
contributor to emissions to water in the Netherlands is the 
waste  management  sector  for  heavy  metals,  nitrogen, 
total organic carbon and phosphorus. 

in  Figure 23,  the  main 

Figure 22: Industrial releases and intensity of heavy 
metals to water per Member State, 2022 

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

2024, 

Overall, the industrial emissions to water in the EU have 
decreased  over  time  for  all  the  main  pollutants.  On 
average in the EU, they appear to be decoupled from the 
industrial  activity  which  has  increased  over  the  same 
period (expressed in GVA), as shown in Figure 20. 

Figure 21: Industrial releases of pollutants to water and 
industrial activity in the EU-27 

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

Figure 23: Relative releases to water from industry in 
the Netherlands (%), 2022 

100%

75%

50%

25%

0%

Heavy Metals
Ecotoxicity

Heavy Metals
Human
Toxicity

Polycyclic
aromatic
hydrocarbons
(PAHs)

Total nitrogen Total organic
carbon (TOC)

Total
phosphorus

Chemicals
Food and drink
Landfill
Pulp, paper and wood

Ferrous metal
Incineration with energy recovery
Other waste management
Refineries

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

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

Concerning the Netherlands in particular, Figure 21 shows 
the industrial emissions of heavy metals to water, taking 
into account the human toxicity of each metal, as well as 
emissions ‘intensity’, based on the ratio with the industrial 
activity (expressed in GVA). The Netherlands has the 8th 
highest  amount  of  emissions  of  heavy  metals  to  water, 
and  is  in  12th  position  for  emission  intensity  (slightly 

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 
information  and  participate  in  the  approval  process  for 
potentially  polluting  installations.  Thus,  the  public  and 
non-governmental  organisations 
(NGOs),  alongside 
competent authorities, play a role in ensuring compliance 
of  these  permits  with  EU  legislation.  The  IED  contains 
mandatory  requirements  on  environmental  inspections, 
requiring a site visit to take place at least every 1–3 years, 
using  risk-based  criteria.  In  addition,  IED  enforcement 

(93) 
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 – The Netherlands 

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

set 

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

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

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

In  2022,  the  Netherlands  received  priority  actions  to 
address pollution from  the metal sector, especially  from 
the  Tata  Steel  plant,  and  to  improve  reporting  to  the 
European Pollutant Release and Transfer Register. 

Data are not yet available to assess progress towards the 
first  priority  action;  nevertheless,  Tata  Steel  remained 
among the 30 (19th) iron and steel plants with the highest 
damage  costs  due  to  pollution  in  2021 (94).  As  regards 
Industrial  Emissions  Portal 
reporting  under 
Regulation (95) (replacing the European Pollutant Release 
and Transfer Register Regulation), the priority action has 
been fulfilled, as the data are reported on time. 

the 

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. 

(94) 

(95) 

EEA, The costs to health and the environment from industrial air 
in  Europe –  2024  update,  briefing  No 24/2023, 
pollution 
Copenhagen, 
2024, 
https://www.eea.europa.eu/publications/the-cost-to-health-
and-the. 
Regulation (EU) 2024/1244 of the European Parliament and of the 
Council of 24 April 2024 on reporting of environmental data from 
industrial installations, establishing an industrial emissions portal 
and  repealing  Regulation  (EC)  No 166/2006  (OJ  L,  2024/1244, 
2.5.2024), https://eur-lex.europa.eu/eli/reg/2024/1244/oj/eng. 

The Netherlands  29 

•  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: 
—  control  major-accident  hazards  involving  dangerous 

— 

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

—  continuously 

improve 

the 

prevention 

of, 

preparedness for and response to major accidents. 
The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive) (96). 

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 (97) and the report by the 
Netherlands  on  the  implementation  of  the  Seveso III 
Directive for 2019–2022 (98). 

In  the  Netherlands,  in  2024,  among  the  384  Seveso 
establishments,  163  were  categorised  as 
lower-tier 
establishments  and  221  as  upper-tier  establishments 
(UTEs),  based  on  the  quantity  of  hazardous  substances 
likely  to  be  present.  UTEs  are  subject  to  more  stringent 
requirements.  The  change  in  the  number  of  Seveso 
establishments is presented in Figure 24. 

Figure 24: Number of Seveso establishments in the 
Netherlands, 2018, 2022 and 2024 

NB: LTE, lower-tier establishment. 

(96)  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. 
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. 

(97) 

(98) 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
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. 

Member  States  are  required  to  draw  up  external 
emergency plans (EEPs). These EEPs are essential to allow 
proper  preparation  and  effective  implementation  of  the 
necessary  actions  to  protect  the  environment  and  the 
population  should  a  major  industrial  accident  occur. 
According  to  the  Netherlands,  in  2022,  an  EEP  was 
required for 214 UTEs. In the same year, 194 UTEs had a 
plan and 186 of these had been tested over the previous 
three years. The summary is shown in Figure 25. 

Figure 25: Situation regarding EEPs in the Netherlands, 
2022 

2022, 

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

The information for the public referred to in  Annex V to 
the  Seveso III  Directive  is  permanently  available  for  all 
UTEs 
in  the  Netherlands.  This  applies  especially  to 
information on how the public concerned will be warned 
in  the  event  of  a  major  accident;  the  appropriate 

(99) No data available for Greece 

The Netherlands  30 

behaviour to take in the event of a major accident; and the 
date of the last site visit. 

The  shares  of  UTEs  for  which  information  on  safety 
measures  and  requisite  behaviours  was  actively  made 
available to the public in 2022 in the EU-27 are presented 
in  Figure 26(99).  This  provision  on  knowledge 
is  an 
important  provision  of  the  Seveso III  Directive,  as 
information  may 
awareness  by  the  public  of  this 
ameliorate  the  consequences  of  a  major 
industrial 
accident. 

Figure 26: 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 
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. 

In  2022,  the  Netherlands  received  a  priority  action  to 
strengthen 
to  ensure 
control  and  enforcement 
compliance with Seveso III Directive provisions, especially 
those  on  EEPs.  Data  reported  on  the  implementation  of 
the directive for 2019–2022 show that the number of EEPs 
established for UTEs in the Netherlands is still insufficient, 
as well as the number of EEPs tested. 

2025 priority action 

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

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
The Netherlands  31 

updating  EEPs,  at  intervals  of  no  more  than  three 
years. 

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. 

Mercury Regulation 

The  Mercury  Regulation  establishes  measures  and 
conditions concerning the use and storage of and trade in 
mercury,  mercury  compounds  and  mixtures  of  mercury, 
the manufacture and use of and trade in  mercury-added 
products and the management of mercury waste, in order 
to ensure a high level of protection of human health and 
the  environment  from  anthropogenic  emissions  and 
releases of mercury and mercury compounds. The revision 
of the Mercury Regulation adopted in 2024 sets out rules 
to address the last intentional uses of mercury in the EU 
by  phasing  out  the  use  of  dental  amalgam  by  1 January 
2025 except when deemed strictly necessary by the dental 
practitioner  based  on  the  specific  medical  needs  of  the 
patient,  and  prohibiting  the  manufacture  and  export  of 
additional mercury-containing lamps from 1 January 2026 
or 1 January 2027 (depending on the lamp category). 

in  place 

Measures  should  have  been  put 
in  the 
Netherlands to ensure a socially and economically sound 
phase-out  of  dental  amalgam,  including  the  adequate 
reimbursement  of  the  alternatives  through  the  health 
insurance scheme and the training of dental practitioners. 
The Commission is monitoring whether the phase-out has 
taken  place  under  the  terms  and  conditions  of  the 
regulation. The Netherlands 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 (100)  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, 

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 (101). 

In  the  Netherlands,  environmental  noise  is  estimated  to 
cause at least around 680 cases of ischaemic heart disease 
annually (102)  and  some  130 000  people  to  suffer  from 
disturbed sleep(103). 

Based  on  the  latest  set  of  information  analysed,  the 
Netherlands have completed its noise mapping of roads, 
railways  and  airports,  while  noise  mapping  of 
agglomerations remains incomplete. 

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 actions 

•  Complete noise mapping 
•  Complete  and 
management. 

implement  action  plans  on  noise 

Water quality and management 

EU  legislation  and  policy  requires  that  the  impact  of 
pressures  on  transitional,  coastal  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. 

(100)  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. 

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

(102)  These figures are an estimation by the EEA based on (i) the data 
reported  by  Member  States  on  noise  exposure  covered  by 
Directive 2002/49/EC for the round of noise mapping of 2022 ; (ii) 

European  Topic  Centre  on  Air  Pollution,  Transport,  Noise  and 
Industrial  Pollution  (ETC/ATNI),  Noise 
Indicators  under  the 
Environmental Noise Directive 2021: Methodology for estimating 
missing  data,  Eionet  report  ETC/ATNI  No 2021/06,  Kjeller,  2021; 
and  (iii)  the  methodology  for  health  impact  calculations  in 
European  Topic  Centre  on  Air  Pollution  and  Climate  Change 
Mitigation  (ETC/ACM),  Implications  of  environmental  noise  on 
in  Europe,  Eionet  report  ETC/ACM 
health  and  wellbeing 
No 2018/10, 
2018, 
https://www.eionet.europa.eu/etcs/etc-atni/products/etc-atni-
reports/eionet_rep_etcacm_2018_10_healthimplicationsnoise. 

Bilthoven, 

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

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

2025 Environmental Implementation Review – The Netherlands 

 
 
  
Water Framework Directive 

The Water Framework Directive (104) is the cornerstone of 
EU water policy (105). The Water Framework Directive and 
other  water-related  directives (106)  form  the  basis  of 
sustainable and integrated water management in the EU. 
They  aim  to  achieve  a  high  level  of  protection  of  water 
resources,  prevention  of 
further  deterioration  and 
restoration  to  good  status.  These  objectives  are  very 
important 
the  EU’s  competitiveness,  strategic 
autonomy  and  security,  yet  have  become  even  more 
challenging  in  the  face  of  climate  change  affecting  our 
precious water resources. 

for 

The Water Framework Directive establishes a procedural 
framework for reaching good surface water ecological and 
chemical  status  and  good  groundwater  quantitative  and 
chemical status. This implies monitoring and classification 
of all waterbodies, assessment  of pressures and impacts 
and identification of the most cost-effective measures to 
achieve the objectives of the directive. The directive dates 
from 2000 and set an initial deadline of 2015 for achieving 
its objectives, with the option to extend the deadline to 
the  end  of  2027.  Every  six  years,  Member  States  must 
report their river basin management plans (RBMPs) to the 
Commission. They should cover river basin districts in their 
countries,  some  of  which  may  be  shared  with  other 
countries. The Commission has assessed the third cycle of 
RBMPs, which were to be submitted by March 2022, and 
reported  its  findings  to  the  European  Parliament  and  to 
the Council on 4th February 2025(107). 

The  Netherlands’  four  river  basin  districts  include  745 
surface  waterbodies  and  23  groundwater  bodies.  Most 
surface waterbodies are heavily modified (286) or artificial 
(435), while only 24 are natural. 

The Netherlands  32 

modified/artificial,  while  not  significantly  affecting  these 
activities 

It follows from the assessment of the third RBMPs that the 
ecological  status/potential  of  surface  waterbodies  and 
their  chemical  status  have  deteriorated  compared  with 
the  statuses  reported  in  the  second  RBMPs  (covering 
2015–2021). 

Figure 27: Ecological status/potential of surface 
waterbodies in each RBMP cycle (%) 

None  of  the  surface  waterbodies  is  in  good  or  better 
ecological status/potential. 

The  main  pressures  are  a  dense  population,  land  use, 
economic/agricultural  activities,  past  pollution  and 
transboundary  pollution.  These  affect  hydromorphology 
(canalisation, flood protection, agriculture), and result in 
pollution  from  nitrates,  fertilisers/pesticides  and  river-
basin-specific  pollutants.  The  Netherlands  regulate  a 
considerable  amount  of  river-basin-specific  pollutants 
(about 80), a small subset of which cause failure to achieve 
good  status  or  potential  (including  ammonium,  cobalt, 
arsenic, selenium, silver and zinc). 

in 

the 

show 

change 

Figures 27–30 
ecological 
status/potential  and  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 have a good ecological status, which 
means  that  all  measures  must  be  taken  to  mitigate  the 
adverse  impact  of  the  sustainable  human  development 
to  be  heavily 
the  waterbody 
activities  causing 

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

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

(105)  https://environment.ec.europa.eu/topics/water_en. 
(106)  These 

the  Groundwater  Directive 

include 

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

Treatment 

Floods 

the 

the 

Directive 

Drinking  Water 

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

and 

the 

the 

(107) ENV - Bibliothèque 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
Figure 28: Chemical status of surface waterbodies in 
each RBMP cycle (%) 

Figure 30: Chemical status of groundwater bodies in 
each RBMP cycle (%) 

The Netherlands  33 

Failure to achieve good chemical status is mostly due to 
exceedances of the EU environmental quality standards of 
about  10 %  of  regulated  priority  substances,  the  most 
relevant  being  polybrominated  diphenyl  ethers  (79 %), 
fluoranthene (27 %), mercury (26 %), benzo(g,h,i)perylene 
(24.7 %), benzo(b)fluoranthene (20 %), tributyltin (15 %), 
Benzo(a)pryene  (6 %)  and  benzo(k)fluoranthene  (5.8 %). 
Mercury is responsible for failure in 25 % of waterbodies. 
The ubiquitous presence of mercury and other ubiquitous 
bioaccumulative persistent and toxic chemicals is common 
to  many  Member  States,  including  as  a  result  of  long-
range air deposition from other continents. 

Figure 29: Quantitative status of groundwater bodies in 
each RBMP cycle (%) 

Only 1 out of 23 groundwater bodies does not have a good 
quantitative  status,  due  to  water  balance.  Three  others 
are at risk of not achieving good status by 2027. 

The  prolonged  period  of  drought  in  2018  played  a 
significant  role  in  the  deterioration  of  the  status  of 
groundwater  bodies,  as  the  abstraction  rate  was  much 
higher  than  the  recharge  rate.  Climate-change-related 
effects  are  likely  to  increase  in  the  future  and  require 
specific controls on abstractions and water efficiency. 

Compared  with  surface  waters,  a  much  better  situation 
can be seen for groundwater, partly because groundwater 
is more shielded and less vulnerable to depositions of air 
pollutants.  As  for  surface  waters,  a  small  subset  of 
compounds is causing the problem, with all of them largely 
linked to agriculture: nitrates and pesticides, chloride and 
total phosphorous. 

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

The 2022 EIR identified the following priority actions. 

•  Assess new physical modifications of waterbodies in 
line  with  Article 4(7)  of  the  water  framework 
Directive; 

•  Continue  current  efforts  to  further  reduce  nitrates 
pollution from agriculture in groundwater and step up 
efforts  to  ensure  the  timely  achievement  of  the 
objective under the Water Framework Directive. 

The  Netherlands  has  made  some  progress  and  seeks  to 
improve  the  link  between  water  quality  objectives  and 
permitting, control and enforcement systems, which have 
become  too  decentralised  and  fragmented.  It  is  also 
positive  that  the  Netherlands  has  a 
long-standing 
programme –  the  delta  programme –  to  combat  the 
consequences of and cope with climate change focusing 
on (i) protection against flooding, (ii) the adequate supply 
of  fresh  water  for  both  drinking  and  agriculture  and  (iii) 
climate-resilient spatial planning. 

legal  case 
the  Commission  opened  a 
In  2024, 
(INFR(2024)2161) alleging that Article 11(3) of the Water 
Framework  Directive  must  be  understood  as  requiring 
that  authorisations  for  abstraction  of  and  discharge  into 
water are always subject to periodic review and that the 
review  interval  should  not  exceed  12 years.  Dutch  law 
does  not  always  require  review  or  has  too  long  review 
intervals. In their response to the Commission, the Dutch 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
 
 
 
authorities agree that requiring review and setting review 
intervals  is  useful  for  achieving  the  objectives  of  the 
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 to introduce nature-based solutions 
to reduce hydromorphological pressures. 

Ensure  periodic  reviews  of  permits  for  discharges, 
abstractions  and  other  water  uses, 
including 
hydropower pressures. 

•  Reduce  pollution  from  nutrients,  chemicals,  metals 

and saline discharges. 

•  Better justify exemptions to the achievement of good 

status. 

• 

Improve  the  classification  of  water  bodies  and 
strengthen monitoring systems; 

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

financing 

Floods Directive 

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

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

The  main  progress  resulting  from  the  assessment  of  the 
second  FRMP  is  found  in  more  detailed,  area-specific 

Link eur-lex to be provided once published in OJ. 

(108) 
(109)  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, 

(110)  OJ L, 

2024/369, 

The Netherlands  34 

objectives that are tailored to the different types of flood 
areas,  including  some  measurable  elements.  Flood  risk 
management  is  better  linked  to  the  national  climate 
strategy and pluvial flooding (expected to increase due to 
climate impacts) is included. 

2025 priority actions 

• 

FRMPs should provide details on how FHRMs are used 
in  the  choice  of  measures  and  how  pluvial  flooding 
should be taken into account. 

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

• 

Improve  public 
involvement. 

consultation  and 

stakeholder 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
list  of 
implementing  acts  establishing  (i)  a  watch 
substances  and  compounds  of  concern  for  drinking 
water (108), (ii) a methodology for measuring microplastics 
in drinking water (109) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking (110). 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. At this stage, the quality of drinking water (supplied 
by large water suppliers) in Netherlands does not give rise 
to concern (111). 

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

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  the 
Netherlands  was  at  least  99.97 %  in  2017,  99.96 %  in  2018  and 
99.97 % in 2019. 

(111) 

2025 Environmental Implementation Review – The Netherlands 

 
 
Bathing Water Directive 

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

Figure 31 shows that in 2023, out of the 746 Dutch bathing 
waters, 539 (72.3 %) were of excellent quality, 127 (17 %) 
were  of  good  quality  and  31  (4.2 %)  were  of  sufficient 
quality. A total of 32 (4.3 %) bathing waters were found to 
be of poor quality.  

Figure 31: Bathing water quality per Member State (%), 
2023 

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

in  2023,  briefing 
2024, 

Copenhagen, 

Nitrates Directive 

The  Nitrates  Directive112  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 (113), dating back to 2022, warns that 
nitrates are still causing harmful pollution to water in the 
EU. Excessive nitrates in water are harmful to both human 
health  and  ecosystems,  causing  oxygen  depletion  and 
eutrophication. Cleaning of waters by national authorities 
or  farmers,  where  it  has  been  undertaken,  has  had  a 
positive  impact  on  the  drinking  water  supply  and  on 
biodiversity.  It  has  also  benefited  the  sectors –  such  as 
fisheries and tourism – that depend on biodiversity and on 
a good supply of drinking  water. Nevertheless, excessive 
fertilisation remains a  problem in  many parts of the EU. 

The Netherlands  35 

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

implementation  of  the  Nitrates 

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

2025 priority action 

•  Tackle  nutrient  pollution,  especially  nitrates  from 
implementation  of  the 

agriculture,  through  the 
Nitrates Directive. 

Urban Wastewater Treatment Directive 

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

In  the  Netherlands,  the  compliance  rate  was  100 %  in 
2020. 

Figure 32: Proportion of urban waste water that fully 
complies with the UWWTD (%), 2020 

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

(112) 
content/EN/TXT/?qid=1561542776070&uri=CELEX:01991L0676-
20081211. 

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

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

2025 Environmental Implementation Review – The Netherlands 

 
 
 
The directive has been revised(114). The revised directive 
builds  on  the  current  acquis,  strengthens  existing 
treatment  standards  and  establishes  an  additional 
treatment of micropollutants in urban waste water. Other 
new  requirements  relate  to  moving  towards  the  energy 
neutrality  of  the  sector,  establishing  an  EPR  system  to 
ensure sustainable financing of micropollutant treatment 
by  the  most  polluting  industries  and  ensuring  access  to 
sanitation,  especially  for  vulnerable  and  marginalised 
groups.  The  Netherlands  has  until  31  July  2027  to 
incorporate  the  new  directive  into  its  national  legal 
system. 

The Netherlands’ evaluation of the 2022 priority action is 
as  follows:  despite  some  progress  being  made,  the 
Netherlands has not fully implemented the UWWTD. 

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 (115), 
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 (116)  provides  a  baseline 
protection for human health and the environment. It also 

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

(115)  Communication 

to 

from 

the  Commission 

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

31.12.2008, 

(OJ 

(116)  Namely,  Regulation 

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

p. 1), 

The Netherlands  36 

ensures  stability  and  predictability 
operating in the internal market. 

for  businesses 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  Registration,  Evaluation, 
the  enforcement  of 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (117)  on  the 
implementation 
these 
regulations (118).  It  is  apparent  from  the  Commission’s 
report  that  there  are  still  many  disparities 
in  the 
implementation  of  the  REACH  and  CLP  Regulations, 
notably 
law  enforcement.  Recorded 
compliance levels in Member States, generally quite stable 
over time, appear to be getting slightly worse. This may be 
because  (i)  enforcement  authorities  are  becoming  more 
effective in detecting non-compliant products/companies; 
and (ii) more non-compliant products are being placed on 
the EU market. 

in  the  area  of 

of 

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

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (121).  The  new  hazard 

substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
L 353,  31.12.2008,  p. 1),  https://eur-
(OJ 
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008R1272-20221217. 
(117)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
2020, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 
In 
Article 46(2) of the CLP Regulation. 

line  with  Article 117(1)  of  the  REACH  Regulation  and 

Luxembourg, 

Union, 

(118) 

the 

European 

(119)  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/. 
(120)  These are substances in tattoo inks and permanent make-up, N,N-
dimethylformamide, formaldehyde (and formaldehyde releasers), 
lead in PVC (polyvinyl chloride), siloxanes (D4, D5, D6) and, finally, 
microplastics. 

Luxembourg, 

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

2025 Environmental Implementation Review – The Netherlands 

 
 
The Netherlands  37 

Figure 33: Compliances of imported products – results of 
the REF-8 project 

classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention (COP) decided to include, in its Annex A (which 
lists  banned  substances),  three  new  chemicals (122).  The 
Commission  is  working  on  the  delegated  acts  to  include 
these  substances  in  Annex I  to  the  Persistent  Organic 
Pollutants Regulation by 2025 at the latest. 

Responsibility  for  checking  compliance  with  the  REACH 
Regulation  in  the  Netherlands  lies  with  the  following 
authorities (123): 

• 

• 

the  Netherlands  Food  and  Consumer  Product  Safety 
Authority (as with the CLP Regulation), 
the  Human  Environment  and  Transport  Inspectorate 
(as with the CLP Regulation), 
the labour inspectorate (Inspectorate SZW), 

• 
•  State Supervision of Mines, 
•  Customs Administration of the Netherlands. 

The  Netherlands  has  devised  and  fully  implemented 
enforcement  strategies  for  both  the  REACH  Regulation 
and the CLP Regulation (124). 

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, some 20–25 inspectors were (partly) involved in 
REACH Regulation enforcement. 

In  2020,  the  Netherlands  participated 
in  an  EU 
coordinated enforcement project on products sold online, 
called  the  REACH-EN-FORCE  (REF)-8  project (125).  The 
report was adopted in November 2021, so it could not be 
taken into account in the previous EIR. 

(122)  These are methoxychlor, dechlorane plus and UV-328. In the case 
of the pesticide methoxychlor, there are no exemptions from the 
ban. However, for the two plastic additives, dechlorane plus and 
UV-328,  the  COP  decision 
lists  some  time-limited  specific 
exemptions. 

(123)  European Commission, Technical assistance to review the existing 
Member  States  reporting  questionnaire  under  Articles 117(1)  of 
REACH and 46(2) of CLP – Final report, Publications Office of the 
European 
p. 70, 
https://circabc.europa.eu/ui/group/8ee3c69a-bccb-4f22-89ca-
277e35de7c63/library/a4abce8c-8425-455f-b7e6-
0ead917bde6b/details. 

Luxembourg, 

Union, 

2020, 

A  risk  approach  was  used  for  the  targeting  of  control 
measures in order to maximise the chances of identifying 
non-compliances.  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. 

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

Luxembourg, 

Union, 

2020, 

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

Helsinki, 

articles 

online, 

2021, 

sold 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
Figure 34: Number of REF-8 checks performed per 
100 000 inhabitants (EU average = 1.24) 

The Netherlands  38 

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

In 2022, the Netherlands received a priority action related 
to upgrading administrative capacities in implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of non-compliance. In the absence of reporting 
since 2022, no progress has been shown and this priority 
action  remains  valid  in  2025,  partly  because  of  the 
experience with the REF-8 project. 

2025 priority actions 

• 

• 

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

•  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 
the 
European  Chemicals  Agency, 
coordinated enforcement projects, called REF projects. 
Increase customs checks and checks of products sold 
online  with  regard  to  compliance  with  chemicals 
legislations. 

including 

in 

2025 Environmental Implementation Review – The Netherlands 

 
 
The Netherlands  39 

4. Climate action 

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

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running total in 2022 of –32.5 % (126). 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  the 
Netherlands  decreased  by  31 %,  making  it  one  of  the 
countries with a below-average decrease. 

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

regulation 
for  Land  Use,  Land  Use  Change  and 
Forestry (127). The package has been fully adopted, and the 
Member States have been implementing the legislation. 

A key strategic document at country level is the National 
(NECP) (128).  Netherlands 
Energy  and  Climate  Plan 
submitted  its  updated  plan  on  24 June  2024,  which  was 
ahead of the deadline set by the regulation. The European 
Commission assessed the plan and the extent to which the 
Netherlands  has  followed  the  recommendations  for  the 
draft version. The findings from the assessment are: 

• 

• 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease by 39% in 2030 compared to 2005 which is 
below  its  target  of  48%.  But  the  Netherlands  is  on 
track to stay within its cumulative emissions cap. 
The  Netherlands  is  in  line  with  its  LULUCF  target, 
target  for  the  share  of  renewable  energy  and  final 
energy consumption target.  

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

Figure 35: Total GHG emissions (excluding international 
aviation) (%), 1990–2022 

The EU emissions trading system 

The  EU  ETS  is  the  key  tool  for  reducing  GHG  emissions 
cost-effectively across all Member States. It is the world’s 

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

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

(127)  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. 

(128)  More information about NECP is on the dedicated 

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

 Environmental Implementation Review 2025 – The Netherlands 

 
 
 
biggest carbon market, covering around 40 % of the EU’s 
total GHG emissions from electricity and heat generation, 
the  manufacturing  industry,  aviation  within  Europe (129) 
and, from 2024, maritime transport also. 

The system sets a limit or cap on the total amount of GHGs 
that  can  be  emitted  at  the  EU  level.  Within  this  limit, 
companies buy emissions allowances (one allowance gives 
the right to emit 1 t of CO2 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 32 % from 2005 
to 2023 in the Netherlands. 

In 2023, about 39 % of greenhouse gases emitted by ETS 
installations 
in  the  Netherlands  came  from  power 
generation  (EU  average:  57 %).  Refineries  accounted  for 
about  20 %,  chemicals  for  24 %,  the  metals  industry  for 
8 %, while 9 % came from other industries. Between 2019 
and 2023, overall ETS emissions declined by about 30 %. 
Greenhouse gas emissions from refineries slightly rose, by 
4 %. All other ETS sectors saw their emissions decline, by 
between 18 % and 44 %. In the Netherlands, the EU ETS is 
supplemented by a CO2 levy. 

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 (130).  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.  The  Netherlands  did  not 
communicate  full  transposition  into  national  law  by  this 
therefore  opened  an 
deadline.  The  Commission 
infringement  procedure  against  the  Netherlands  on 
25 July 2024, by sending a letter of formal notice for failing 
to fully transpose the provisions into national law. 

The Netherlands had two months to respond and address 
the  shortcomings  raised  by  the  Commission.  In  the 
absence of a satisfactory response, the Commission may 
decide to issue a reasoned opinion. 

The  Commission  also  opened  infringement  procedures 
against the Netherlands on 25 January 2024, by sending a 
letter  of  formal  notice  for  failing  to  fully  transpose 
previous revisions of ETS directive (131) into national law. 

The Netherlands  40 

The  Netherlands  has  since  notified  full  transpositions  of 
the abovementioned directives to the Commission. 

Effort sharing 

from  domestic  transport 

The  Effort  Sharing  Regulation (ESR) (132)  covers  GHG 
emissions 
(excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture,  small 
industry and waste. Emissions from these sectors account 
for  around  60 %  of  the  EU’s  domestic  emissions.  The 
regulation  sets  the  EU-wide  target  to  reduce  emissions 
from the effort sharing sectors by 40 % by 2030 compared 
to 2005 levels. This overall target for the EU translates to 
binding  national  emission  reduction  targets  for  each 
Member State. The Netherlands’ target is –48 %. 

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

limits 

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

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

Projected gap is 9.3 percentage points to the 2030 target. 

The largest contributor are buildings, which accounted for 
32 %  of  all  effort  sharing  emissions  in  2022.  Emissions 
have  decreased  by  30 %  since  2005  and  Netherlands 
should keep up the positive contribution of the residential 
sector  to 
its  2030  buildings’  targets.  The  share  of 
renewable energy in heating and cooling remains very low 
(8.5 %) compared to the EU average (25 %). 

Transport accounted for 30 % of effort sharing emissions 
and have decreased by 28 % since 2005. The Netherlands 
is an EU frontrunner in sustainable transport, but still has 
room to improve. Standing at 5 % in 2023, the Netherlands 
has  one  of  the  EU’s  highest  shares  of  battery  electric 
vehicles in its passenger car fleet (EU average is 1.2 %). In 
2023,  its  144  100  publicly  accessible  charging  points 
provided a charging point for every four e-vehicles, above 
the  EU  average  of  1:10.  Car  trips  account  for  87 %  of 
distances  travelled.  For  freight,  road  transport  plays  a 
lesser  role,  accounting  for  49 %  of  tonnes  transported, 
while 40 % of freight is carried on inland waterways, far 
higher  that  the  EU average.  Railways  account  for  8 %  of 

(129)  Flights between the EU Member States including departing 

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

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

- EUR-Lex 

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

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

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

2025 Environmental Implementation Review – The Netherlands 

 
 
passenger transport, slightly above the EU average (6 %), 
as well as 6 % of freight transport. 74 % of the rail network 
is electrified (EU average: 56 %). 

Figure 36: Effort-sharing emissions by sector (%), 2022 

Land use, land-use change and forestry 

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

is  not  the  case 

But  that 
in  the  Netherlands.  The 
Netherlands’  LULUCF  sector  has  had  relatively  high 
emissions compared to its total land area, and has not had 
negative emissions since 1990. The main source of these 
emissions is agricultural land. Since 2018, there has been 
a modest decline in LULUCF emissions. 

The  Netherlands’  target  in  2030  is  to  enhance  land 
removals  by  an  additional  −0.4  Mt  of  CO2  equivalent 
compared to the yearly average of the period 2016–2018. 
The  latest  available  projections  show  a  surplus  to  the 
target of −1.2 Mt of CO2 equivalent in 2030. Therefore, the 
Netherlands is on track to meet its 2030 target. 

Adaptation to climate change 

Halting  all  greenhouse  gas  emissions  would  still  not 
prevent  climate  impacts  that  are  already  occurring. 

The Netherlands  41 

Therefore,  adaptation  to  climate  change  is  also  a  key 
component of climate policy. 

The Netherlands has one out of three regions identified as 
a  hotspots  of  climate  risks  most  affected  by  climate 
change – namely, low-lying coastal regions (133). 

The  Netherlands  is  vulnerable  to  climate  impacts,  in 
particular  sea  level  rise  and  a  higher  intensity  and 
frequency of rainfall, heatwaves and prolonged droughts. 
Economic damage caused by weather and climate-related 
extreme  events  stood  at  almost  EUR 10 billion  in  1980–
2020. The Netherlands has a high climate protection gap 
for coastal floods and a medium-high gap for floods. 

The Netherlands adopted its national adaptation strategy 
in  2007  and  updated  it  in  2016.  It  also  has  a  national 
adaptation  plan,  but  there  are  no  sectoral  or  regional 
adaptation plans. 

This climate adaptation framework provides a good basis 
for  climate  resilience,  but  it  could  be  strengthened  by  a 
legal  basis  for  adaptation  and  new  programmes  for 
specific climate threats such as changes in wind regimes, 
lightning, wildfires and the spread of invasive species and 
tropical  diseases.  There 
further 
mainstream adaptation across governmental policies and 
long-term plans. 

is  also  scope  to 

The European Commission identified three priority actions 
in the 2022 edition of the review. Concerning progress on 
those actions, the Netherlands has made major efforts to 
accelerate the deployment of renewables and renewable 
power  generation  capacity  is  growing.  But  the  overall 
share of renewables remains below EU average. There is 
progress in sustainable transport  and the Netherlands is 
the  frontrunner.  Energy  efficiency  of  buildings  is  on  the 
good pathway, but the share of renewables in heating and 
cooling remains below the EU average. 

2025 priority 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)(134).

(133)  European Climate Risk Assessment (europa.eu). 

(134)   National energy and climate plans. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
The Netherlands  42 

Part II: Enabling framework – implementation tools

5. Financing

The  EU  budget  supports  climate  investment  in  The 
Netherlands with significant amounts in 2021–2027, with 
revenues from the  EU ETS also feeding into the national 
budget.  During  2020–2022,  The  Netherlands’  revenues 
from auctioning reached EUR 2 471 million in total, 100 % 
of which was spent on climate action in 2020. 

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  20 billion per year in 
the Netherlands. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 15.9 billion per year; thus, there is 
a gap of EUR  4.1 billion per year. 

Of  the  annual  environmental  investment  gap,  the  most 
significant gap concerns pollution prevention and control, 
at EUR 2.3 billion per year. 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
European  Regional  Development  Fund  (ERDF)),  the 
recovery  and  resilience  facility  (RRF)  EUR 275.7 billion, 
and CAP EUR 145.9 billion (135). 

In the Netherlands, the EU cohesion policy (considering EU 
contribution amounts) provides EUR 0.8 billion for climate 
action in 2021–2027 (with around one fifth via the ERDF 
and three quarters from the Just Transition Fund), with a 
further  EUR 75.1 million  from  the  European  Maritime, 
Fisheries and Aquaculture Fund (136). 

(135)  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, 

(136)  See 

the 

Cohesion 

Open 

Data 

Platform 

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

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

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

The RRF contributes to climate finance in the Netherlands 
with  EUR 2.99 billion  up  to  2026,  representing  54.9 %  of 
the national RRP (137). 

(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 billion was assigned to 
the Netherlands in the reference period (138). 

National financing, including EU emissions trading 
system revenues 

to  EUR 441 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feed  directly  into  national 
in  2020, 
budgets,  amounted 
EUR 894 million in 2021 and EUR 1 136 million in 2022 in 
the Netherlands, totalling EUR 2 471 million in the three-
year  period.  Auctioning  revenues  go  to  the  national 
general  budget,  which  is  used  for,  among  other  things, 
climate and energy purposes. Amounts spent  are higher 
than  100 %  of  revenues,  but  it  is  not  possible  to  link 
auctioning revenues to specific projects funded (139). 

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

the  environment 

It should be noted that investment in climate action also 
supports 
the 
environmental  investments  described  in  the  following 
sections  cannot  be  regarded  as  entirely  additional  to 
climate investment (140). 

therefore, 

and, 

Environmental financing and investments 

This section describes the Netherlands’ investment needs, 
current  financing  and  gaps  as  they  relate  to  the  four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 

(138)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

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

Union, 

(139)  European  Commission:  Directorate-General  for  Climate  Action, 
Progress Report 2023 – Climate action, Publications Office of the 
European 
2023, 
https://climate.ec.europa.eu/news-your-voice/news/climate-
action-progress-report-2023-2023-10-
24_enhttps://climate.ec.europa.eu/news-your-
voice/news/climate-action-progress-report-2023-2023-10-24_en. 
(140)  NB:  Indirect  investments  (from  climate  and  other  policies)  in 

Luxembourg, 

support of the environment are accounted for via the tracking. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (141). 

The environment overall 

Investment needs 

The  overall  environmental 
investment  needs  to  be 
sufficient to enable the Netherlands to meet its objectives 
in  the  areas  of  pollution  prevention  and  control,  the 
circular  economy  and  waste,  water  protection  and 
management,  and  biodiversity  and  ecosystems.  The 
required investment is estimated to be EUR 20 billion per 
year (in 2022 prices). 

A  significant  part  of  the  estimated  requirement,  around 
EUR 11.5 billion per year, can be attributed to the need to 
support  circular  economy.  A  total  of  EUR 4.6 billion  per 
year  is  required  for  water,  EUR 2.8 billion  for  pollution 
prevention  and  control,  and  EUR   1.1 billion 
for 
biodiversity and ecosystems (in 2022 prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 15.9 billion  in  the  Netherlands  from  EU  and 
national sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework 
is  estimated  to  reach  around 
EUR 2.5 billion for the Netherlands in total, during 2021–
2027 (or EUR 363.4 million per year). 

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

Instrument 

Cohesion policy 
ERDF 
Just Transition Fund 

Agricultural 

CAP 
European 
Guarantee Fund 
European  Agricultural  Fund 
for Rural Development 

European 
Maritime, 
Fisheries  and  Aquaculture 
Fund 

Allocations 

192.7 (a) 
108.5 
84.2 
1 531.8 (b) 
767.9 
763.9 

79.1 

Other MFF sources 

740.1 (c) 

The Netherlands  43 

RRF (d) (2021–2026) 

 2 590 

(a) 

(b) 

(c) 

(d) 

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 .  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 the Netherlands is not eligible for 
the  Cohesion  Fund.  Source  and 
information: 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

further 

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

6.12.2021, 

Annex XI, 

L 435 

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

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

instrument  for  the 

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

The  Netherlands,  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 
the 
financial 
(EUR 5.4 billion) (142), 
environment 
Horizon  Europe  (EUR 95.5 billion) (143),  the  Connecting 
Europe  Facility  (EUR 33.7 billion) (144)  and  funds  that  can 
be mobilised through the InvestEU programme (145). 

(LIFE)  programme 

instrument 

include 

the 

for 

The Netherlands’ RRP supports climate objectives through 
funding of EUR 3 billion (55 % of total), with an additional 
EUR 0.89 billion (16.3 %) for the environment. 

The EIB provided around EUR 1.26 billion in environment-
related  financial  contributions  to  the  Netherlands  from 
2021  to  mid  2024,  most  of  which,  EUR 180.8 million 
(56 %),  was  in  the  area  of  sustainable  energy,  transport 
and  industrial  projects,  which  provides  significant  co-

(141)  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. 

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

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

(145)  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 – The Netherlands 

 
 
 
 
benefits  to  reducing  air  pollution,  environmental  noise 
and other pollution. 

The Netherlands  44 

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  the 
Netherlands, the total national environmental protection 
and 
EUR 15.6 billion 
expenditure  was 
EUR 16.4 billion  in  2021,  representing  2 %  and  1.9 %  of 
GDP, respectively. 

2020 

in 

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 
0.4 %  of  the  EU’s  GDP.  In  the  Netherlands,  the  national 
reached 
environmental 
EUR 3.5 billion  in  2020,  rising  to  EUR 3.8 billion  in  2021, 
representing around 0.4 % of GDP. 

investment 

protection 

Split  by  institutional  sector,  78 %  of  the  Netherlands’ 
national  environmental  protection  investment  (capital 
expenditure) comes from the general government budget, 
with 22 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water companies). Data from the business sector, whose 
environmental  activities  are  usually  ancillary  to  its  main 
activities,  were  not  available.  At  the  EU  level,  38 %  of 
from 
environmental  protection 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (146). 

investment  comes 

from 

The  Netherlands’  total  financing  for  environmental 
investment reaches an estimated EUR 15.9 billion per year 
(in 2022 prices), including EU funding and national public 
and national private expenditure. Of the total, the share 
of EU fund (including EIB funds) reaches 5 %, with around 
95 % national financing. The total public financing (EU plus 
national public) represents 79 % 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 4.1 billion 
per year in the Netherlands, representing around 0.4 % of 
the  national  GDP,  being  lower  than  the  EU  average 
(0.77 %). 

Figure 37: Environmental financing, needs and gaps  per 
Member State (% of GDP) 

Source: Analysis of Directorate-General for Environment. 

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

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

Investment gap per year  

% of GDP 

% of 
total 

Million 
EUR 
(2022 
prices) 

2 312 

56.2 

0.3 

1 507 

36.6 

0.2 

945 

22.7 

0.1 

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Total 

  4 117 

100.0 

— 

— 

— 

0.4 

(146)  Eurostat, 

‘Environmental  protection  expenditure  accounts’, 

env_ac_epea. 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
NB: For biodiversity and ecosystems, no significant gap is observed, 
based on currently available data. 

Source: Directorate-General for Environment analysis. 

Pollution prevention and control 

Investment needs 

In  pollution  prevention  and  control,  the  Netherlands’ 
investment  needs  are  estimated  to  reach  EUR 2.8 billion 
per  year  (including  baseline  investments)  in  2021–2027. 
Most of this, EUR 2.4 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 
needs to reduce environmental noise reach EUR 1.4 billion 
per  year,  most  of  which  is  delivered  by  the  (same) 
sustainable  energy  and  transport  investments  that  also 
benefit clean air (147). Industrial site remediation requires 
an  estimated  EUR 173 million  per  year.  Microplastics 
pollution  and  the  chemicals  strategy  require  around 
EUR 100–130 million per year (each) (148). 

Current investments 

reach 

control 

investment 
and 

levels  supporting  pollution 
The  current 
estimated 
an 
prevention 
EUR 528 million per year in the Netherlands in 2021–2027. 
Most of the financing concerns clean air (EUR 311 million 
per  year).  Protection  from  environmental  noise  receives 
around  EUR 65 million,  the  chemicals  EUR 60 million  per 
year, with a further EUR 20 million for site remediation. 

In  the  Netherlands,  the  EU  MFF  provides  an  estimated 
12.4 %  of  the  clean  air  financing  (mostly  via  cohesion 
policy), with a further 27.6 % from the RRF, adding up to 
40 %  of  the  total.  EIB  financing  contributes  18 %  and 
national sources reach 42 % (149). 
The gap 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  the 
Netherlands needs to provide an additional EUR 2.3 billion 
per year (0.25 % of GDP), mostly related to clean air and 

(147)  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 

(148)  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). 

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

The Netherlands  45 

noise. The adequate implementation of the NECP with the 
investments included for sustainable energy and transport 
would largely deliver this, while in many Member States 
additional measures and investments may be required to 
comply with the ammonia reduction requirements. 

According to the latest (2023) NAPCP review report (150), 
the  Netherlands  complied  with  ammonia  reduction 
requirements in 2020 and 2021, and it is not at risk of non-
compliance  with  ammonia  concerning  the  NECD’s  2030 
emission  reduction  commitments,  based  on  the  policies 
and measures in its NAPCP that take into account climate, 
energy and CAP plans and financing baselines. 

Circular economy and waste 

Investment needs 

The  Netherlands’  investment  needs  in  circular  economy 
and  waste  reach  EUR 11.5 billion  per  year  (including 
baseline investments). Most of this, around EUR 9.8 billion 
per  year,  relates  to  circular  economy  measures  in  the 
mobility,  food  and  built  environment  systems,  with  a 
further  EUR 1.7 billion  necessary  for  waste  management 
(municipal  and  packaging  waste),  covering  waste 
collection,  biowaste  treatment,  recycling  reprocessors, 
waste-sorting  facilities,  and  digitalisation  of  the  waste 
registry. The amount for waste excludes the investments 
needed for the uptake of circularity and waste prevention 
across the economy (151). 

Current investments 

Circular economy investments across the economy reach 
around  EUR 8.4 billion  per  year  in  the  Netherlands  in 
2021-2027,  with  a  further  EUR 1.6 billion  provided  for 
waste  management  that  does  not  constitute  circular 
economy. 

Around 0.3 % of this combined financing for circularity and 
waste  comes  from  the  EU  MFF,  with  no  further 
contribution from the RRF. EIB loans identified in support 
of circularity and waste represent 0.2 % of the total. The 

information  on  clean  air 

Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(150)  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. 

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

2025 Environmental Implementation Review – The Netherlands 

 
 
share  of  national  sources  is  absolutely  overwhelming, 
reaching 99.5 % of the total financing (152). 
The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  the  Netherlands  needs  to 
increase  circular  economy  investments  by  an  estimated 
EUR 1 402 million  per 
additional 
EUR 105 million  concerning  waste  management  action, 
not  belonging  to  circular  economy.  Combined,  this 
amounts  to  EUR 1 507 million  per  year,  representing 
0.16 % of the Netherlands’ GDP. 

year,  with 

an 

Of  the  circular  economy  gap,  EUR 367 million  relates  to 
recent  initiatives,  such  as  the  eco-design  for  sustainable 
products,  packaging  and  packaging  waste,  labelling  and 
digital  tools,  CRM  recycling,  and  measures  proposed 
under the amendment of the Waste Framework Directive, 
and  EUR 1 035 million  constitutes  further 
investment 
need  to  unlock  the  Netherlands’  circular  economy 
potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 4.6 billion  (in  2022  prices)  in  the  Netherlands.  This 
comprises investment needs both for the water industry 
and for the protection and the management of water. Of 
the  total  annual  need,  EUR 1.9 billion,  relates  to  the 
management  of  waste  water  (also  including  additional 
costs  associated  with  the  revised  UWWTD).  A  further 
EUR 2.7 billion  is  necessary  for  drinking-water-related 
investments and around EUR 64 million for the protection 
and management of water (153). 

The Netherlands  46 

EUR 71 million the other aspects of the Water Framework 
Directive (water management and protection). 

Of  the  total  financing,  0.4 %  is  provided  by  the  EU  MFF 
(mostly through cohesion policy), with further support of 
0.3%  from  the  RRF.  EIB  financing  is  around  1.4 %  of  the 
total,  while  the  bulk  of  financing  comes  from  national 
sources (98 %) (154). 

The gap 

water 

To  meet  the  various  environmental  targets  under  the 
Water Framework Directive and the Floods Directive, the 
reaches 
Netherlands’ 
gap 
EUR 935 million  per  year 
(0.1 %  of  GDP),  with 
EUR 567 million linked to wastewater measures. Drinking 
water measures require an additional EUR 367 million per 
year over the existing levels of financing. 

investment 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 1.1 billion per year (in 2022 prices) in 
the Netherlands in 2021–2027. This includes the following 
financing needs: 

• 

• 

• 

the  Netherlands’  prioritised  action  framework (155) 
concerning  the  Natura  2000  areas:  EUR 902 million 
per year, mostly running costs; 
additional  BDS  costs (156):  this  is  not  possible  to 
quantify,  as  the  financing  needs  estimated  for  the 
strategy are lower than those in the prioritised action 
framework; 
sustainable 
EUR 154 million per year. 

management 

costs (157): 

soil 

Current investments 

Current investments 

Water investments in the Netherlands are estimated to be 
around EUR 3.7 billion per year (in 2022 prices) in 2021–
2027.  Of  this,  EUR 1.3 billion  supports  wastewater 
management,  EUR 2.3 billion  drinking  water  and  around 

The current level of biodiversity financing is estimated to 
be EUR 1.7 billion per year (in 2022 prices) in 2021–2027. 
97 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

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

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

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

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

Commission 

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

European 

(156)  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 

(157)  See 

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

5 July 

for 

of 

2025 Environmental Implementation Review – The Netherlands 

 
 
No  financing  is  estimated  to  come  from  EU  cohesion 
policy, 12 % from CAP, 1 % from Horizon Europe, around 
0.4 %  from  LIFE  and  0.4 %  from  the  European  Maritime, 
Fisheries  and  Aquaculture  Fund.  The  EU  MFF  altogether 
accounts for 14 % of the financing and the RRF for 11.4 %, 
adding  up  to  a  total  of  25.4 %  from  the  EU  budget.  The 
rest, 75 %, comes from national sources (158). 

The  Netherlands  envisages  dedicating  to  biodiversity 
investments 27.5 % of its CAP budget for 2021–2027, and 
an estimated 26.5 % of its RRF funds. This is the highest 
share of CAP and RRF investments in biodiversity for this 
period of all Member States. However, nothing from the 
cohesion  policy  EU  contribution  amount  is  planned  to 
contribute to biodiversity (see Figure 38). 

Figure 38: 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, based on the 
available data and estimates, a significant investment gap 
cannot be observed in the case of the Netherlands. 

The Netherlands  47 

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  the  Netherlands,  already  use  green 
budgeting  tools  for 
identifying  and  tracking  green 
expenditures  and/or  revenues(159).  Green  budgeting 
practices  provide 
the 
environmental implications of budgetary policies 

transparency  on 

increased 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (160).  

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 (161). 

The Netherlands did not participate. 

At  the  subnational  level,  under  the  2024  TSI,  the  city  of 
Amsterdam  is  developing  methodologies  jointly  with 
other  European  cities  to  align  local  budgeting  processes 
with the sustainable development goals (162). 

The regional  dimension of the European Green Deal has 
been  emphasised  by  the  Committee  of  the  Regions 
through the Green Deal Going Local initiative (163). 

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

Green taxation and tax reform 

Total environmental taxes amounted to EUR 22.8 billion in 
the Netherlands in 2022, representing 2.4 % of its GDP (EU 
largest 
average:  2.0 %).  Energy  taxes 

formed  the 

(158)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

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

(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. 

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

2023, 

(160)  European  Commission, 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

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

administration-and-public-financial-management/supporting-
implementation-green-budgeting-practices-eu_en. 
(162)  Technical support is received under the TSI project 24NL03. 
(163)  European  Committee  of  the  Regions,  ‘Green  Deal  going  local: 
Cities and regions put forward economic and social measures to 
support  citizens  and  businesses  to  overcome  the  energy  crisis’, 
press  release,  European  Committee  of  the  Regions  website, 
30 June 
https://cor.europa.eu/en/news/Pages/gdgl-
economic-social-measures-support-energy-crisis.aspx. 

2022, 

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

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
component of environmental taxes, accounting for 1.2 % 
of  GDP,  which  is  lower  than  the  EU  average  of  1.6 %. 
Transport  taxes,  at  0.8 %  of  GDP,  were  above  the  EU 
average (0.4 %), while taxes on pollution and resources, at 
0.39 %,  were  above  the  EU  average  (0.08 %).  In  2022, 
environmental  taxes  in  the  Netherlands  accounted  for 
6.2 %  of  total  revenues  from  taxes  and  social  security 
contributions (above the EU average of 5.0 %) (165). 

Figure 39: Environmental taxes per Member State, 2022 

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

According  to  a  2024  study (166),  the  Netherlands  applies 
emission  charges  (e.g.  aircraft  noise  emissions,  water 
biochemical  oxygen  demand,  solid  waste  landfill  fee, 

The Netherlands  48 

manure  tax),  product  charges  (vehicle  tax,  levies  on 
plastics)  and  user  charges  (water  abstraction  volumes, 
waste volumes). There is a tax on tap water (EUR 0.359/m3 
of tap water delivered up to 300 m3) (167) and incineration 
taxes  complemented  by  bans  on  the  landfill  of  specific 
substances.  However,  water  for  agriculture  or  industrial 
uses is taxed at a lower rate of EUR 0.08/m3, with this rate 
only  applying  to 
irrigation  users  abstracting  over 
40 000 m3 per year (168). The Netherlands taxes waste at 
EUR 35.70/t  for  waste  going  to  landfill  or  mixed  waste 
incineration  plants  in  and  outside  the  Netherlands (169). 
Vehicle registration taxes have been designed to promote 
the  purchase  of  low-carbon  vehicles.  Tax  on  mineral 
extraction charged per volume (m3) or weight (kg or t) of 
materials extracted cover the extraction of various natural 
resources,  for  example  coal,  lignite  or  peat.  The  same 
study  proposes  the  introduction  of  air  pollution  tax  and 
intensive agriculture tax (170). 

Green bonds and sustainable bonds 

In  2023,  the  total  value  of  green  bonds  issued  by  the 
Member States  was USD 245 billion (EUR 227 billion), up 
from USD 234 billion (EUR 198 billion) in 2021 (171). 

During  2021–2023  combined,  the  Netherlands  issued 
green bonds worth USD 76.8 billion (EUR 64.9 billion). Of 
this,  the  issuance  in  2023  amounted  to  USD 20.6 billion 
(EUR 19 billion). 

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

issuances)  were 

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

(167)  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. 

(168)  Berbel, J., Borrego-Marín, M. and Expósito, A. et al., ‘Analysis of 
irrigation water tariffs and taxes in Europe’, Water Policy, Vol. 21, 
Issue 4, 
pp. 806–825, 
https://doi.org/10.2166/wp.2019.197. 

2019, 

(169)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
p. 10, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
e. 

(170)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
p. 17, 
https://op.europa.eu/en/publication-detail/-
/publication/35c1bbdf-2931-11ef-9290-01aa75ed71a1/language-
e. 

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

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
financial  corporates,  29.1 %  by  sovereign  governments 
and  23.1 %  by  non-financial  corporates.  8.3 %  of  the 
issuances  were  linked  to  government-backed  entities, 
6.4 %  to  developments  banks  and  1.4 %  to 
local 
governments. 

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

The Netherlands  49 

Figure 40: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 2023 

In  the  Netherlands,  the  energy  subsidies  were  relatively 
stable between 2015 and 2019, and have shown increases 
since then, which accelerated in 2022 and 2023. FFS grew 
from EUR 0.6 billion in 2015 to EUR 1 billion in 2017 and 
stayed  around  that 
level  until  2021.  In  2022,  FFS 
amounted to EUR 2.5 billion, and in 2023, 2.9 billion. 

less  than  0.1 % 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to 
in  Denmark  and  Sweden.  The 
Netherlands’ value reached 0.3 %, above the EU average 
(0.8 %) (175). 

Figure 41: Energy subsidies by energy carrier (billion 
EUR), 2015–2023 

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

Environmentally harmful subsidies 

Addressing  and  phasing  out  environmentally  harmful 
subsidies,  in  particular  fossil  fuel  subsidies  (FFS),  is  a 
further  step  towards  achieving  the  eighth  environment 
the  enabling 
action  programme  objectives  and 
conditions (172). FFS are costly for public budgets and make 
it difficult to achieve European Green Deal objectives. 

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

As a direct consequence, annual FFS in the EU increased to 
EUR 103 billion in 2023 from EUR 57 billion in 2020. From 
2021 to 2023, there was a marked increase in annual FFS 
of 72 % in the EU (173). 

• 

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 
The 2022 EIR included the following recommendations for 
the Netherlands. 

•  Devise  an  environmental 

financing  strategy  to 
maximise  opportunities  for  closing  environmental 
implementation  gaps,  bringing  together  all  relevant 
administrative levels. 
Ensure  an 
level  of  financing  for  the 
increased 
environment,  in  particular  further  exploring  private 
financing  flows  (currently  around  a  fourth  of  the 
total), to cover the level of investment needs across 

(172)  Article 3(h)  and  3(v)  of  the  eighth  environmental  action 

(174)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

programme. 

PT, RO and SE. 

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

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

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

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

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
 
 
 
the  environmental  objectives  by  closing 
investment gaps. 

the 

2025 priority action 

The Netherlands  50 

Important  to  note  is  that  the  Netherlands  organised  a 
conference  on  the  30 March  2023 (176)  on  the  European 
Commission’s 
environmental 
financing (177),  which  is  considered  an  element  of  a 
strategy. 

vade  mecum 

for 

The overall level of financing for the environment for the 
Netherlands remains, however, similar to that at the time 
of the 2022 EIR, at around 0.4 % of  GDP, which is lower 
than the EU average. 

(176)  https://environment.ec.europa.eu/events/second-vademecum-

online-event-environmental-funding-netherlands-30th-march-
2023-2023-03-30_en. 

(177)  European Commission: Directorate-General for Environment, Find 
Your EU Funding Programme for the Environment – Supporting the 

In  light  of  the  observation  of  similar  overall  investment 
gaps to those in 2022, one recommendation from 2022 is 
maintained for the Netherlands. 

•  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.

the  2021–2027  multiannual 

environment  under 
financial 
framework  and  NextGenerationEU,  Publications  Office  of  the 
European 
2022, 
Union, 
https://op.europa.eu/en/publication-detail/-
/publication/33b54f0d-0251-11ed-acce-01aa75ed71a1. 

Luxembourg, 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
 
The Netherlands  51 

6. Environmental governance

Information, public participation and access to 
justice 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
is 
shared  efficiently  and  effectively (178).  Public 
participation  allows  authorities  to  make  decisions  that 
take public concerns into account. Access to justice is a set 
of  guarantees  that  allows  citizens  and  NGOs  to  use 
national courts to protect the environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
legal 
includes  the  right  to  bring 
authorities (179).  It 
challenges (‘legal standing’) (180). 

Environmental information 

This  section  focuses  on  the  implementation  of  the 
Infrastructure  for  Spatial  Information  in  the  European 
Community (Inspire) Directive. The Inspire Directive aims 
to set up a European spatial-data infrastructure for sharing 
environmental  spatial 
information  between  public 
authorities across Europe. It is expected that this will help 
policymaking  across  boundaries  and  facilitate  public 
access  to  this  information.  Geographical  information  is 
needed  for  good  governance  at  all  levels  and  should  be 
readily and transparently available (Table 3). 

(178)  The 

Aarhus 

Convention 

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

and 

the 

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

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

2016 

2023 

Legend 

Ensure  effective 
coordination 

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

Data 
without obstacle 

Inspire performance indicators 

■ 

■ 

■ 

■ 

sharing 

(i)  Conformity  of 
metadata 0 

(ii)  Conformity  of 
spatial datasets  

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

■ 

■ 

■ 

■ 

■ 

■ 

(iv)  Conformity  of 
network services 

■ 

■ 

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

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

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

implementing  the 
The  Netherlands’  performance 
Inspire  Directive  is  substantial  and  has  been  reviewed 
based on its 2023 country fiche (181) (see Table 3). 

in 

The Netherlands received a priority action in the 2019 EIR 
on the need to improve access to spatial data and services. 
It is making stronger links to the country’s Inspire portals 
and  better  informing  the  public  about  their  access  to 
justice  rights,  notably  in  relation  to  air  pollution  and 
nature, where substantial progress can be seen. 

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

(180)  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. 

(181)  European  Commission,  ‘Netherlands’,  Inspire  Knowledge  Base, 

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

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
 
 
 
 
 
 
In 2022, the Netherlands received a priority action on the 
need  to  make  spatial  data  more  widely  accessible  and 
prioritise  environmental  datasets (182).  Netherlands  has 
made  good  progress  on  improving  the  accessibility  of 
spatial data, but more efforts are needed. Therefore, the 
2022 priority action is repeated in 2025. 

Public participation 

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

information  available 

This  section  examines  how  public 
involvement  and 
transparency are ensured under two instruments, namely 
the Environmental Impact Assessment (EIA) Directive (183) 
(SEA) 
and  the  Strategic  Environmental  Assessment 
Directive (184). 

EU law provides for a flexible framework concerning EIAs. 
The aim of this framework is to ensure the application of 
the  necessary  environmental  safeguards,  while  enabling 
speedy  approval  of  projects.  The  Commission  has 
contributed to simplifying and accelerating permitting for 
renewable energy projects and continues to support the 
Member States in this regard(185).    

The  Netherlands  has  already  taken  steps  aiming  to 
accelerate permit-issuing procedures taking advantage of 
the broad flexibilities offered by the EU legal framework, 

(182)  See the European Commission’s list of high-value spatial datasets 

(https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx). 

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

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

The Netherlands  52 

is 

through 

implemented 

such  as  the  establishment  of  one-stop  shops  and 
accelerated  short  deadlines  for 
issuing  permits  for 
renewable  energy  projects.  The  acceleration  of  the 
permitting  process 
two 
processes: the multiannual programme for infrastructure, 
energy  and  climate  and  the 
federal  coordination 
procedure (Rijkscoördinatieregeling/projectprocedure). In 
addition, the support provided in 2023 through the TSI by 
the Commission included projects to help the authorities 
supervise  artificial  intelligence,  improve  the  permitting 
process  for  renewable  energy  projects  and  improve 
policies for attracting and retaining highly skilled talent. 

(screening, 

scoping,  EIA 

The average speed in the EU for issuing permits involving 
an  EIA  procedure 
is  20.6 months,  with  a  minimum 
duration  of  11.4 months  and  the  maximum  duration  of 
75.7 months (186).  The  duration  of  each  step  in  an  EIA 
report,  public 
process 
consultation, reasoned conclusion, development consent) 
varies considerably between Member States and projects. 
The available data  for  the Netherlands do not  allow any 
conclusions to be drawn. A priority action is included for 
2025  to  provide  more  detailed 
information  on  the 
different  stages  of  the  EIA  process.  Effective  use  of  EU 
procedures can positively influence the timely approval of 
activities  underpinning  the  decarbonisation  of  the 
economy on the way to net zero by 2050. 

A new report  is not  yet  available on the application and 
effectiveness of the SEA Directive in the EU. Nevertheless, 
a  support  study has been published with information by 
Member State (187). 

In the 2022 EIR, the Netherlands received a priority action 
to collect and publish data  on public participation in EIA 
and SEA processes, including information on the extent to 
which  final  decisions  are  affected  by  public  comments. 
Extensive information and electronic tools are available in 
the Netherlands to facilitate public participation in EIA and 
SEA procedures. A Dutch government web page collects all 
official  notifications  and  publications  regarding  the 
initiation  of  plans  and  projects  to  which  EIA  or  SEA 

(185) 
Commission  Staff  Working  Document    (SWD/2022/0149 
final), 
(https://eur-lex.europa.eu/legal-
18 
content/EN/TXT/?uri=CELEX%3A52022SC0149&qid=1653034229953). 

2022, 

May 

Impact  Assessment 

(186)  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/. 
(187)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 
supporting  the  preparation  of  the  report  on  the  application  and 
effectiveness  of  the  SEA  Directive  (Directive  2001/42/EC)  –  Final 
study,  Publications  Office  of  the  European  Union,  2025, 
https://data.europa.eu/doi/10.2779/1615072 

2025 Environmental Implementation Review – The Netherlands 

 
 
procedures  apply (188). 
In  addition,  the  Ministry  of 
Infrastructure and Water Management provides an online 
participation platform (189) and quick scan facility (190) for 
citizens  and  developers  to  determine  whether  an  EIA 
procedure  applies.  Furthermore,  public  participation  in 
EIA  and  SEA  procedures 
in  national 
environmental  law,  providing  rules  for  participation  in 
national, 
planning 
procedures (191) 
information  obligations, 
obligatory  public  consultation  and  a  duty  to  explain  to 
what extent public feedback was considered. However, to 
date,  there 
information  available  on  public 
participation in EIA and SEA. 

and  municipal 

is  embedded 

provincial 

including 

is  no 

A  new  Environment  and  Planning  Act  (Omgevingswet) 
entered into force in the Netherlands on 1 January 2024, 
consolidating various areas of environmental law to make 
decision making more effective and efficient and further 
improve  public  participation  in  environmental  decision 
making (192). An environment platform is being developed 
as part of the digital infrastructure to facilitate the entry 
into force of the new Environment and Planning Act and 
stimulate  participation  by  citizens (193).  Some  data  on 
public  participation  in  EIA  and  SEA  procedures  and  the 
extent to which public views are considered are published, 
in  which  the  Netherlands 
but  only  for  procedures 
Commission for Environmental Assessment is specifically 
requested to take public views into account (194). 

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, 

The Netherlands  53 

irrespective of the form of the legal act (i.e. regulatory act 
or administrative decision). 

As mentioned in the 2022 EIR, the Netherlands provides 
for  access  to  justice  in  environmental  matters  regarding 
certain administrative acts, particularly EIAs. NGOs do not 
have  to  demonstrate  an  interest  to  have  standing  in  an 
administrative environmental court case or in cases  that 
have significant effects on the environment, but they do 
have to meet some conditions regarding their legal status 
and operation. For citizens, the requirement is to have a 
sufficient interest in the decision. In practice, meeting that 
standard in environmental cases may be more demanding 
on citizens than on NGOs. 

Under  Dutch  administrative  law,  only  final  decisions  can 
be  subject  to  legal  review  and  appeal  to  the  courts. 
Decisions are defined in  Article 1:3 of the Dutch General 
Administrative  Law  Act  (Algemene  wet  bestuursrecht). 
Administrative review and judicial review are not available 
against  general  binding  rules  or  policy  rules,  but  only 
against  the  decisions  based  on  them.  Article 120  of  the 
Dutch Constitution does not allow the judge to check the 
validity  of 
laws  adopted  by  parliament  against  the 
constitution: ‘The constitutionality of Acts of  Parliament 
and  treaties  shall  not  be  reviewed  by  the  courts.’  The 
judge is allowed, though, in a dispute over the (formal or 
material) legality of a decision, to raise arguments calling 
into question the legality of the legal basis on which the 
decision  is  based.  So  it  is  possible  to  check  whether  a 
decision 
including 
environmental law. It is also possible for the national judge 
to  check  whether  national  law  complies  with  binding 
international law. Where it does not, the judge can leave 
aside national law. 

compatible  with  EU 

law, 

is 

More  specific  rules  apply  on  challenging  EIAs.  The  EIA 
report itself can only be made subject to review together 
with the decision (e.g. on the application for a permit). If 
the EIA report is found to be flawed, the decision will be 
ruled to be flawed as well (because it is not substantiated 
by  the  EIA  report)  and  will  therefore –  typically –  be 
annulled (Article 3:46 of the Dutch General Administrative 
Law Act). 

(188)  https://zoek.officielebekendmakingen.nl/uitgebreidzoeken. 
(189)  Platform 

Participatie 

(https://www.platformparticipatie.nl/default.aspx). 

(190)  EIA-scan 

website 
(https://www.rijksoverheid.nl/onderwerpen/omgevingswet)  and 
https://iplo.nl/regelgeving/omgevingswet/english-
at 
environment-and-planning-act/. 

(https://iplo.nl/regelgeving/instrumenten/milieueffectrapportag
e/)  in  the  knowledge  database  of  the  Ministry  of  Infrastructure 
and Water Management. 

(191)  Chapter 7  (SEA  and  EIA)  and  Chapter 4  of  the  Environmental 

(193)  More information on the Digital System for the Environment Act 
and  the  Environment  Platform  (Omgevingsloket)  is  available  at 
https://aandeslagmetdeomgevingswet.nl/ontwikkelaarsportaal/
dso/dso/digitaal-stelsel/. 

Management Act. 

(192)  More information on the new Environment and Planning Act and 
its  entry  into  force  is  available  on  the  dedicated  government 

(194)  Facts  and  figures  from  the  Netherlands  Commission  for 
report 
Assessment’s 

annual 

Environmental 
(https://www.eia.nl/annualreport2020/). 

2025 Environmental Implementation Review – The Netherlands 

 
 
There is a general website on SEA/EIA (195), but it does not 
provide an overview of consultations (196). 

A  case  on  access  to  justice  in  the  Netherlands  was 
launched  in  2023 (197),  mainly  seeking  clarification  on 
whether administrative or regulatory decisions in the field 
of  the  environment,  particularly  in  areas  of  planning 
related  to  water,  nature,  air  quality  and  noise,  can  be 
legally challenged at the national level (as is required by 
the  Aarhus  Convention  and  EU  law).  The  reply  is  under 
assessment. 

2025 priority actions 

•  Make  spatial  data  more  widely  accessible  and 
prioritise environmental datasets in implementing the 
Inspire  Directive,  especially  those  identified  as  high-
value spatial datasets for implementing environmental 
legislation (198). 

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

•  Provide  information  on  the  average  duration  of  all 

steps in the EIA process. 

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 (199) 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. 

The Netherlands  54 

criminality.  Compliance  promotion  activities  help  duty-
holders to comply by providing information, guidance and 
other  support.  This  is  particularly  important  in  areas 
where new and complex legislation is put in place. 

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

While  centralised  online  publication  of  non-compliance 
statistics remains limited, recent government reforms and 
regional  authorities 
focus  on  ensuring 
increasingly 
transparency  by  providing  public  access  to  decisions  on 
environmental  violations  and  sanctions  through  various 
regional platforms (200). 

As mentioned in the 2022 EIR, every four years, a national 
threat assessment on environmental crime is carried out 
by  the  Strategic  Environmental  Chamber,  involving  all 
parties  involved  in  the  enforcement  of  environmental 
legislation  in  the  Netherlands,  both  administrative  and 
criminal  enforcement  services  as  well  as  specialised 
inspectorates (201).  Since 
threat 
assessment,  the  Dutch  government  has  intensified  its 
focus on environmental crime. 

last  national 

the 

linked 

reports/statistics 

The  2022  EIR  recommended  that  the  Netherlands  (i) 
publishes inspection plans, inspection reports and annual 
activity 
to  environmental 
inspections of industrial installations under the IED, in the 
same  manner  as  is  done  for  installations  under  the 
Seveso III  Directive;  (ii)  improves  cooperation  between 
enforcement  authorities  on  environmental  crime,  for 
example  by  improving  information  exchange,  resources, 
systems  of 
level  of  expertise  and  cooperation 
administrative  and 
involved. 
However, such actions concerning compliance promotion, 
monitoring and criminal and administrative enforcement 
are  not  assessed  here  due  to  a  lack  of  systematic 
information. 

criminal  authorities 

Compliance promotion, monitoring and enforcement 

The new EU Environmental Crime Directive 

Non-compliance  with  environmental  obligations  may 
occur for different reasons, including poor understanding 
or  lack  of  acceptance  of  the  rules,  opportunism  or  even 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations, notably by the adoption of the Environmental 

(195)

https://iplo.nl/regelgeving/instrumenten/milieueffectrappor

tage/. 

(196)  https://www.commissiemer.nl/english. 
(197)  European Commission infringement decision INFR(2023)2149. 
(198)  European  Commission’s list  of  high-value  spatial  datasets 

(https://github.com/INSPIRE-MIF/need-driven-data-
prioritisation/blob/main/documents/eReporting_PriorityDataList
_V2.1_final_20201008.xlsx). 

(199)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 
compliance  and  governance  (https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX%3A52018DC0010)  and  the  related 
Commission 
(https://eur-
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52018SC0010). 

document 

working 

staff 

(200)  For 

example, 

regional 
Noordzeekanaalgebied  makes 
enforcement measures publicly accessible at https://odnzkg.nl/. 

agency  Omgevingsdienst 
concerning 
information 

the 

(201)  Openbaar  Ministerie, 

en 

Transport 

Leefomgeving 
Milieucriminaliteit 
https://www.om.nl/onderwerpen/milieucriminaliteit/dreigingsb
eeld-milieucriminaliteit. 

et 
2021, 

Omgevingsdienst 
al., 

NL, 

Inspectie 
Dreigingsbeeld 
2021, 

2025 Environmental Implementation Review – The Netherlands 

 
 
 
important 

Crime Directive (ECD) (Directive (EU) 2024/1203)(202) and 
new  sectoral  legislation  with  stronger  provisions  on 
compliance  monitoring,  enforcement  and  penalties. 
Issues 
the 
the 
implementation  of  the  relevant  new  instruments  are 
highlighted below; a detailed assessment of these topics 
will be included in the next EIR once more implementation 
measures  are  put 
in  place  and  more  systematic 
information is available. 

transposition  and 

for 

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

and 

including  by 

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 
measures  to  more  effectively  combat  environmental 
in  particular  through  training,  coordination, 
crime, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification and sharing good practices. Member States 
are  expected  to  ensure  the  necessary  resources  and 
invited  to 
specialised  skills  required  and  they  are 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement  practitioners,  such  the  EU  Network  for  the 
Implementation  and  Enforcement  of  Environmental 
Law (203),  EnviCrimeNet (204),  the  European  Network  of 
Prosecutors for the Environment (205) and the EU Forum of 

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

criminal 

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

(203)  https://www.impel.eu/en. 
(204) 

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 

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

The Netherlands  55 

Judges  for  the  Environment (206).  The  European  Union 
Agency for Law Enforcement  Cooperation  and European 
Union  Agency 
Justice  Cooperation 
mechanisms for cooperation on cross-border cases should 
be used more systematically for environmental offences. 

for  Criminal 

Environmental Liability Directive 

The  Environmental  Liability  Directive  (ELD)(207)  aims  to 
ensure that environmental damage is remediated in kind 
at the expense of those who have caused it, in line with 
the polluter-pays principle. It helps to halt the net loss in 
biodiversity,  as  well  as  reducing  the  number  of 
contaminated  sites  and  protecting  the  environmental 
quality of groundwater and surface waters. The ELD is a 
cross-cutting 
for  better 
tool  and  a  key  enabler 
implementation of EU environmental law. 

The  ELD  addresses  cases  of  significant  environmental 
damage  to  protected  species  and  natural  habitats,  and, 
when caused by operators carrying out certain potentially 
hazardous  activities,  also  damages  to  water  and  to  soil. 
The  Commission  has  the  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (208), which will be finalised in 2025, and which 
was  supported  by  an  external  study (209),  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  were 
reported in the second reporting period (2013–2022) than 
in  the  first  one  (2007–2013).  However,  the  downward 
tendency  in  the  number  of  ELD  occurrences  and  their 
overall low number do not necessarily mean that the ELD 
has  achieved  its  objectives,  as  it  needs  to  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 

(207)   Directive 2004/35/EC on environmental liability with regard to the 
prevention and remedying of environmental damage (https://eur-
lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02004L0035-20190626). 
(208)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

(209)  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 – The Netherlands 

 
 
The Netherlands  56 

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 

the  environment  provided  by 

of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
for 
the  European 
Commission  are  the  TSI (211)  and  the  TAIEX-EIR  PEER  2 
PEER tool (212). The technical assistance available through 
the cohesion policy is subject to shared management and 
is not dealt with in this subsection. 

From 1 May 2013 to 31 December 2021, the Netherlands 
did not identify any occurrences of environmental damage 
under  the  ELD.  Moreover,  in  the  previous  reporting 
period,  no  environmental  damage  occurrences  were 
reported under the ELD. 

for  ELD 

The Netherlands has not introduced a mandatory financial 
security  system 
liabilities.  Environmental 
insurance policies that provide cover for all on-site and off-
site  ELD  liabilities,  sometimes  including  complementary 
and compensatory remediation, are widely available and 
demand  is  good.  Environmental  extensions  to  general 
liability  policies  are  available  but  they  generally  only 
provide  cover  for  ELD  liabilities  if  such  liabilities  overlap 
with  requirements  under  other  national  environmental 
legislation to remediate off-site land/soil pollution from a 
sudden  and  accidental  incident  on  an  insured  site.  The 
extensions, which tend to be included automatically in the 
body  of  the  policy,  rarely  provide  cover  for  remediating 
biodiversity damage under the ELD. 

The 2022 EIR recommended that the Netherlands improve 
its financial security system for environmental liability to 
meet 
the  costs  of  environmental  damage.  The 
Netherlands  achieved  some  progress.  The  efforts  to 
implement  2022  priority  actions  should  continue  along 
with those for the 2025 priority action. 

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 

The Commission’s 2023 Compact (210) initiative to enhance 
the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 

(210)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-
governance-coordination/enhancing-european-administrative-
space-compact_en). 

(211)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-

The Commission’s technical support instrument 

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

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

• 

•  Digitalising monitoring of East Atlantic Flyway (2022), 
a multi-country project with Denmark and Germany; 
Tackling greenwashing risk in the German and Dutch 
sustainable investment fund market, run by the Dutch 
Authority for the Financial Markets (2023); 
Technical support for the implementation of the RRP, 
run by the Ministry of Finance (2023); 

• 

• 

• 

•  Accelerating permitting for renewable energy, run by 
the Ministry of Economic Affairs and Climate Policy, 
and the Directorate-General for Climate and Energy, 
Department of Strategy Energy System (2023). 
Support  for  the  assessment  of  environmentally 
harmful subsidies and for the preparation of national 
biodiversity  plans  in  Belgium,  the  Netherlands  and 
Finland,  run  by  Belgium’s  Federal  Public  Service 
Health, Food Chain Safety and Environment (two calls 
in 2024); 
Identify  financial  solutions  to  mobilise  resources  for 
implementation  of  the  GBF,  through  the 
the 
preparation  of  a  national  biodiversity  finance  plan, 
run  by the  Ministry of Agriculture, Nature and Food 
Quality (2024); 
The assessment of net-zero commitments by financial 
corporates 
run  by  De 
the  Netherlands, 
in 
Nederlandsche Bank (2024); 
Support  to  the  development  of  the  National 
Restoration Plans; multi-country project with HR, NL 
and PL - Ministry of Climate and Environment (2025) 
Integrated 
informs 
adaptive  management  of  coastal  wetlands,  Ministry 
of Agriculture, Nature and Food Quality (2025). 

environmental  monitoring 

• 

• 

• 

funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

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

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

tool 

2025 Environmental Implementation Review – The Netherlands 

 
 
The Netherlands  57 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country). Flagship 
multi-country  workshops  are  those  requested  by  the 
European  Commission  to  present  new  and  upcoming 
environmental 
in  all  Member 
legislation  and  policy 
States (213). 

Workshops involving the Netherlands are as follows: 

• 

• 

Climate adaptation and blue infrastructures: 
Examples across European regions (31 May 2022–
1 June 2022); 
Circular procurement (7 June 2022), hosted by the 
Public Service of Wallonia, Belgium; 

• 

• 

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

•  Make space for biodiversity: Regional action to 

mainstream biodiversity and empower stakeholders 
(21–23 March 2023); 
Circular public procurement and circular public 
investments (7–8 November 2023); 

• 

•  Biodiversity, nature conservation and large 

predators: Examples across European regions (4–
6 June 2024), hosted by the Netherlands; 
•  Online platforms: EU Batteries, Packaging and 

Packaging Waste Regulation (28–29 October 2024); 
•  New aspects in the cross-border cooperation against 

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

2025 priority action 

•  Good practices on noise abatement measures and 

• 

noise mapping: Directive 2002/49/CE (26–
27 September 2022); 

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

(213)  Flagship  multi-country  workshops  in  the  reporting  period  are: 
Recast  Drinking    Water  Directive  (3  April  2025);  Environmental 
compliance  and  governance  (18  March  2025);  Planning  of 
Renewable  Energy  Projects  (20  February  2025);  Air  Quality: 
Implementation  of  the  revised  Air  Quality  Directive  (16  January 
2025); Industrial safety: awareness raising of emerging risks linked 
with climate change and decarbonation   (12 December 2024); Air 
quality: 
further 
implementation  of  the  NEC  Directive  to 
mainstream  air  and  broader  pollution  reduction  in  agricultural 
policy  (25  September  2024);  Industrial  emissions  transposition 
and implementation of the revised Directive (12 September 2024); 
Noise:  progress  towards  meeting  Member  States’  noise  limit 
values and EU reduction targets (5 June 2024); Best practice use 
of  environmental  footprint  methods  on  the  EU  market  (30  May 

2024);  Sustainable  finance  (9  November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13  June  2023);  Advisory 
service  for    businesses  to  go  circular  (24  April  2023);  Digital 
product  passport  implementation  (6  December  2022);  Public 
involvement  in  planning  and  approval  of  renewable  energy 
projects  (17  November  2022);  Environmental  compliance  and 
governance  (14  November  2022); Biowaste  management  (19-20 
September 2022); 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. 

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

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

(214)

2025 Environmental Implementation Review – The Netherlands 

 
 
 
 
 
 
 
 
 
 
 
 
The Netherlands  58 

Annex 

2025 priority actions 

Circular economy and waste management 

Waste management 

• 

• 

• 

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

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

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

•  Extend a pay-as-you-throw system to all households, and fully introduce the cost-coverage rules as part of extended 

producer responsibility for packaging 

Biodiversity and natural capital 

Global and EU biodiversity frameworks 

• 

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

Nature protection and restoration – Natura 2000 

•  Complete the Natura 2000 site designation process 

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

Recovery of species 

•  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. 

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

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

Recovery of ecosystems 

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

and habitats..  

• 

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

• 

Implement and scale up the uptake of organic farming practices.  

Forest ecosystems 

• 

• 

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

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

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

Directive to recover 

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

Marine ecosystems 

2025 Environmental Implementation Review – The Netherlands 

 
The Netherlands  59 

Prevention and management of invasive alien species 

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

authorities.  

•  Ensure regional cooperation with neighbouring Member States to address predominant pressures. 

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.  

•  Reduce industrial air pollution damage and intensity.  

•  Reduce industrial releases to water and their intensity.  

Industrial emissions  

•  Engage  with  industry  and  environmental  NGOs  to  ensure  proper  contribution  to  and  implementation  of  BAT 

conclusions and ensure timely updates to permits following the publication of BAT conclusions.  

• 

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

Major industrial accidents prevention – Seveso  

• 

Strengthen  compliance  with  requirements  on  safety  measures  to  prevent  major  accidents  and  ensure  appropriate 
preparedness  and  response  in  relation  to  UTEs,  in  particular  as  regards  reviewing,  testing  and  updating  EEPs,  at 
intervals of no more than three years.  

•  Complete noise mapping.  

•  Complete and implement action plans on noise management.  

Noise 

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. 

• 

Improve the classification of water bodies and strengthen monitoring systems. 

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

Floods Directive   

• 

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

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

costs of measures).  

• 

Improve public consultation and stakeholder involvement. 

Nitrates Directive   

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

2025 Environmental Implementation Review – The Netherlands 

 
The Netherlands  60 

Chemicals 

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

non-compliance.  

• 

Increase  involvement  in  the  activities  of  the  Forum  for  Exchange  of  Information  on  Enforcement  of  the  European 
Chemicals Agency, including in the coordinated enforcement projects, called REF projects.  

• 

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

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.  

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

Compliance assurance   

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

EU-supported environmental capacity building  

• 

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

2025 Environmental Implementation Review – The Netherlands