COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review Country Report - SPAIN 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, Spain, 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) 325 final  COMMISSION STAFF WORKING DOCUMENT 2025 Environmental Implementation Review       Country Report - SPAIN             Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2025 Environmental Implementation Review for prosperity and security       {COM(2025) 420 final} - {SWD(2025) 300 final} - {SWD(2025) 301 final} - {SWD(2025) 302 final} - {SWD(2025) 303 final} - {SWD(2025) 304 final} - {SWD(2025) 305 final} - {SWD(2025) 306 final} - {SWD(2025) 307 final} - {SWD(2025) 308 final} - {SWD(2025) 309 final} - {SWD(2025) 310 final} - {SWD(2025) 311 final} - {SWD(2025) 312 final} - {SWD(2025) 313 final} - {SWD(2025) 314 final} - {SWD(2025) 315 final} - {SWD(2025) 316 final} - {SWD(2025) 317 final} - {SWD(2025) 318 final} - {SWD(2025) 319 final} - {SWD(2025) 320 final} - {SWD(2025) 321 final} - {SWD(2025) 322 final} - {SWD(2025) 323 final} - {SWD(2025) 324 final} - {SWD(2025) 326 final}  
 
 
Spain  2 

Contents 

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

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

1. CIRCULAR ECONOMY AND WASTE MANAGEMENT ....................................................................................................... 5 
Transitioning to a circular economy ..................................................................................................................... 5 
Waste management ............................................................................................................................................. 7 
2. BIODIVERSITY AND NATURAL CAPITAL .................................................................................................................... 15 
Global and EU biodiversity frameworks ............................................................................................................. 15 
Nature protection and restoration – Natura 2000 ............................................................................................. 16 
Recovery of species ............................................................................................................................................ 18 
Recovery of ecosystems ..................................................................................................................................... 20 
Prevention and management of invasive alien species ...................................................................................... 26 
Ecosystem assessment and accounting ............................................................................................................. 27 
3. ZERO POLLUTION .............................................................................................................................................. 29 
Clean air ............................................................................................................................................................. 29 
Industrial emissions ............................................................................................................................................ 30 
Major industrial accidents prevention – Seveso ................................................................................................. 32 
Mercury Regulation ............................................................................................................................................ 34 
Noise .................................................................................................................................................................. 34 
Water quality and management ........................................................................................................................ 35 
Chemicals ........................................................................................................................................................... 40 
4. CLIMATE ACTION .............................................................................................................................................. 43 
The EU emissions trading system ....................................................................................................................... 44 
Effort sharing ..................................................................................................................................................... 44 
Land use, land use change and forestry ............................................................................................................. 45 
Adaptation to climate change ............................................................................................................................ 45 

PART II: ENABLING FRAMEWORK – IMPLEMENTATION TOOLS ............................................................................ 46 

5. FINANCING ...................................................................................................................................................... 46 
Climate finance landmarks ................................................................................................................................. 46 
Environmental financing and investments ......................................................................................................... 47 
Public financial management ............................................................................................................................. 52 
6. ENVIRONMENTAL GOVERNANCE ........................................................................................................................... 56 
Information, public participation and access to justice...................................................................................... 56 
Compliance assurance ........................................................................................................................................ 58 
EU-supported environmental capacity building ............................................................................................... 61 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
Executive summary 

Spain  3 

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 Spain. The purpose of this report is to 
provide information on the implementation performance 
and  highlight  the  most  effective  ways  to  address  the 
implementation gaps  that  impact human health and the 
environment and hamper the economic development and 
competitiveness  of  the  country.  The  report  relies  on 
detailed  sectoral  implementation  reports  collected  or 
issued  by  the  Commission  under  specific  environmental 
legislation. 

environmental 

regarding 

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

There has been some progress on  circular economy and 
waste  management.  Spain  approved  in  2020  a  national 
Circular Economy Strategy that is under implementation. 
Many  Autonomous  Communities  have  also  adopted 
regional  strategies  on  circular  economy.  A  new  Law  on 
waste and contaminated soils for a circular economy was 
adopted  in  2022.  However,  despite  this  progress,  waste 
management remains a significant challenge. Spain is one 
of  the  countries  that  missed  the  EU  target  of  recycling 
50 %  of  municipal  waste  by  2020.  Achieving  the  next 
targets will require further efforts. 

On water management, Spain approved in 2021 the Plan 
DSEAR on wastewater, sanitation, water efficiency, saving 
and reuse. In 2023, it adopted the third cycle River Basin 
Management Plans under the Water Framework Directive 
and the second cycle Flood Risks Management Plans under 
the  Floods  Directive.  Progress 
is  being  made  on 
wastewater,  although  many  agglomerations  do  not  yet 
comply with the Urban Wastewater Treatment Directive, 
and Spain is still paying fines following a ruling of the Court 

(1) 

from 

the  Commission 

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

to 

of Justice of the EU of 2018.  Many challenges remain in 
the water sector, especially in terms of water governance, 
water  body  rehabilitation  and  water  efficiency.  Further 
infrastructure investment is needed in many areas. 

Spain stands out within the EU in terms of natural capital, 
implies  a  special 
which  provides  opportunities  but 
responsibility  too.  Spain  has  a  very  rich  biodiversity  and 
contributes the largest terrestrial surface to the EU Natura 
2000  network,  covering  27.3 %  of  its  territory  (the  EU 
average is 18.6 %). Some designations are still needed in 
the  marine  part.  The  main  challenge  is  the  adoption  of 
site-specific  conservation  objectives  and  measures, 
together  with  allocating  sufficient  resources  to  manage 
the  Natura  2000  network.  Spain  could  also  further 
capitalise on its very valuable natural capital to promote 
green growth and job creation. 

Anticipating and adapting to the adverse effects of climate 
change,  such  as  floods,  coastal  and  soil  erosion, 
desertification,  droughts,  heat  waves  and  forest  fires, 
remains a core challenge in Spain, which is one of the most 
affected  countries  in  the  EU.  In  addition,  sustainable 
development  could  be  further  mainstreamed  into  other 
policy areas. 

EU funding has significantly contributed to improving the 
implementation  of  EU  environmental  law  and  policy  in 
Spain. However, Spain still faces considerable investment 
needs  in  this  area.  To  meet  the  four  environmental 
objectives beyond climate change, the investment gap in 
Spain  is  estimated  at  EUR 10.7 billion  per  year,  around 
0.81 % of its national GDP, above the EU average (0.77%), 
with  the  highest  needs  for  biodiversity  and  ecosystems. 
EU funds will continue to play a key role in narrowing the 
investment gap. 

On environmental governance, there is room to improve 
the coordination and cooperation among the competent 
authorities in the environment. Moreover, environmental 
enforcement needs to be strengthened in Spain. 

On the positive side, Spain has implemented several good 
practices,  such  as  Spain's  good  performance  in  applying 
the INSPIRE Directive and managing LIFE projects, or  the 
creation of a division within the Ministry for the Ecological 
Transition  to  implement  the  ‘do  no  significant  harm’ 
(DNSH) principle in the Recovery and Resilience Plan.

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

2025 Environmental Implementation Review – Spain 

 
 
 
Part I: Thematic areas 

1. Circular economy and waste management

Transitioning to a circular economy 

Figure 1: CMUR (%), 2013–2023 

Spain  4 

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

consumption.  A 

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

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

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

Spain’s  circular  use  of  material  was  8.5 %  in  2023 
(Figure 1).  While  there  was  progress  between  2014  and 
2020, Spain remains below the EU average of 11.8 % due 
to decreases in 2021 and 2023 setting the country back to 
the  level  of  2016.  However,  it  is  premature  to  draw 
conclusions,  since  in  2022  the  rate  reached  9.4 %,  the 
highest in the historical series. 

15

10

5

0

2013

2015

2017

2019

2021

2023

Spain

EU-27

Source:  Eurostat,  ‘Circular  material  use  rate’,  env_ac_rp,  last  updated 
2024, 
13 November 
https://ec.europa.eu/eurostat/databrowser/view/cei_srm030/default/t
able?lang=en. 

Resource  productivity  measures  the  total  amount  of 
materials directly used by an economy in relation to gross 
domestic product (GDP). Improving resource productivity 
can help to minimise negative impacts on the environment 
and reduce dependency on volatile raw material markets. 
As shown in Figure 2, with EUR 3.13 generated per kg of 
material consumed in 2023, Spain’s resource productivity 
is  well  above  the  EU  average  of  EUR 2.23  per  kg.  This 
positive performance is reflected in an overall increase in 
the resource productivity of Spain over the last decade. 

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

4,0

3,0

2,0

1,0

0,0

2013

2015

2017

2019

2021

2023

Spain

EU-27

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

(2) 

from 

the  Commission 

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

to 

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

11 March 

2020, 

final 

of 

https://eur-

2025 Environmental Implementation Review – Spain 

 
 
 
 
Spain  5 

Source:  Eurostat,  ‘Resource  productivity’,  env_ac_rp,  last  updated 
7 August 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/cei_pc030/default/ta
ble?lang=en. 

Policies and measures 

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

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

In  June  2020,  Spain  adopted  a  comprehensive  Circular 
Economy Strategy titled “España Circular 2030” (5), which 
sets out the long-term vision for the country’s circularity 
transition.  The  Spanish  strategy’s  objectives  will  be 
achieved with the approval of three-year action plans. A 
first Circular Economy Action Plan 2021–2023 (6) has been 
implemented, and a second Circular Economy Action Plan 
for 2024–2026 is expected to be published shortly. 

Under the Recovery and Resilience Facility (RRF), Spain’s 
Recovery  and  Resilience  Plan  (RRP) (7)  places  strong 
emphasis on the circular economy as a cross-cutting topic, 
being  part  of  its  commitment  to the  green  transition.  In 
addition, part of Component 12 of the RRP is specifically 
dedicated to advancing circular economy efforts, including 
measures  (reforms  and  investments)  aiming  at  reducing 
waste  generation,  enhancing  recycling  and  supporting 
private  sector  circularity.  The  Strategic  Project  for 
Economic  Recovery  and  Transformation  (PERTE)  on 
Circular  Economy  will  invest  in  improving  the  circular 
economy  in  industrial  sectors  and  in  three  key  sectors: 
plastics, textiles and equipment for renewable energy. 

Spain’s  regional  and  local  authorities  are  committed  to 
circular  economy  policies,  with  most  of  the  regions  and 
many cities having their own strategies or action plans. For 

example,  Andalusia,  Asturias,  the  Balearic  Islands,  the 
Basque Country, the Canary Islands, Cantabria, Castile and 
Leon, Catalonia, Extremadura, La Rioja, the Community of 
Madrid  and  the  Valencian  Community  all  have  regional 
strategies or action plans for the circular economy. So, at 
the local level, do  cities such as Barcelona, Fuenlabrada, 
Gijon  and  Malaga.  Regional  strategies  on  the  circular 
economy  play  a  key  role  in  supporting  the  circular 
transition  on  the  ground.  Civil  society  and  the  business 
community  are  also  playing  a  crucial  role  in  helping  to 
shape this transition in Spain. 

Green public procurement 

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

The  national  legal  framework  on  public  procurement  in 
Spain  (Law 9/2017  of  8 November,  on  Public  Sector 
Contracts  (LCSP),  Royal  Decree-Law 3/2020,  Law 7/2021, 
of 20 May, on Climate Change and Energy Transition, and 
Law 7/2022, of  8 April, on waste and contaminated soils 
for a circular economy) makes green public procurement 
(GPP)  mandatory,  across  all  levels  of  government.  Thus, 
environmental considerations should be integrated across 
the different phases of the procurement procedure. 

In  Spain,  a  first  national  action  plan  for  green  public 
procurement was adopted in 2008. Two implementation 
reports on this plan were published in 2011 and 2015. An 
interministerial  commission  for  the 
incorporation  of 
ecological  criteria  in  public  procurement  was  created  in 
2018.  The  second  national  plan  for  green  public 
procurement  in  the  central  public  administration  for 
2018–2025  was  approved  in  December  2018  and  is 
currently under implementation (8). 

The  plan  sets  out  examples  of  environmental  award 
criteria  within  a  group  of  20  priority  goods,  works  and 
services in accordance with EU GPP. As an innovation with 
respect  to  the  European  criteria,  specific  criteria  have 

(3) 

(4) 

website, 

Commission 

European Commission, ‘Proximity and social economy ecosystem’, 
European 
https://single-market-
economy.ec.europa.eu/sectors/proximity-and-social-
economy_en. 
Circular 
(https://circulareconomy.europa.eu/platform/en/strategies). 
(5)  Ministry  for  the  Ecological  Transition  and  the  Demographic 
Challenge  (MITECO),  ‘Estrategia  española  de  economía  circular’ 
[Spanish  strategy  on  circular  economy],  Spanish  Government 
https://www.miteco.gob.es/es/calidad-y-evaluacion-
website, 
ambiental/temas/economia-circular/estrategia/. 

Stakeholder 

Economy 

Platform 

(6)  MITECO,  I  plan  de  acción  de  economía  circular  2021–2023 [First 
2021–2023], 

economy 

circular 

action 

plan 

(7) 

(8) 

https://www.miteco.gob.es/content/dam/miteco/es/calidad-y-
evaluacion-ambiental/temas/economia-
circular/plan_accion_eco_circular_def_nipo_tcm30-529618.pdf. 
European  Commission,  ‘Spain’s  Recovery  and  Resilience  Plan’, 
website, 
Commission 
European 
https://commission.europa.eu/business-economy-
euro/economic-recovery/recovery-and-resilience-
facility/country-pages/spains-recovery-and-resilience-plan_en. 
The  details  can  be  consulted  on  MITECO,  ‘Plan  de  Contratación 
website, 
Pública 
https://www.miteco.gob.es/es/ministerio/planes-
estrategias/plan-de-contratacion-publica-ecologica.html. 

Government 

Ecológica’, 

Spanish 

2025 Environmental Implementation Review – Spain 

 
 
been  included  for  holding  events  and  conferences.  The 
plan incorporates the legal criteria related to sustainable 
production, including waste management and the circular 
economy. 
integrates  any  updates  to  EU  criteria 
automatically without the need to approve them. 

It 

• 

Beyond these basic award criteria, various Ministries have 
developed specific sectoral criteria, such as the following: 
• 
Civil Guard’s supply service (Ministry of the Interior): 
a minimum of 50 % recycled fibres in garments. 
Treasury:  sustainability  and  CE  award  criteria  to  be 
included  in  framework  agreements;  sustainability 
award  criteria  applied  to  various  categories  of 
laptops  and  monitors,  fuel,  electricity 
vehicles, 
service, 
communications 
software, 
equipment,  servers  and  storage  systems.  CE  award 
criteria  applied  to  printers,  copiers  and  scanners, 
servers  and  storage  systems,  paper,  audiovisual 
equipment and furniture. 

supply  of 

Some regions have also implemented measures on GPP. 
For example, Catalonia and the Basque Country have GPP 
policies  based  on  the EU  GPP  criteria.  Other  regions  are 
also working on their action plans. At the municipal level, 
there are also many actions to promote GPP. 

The  EU  Ecolabel  and  the  eco-management  and  audit 
scheme 

The  numbers  of  EU  Ecolabel (9)  products  and  eco-
management  and  audit  scheme  (EMAS) (10)-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, Spain had 14 570 Ecolabel products 
out  of  98 977  in  the  EU,  and  377  licences  out  of  2 983 
registered in the EU Ecolabel scheme. In fact, Spain has the 
highest  number  of  products  in  the  EU.  Moreover,  in 
October  2024,  91 866  organisations  from  Spain  were 
registered in EMAS, 48 fewer than in October 2021. 

It is also worth mentioning that the city of Valencia  was 
in  2024 (11). 
designated  as  European  Green  Capital 

(9) 

(10) 

figures’, 

facts  and 

‘EU  Ecolabel 

European  Commission, 
http://ec.europa.eu/environment/ecolabel/facts-and-
figures.html. 
EMAS  is  a  European  Commission  programme  to  encourage 
organisations  to  behave  in  a  more  environmentally  sustainable 
way.  See  European  Commission,  ‘Eco-management  and  audit 
scheme 
website, 
https://ec.europa.eu/environment/emas/emas_registrations/sta
tistics_graphs_en.htm. 

Commission 

European 

(EMAS)’, 

Spain  6 

Moreover,  the  city  of  Viladecans  has  won  the  European 
Green Leaf Award in 2025l (12). 

The 2022 EIR included a priority action on adopting further 
measures  to  increase  the  circular  material  use  rate. 
Spain’s CMUR has decreased by 1.1 percentage points in 
2023.  This  represents  no  progress  towards  this  2022 
priority  action.  Spain’s  efforts  to  transition  to  a  circular 
economy  are  considerable,  but  quick  and  consistent 
implementation is needed. 

2025 priority actions 

•  Adopt measures to increase the circular material use 

• 

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

Waste management 

Turning waste into a resource is supported by: 

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

(ii)  fully 

implementing  EU  waste 

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

(iii)  reducing waste generation per capita and in absolute 

terms; 

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

(v) 

(vi)  phasing  out  landfilling  of  recyclable  or  recoverable 

waste. 

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

(11) 

(12) 

European  Commission,  European  Green  Capital  Award, 
https://environment.ec.europa.eu/topics/urban-
environment/european-green-capital-award/winning-
cities/valencia-2024_en  
European  Commission, 
‘European  Green 
https://environment.ec.europa.eu/topics/urban-
environment/european-green-capital-award/winning-
cities/viladecans-2025_en 

Leaf  Award, 

2025 Environmental Implementation Review – Spain 

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

(which 

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

The  total  amount  of  waste  generated  in  Spain  has 
decreased over the last 12 years (Figure 3), mainly driven 
by  mineral  and  solidified  wastes,  particularly  from  the 
mining and quarrying sector. If major mineral wastes are 
excluded,  the  waste  generation  trend  shows  an  overall 
small  increase,  largely  driven  by  sorting  residues  and 
recyclables.  Spain’s  GDP  decreased  in  2020,  most  likely 
due to the Covid-19 outbreak, which led to a temporary 
drop in waste generation as well. Overall, there appears to 
be  no  decoupling  between  waste  generation  and 
economic growth. 

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

Sources: Eurostat, ‘GDP and main components (output, expenditure and 
income)’, 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/nama_10_gdp__cust
om_9301905/default/table. 

nama_10_gdp, 

15 October 

accessed 

Critical raw materials 

Spain  has  published  a  roadmap  for  the  sustainable 
management of mineral raw materials (13). In Spain, there 

(13)  MITECO, Hoja de ruta para  la gestión sostenible de las materias 
2022, 

minerales, 

primas 
https://www.miteco.gob.es/content/dam/miteco/es/ministerio/
planes-estrategias/materias-primas-minerales/hr-materias-
primas-minerales_23-8-22_web_tcm30-544770.pdf.  
European  Commission:  Joint  Research  Centre,  Techno-economic 
and  environmental  assessment  of  construction  and  demolition 
waste management in the European Union, Publications Office of 
the 
2024, 
https://data.europa.eu/doi/10.2760/721895. 
European  Commission:  Directorate-General  for  Internal  Market, 
Industry,  Entrepreneurship  and  SMEs,  EU  Construction  & 
Demolition Waste Management Protocol including guidelines for 
pre-demolition and pre-renovation audits of construction works – 

Luxembourg, 

European 

Union, 

(14) 

(15) 

Spain  7 

is specific legislation on batteries, electrical and electronic 
equipment,  vehicles,  and  construction  and  demolition 
waste, which includes measures to improve the circularity 
of these products. In the case of ashes and slag, although 
there is no specific end-of-life regulation, Spain is working 
on end-of-waste criteria for different types of slag. 

Construction and demolition waste 

Construction  and  demolition  waste  accounts  for  almost 
40 % of all waste generated in the EU. A recent study (14) 
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 save an additional 33 Mt of GHG emissions annually 
(more  than,  for  example,  the  combined  annual  GHG 
emissions from Estonia, Latvia and Luxembourg). 

The rate of preparing mineral construction and demolition 
waste for reuse and recycling in Spain in 2022 was 70.1 %, 
compared  with  the  EU  average  of  79.8 %.  Measures  to 
further  increase  the  rate  include  separate  collection  at 
source,  for  instance  through  digitalised  pre-demolition 
audits (15) 
(‘resource  assessments’),  and  Extended 
Producer  Responsibility 
(EPR)  and  other  economic 
instruments  as  well  as  upstream  measures  such  as 
increasing the recycled content  in construction products 
and the circular design (16) of construction works. 

Boosting 
Warning Report 

implementation –  the  2023  Waste  Early 

This  section  focuses  on  the  management  of  municipal 
waste,  for  which  EU 
law  sets  mandatory  recycling 
targets (17).  It  is  worth  recalling  that  Spain  is  one  of  the 
countries  that  missed  the  EU  target  of  recycling  50 %  of 
municipal waste by 2020. 

Updated edition 2024, Publications Office of the European Union, 
Luxembourg,  2024,  https://op.europa.eu/en/publication-detail/-
/publication/d63d5a8f-64e8-11ef-a8ba-01aa75ed71a1/language-
en. 
European Commission, Circular Economy – Principles for buildings 
2020, 
Brussels, 
design, 
https://ec.europa.eu/docsroom/documents/39984. 

(16) 

(17)  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 
including  mattresses  and 
accumulators,  and  bulky  waste, 

2025 Environmental Implementation Review – Spain 

 
 
 
 
Spain  8 

In  June  2023,  the  Commission  published  a  new  Waste 
Early Warning Report (18) identifying the general trends in 
waste  management  and  the  Member  States  at  risk  of 
missing 2025 waste targets (see Figure 4). 

Spain is in the category of countries at risk of missing the 
municipal  waste  targets.  Spain  is  also  at  risk  of  not 
meeting  the  2035  target  of  a  maximum  of  10 %  of 
municipal waste landfilled. 

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

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  must  notify  the  Commission  24 months  in 
advance  of  the  deadline  and  submit  an  implementation 
plan  laying  down  the  steps  they  envisage  to  reach  the 
postponed targets within a new time frame. Regarding the 
2025 targets, 11 Member States, not including Spain, have 
used this prerogative. 

In  the  Waste  Early  Warning  Report,  the  Commission 
recommended  that  Member  States  accelerate  their 
efforts to improve their recycling performance. 

On one hand, the Commission is working with the national 
authorities  and 
the 
implementation  of  appropriate  measures  to  meet  the 
targets, including through dedicated financing. 

stakeholders 

speed  up 

to 

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 (19), 
the Packaging and Packaging Waste Directive 2024 (20) and 
the  Directive  on  Waste  Electrical  and  Electronic 
Equipment (21). 

Like  other Member States, Spain has failed to attain the 
2020 target for preparing for reuse and recycling 50 % of 
waste  from  households,  and  hence  an  infringement 
procedure (2024/2147) was launched in July 2024 (22). 

Reference data: ©ESRI 

Municipal 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. 

Spain’s  municipal  waste  generation  shows  a  small 
decrease over the last 10 years (Figure 5). In 2022, Spain 
generated 467 kg per capita of municipal waste, which is 
slightly below the estimated EU-27 average of 513 kg per 
capita. 

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. 

(18) 

(19)  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 

(20) 

European  Parliament  and  Council  Directive  94/62/EC  of  20 
December  1994  on  packaging  and  packaging  waste,  Directive  - 
94/62 - EN - EUR-Lex. 

(21)  Directive  2012/19/EU  of  the  European  Parliament  and  of  the 
Council  of  4 July  2012  on  waste  electrical  and  electronic 
equipment (WEEE), Directive - 2012/19 - EN - EUR-Lex. 
European Commission, ‘July infringement package: Key decisions’, 
https://ec.europa.eu/commission/presscorner/detail/en/inf_24_
3228. 

(22) 

2025 Environmental Implementation Review – Spain 

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

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

Spain  9 

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

22 October 

accessed 

Packaging waste 

Packaging  waste  generation 
in  Spain  has  shown  a 
moderate  increase  since  2010  (Figure 7).  The  country 
generated 183 kg per capita in 2022, which is close to the 
estimated EU-27 average of 186 kg per capita in the same 
year (23). 

Figure 7: Packaging waste generation, 2010–2022 

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  rate  of  preparing  municipal  waste  for  reuse  and 
recycling shows a moderate increase from 29 % in 2010 to 
39 %  in  2022  (Figure 6),  which  is  significantly  below  the 
estimated  EU-27  average  of  49 %.  The  share  of 
incineration  remained  stable  during  this  time  frame  and 
was  11 %  in  2022.  Spain  relies  heavily  on  mechanical 
biological treatment (MBT) for the pretreatment of mixed 
municipal  solid  waste.  Currently,  the  composted  and 
digested category includes some outputs from MBT plants 
(municipal  biowaste  treated  and  recovered  in  these 
plants, and other recovered materials subsequently sent 
to recycling). However, as of 2027 these outputs (from the 
municipal  biowaste  treated)  will  not  be  considered 
recycled  waste  according  to  the  Waste  Framework 
Directive, indicating an urgent need to speed up separate 
collection and treatment of biowaste in Spain. 

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. 

(23) 

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

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
 
 
 
Spain’s  overall  packaging  waste  recycling  rate  shows  a 
small increase between 2010 and 2022, reaching 69 % in 
2022  (Figure 8).  The  overall  packaging  recycling  rate  is 
strongly influenced by paper and cardboard packaging, as 
this is the largest fraction. In 2022, the recycling rates for 
all materials except plastics were above the 2025 recycling 
targets. The shift to the new reporting rules in 2020 seems 
to have led to decreases in recycling rates, especially for 
plastic,  glass  and  steel  packaging.  However,  there  are 
indications that the generated packaging waste is under-
reported and thus the recycling rate over-reported. 

Figure 8: Packaging waste recycling rates, 2010–2022 

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

Legal framework and waste management plans 

By 5 July 2020, Member States had to bring their national 
laws  into  line  with  modifications  included  in  the  revised 
Waste Framework Directive, the Packaging and Packaging 
Waste Directive and the Landfill Directive (24). 

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 

(24)  Directive (EU) 2018/851, Directive (EU) 2018/852, Directive (EU) 
2018/850 and Directive (EU) 2018/849 amend the previous waste 
legislation and set more ambitious recycling targets for the period 
up to 2035. 
https://www.boe.es/buscar/pdf/2022/BOE-A-2022-5809-
consolidado.pdf. 

(25) 

(26)  Ministry  of  Agriculture,  Food  and  the  Environment,  Plan  estatal 
(PEMAR) –  2016–2022, 

marco  de  gestión  de 
https://www.miteco.gob.es/content/dam/miteco/es/calidad-y-
evaluacion-ambiental/planes-y-
estrategias/pemaraprobado6noviembrecondae_tcm30-
170428.pdf. 

residuos 

Spain  10 

landfill targets). Revised plans and programmes were also 
due on 5 July 2020. 

Spain  has  adopted  the  new  Law 7/2022,  of  8 April,  on 
waste and contaminated soils for a circular economy (25). 
This legislation implements the modifications introduced 
by  Directive  (EU)  2018/851  on  waste  and  Directive  (EU) 
2019/904 on single-use plastics. This law requires Spain to 
develop a national waste framework plan and to establish 
the basic goals regarding waste generation prevention and 
reduction,  as  well  as  separate  collection  and  reuse  and 
recycling  measures. 
regional  waste 
In  addition, 
management plans are also required. 

Following  the  previous  national  legislation  in  this  field, 
Spain  adopted  the  2016–2022  National  Framework  Plan 
for Waste Management (PEMAR) (26), which sets out the 
strategic  guidelines  for  waste  management  in  Spain  and 
the  measures  needed  to  meet  EU  targets.  This  plan  and 
the  national  waste  prevention  programme  (NWPP)  for 
2014–2020 (27) have still to be revised in line with the new 
EU requirements in the waste sector. During the last few 
years,  the  new  PEMAR  for  2023–2035  has  been  in 
preparation, but it is still in the process of adoption. The 
regional waste management plans for the 17 Autonomous 
Communities and the 2 Autonomous Cities have also to be 
updated;  many  of  them  are  still  pending.  This  fact 
prevents Spain from meeting the waste enabling condition 
for the 2021–2027 European Regional Development Fund 
(ERDF).  It  is  worth  mentioning  that  several  regions  have 
already  communicated  their  revised  waste  management 
plans to the Commission. 

The  main  goal  of  the  new  national  waste  management 
plan is to guide the Spanish waste policy, as well as provide 
all  the  measures  needed  to  alleviate  the  inefficiencies 
detected in previous policies and to promote actions that 
can  guarantee  the  achievement  of  legislative  goals  and 
deliver better environmental results. The PEMAR refers to 
municipal  waste,  industrial  waste,  waste  with  specific 
legislation, hospital waste and agricultural waste, among 
others.  The  strategy  for  the  reduction  of  biodegradable 
waste is also included in the new PEMAR (28). 

(27)  Ministry  of  Agriculture,  Food  and  the  Environment,  Programa 
27.11.2013, 

prevención 

de 

de 

residuos 

estatal 
https://www.miteco.gob.es/content/dam/miteco/es/calidad-y-
de 
evaluacion-ambiental/planes-y-estrategias/Programa 
prevención  aprobado  actualizado  ANFABRA  11  02  2014_tcm30-
192127.pdf. 
EEA,  ‘Early  warning  assessment  related  to  the  2025  targets  for 
municipal waste and packaging waste’, EEA website, last updated 
9 October 2024, https://www.eea.europa.eu/publications/many-
eu-member-states/early-warning-assessment-related-to. 

(28) 

2025 Environmental Implementation Review – Spain 

 
 
 
Policies to encourage waste prevention 

cooking oil have to be collected separately as of the end of 
2024. 

Spain  11 

Spain’s 2014–2020 NWPP is a stand-alone document that 
aimed to reduce the annual generation of waste by 10 % 
by  2020  compared  with  2010,  measured  in  tonnes.  The 
primary goals of the NWPP connected to waste prevention 
were  to  promote  product  reuse  and  the  extension  of 
product lifetimes (29). A new NWPP is under development 
and  is  expected  to  be  approved  together  with  the  new 
PEMAR. 

Spain’s 2014–2020 NWPP prioritised the following waste 
streams: food waste, construction and demolition waste, 
hazardous  waste,  household  waste,  municipal  waste, 
paper  waste,  packaging  waste,  waste  tyres,  vehicles, 
furniture,  toys  and  books,  textile  waste,  waste  electrical 
and electronic equipment, manufacturing waste and bulky 
waste (30). 

In addition,  Spain has adopted  several  waste prevention 
targets within the national Circular Economy Strategy, to 
be achieved by 2030: 
•  Reduce waste generation by 15 % compared with the 

2010 level. 

•  Reduce food waste generation by 50 % per capita in 
retail  and  households  and  by  20 %  in  production 
chains and supply compared with 2020 levels. 

This  strategy  also  includes  measures  related  to  food 
redistribution,  as  well  as  measures  to  valorise  food 
resources and to create new market opportunities. 

Furthermore,  Spain  has  promoted  the  reduction  of 
packaging and the use of reusable or refillable packaging 
within  public  procurement;  eco-design  for  vehicles;  and 
the founding of shops for the repair and second-hand sale 
of  electrical  and  electronic  equipment,  furniture,  toys, 
books and textile. 

Policies to encourage separate collection and recycling 

Law 7/2022 has required the separate collection of waste 
paper,  metals,  plastics,  glass  and  biowaste 
from 
households  since  the  beginning  of  2024,  while  textile 
waste, bulky waste, hazardous household waste and used 

is  a 

locations,  as 

Different  separate  collection  systems  are  in  place  in 
local  authority 
this 
different 
responsibility.  The  most  widespread  separate  collection 
system  consists  of  using  four  different  waste  bins  for 
lightweight  packaging,  glass  packaging,  paper  and 
cardboard,  and  mixed  residual  waste.  Door-to-door 
separate collection of biowaste is limited to some towns 
and suburbs. This system is usually complemented with a 
network  of  civic  amenity  sites  that  allow  the  separate 
collection of other waste streams such as waste electrical 
and electronic equipment, bulky waste or textiles (31). 

Pay-as-you-throw  schemes  are  scarcely  applied  and  are 
usually  volume  based (32).  Law 7/2022 
introduced 
provisions aimed at advancing the implementation of pay-
as-you-throw schemes such as specific and differentiated 
fees  that  reflect  the  real  cost  of  municipal  waste 
management, and a national tax of EUR 0.45/kg levied on 
non-reusable non-recycled plastic packaging. 

In  Spain,  the  EPR  system  in  place  for  cans,  plastics, 
beverage  cartons,  paper  and  cardboard,  and  glass 
packaging  covered  only  household  packaging  until 
2024 (33).  As  of  2025,  EPR  systems  for  commercial  and 
industrial  packaging  will  also  be  in  operation.  Different 
fees are applied for different packaging material such as 
steel and aluminium in metal packaging, or polyethylene 
terephthalate and high- and  low-density polyethylene in 
the plastic packaging group. Law 7/2022 does not include 
more advanced fee modulation apart from the possibility 
of introducing eco-modulation in generic terms. However, 
the recently adopted packaging decree includes a system 
of advanced fee modulation and introduced EPR schemes 
for commercial and industrial packaging waste (34). 

Currently, Spain has no mandatory deposit return system 
in  place.  Law 7/2022  establishes  separate  collection 
targets  for  single-use  plastic  bottles:  70 %  by  weight  of 
what was put on the market by 2023, and 90 % by 2027. If 
those  objectives  are  not  met,  Spain  will  implement  a 
deposit  return  system  at  the  national  level.  Recent  data 
for  reference  year  2023  indicate  a  collection  rate  of 

(29) 

(30) 

(31) 

EEA,  ‘Country  profiles  on  waste  prevention’,  EEA  website, 
https://www.eea.europa.eu/themes/waste/waste-
prevention/countries. 
EEA,  ‘Technical  note  accompanying  the  EEA  briefing  “Economic 
instruments and separate collection – key instruments to increase 
recycling”’,  https://www.eea.europa.eu/publications/economic-
instruments-and-separate-collection/technical-note-
accompanying-the-eea/view. 
EEA,  ‘Early  warning  assessment  related  to  the  2025  targets  for 
municipal waste and packaging waste’, EEA website, last updated 
9 October 2024, https://www.eea.europa.eu/publications/many-
eu-member-states/early-warning-assessment-related-to. 

(32) 

(33) 

(34) 

EEA,  ‘Technical  note  accompanying  the  EEA  briefing  “Economic 
instruments and separate collection – key instruments to increase 
recycling”’,  https://www.eea.europa.eu/publications/economic-
instruments-and-separate-collection/technical-note-
accompanying-the-eea/view. 
EEA,  ‘Early  warning  assessment  related  to  the  2025  targets  for 
municipal waste and packaging waste’, EEA website, last updated 
9 October 2024, https://www.eea.europa.eu/publications/many-
eu-member-states/early-warning-assessment-related-to. 
EEA,  ‘Early  warning  assessment  related  to  the  2025  targets  for 
municipal waste and packaging waste’, EEA website, last updated 
9 October 2024, https://www.eea.europa.eu/publications/many-
eu-member-states/early-warning-assessment-related-to. 

2025 Environmental Implementation Review – Spain 

 
 
41.3 %, and the Ministry concluded that a deposit return 
system should be implemented within two years (35). 

Policies to discourage landfilling or incineration 

Spain has a national landfill tax, set by Law 7/2022, which 
establishes  the  minimum  baseline  for  a  landfill  tax  for 
regional  authorities.  The  national 
is 
EUR 40/tonne for municipal solid waste and EUR 30/tonne 
for  rejects  from  the  treatment  of  municipal  solid  waste, 
which is close to the EU average. The landfilling of waste 
without prior treatment, of separately collected waste and 
of unsold surpluses of non-perishable products is banned. 
However, this ban is not fully implemented. 

landfill 

tax 

Law 7/2022 also sets a tax on incineration at the national 
level,  which  can  be  increased  by  regional  authorities  in 
their regions (36). A ministerial  order established a  list  of 
waste that can be prepared for reuse or recycling and that 
cannot be destined for incineration. The incineration taxes 
are lower for facilities with energy recovery. 

Illegal  or  substandard  landfilling  is  still  present  in  Spain. 
is  closely  monitoring  the  situation 
The  Commission 
through  several  horizontal 
infringement  procedures, 
including  rulings  of  the  Court  of  Justice  of  the  EU 
condemning Spain. 

Moreover,  as  explained  in  the  2022  EIR,  a  study (37) 
launched by the Commission to examine the landfilling of 
untreated  non-hazardous  municipal  solid  waste  has 
identified  some  possible  shortcomings.  The  Commission 
services  opened  investigations  to  assess  whether  the 
waste  disposal  sites  in  Spain  comply  with  the  landfilling 
standards  (i.e.  obligation  of  appropriate  treatment  and 
removal  of  the  organic  fraction  before  landfilling),  as 
required by the Court of Justice of the EU in its judgment 
Italy,  C-323/13, 
of  15 October  2014,  Commission  v 
(Malagrotta  ruling).  The  Commission  decided  in  2024  to 
open  an  infringement  procedure  (2024/2013)  against 
Spain. 

In the abovementioned 2023 Waste Early Warning Report, 
the  European  Commission  issued  a  number  of  policy 
recommendations to improve Spain’s waste management 
performance: 

Spain  12 

• 

• 
• 

• 

• 

treatment 

Support  preparing for reuse  of municipal  waste and 
reuse systems for packaging. 
Improve separate collection systems. 
Further  develop  waste  treatment  infrastructure  in 
line with the waste hierarchy and ensure that there is 
appropriate 
to 
separately collected biowaste. 
Implement restrictions on landfilling of all waste that 
is  suitable  for  recycling  by  means  of  implementing 
landfilling taxes. 
Introduce  enforcement  mechanisms 
allocation  of 
and 
coordination to meet the recycling targets. 

to  clarify 
strengthen 

capacity  dedicated 

responsibilities 

Spain has made some progress in increasing the preparing 
for  reuse  and  recycling  rate  for  municipal  waste  and 
reducing  the  landfill  rate,  but  still  needs  to  speed  up  its 
progress  towards  reaching  the  2025  target  for  the 
preparing for reuse and recycling rate for municipal waste, 
which stood at 39 % in 2022. Spain also needs to speed up 
progress  to  shift  municipal  waste  away  from  landfilling. 
With  respect  to  packaging  waste,  more  efforts  are 
especially needed to move towards higher recycling rates 
for plastic packaging waste. Spain also needs to improve 
the  effectiveness  of  the  separate  collection  system, 
especially  for  biowaste,  and  to  incentivise  sorting  at 
source. 

is 

in 

important  to  note  that, 

It 
line  with  the  EIR 
assessment,  in  the  framework  of  the  2022  European 
Semester (38),  Spain 
received  a  Country  Specific 
Recommendation (CSR-3) on circular economy and waste 
management: 
• 

‘Increase  recycling  rates  to  meet  EU  targets  and 
promote 
the  circular  economy  by  enhancing 
coordination  among  all  levels  of  government  and 
undertaking  further  investment  to  meet  separate 
collection of waste and recycling obligations, as well 
as to enhance water reuse.’ 

Moreover,  the  2022  EIR  also  included  several  priority 
actions  addressed  to  Spain  on  waste  management, 
planning, 
and 
concerning 
cooperation 
authorities, 
optimisation  of  the  use  of  existing  waste  treatment 

adequate 
among 

competent 

up-to-date 

the 

(35)  MITECO  ‘Informe  relativo  al  cálculo  de  la  recogida  separada  de 
botellas de plástico de un solo uso para bebidas en el año 2023’, 
November 
2024, 
https://www.miteco.gob.es/content/dam/miteco/es/calidad-y-
evaluacion-ambiental/sgecocir/plasticos--
sup/INFORME%20RECOGIDA%20SEPARADA%20BOTELLAS%20SU
P%20A%C3%91O%202023_.pdf 
EEA,  ‘Technical  note  accompanying  the  EEA  briefing  “Economic 
instruments and separate collection – key instruments to increase 
recycling”’,  https://www.eea.europa.eu/publications/economic-
instruments-and-separate-collection/technical-note-
accompanying-the-eea/view. 

(36) 

(37) 

(38) 

European  Commission:  Directorate-General  for  Environment, 
Study to assess the implementation by the EU Member States of 
certain  provisions  of  Directive  1999/31/EC  on  the  landfill  of 
waste’,  Publications  Office  of  the  European  Union,  Luxembourg, 
https://op.europa.eu/en/publication-detail/-
2017, 
/publication/cd1748fb-0884-11e7-8a35-01aa75ed71a1. 
European  Commission,  Recommendation 
for  a  Council 
recommendation  on  the  2022  national  reform  programme  of 
Spain  and  delivering  a  Council  opinion  on  the  2022  stability 
programme  of  Spain,  COM(2022) 610  final  of  23 May  2022, 
https://commission.europa.eu/document/download/41387043-
7d64-4c75-9cea-398b260b026c_en?filename=2022-european-
semester-csr-spain_en.pdf. In particular, see CSR 3 and recital 25. 

2025 Environmental Implementation Review – Spain 

 
 
infrastructure, and the closure and rehabilitation of non-
compliant landfills. 

Spain  13 

legislation.  This  measure 

Some  progress  can  be  observed  on 
the  above 
recommendations  and  priority  actions.  For  instance,  the 
addendum  to  Spain’s  RRP  includes  as  a  new  reform  the 
establishment  of  a  working  group  within  the  Waste 
Coordination  Committee  to  monitor  compliance  with 
waste 
improve 
governance  and  coordination  among  the  different 
competent  authorities.  In  addition,  the  adoption  and 
implementation  of  Law 7/2022  is  a  significant  positive 
step. Moreover, the measures and significant investments 
included  in  Component 12  of  Spain’s  RRP  should  also 
improve the results in the medium term. 

should 

Nevertheless,  as  explained 
this  section,  many 
challenges regarding waste management in Spain remain. 

in 

2025 priority actions 

• 
• 

• 

• 

• 

• 

• 

Complete closure of non-compliant landfills. 
Improve  separate  collection  at  source  e.g.  through 
economic instruments, investing in infrastructure for 
separate  collection,  sorting  and  recycling,  and 
increasing public awareness. 
Increase  reuse  of  products  and  scale  up  waste 
recycling  infrastructure  associated  with  the  higher 
steps  of  the  waste  hierarchy.  In  particular,  improve 
collection  and  increase  treatment  capacity  for  bio-
waste. 
Improve  municipal  waste  preparation  for  reuse  and 
recycling. 
Increase  the  collection  and  recycling  rate  of  waste 
electronic and electric equipment (WEEE). 
Invest  in  waste  prevention  measures  to  reduce  the 
total amount of waste generated. 
Ensure  the  achievement  of  the  2025  waste  targets, 
the 
following 
Commission  in  the  Early  Warning  Reports  where 
applicable. 

the  recommendations  made  by 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2. Biodiversity and natural capital 

Spain  14 

Global and EU biodiversity frameworks 

Biological  diversity  and  healthy  ecosystems  are  critical 
for our societies, underpin our economies and well-being 
and  are  essential  for  climate  change  adaptation  and 
mitigation.  The  Kunming–Montreal  Global  Biodiversity 
Framework  (GBF),  adopted  in  December  2022,  sets 
comprehensive  and  measurable  targets  to  tackle 
biodiversity  loss  by  2030.  To  implement  this  global 
framework and integrate biodiversity considerations into 
national decision-making, the EU and 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 (39)  and  a  dashboard  of  indicators (40) 
provide information on implementation progress. 

implementation 

enable 

to 

recently 

adopted 

The 
EU  Nature  Restoration 
Regulation (41) is the first EU-wide, comprehensive law of 
its kind and a key instrument for the EU to deliver on the 
global  biodiversity  targets  for  2030.  It  lays  down  an 
overarching  objective  at  the  EU  level  to  put  in  place 
effective  restoration  measures  on  20 %  of  EU  land  and 
sea by 2030 and for all ecosystems in need of restoration 
by  2050.  To  achieve  this,  it  sets  binding  targets  for 
Member States to restore and maintain ecosystems, as 
well as an effective implementation framework based on 
national restoration plans. 

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

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

In 

In  December  2022,  the  Spanish  government  approved 
the  State  Strategic  Plan  for  Natural  Heritage  and 
Biodiversity  for  2030 (42).  It  sets  the  objectives,  targets 
and actions for the conservation and sustainable use of 
biodiversity  and  natural  heritage  in  Spain.  The  plan 
implements  Spain’s  commitments  in  the  field  at  the 
international and EU levels, especially those arising from 
the GBF for 2030 and the EU’s BDS. The strategic plan is 
the  result  of  a  participatory  drafting  process  involving 
cooperation  across  government  ministries  with  the 
involvement of the regions, as well as consultations with 
social 
the 
organisations,  non-governmental  organisations  (NGOs) 
and  the  public.  Spain  was  the  first  party  to  submit  an 
NBSAP  to  the  CBD  after  the  15th  Conference  of  the 
Parties  of  the  Stockholm  Convention,  and  it  has  also 
uploaded its national targets to the CBD Online Reporting 
Tool (43). 

community,  economic  and 

scientific 

Spain  has  also  adopted  other  important  strategies  and 
plans  in  the  biodiversity  field,  most  of  them  part  of 
reforms in the framework of the RRP for Spain (44). This 
is the case with the National Strategy for Biodiversity and 
Science, also adopted in December 2022  which aims to 
be  an  integrating  tool  that  seeks  to  serve  as  a  link 
between  national  initiatives  in  biodiversity  and  natural 
heritage  and 
technology,  and 
innovation,  fostering  the  generation  and  transfer  of 
knowledge and improving planning and management. 

in  science, 

those 

Spain  also  adopted  in  December  2022  the  Master  Plan 
for  the  Spanish  Marine  Protected  Areas  Network, 
together  with  the  criteria  for  shared  and  consistent 

(39) 

(40) 

(41) 

Actions 

Tracker 

Strategy 

Strategy 

Biodiversity 

Biodiversity 

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

Dashboard 

see  also 

(42) 

(43) 
(44) 

on 

law 

web 

page 

the 
Commission 
(https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en). 
Adopted  by  Royal  Decree  1057/2022  of  27 December  2022 
(https://www.boe.es/eli/es/rd/2022/12/27/1057/con). 
https://ort.cbd.int/national-targets?countries=es. 
In particular,  in Component  4  (Biodiversity  and Ecosystems)  of 
the RRP Spain. 

2025 Environmental Implementation Review – Spain 

 
 
 
management  of  the  network,  with  the  political 
commitment to protect 30 % of land and sea in Spain in 
2030, with an intermediate milestone of 25 % protection 
in  2025,  ensuring  all  the  necessary  discussions  and 
the 
participatory  actions  with 
Autonomous Communities involved. 

the  sectors  and 

In  November  2022,  Spain  also  approved  the  Strategic 
Plan  on  Wetlands  to  2030,  highlighting  a  number  for 
measures  to  ensure  the  protection,  conservation  and 
restoration of these very important ecosystems. 

Spain  has  also  adopted  a  number  of  strategies  for  the 
conservation and recovery of protected species, such as 
the fan mussel, the ribbed Mediterranean limpet (Patella 
ferrugiena),  the  loggerhead  turtle  and  other  marine 
turtles. the Iberian freshwater crayfish, the marble duck, 
the  red-knobbed  coot,  the  white-headed  duck,  the 
ferruginous  duck,  the 
lynx,  the  wolf  and 
Iberian 
threatened  bird  species  associated  with  agro-steppe 
ecosystems, as well as Guidelines with regard to ex situ 
flora conservation or the conservation and management 
of marine meadows. The national plan for the reduction 
of bycatch, adopted in January 2022, aims to reduce the 
impact of fishing activities to a level that no longer poses 
a risk to the populations of sensitive species. 

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

Nature protection and restoration – Natura 
2000 

Natura  2000 (45),  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 

(45)  Natura  2000  comprises  Sites  of  Community  Importance  (SCIs), 
designated pursuant to the Habitats Directive, as well as Special 
Protection  Areas  (SPAs),  classified  pursuant  to  the  Birds 
Directive. Numbers of protected areas in Figure 9 do not add up 
to  the  total  of  SCIs  plus  SPAs,  because  some  SCIs  and  SPAs 
overlap. An SAC is an SCI designated by a Member State. 
SCIs are designated pursuant to the Habitats Directive, whereas 
SPAs are designated pursuant to the Birds Directive. Figures of 
coverage do not add up because some SCIs and SPAs overlap. 
European Environment Agency (EEA), ‘Number of habitats and 
species per Member State’, Article 17 dashboard, Annex I total, 
19 December 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-

(47) 

(46) 

Spain  15 

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) (46); 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. 

for 

regions  defined 

Spain boasts a very rich biodiversity. It covers four of the 
nine  biogeographical 
the 
implementation  of  the  Habitats  Directive –  Alpine, 
Atlantic,  Mediterranean  and  Macaronesian –  and  three 
of the five marine regions: Atlantic, Mediterranean and 
Macaronesian. Spain hosts 117 habitat types (47) and 426 
species (48)  covered  by  the  Habitats  Directive.  The 
country also hosts populations of 405 bird taxa covered 
by the Birds Directive (49). 

As shown in figure 9, in 2023, 27.3 % of Spain’s national 
land  area  is  covered  by  Natura  2000  (EU  coverage: 
18.6 %),  with  Special  Protection  Areas  (SPAs)  classified 
under  the  Birds  Directive  covering  20.2 %  of  Spain’s 
territory (EU coverage: 12.8 %) and Sites of Community 
Importance  (SCIs  under  the  Habitats  Directive  covering 
23.4 %  (EU  coverage:  14.3 %).  In  addition,  16.8 %  of 

(48) 

(49) 

dashboard, 

19 December 

nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  habitats  and  species  per  Member  State’, 
Article 17 
2019, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-17-national-summary-
dashboards/general-information-on-habitats-and-species. 
EEA,  ‘Number  of  bird  species/populations  per  Member  State’, 
Article 12 dashboard, Annex I total, last updated 11 May 2023, 
https://www.eea.europa.eu/themes/biodiversity/state-of-
nature-in-the-eu/article-12-national-summary-
dashboards/general-information-on-bird-species-populations. 
This  counting  only  takes  into  account  birds  taxa  for  which 
information was requested. 

2025 Environmental Implementation Review – Spain 

 
 
Spain’s national marine area is covered by Natura 2000, 
with SPAs under the Birds Directive covering  5.7 % and 
SCIs under the Habitats Directive covering 13.4 %. 

This  makes  Spain  the  Member  State  contributing  the 
largest  surface  area  to  the  EU  Natura  2000  network 
(138 663 km²  of  terrestrial  area),  although  it  does  not 
contribute the highest percentage, as Figure 9 shows. 

In addition, Spain contributes 180 508.96 km² of marine 
area  to  Natura  2000.  The  LIFE 
integrated  project 
INTEMARES  is  contributing  to  identifying  the  areas 
protected and to ensuring the effective management of 
the marine Natura 2000 Network (50). It is a major step 
forward  in  marine  research  and  knowledge.  It  will 
contribute  to  eliminating  all  the  unknowns  in  marine 
protected species and habitats and it is very relevant to 
the Nature Restoration Regulation. Eliminating the high 
level  of  uncertainty  in  the  marine  environment  will 
facilitate  the  design  of  marine  restoration  measures  in 
the  future  National  Restoration  Plan.  The  knowledge 
gained  is  also  very  important  to  prevent  or  mitigate 
potential damage to marine biodiversity from the rapid 
development of the energy sector. 

Considering  both  Natura  2000  and  other  nationally 
designated protected areas, Spain legally protects 28.1 % 
of  its  terrestrial  areas  (EU-27  coverage:  26.1 %)  and 
12.4 % of its marine areas (EU-27 coverage: 12.3 %) (51). 

Figure 9:  Natura  2000  terrestrial  protected  area 
coverage, 2023 

Spain  16 

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. 

Natura  2000  management  and  nature  protection  is 
mainly the responsibility of the regions in Spain, except 
for the marine sites, which are under the jurisdiction of 
the national administration if they do not have ecological 
continuity with adjacent terrestrial sites. 

Spain’s  basic 
legislation  transposing  the  Habitats 
Directive is, overall, adequate. It requires management 
plans to be drawn up before sites can be designated as 
SACs. This ensures that the SAC designation triggers the 
adoption  of  conservation  measures,  as  required  under 
Article 6(1) of the Habitats Directive. 

The six-year deadline set under the Habitats Directive to 
designate SCIs as SACs and set appropriate conservation 
objectives and measures has expired for all sites in Spain. 

the  Macaronesian 
Spain  has  already  designated 
biogeographical region’s SCIs as SACs. These sites are in 
the Canary Islands. 

However,  in  the  other  biogeographical  regions,  site-
specific conservation objectives and measures have not 
been adopted for all designated SACs, and the quality of 
many  of  those  adopted  does  not  fulfil  the  required 
standards.  An  infringement  procedure  (2015/2003)  is 
ongoing  to  address  these  problems,  as  for  some  other 
Member States. In this context, Spain has adopted in July 
2024  specific  guidelines  for  the  conservation  of  the 
Natura 2000 network. 

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. 

2025 priority actions 

• 

Complete the Natura 2000 site designation process. 

(50) 

project 

As highlighted in the 2019 EIR, the use of the LIFE programme – 
LIFE 
INDEMARES 
(https://webgate.ec.europa.eu/life/publicWebsite/index.cfm?f
useaction=search.dspPage&n_proj_id=3370) 
integrated 
project 
(https://webgate.ec.europa.eu/life/publicWebsite/index.cfm?f
useaction=search.dspPage&n_proj_id=6101)  has  been  very 

LIFE 
INTEMARES 

and 

(51) 

helpful  to  designate  a  consolidated  network  of  marine  Natura 
2000 sites in Spain. 
 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 – Spain 

 
 
 
• 

• 

of 

the 

establishment 

site-specific 
Finalise 
conservation objectives and measures for all Natura 
2000 sites (including by adopting their management 
plans) and ensure their effective implementation. 
Ensure the effective implementation of Natura 2000 
management  plans  and  sufficient  administrative 
capacity and financing both for Natura 2000 and the 
implementation  of 
the  Nature  Restoration 
Regulation.  Ensure  implementation  of  Prioritised 
Actions Framework 2021-2027 (PAFs). 

Recovery of species 

One  objective  set  by  the  BDS  is  that,  by  2030,  there 
should be no further deterioration in conservation trends 
or  the  status  of  any  protected  species.  The  BDS  also 
states  that  Member  States  should  ensure  that  at  least 
30 % of species not currently in favourable conservation 
status  achieve  that  status  or  show  progress  towards 
doing so (e.g. by exhibiting positive population dynamics 
or stable or increasing range and habitat size), by 2030. 
According  to  the  European  Environment  Agency  (EEA), 
based  on  reporting  required  under  Article 17  of  the 
habitats directive, a quarter of species in the EU were of 
good conservation status as of 2018 (52). 

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. 

To  measure  the  performance  of  Member  States, 
Article 17 of the Habitats Directive and Article 12 of the 
Birds Directive require reporting on the progress towards 
maintaining or restoring favourable conservation status 
of species and habitats. 

The current reporting cycle, covering 2019 to 2024, is due 
for submission in July 2025. Figures 10 and 11 show the 
latest available conservation status data. 

According  to  the  report  submitted  by  Spain  on  the 
conservation  status  of  habitats  and  species  covered  by 
Article 17  of  the  Habitats  Directive  for  2013–2018,  the 
share  of  assessments  of  habitats  in  good  conservation 
status in 2018 (8.91 %) is less than the 12.3 % reported in 
the previous reporting period (2007–2012). On protected 

Spain  17 

species, the share of assessments in good conservation 
status in 2018 is 18.93 %, less than the 21.63 % reported 
in the previous reporting period. 

As far as birds are concerned, the EU protects over 460 
species  of  wild  birds  throughout  their  entire  life  cycle 
under  the  Birds  Directive.  According  to  the  latest 
assessment, around half of these wild bird species have 
a good population status at the EU level, which is slightly 
less  (by  5  percentage  points)  than  in the  last  reporting 
period  (2008–2012).  In  Spain,  the  proportion  of  birds 
having a poor or bad conservation status has increased 
by 7 % to reach a  total of 39 %. Moreover, 60 %  of the 
breeding  species  showed  short-term  and  long-term 
increasing  or  stable  population  trends  (for  wintering 
species this figure was 71.16 % for short-term trend and 
65.39 % for long-term trend). 

At  the  same  time,  the  share  of  habitats  having  a  bad 
conservation status has increased to 17 % and the share 
of  assessments  for  species  having  a  bad  conservation 
status has increased to 26.63 %. 

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

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

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

(52) 

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

Luxembourg, 

Union, 

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

2025 Environmental Implementation Review – Spain 

 
 
 
The  main  pressures  and  threats  on  habitats  are 
agricultural  development,  construction  and  use  of 
residential,  commercial, 
industrial  and  recreational 
infrastructure and areas, development and operation of 
transport  systems,  forestry,  alien  species  and  climate 
change. For species, the reported pressures and threats 
are  similar.  For  bird  species,  the  main  pressures  and 
threats are not reported. 

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

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

Source: EEA, ‘Conservation status and trends of habitats and species’, 
19 December 
2021, 
https://www.eea.europa.eu/themes/biodiversity/state-of-nature-in-
the-eu/article-17-national-summary-dashboards/conservation-status-
and-trends. 

December 

accessed 

2019, 

As in other Member States, Spain showed a worsening in 
the  conservation  status  of  species  and  habitats  of 
community interest. However, knowledge has improved 
since the previous reporting period (2007–2012), when 
the  conservation  status  was  unknown  for  25 %  of  the 
habitat  assessments,  while  it  was  17.81 %  in  the  latest 
report (2013–2018). In the case of breeding birds, twice 
as  many  species  are  reported  as  having  a  downward 
trend,  in  both  the  short  and  the  long  term,  as  in  the 
previous  period.  However,  the  percentage  of  species 
presenting  an  upward  trend  has  increased  in  the  short 
term as well as the long term, comparing both periods. 
The  main  pressures  on  bird  species  are  agriculture, 
forestry,  and  extraction  and  cultivation  of  biological 
living resources (other than agriculture and forestry). 

(53) 

Judgment of 21 June 2021, European Commission v Kingdom of 
Spain, in Case C-559/19. 

Spain  18 

The  Commission  receives  a  high  number  of  complaints 
about  the  implementation  of  the  Nature  Directives  in 
Spain.  These  mainly  concern  the  degradation  of 
designated sites, inadequate management and the poor 
quality of appropriate assessments under Article 6(3) of 
the  Habitats  Directive.  The  degradation  of  protected 
water-dependent  habitats  within  Natura  2000  is  also  a 
frequent concern. 

infringement  procedure 
In  the  framework  of  the 
launched by the Commission, the Court of Justice of the 
EU  ruled  in  June  2021  on  the  failure  to  correctly 
implement  the  EU  nature  and  water  legislation  in  the 
Doñana  area (53).  The  Commission  is  monitoring  the 
implementation of the Court ruling by Spain. 

An infringement procedure was opened against Spain in 
February 2021 for failing to prevent deterioration of the 
Natura  2000  site  Delta  del  Llobregat  following  the 
construction  of the  expansion  of  Barcelona  airport  and 
other infrastructure in the area. 

An infringement procedure was opened against Spain in 
2020  for  failing  to  protect  marine  species  such  as 
cetaceans and sea turtles from by-catch. The procedure 
concerns the lack of by-catch monitoring and of effective 
conservation measures to prevent or reduce the impact 
on protected species, including in Natura 2000 sites and 
the  lack  of  monitoring  of  the  conservation  status  of 
certain species. 

As  regards  concerns  about  the  implementation  of  the 
Birds  Directive  in  Spain,  another  infringement  was 
opened for failure to adequately protect the turtle dove. 
The  commitment  of  authorities  across  Spain  to  take 
action to reverse the declining status of the turtle dove, 
by  declaring  a  hunting  moratorium 
for  several 
consecutive years and engaging in setting an adaptative 
harvesting  mechanism,  is  yielding  positive  results.  The 
species population is increasing for the first time after a 
prolonged  decline  since  2007.  Spain  has  now  to 
consolidate  this  trend  by  defining  and  implementing  a 
governance  system 
for  sustainable  hunting,  and 
adopting  habitat  management  measures  at  sufficient 
scale,  including  agri-environmental  measures  and  the 
necessary  monitoring  and  research  activities  to  ensure 
the effectiveness of the measures. 

The most significant factors limiting the achievement of 
the  objectives  of  the  Nature  Directives  are  the  lack  of 
sufficient  financial  resources  and  the  lack  of  scientific 
knowledge of some species and habitat types to support 
appropriate management. 

The  management  plans  for  Natura  2000  sites  must 
provide  for  the  necessary  budget  to  apply  defined 

2025 Environmental Implementation Review – Spain 

 
 
 
measures  to  achieve  specific  targets  and  preventive 
measures to avoid deterioration. They need to focus on 
improving  the  situation.  The  definition  of  conservation 
objectives and measures is also key to reflect real needs 
in the Priority Action Framework (PAF) and gain access to 
available funds. This must also be taken into account in 
the review of the existing and future Natura 2000 sites’ 
management plans. 

the  knowledge,  monitoring  and  data 
Regarding 
necessary  for  implementing  the  Nature  Directives,  it  is 
worth  noting  the  active  involvement  of  Spain  in  the 
framework  of  the  biogeographical  process.  As  regards 
the Macaronesian region, the Spanish authorities led the 
work of two working groups in the region: 1) Pilot action 
plan  for  a  habitat  type  of  community  interest  (Laurel 
forest type H9360); 2) Maintaining ecological coherence 
of the Natura 2000 network in the Macaronesian region. 
They  were 
the  Macaronesian 
biogeographical seminar of 2018, and their results were 
presented at the seminar held in November 2023. 

initiated 

after 

The Spanish initiative ‘Grazing to preserve Natura 2000 
habitats  and  species:  a  Pyrenees  example  from  France 
and Spain’ can be highlighted as a good practice. Led by 
Fundación  HAZI  and  co-financed  by  the  EU  LIFE 
programme, it addressed inappropriate grazing practices 
and  restored  1 670  hectares  of  grassland  habitats.  It 
defined  parameters  for  pro-biodiversity  grazing  and 
established  the  grazing  capacity  of  specific  grasslands 
according to the kinds of livestock grazed. This initiative, 
which  improved  the  conservation  status  of  pasture 
habitats  in  8  French  and  15 Spanish  Natura  2000  sites, 
won  the  2024  Natura  2000  award  in  the  cross-border 
category  and  it  is  highly  replicable  for  other  mountain 
pasture lands across the EU. 

to 

implemented  a  system 

Spain  has 
recognise 
sustainable nature-based tourism in Natura 2000, and in 
December  2021  signed  a  licence  agreement  with  the 
Commission to use the Natura 2000 logo on the activities 
accredited  by  the  national  system.  Since  then,  over  90 
companies  in  a  total  of  28  Natura  2000  sites  in  five 
autonomous  communities  have  used  the  Natura  2000 
logo  on  tourism  services  that  are  aligned  with  or 
contribute to the conservation of the Natura 2000 sites. 

In the same vein, as also highlighted in the previous EIRs, 
special attention should be paid to Spain’s potential to 
take  advantage  of  its  very  valuable  natural  capital  to 
create jobs. Spain makes the largest contribution to the 
EU Natura 2000 network. Therefore, jobs related to the 
green 
protection  of  biodiversity, 

reforestation, 

Spain  19 

infrastructure  and  ecosystem  services  have  a  great 
potential in Spain. In this regard, for instance, Castile-La 
Mancha  created  an  Alliance  for  ecosystem  services  to 
recognise  the  value  of  the  services  that  the  region’s 
ecosystems contribute to the well-being of citizens and 
the economy as a whole (54). 

As highlighted in the 2022 EIR, the RRP for Spain contains 
a dedicated Component 4, ‘Conservation and restoration 
of  ecosystems  and  their  biodiversity’,  which  makes  a 
significant  contribution 
the  enhancement  of 
to 
biodiversity, which is also reflected in other components. 
This provides a great opportunity to face many existing 
challenges.  Moreover,  as  explained  in  Chapter 5,  other 
EU funds are also available. 

On the priority actions that Spain received in this section 
in  the  2022  EIR,  there  has  been  limited  progress. 
Therefore,  they  are  reiterated,  since  they  are  key  to 
achieving the Habitats and Birds Directives’ objectives, as 
well  to  addressing  key  pressures  and  threats  on 
biodiversity. 

2025 priority actions 

• 

Strengthen  the  integration  of  biodiversity  actions 
into other policies, e.g. energy, agriculture, fisheries, 
forestry,  urban  and  infrastructure  planning  and 
sustainable  tourism,  and  promote  communication 
between stakeholders. 

•  Reinforce  action 

for  habitats  and  species 

in 
unfavourable  conservation  status,  for  example 
through 
increased 
restoration  measures, 
connectivity,  better  policy  coordination  and 
integration, and increased funding. 

Recovery of ecosystems 

Agricultural ecosystems 

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

The  strategy  has  set  five  common  agriculture-related 
targets for 2030, namely to: 
—  reduce by 50 % the overall use of – and risk from – 

chemical pesticides; 

—  reduce  by  50 %  the  use  of  more  hazardous 

pesticides; 

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

there 

that 

—  restore  at  least  10 %  of  agricultural  area  to  have 

(54)

https://www.castillalamancha.es/gobierno/desarrollososte

nible/estructura/dgapfyen/actuaciones/alianza-por-los-
servicios-de-los-ecosistemas-de-castilla-la-mancha. 

2025 Environmental Implementation Review – Spain 

 
 
 
— 

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

The  “Vision  for  agriculture  and  food”,  adopted  by  the 
European Commission in February 2025, sets a roadmap 
to  an  agri-food  system  that  is  attractive,  competitive, 
sustainable and fair for current and future generations. 
To  ensure  a  sustainable  future  for  EU  agriculture,  it  is 
crucial  that  these  four  priority  areas  are  pursued 
together,  and  that  public  and  private  support  are 
adequately targeted toward this objective (55). 

The  CAP  and  national  CAP  strategic  plans  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’  CAP  strategic  plans  in  2022  for  the 
programming period 2023-2027. The CAP is the  largest 
source  of  funding  dedicated  to  supporting  biodiversity 
implementing  EU 
and  plays  a  significant  role 
environmental policy. Strategic plans should continue to 
support  the  protection  of  soil,  water,  air  quality  and 
biodiversity. 

in 

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

The  utilised  agricultural  area  in  Spain  increased  from 
23 463 120 ha in 2012 to 24 692 570 ha in 2022 (56). 

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 

(55) 

(56) 

(57) 

(58) 

is 

the 

5 December 

https://agriculture.ec.europa.eu/overview-vision-agriculture-
food/vision-agriculture-and-food_en 
Eurostat,  ‘Utilised  agricultural  area  by  categories’,  tag00025, 
accessed 
2024, 
https://ec.europa.eu/eurostat/databrowser/view/tag00025/de
fault/table?lang=en. 
European  Commission,  JRC,  Landscape  features  in  agricultural 
land:  what 
https://joint-research-
centre.ec.europa.eu/jrc-news-and-updates/landscape-features-
agricultural-land-what-extent-2024-09-30_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. 

extent? 

Spain  20 

land.  Based  on  the  Land 
covered  by  agricultural 
Use/Cover  Area  Frame  Survey 
landscape  features 
estimates (57), the share of agricultural land covered  by 
non-productive  landscape  features  in  Spain  is  5.3 %, 
slightly  below  the  EU  average  of  5.6 %  of  agricultural 
land. 

In  2024,  the  CAP  basic  regulations  were  amended (58) 
inter  alia,  the  standards  for  the  good 
regarding, 
agricultural and environmental condition (GAEC) of land. 
These  changes  removed  the  obligation  for  farmers 
benefiting  from  CAP  area-related  support  to  have  a 
minimum  share  of  3–4  %  of  non-productive  areas  or 
landscape  features 
in  their  farms.  However,  the 
amended  regulation  does  not  remove  the  obligation 
under the GAEC 8 to maintain existing landscape features 
and sets out an obligation for Member States to establish 
and provide support for eco-schemes covering practices 
for  the  maintenance  of  non-productive  areas,  such  as 
land  lying  fallow,  and  for  the  establishment  of  new 
landscape features on arable land. 

The recently adopted Nature Restoration Regulation (59) 
focuses on the restoration of agricultural ecosystems and 
requires  Member  States  to  put  in  place  measures  that 
aim to achieve an increasing trend at the national level 
of  at  least  two  out  of  three  indicators  for  agricultural 
ecosystems (60). One of these indicators is the ‘share of 
agricultural land with high-diversity landscape features’. 

Organic  farming  practices  are  highly  beneficial  to 
biodiversity. As shown in  Figure 12, it is estimated that 
10.83 % of Spain’s land area is used for organic farming. 
This 
is  marginally  higher  than  the  EU  average  of 
10.50 % (61).  Spain,  with  a  steady  positive  trend,  is 
contributing to achieving the target to have 25 % of the 
EU’s agricultural land being used for organic farming by 
2030. 

(59) 

(60) 

(61) 

Regulation (EU) 2024/1991 of the European Parliament and of 
the Council of 24 June 2024 on nature restoration and amending 
Regulation  (EU)  2022/869  (OJ  L,  2024/1991,  29.7.2024), 
http://data.europa.eu/eli/reg/2024/1991/oj; see also European 
Commission,  ‘Nature  Restoration  Law’,  European  Commission 
website,  https://environment.ec.europa.eu/topics/nature-and-
biodiversity/nature-restoration-law_en. 
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. 

in  cropland  mineral  soils’  and 

2025 Environmental Implementation Review – Spain 

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

Spain  21 

The  proposed  Directive  on  soil  monitoring  and 
resilience (62) aims to introduce the first comprehensive 
legislation on the protection of all soils in the EU. Should 
the  Directive  be  adopted,  Member  States  will  have  to 
transpose  it  into  national  legislation  and  implement  it, 
starting  with  putting  in  place  the  governance  systems 
and a sound monitoring framework building on existing 
national  soil  monitoring  frameworks.  The  objective  of 
the  proposed  Directive  is  to  provide  better  and  more 
comparable  soil  health  data  with  a  view  to  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. 

2025 priority action 

• 

Implement  eco-schemes  and  agri-environmental 
measures 
the 
and 
environmental needs of Spain. 

practices 

address 

to 

Soil ecosystems 

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

The EU soil strategy, adopted in November 2021, aims to 
support  soil  protection,  sustainable  soil  management 
and  the  restoration  of  degraded  soils  to  achieve  the 
Green  Deal  objectives  as  well  as  land  degradation 
neutrality by 2030. 

This entails: 
—  preventing further soil degradation; 
—  making  sustainable  soil  management  the  new 

normal; 

—  taking action for ecosystem restoration. 

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 
soil 
compaction, 
contamination, soil salinisation and the presence in soil 
of  nitrogen  and  phosphorus  in  excess.  The  impact 
assessment accompanying the proposal, which builds on 
the data available in the EU Soil Observatory, points to 
the following soil degradation issues in Spain (63). 

soil  organic 

loss  of 

carbon, 

A fifth of Spain is affected by loss of soil organic carbon 
in mineral soils (64), representing 86 % of total cropland 
and  grassland  area.  18 %  of  the  national  territory  is 
experiencing unsustainable soil erosion by water, wind, 
tillage and harvest, representing 72 % of total cropland 
area. 

included 

Inventory. 

This  process 

By the end of 2022, Spain had finalised the integration at 
the national level of all the elements of the National Soil 
Erosion 
the 
harmonisation  of  all  provincial  soil  erosion  inventories. 
The  National  Soil  Erosion  Inventory  is  an  essential 
instrument  for  analysing,  quantifying  and  mapping  the 
in  Spain,  as  well  as  for 
main  erosion  processes 
time.  The 
their  development  over 
determining 
integration of the different provincial inventories allows 
for a broader perspective on erosion processes over the 
entire  surface  of  the  country.  Although  erosion  should 
not  be  confused  with  desertification,  the  National  Soil 
Erosion Inventory is also an essential instrument for the 
implementation of actions to combat desertification. 

(62) 

(63) 

final 

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

2023, 

5 July 

of 

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

2023, 

ASSESSMENT 

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

2025 Environmental Implementation Review – Spain 

 
 
 
Spain  22 

In  June  2022,  Spain  adopted  the  National  Strategy  to 
Combat Desertification (ENLD), which updates the 2008 
National Action Programme against Desertification. This 
strategy  sets  out  a  new  framework  for  desertification 
policies and initiatives in Spain. The document  sets out 
objectives and principles, analyses the policies that have 
the  greatest  impact  on  desertification,  draws  up  a 
diagnosis of the situation in Spain (causes, impacts, main 
desertification  scenarios  and  analysis)  and  proposes 
measures and actions to improve the governance of the 
fight  against  desertification  and  promote 
land 
management  that  prevents 
land  degradation.  This 
strategy  has  been  developed  by  the  Ministry  for  the 
Ecological  Transition  and  the  Demographic  Challenge 
(MITECO),  in  collaboration  with  the  other  ministries,  in 
particular the Ministry for Agriculture, Fisheries and Food 
(MAPA), and with the participation of the Autonomous 
Communities,  the  scientific  community,  NGOs  and  the 
rest of society through a public participation procedure. 
The  ENLD 
implements  Spain’s  commitment  as  an 
affected  party  to  the  UN  Convention  to  Combat 
Desertification.  The  ENLD  can  be  considered  to  mark 
substantial progress on addressing the following priority 
action received by Spain in the 2022 EIR: ‘Take additional 
measures to fight against land degradation, soil erosion 
and desertification.’ 

Grasslands 

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

Out of the 32 reports (65) on grassland habitat types, only 
3 (9.4 %) indicate favourable conservation status (66). The 
conservation status of four habitat types (12.5 %) (67) is 
unknown.  The  conservation  status  of  25  habitat  types 
(78.1 %) is unfavourable. 

and areas, followed by the development and operation 
of  transport  systems,  are  also  significant  pressures  on 
and threats to these habitats. 

Wetlands/peatlands 

Wetlands act as water sources and purifiers; they are the 
planet’s  greatest  natural  carbon  stores  and  they  are 
crucial  to  agriculture  and  fisheries.  Peatlands  are  a 
special  type  of  wetlands  dominated  by  peat-forming 
plants such as Sphagnum mosses. Nearly all peatlands in 
the EU are habitat types listed in Annex I 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. 

For wetlands, 2 habitat types (68) are reported as having 
favourable conservation status, 21 coastal habitat types 
are reported as having unfavourable conservation status 
and  13  habitat  types  are  reported  as  unknown. 
Regarding dune habitat types,  5 are reported as having 
favourable conservation status, while 15 are reported as 
having unfavourable conservation status. Of freshwater 
habitat  types,  2  are  reported  as  having  favourable 
conservation  status,  21  as  unfavourable  and  8  as 
unknown. 

The main pressures and threats affecting coastal habitats 
the  development,  construction  and  use  of 
are 
residential,  commercial, 
industrial  and  recreational 
infrastructure and areas. Agriculture and climate change 
are  a major pressure on these habitats  while  alien  and 
problematic species and the development and operation 
of transport systems are also considered major threats to 
these habitat group. 

In  the  case  of  dune  habitats,  the  main  pressures  and 
threats  are  the  development,  construction  and  use  of 
industrial  and  recreational 
residential,  commercial, 
infrastructure  and  areas, 
followed  by  alien  and 
problematic species and the development and operation 
of transport systems. 

Major pressures on and threats to grasslands in Spain are 
due  to  agriculture  activities,  followed  by  forestry  and 
human-induced  changes 
regimes.  The 
development,  construction  and  use  of  residential, 
commercial,  industrial  and  recreational  infrastructure 

in  water 

Regarding  freshwater  habitats,  the  main  pressures  are 
the  development,  construction  and  use  of  residential, 
commercial,  industrial  and  recreational  infrastructure 
and  areas,  followed  by  agriculture  and  human-induced 
in  water  regimes.  The  main  threats  are 
changes 

(65) 

Article 17  web  tool,  ‘Habitat  assessments  at  Member  State 
level’, 
https://nature-
art17.eionet.europa.eu/article17/habitat/report/?period=5&gr
oup=Bogs%2C+mires+%26+fens&country=ES&region=. 

(66) 
(67) 

(68) 

6140, 6230 and 6420, all of them in the Alpine region. 
6110,  6220  and  6230  in  the  Alpine  region,  and  6170  in  the 
Mediterranean region. 
1250 and 1420, both in the Macaronesian region. 

2025 Environmental Implementation Review – Spain 

 
 
agriculture and human-induced changes, followed by the 
development,  construction  and  use  of  residential, 
commercial,  industrial  and  recreational  infrastructure 
and areas. 

Monitoring Law (71) that aims to create a comprehensive 
forest  knowledge  base,  address  information  gaps  and 
enable  a  better  response  to  growing  pressures  on 
forests. 

Spain  23 

For peatlands, 15 out of 17 habitat types reported are in 
unfavourable conservation status, and 2 are reported as 
unknown (69). 

in  water 
Agriculture  and  human-induced  changes 
regimes  are  the  major  pressures  on  and  threats  to 
peatlands 
in  Spain.  After  these,  the  development, 
construction  and  use  of  residential,  commercial, 
industrial  and  recreational  infrastructure  and  areas, 
followed by the development and operation of transport 
systems,  are  also  reported  as  broad  categories  of 
pressures and threats affecting peatlands (bog, mire and 
fen habitat types). 

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 of the 
Habitats  Directive.  Moreover,  forests  host  several 
species  protected  under  the  Birds  and  Habitats 
Directives, 
is  a 
requirement  to  designate  Natura  2000  sites  and  to 
protect breeding sites and resting places. 

including  those  for  which  there 

Several  guidelines  on  forestry  management  were 
published by the Commission in 2023 (70). 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.  They  include  further 
guidance on payment schemes for ecosystems services. 

In  2023,  the  Commission  proposed  a  new  Forest 

(69) 
(70) 

(71) 

(72) 

on 

Closer-to-Nature 

7720 in the Atlantic region and 7230 in the Alpine region. 
European  Commission:  Directorate-General  for  Environment, 
Guidelines 
Forest  Management, 
Publications  Office  of  the  European  Union,  Luxembourg,  2023, 
https://environment.ec.europa.eu/publications/guidelines-
closer-nature-forest-management_en. 
European  Commission, 
Commission 
https://environment.ec.europa.eu/topics/forests/forest-
monitoring_en. 
EEA, State of Nature in the EU: Results from reporting under the 
nature  directives  2013–2018,  EEA  Report  No 10/2020, 
Publications Office of the European Union, Luxembourg, 2020. 

‘Forest  monitoring’, 

European 
website, 

Assessments  show  that,  of  the  27 %  of  EU  forest  area 
protected under the Habitats Directive, less than 15 % is 
of  favourable  conservation  status (72).  The  share  of 
forested areas in the EU with a bad conservation status 
increased from 27 % in 2015 to 31 % in 2018. 

In  Spain,  forests  covered  37.2 %  of  the  territory in 
2020 (73),  and  more  than  90 %  of  the  forest  habitat 
assessments  covered by the Habitats Directive  reveal  a 
bad to poor status (74). 

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. 

. 

Spain  has  updated  its  national  forestry  programme, 
made up of the Spanish Forest Strategy Horizon 2050 and 
the  2022–2032  Spanish  Forest  Plan,  both  approved  by 
agreement  of  the  Council  of  Ministers  of  20 December 
2022. 

(73) 

(74) 

EEA,  Forest  information  system  for  Europe,  ‘Country –  FISE 
country  factsheets’,  forest  information  system  for  Europe 
website, https://forest.eea.europa.eu/countries. 
Commission staff working document – Stakeholder consultation 
and evidence base 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 –  New  EU  forest  strategy  for  2030, 
SWD(2021)  652 
final  of  16 July  2021,  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52021SC0652. 

2025 Environmental Implementation Review – Spain 

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

The  EU  Timber  Regulation  (EUTR) (75)  prohibits  the 
placing on the EU market of illegally harvested timber.  

(EUDR) (76)  entered 

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

force 

into 

Spain  24 

October  2024,  and  these  will  be  assessed  by  the 
Commission.  In  the  context  of  this  next  round  of 
reporting, 
in  accordance  with  the  MSFD  and  the 
Commission  GES  Decision (79),  Member  States  must 
include  as  part  of  their  set  of  GES  characteristics  any 
threshold  values  for  the  descriptors  in  the  MSFD  that 
may  have  been  established  in  cooperation  with  other 
Member States at the EU or regional level (80). 

The  Commission  assessed  the  updated  monitoring 
programme reported by Member States in 2020 (81). At 
that  time  their  updates  on  the  elements,  features  and 
parameters identified monitoring gaps. The Commission 
recommended  that  Member  States  should  prioritise 
work 
levels  of 
implementation of the MSFD. 

those  gaps  at  all 

to  address 

Member States also reported their updated Programme 
of  Measures,  that  is  required  under  Article 13  of  the 
MSFD  and  must  be  updated  every  six  years.  The 
Commission has assessed them. 

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

Marine ecosystems 

The  Marine  Strategy  Framework  Directive  (MSFD (78)) 
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 have to report updates by 

(75) 

(76) 

Regulation (EU) No 995/2010 of the European Parliament and of 
the  Council  of  20 October  2010  laying  down the  obligations  of 
operators who place timber and timber products on the market 
(OJ  L 295,  12.11.2010,  p. 23),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32010R0995. 
Regulation (EU) 2023/1115 of the European Parliament and of 
the Council of 31 May 2023 on the making available on the Union 
market and the export  from the Union of certain commodities 
and  products  associated  with  deforestation  and 
forest 
degradation  and  repealing  Regulation  (EU)  No 995/2010  (OJ 
L 150,  9.6.2023,  p. 206),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32023R1115&qid=1687867231
461. 

(77)   This  new  legislation  will  apply  to  large  and  medium-sized 
companies  starting  on  30  December  2025,  and  to  micro  and 
small enterprises starting on 30 June 2026. 

(78)  Directive  2008/56/EC  of  the  European  Parliament  and  of  the 
Council of 17 June 2008 establishing a framework for community 
action  in  the  field  of  marine  environmental  policy  (Marine 

(79) 

(80) 

(81) 

and 

and 

assessment, 

Strategy  Framework  Directive)  (OJ  L 164,  25.6.2008,  p. 19), 
http://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32008L0056. 
Commission  Decision  (EU)  2017/848  laying  down  criteria  and 
methodological  standards  on  good  environmental  status  of 
marine waters and specifications and standardised methods for 
monitoring 
repealing  Decision 
2010/477/EU 
(OJ  L 125,  18.5.2017,  p. 43),  https://eur-
lex.europa.eu/eli/dec/2017/848/oj/eng. 
Commission Notice on the threshold values set under the MSFD 
(Directive 2008/56/EC) and Commission Decision (EU) 2017/848 
(C/2024/2078). 
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), C(2023) 
2023, 
2203 
https://environment.ec.europa.eu/system/files/2023-
04/C_2023_2203_F1_COMMUNICATION_FROM_COMMISSION
_EN_V5_P1_2532109.PDF. 

4 April 

final 

of 

2025 Environmental Implementation Review – Spain 

 
 
 
Source: 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 January and March 2023. 

Spain’s  updated  Programme  of  Measures  shows 
levels  of  adequacy  across  all 
moderate  to  good 
descriptors, 
revealing  balanced  progress  overall, 
although improvements could be made in several areas. 

Progress  can  be  noted  on  biodiversity  (D1),  with 
additional  measures  on  the  development  of  marine 
protected  areas  and  on  bycatch  reduction.  Regarding 
non-indigenous  species  (D2),  commercial  fish  and 
shellfish  (D3),  eutrophication  (D5),  contaminants  in 
seafood  (D9)  and  marine  litter  (D10),  coverage  of 
pressures 
for 
improvement.  On  marine  litter  for  instance,  although 
Spain  defined  measures  to  address  urban  activities, 
fishing and tourism, greater coverage is needed on more 
specific types of litter such as microlitter. 

is  only  partial,  pointing  to  areas 

Spain has not ratified the Protocol for the Protection of 
the Mediterranean Sea against Pollution Resulting from 
the Exploration and Exploitation of the Continental Shelf 
and the Seabed and its Subsoil (Offshore Protocol to the 
Barcelona Convention). 

Spain  received  two  priority  actions  in  the  2022  EIR:  (i) 
ensure regional cooperation with Member States sharing 
the  same  marine  (sub)region  to  address  predominant 
pressures;  and  (ii)  implement  the  recommendations 
made  by  the  Commission  in  the  2022  MSFD  legal 
reporting.  It  is  not  possible  to  evaluate  these  priority 
actions  currently,  as  relevant  data  have  not  yet  been 
evaluated. 

2025 priority actions 

its 

•  Report  updates  on  the  assessment  of  the  state  of 
Spain’s  marine  waters, 
its 
determinations  of  GES (82),  which  are  expected  to 
include  any  threshold  values  for  the  descriptors  in 
the  MSFD  that  may  have  been  established  in 
cooperation with other Member States at the EU or 
regional level. 

target  and 

(82) 
(83) 

(84) 

In accordance with Article 17 of Directive 2008/56/EC. 
Commission Implementing Regulation (EU) 2016/1141 of 13 July 
2016  adopting  a  list  of  IAS  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 
(https://eur-
and 
lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:02016R1141-
20220802&from=EN). 
Regulation (EU) No 1143/2014 of the European Parliament and 
of  the  Council  of  22 October  2014  on  the  prevention  and 

2022/1203 

(EU) 

Spain  25 

•  Ratify  the  Protocol  for  the  Protection  of  the 
Mediterranean Sea against Pollution Resulting from 
the Exploration and Exploitation of the Continental 
Shelf  and  the  Seabed  and  its  Subsoil  (Offshore 
Protocol to the Barcelona Convention). 

Prevention and management of invasive alien 
species 

Invasive  alien  species  (IAS)  are  a  major  cause  of 
biodiversity  loss  in  the  EU.  Besides  inflicting  direct  and 
indirect damage on nature and the economy, some IAS 
also carry and spread infectious diseases, posing a threat 
to  humans  and  wildlife.  Regulation  (EU)  No 1143/2014 
(the  IAS  Regulation)  aims  to  prevent,  minimise  and 
mitigate  the  adverse  impacts  of  IAS  on  biodiversity.  It 
focuses action on a list of IAS of EU concern (the ‘Union 
list’), which is regularly updated (83). 

The IAS Regulation (84) 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. 

The third update of the Union list entered into force on 
2 August 2022. The fourth update is in preparation. The 
BDS also aims to decrease by 50 % the number of Red List 
species threatened by IAS. 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 (85).  More  recent  studies  have 
put  this  cost  at  USD 28 billion  per  year  in  the  EU, 
increasing  to  USD 148.2 billion  by  2040 (86),  and  at 
USD 423 billion annually at the global level (87). 

The total number of IAS of Union concern in the country 

management  of  the  introduction  and  spread  of  invasive  alien 
species (OJ L 317, 4.11.2014, p. 35).  

(85)  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. 

(87) 

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

Science-Policy 
Services), 

(Intergovernmental 

Ecosystem 

and 

2025 Environmental Implementation Review – Spain 

 
 
is 57. This includes 36 species recorded in the previous 
(2022) EIR and 21 new additions. Of these new additions, 
10 were already on the Union concern list in 2021, and 
11  were  added  later  under  Commission  Implementing 
Regulation (EU) 2022/1203. 

Figure 15:  Number  of  invasive  alien  species  of  EU 
concern, based on available georeferenced information 
for Spain, 2024 

In the 2022 EIR, Spain received a priority action on taking 
further measures to combat IAS and improve the control 
of their pathways as well as to advance their control and 
eradication. There has been substantial progress, and the 
action  can  be  considered  fulfilled.  Moreover,  the 
infringement  procedure open  under the IAS Regulation 
has been closed. 

2025 priority action 

• 

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

Spain  26 

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 (88) aims to ensure the full 
integration  of  biodiversity  and  its  multiple  values  into 
policy  and  planning  and,  as  appropriate,  national 
accounting.  This  requires  effective  and  coherent 
biodiversity  observation  and  reporting  on  ecosystem 
condition in the EU (89). 

The amended Regulation (EU) No 691/2011 on European 
environmental  economic  accounts (90)  introduces  new 
requirements  for  Member  States  to  report  on  the 
condition  of  ecosystems  including  urban  ecosystems, 
croplands,  grasslands,  forest  and  woodlands,  coastal 
beaches,  dunes  and  wetlands.  Data  reported  by  the 
Member  States  will  feed  into  the  second  European 
ecosystem assessment, due in 2027, and can also be used 
to support policy decisions. 

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

An 
increasing  number  of  platforms,  networks  and 
communities of practice involve businesses in protecting 
biodiversity,  including  the  EU  Business  &  Biodiversity 
Platform (91). These platforms and communities are key 
tools  for  promoting  and  facilitating  natural  capital 
assessments  among  businesses  and  financial  services 
providers. 

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

There are two Spanish business and biodiversity network 
members of the EU Business & Biodiversity Platform. 

In  Spain,  the  development  of  ecosystem  accounting  is 
seen as complementary to a broad range of national and 
international policy needs. It contributes in particular to 

(89) 

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

Assessment – 

Summary 

for 

(90) 

(91) 

final 

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

11 July 

2022, 

of 

2025 Environmental Implementation Review – Spain 

 
 
 
 
the  System  of  Environmental  Economic  Accounting 
Ecosystem  Accounting,  the  European  Environmental 
Economic Accounts, and the EU and Spanish Biodiversity 
Strategies. 

Spain  27 

Ecosystem accounting is progressing with a strong focus 
on addressing key gaps and building a robust framework 
for  evaluating  natural  assets.  Within  the  framework  of 
official national accounts, Spain has undertaken its first 
pilot  project  on  extent  accounts.  Complementing  this 
effort,  the  experimental  work  of  the  ‘Mapping  and 
assessment for integrated ecosystem accounting’ project 
has 
led  to  the  development  of  ecosystem  extent 
accounts  and  forest  condition  accounts  at  the  national 
level. 
the 
development  of  ecosystem  services  and  biodiversity 
accounts, 
including  the  development  of  plans  to 
establish  comprehensive  ecosystem  asset  accounts  in 
the near future. 

In  addition,  progress 

continues  on 

Despite this progress, a number of challenges still persist. 
In  particular,  there  is  a  need  to  address  data  gaps  for 
certain  ecosystem  services,  such  as  regulating  and 
cultural  services,  as  well  as  in  the  development  of 
accounts  for  complex  systems  like  marine  ecosystems. 
include  fostering  collaboration  with 
Key  priorities 
institutions  providing  critical  data;  enhancing  data 
accessibility;  and  promoting  political  and  legislative 
frameworks  to  strengthen  ecosystem  accounting.  In 
2022, ecosystem accounting was identified as a priority 
action  for  Spain,  but  progress  has been  constrained  by 
insufficient data. 

At  the  regional  level,  Andalusia  has  made  valuable 
contributions  to  these  efforts  by  developing  monetary 
accounts  for  forest  assets,  along  with  accounts  for 
ecosystem  services,  carbon  storage  and  biodiversity. 
These regional initiatives complement national progress 
and underscore the potential for local efforts to enhance 
ecosystem accounting practices across Spain. 

In  2022,  Spain  received  a  priority  action  on  ecosystem 
accounting, which cannot be assessed due to the lack of 
data. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Spain  28 

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 (92).  These  set  health-based  EU  air  quality 
standards (93)  and  stipulate  Member  States’  national 
emission  reduction  commitments (94)  for  several  air 
pollutants. 

On  air  pollution,  Spain  presents  a  mixed  picture.  While 
emissions  of  several  air  pollutants  have  fallen  in  recent 
decades,  air  quality  in  Spain  continues  to  give  cause  for 
concern  in  some  parts  of  its  territory,  mainly  related  to 
nitrogen  dioxide  (NO2).  In  particular,  private  transport 
exacerbates seasonal problems with air quality and traffic 
congestion  in  the  major  metropolitan  areas,  namely 
Madrid  and  Barcelona,  leading  to  health  and  economic 
costs. The Spanish authorities are taking further measures 
to  tackle  this 
issue,  which  have  to  be  rigorously 
implemented. 

The  latest  available  annual  estimates  (for  2022)  by  the 
EEA (95)  for  Spain  attribute  18 500  deaths  each  year  (or 
184 200 years of life lost (YLL)) to fine particulate matter 
(PM2.5) (96);  5 500  deaths  each  year  (or  54 500 YLL)  to 

NO2 (97);  and  6 100  deaths  each  year  (or  61 300 YLL)  to 
ozone (98). 

The  emissions  of  several  air  pollutants  have  decreased 
significantly  in  Spain  since  2005,  while  GDP  growth  has 
continued  (see  Figure 16).  According  to  the  inventories 
submitted  under  Article 10(2)  of  the  National  Emission 
Reduction  Commitments  Directive  (NECD) (99)  in  2024, 
Spain  has  met  its  emission  reduction  commitments  for 
2020–2029  for  the  air  pollutants  nitrogen  oxides  (NOx), 
non-methane  volatile  organic  compounds  (NMVOC), 
sulphur  dioxide 
(NH3)  and  PM2.5. 
(SO2),  ammonia 
According  to  the  latest  projections  submitted  under 
Article 10(2)  of  the  NECD,  Spain  is  projected  to  meet  its 
emission  reduction  commitments  for  2030  onwards  for 
NOx, SO2, NH3 and PM2.5, but not for NMVOC. 

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

150%

100%

50%

0%

NH₃

PM2.5
PM2.5

NMVOC

SO₂

NOₓ

GDP

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

2024, 

(92) 

(93) 

(94) 

(95) 

(96) 

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

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

(97)  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. 

(98) 

(99)  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 – Spain 

 
 
 
 
Spain  29 

limit  values 

in  2022 (103)  confirming  non-
of  NO2 
compliance  with  Directive  2008/50/EC.  The  aim  is  that 
appropriate  measures  are  put  in  place  to  bring  all  air 
quality zones into compliance. This case is still open and 
the  Commission  is  assessing  the  measures  adopted  by 
Spain to comply with the ruling. 

In the 2022 EIR, Spain received two priority actions. The 
first was to further reduce emissions in the context of the 
NAPCP. Spain has made some progress on this. While the 
latest data show compliance with the 2020–2029 emission 
reduction  commitments,  Spain  is  still  projected  not  to 
reach the emission reduction commitment for NMVOC for 
2030 onwards. The second priority action was to ensure 
full compliance with EU air quality standards and maintain 
downward  emission  trends.  Based  on  the  latest  data, 
Spain  has  made  some  progress  in  this  regard.  However, 
exceedances above limit values and target values remain 
for PM10, ozone and arsenic, requiring further action. Since 
2019, downward emission trends have been reported for 
all  main  pollutants,  except  for  PM2.5,  requiring  further 
action. 

2025 priority actions 

•  As  part  of the  NAPCP,  take  action  towards  reducing 

Spain submitted its updated national air pollution control 
programme  (NAPCP)  to  the  Commission  on  18 January 
2024. 

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

100%

80%

60%

40%

20%

0%

Waste

Transport

Residential,
commercial &
institutional

Manufacturing
and extractive
industry

Energy supply

Agriculture

PM2.5
PM2.5
42,28%

10,93%

NOₓ

9,93%

46,00%

27,74%

7,96%

12,43%

14,86%

• 

2,85%

3,77%

7,53%

13,72%

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

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

2024, 

In  2023,  exceedances  above  the  limit  values  set  by  the 
Ambient Air Quality Directive (AAQD) (100) were registered 
in  two  air  quality  zones (101) 
in  Spain. 
for  PM10 
Furthermore, the target values for ozone concentrations 
were not met for several air quality zones, and neither was 
the target value for arsenic in one air quality zone (102). 

Persistent  breaches  of  air  quality  requirements,  which 
have  severe  negative  effects  on  health  and  the 
environment,  are  being  followed  up  by  the  European 
Commission through infringement procedures covering all 
for 
Member 
exceedances  of  PM10  and  NO2  limit  values.  The  Court  of 
Justice of the EU delivered a judgment about exceedances 

concerned, 

including 

States 

Spain 

Industrial emissions 

The  main objectives of EU policy on industrial emissions 
are to: 
(i)  protect  air,  water  and  soil  and  to  prevent  harmful 

effects on human health and the environment; 

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

water; 

(iv) contribute to decarbonisation. 
The  cornerstone  of  the  policy  is  the  Industrial  Emissions 
Directive  (IED),  which  was  revised  in  2024 (104).  The 
revision improves the directive’s contribution to the zero 
pollution  objective.  It  has  a  strong  focus  on  innovation, 
depollution, 
and 
decarbonisation and circularity, making it a key regulatory 
tool  to  accompany  the  green  transformation  of  EU 

between 

builds 

solid 

links 

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

11.6.2008, 

L 152, 

p. 1), 

(OJ 

(101)  Avilés and Plana de Vic. 
(102)  EEA, 

Eionet 
(https://cdr.eionet.europa.eu). 
Judgment of 22 December 2022, Commission v Spain, C-125/20. 

Central 

Data 

Repository 

(103) 

(104)  Directive  2010/75/EU  of  the  European  Parliament  and  of  the 
Council of 24 November 2010 on industrial and livestock rearing 
emissions (integrated pollution prevention and control) (OJ L 334, 
17.12.2010, p. 17), as amended by Directive (EU) 2024/1785 of the 
European  Parliament  and  of  the  Council  of  24 April  2024, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02010L0075-
20240804&qid=1725983863299. Informal consolidated text. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
industry by 2050. 

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

Spain  30 

The overview of industrial activities regulated by the IED 
below  is  based  on  data  reported  to  the  EU  Registry  in 
2022 (105) . 

In Spain, around 7 000 industrial installations are required 
to  have  a  permit  based  on  the  IED,  with  the  majority  of 
them  falling  in  the  intensive  rearing  of  poultry  and  pigs 
sector (56 %), followed by the food and drink sector (7 %) 
and mineral production (7 %). 

Figure 18  shows  the  damage  to  health  and  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’. Spain has relatively high damage 
(the fifth highest in the EU) and it is above the EU average 
of  EUR 27.5/EUR 1 000  GVA  in  emissions  intensity  (11th 
highest  in  the  EU).  The  main  industrial  contributors  to 
emissions  to  air  (106)  are  the  energy  sector  (including 
refineries,  gasification,  etc.),  the  mineral  sector  and  the 
metal sector. 

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

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

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  Spain 
in  particular,  Figure 20  shows  the 
industrial emissions of heavy metals to water, taking into 
account the human toxicity of each metal, as well as  the 
emissions  intensity,  based  on  its  ratio  with  industrial 
activity  (expressed  in  GVA).  Spain  has  the  5th  highest 
emissions of heavy metals to water and is in 9th position 
for  emissions  intensity  (with  same  intensity  as  the  EU 
average, 0.864 kg/EUR 1 billion GVA). 

Figure 20:  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 19. 

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

As shown in Figure 21, the main industrial contributors to 
emissions  to  water  in  Spain  are  the  energy  sector,  the 
chemical sector, the metal sector and livestock rearing. 

(105)  EEA, 

European 

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

Emissions 

(106) 
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 – Spain 

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

treatment  systems 
smitheries and foundries. 

in  the  chemical  sector  and  (iv) 

Spain  31 

100%

75%

50%

25%

0%

Polycyclic
aromatic
hydrocarbons
(PAHs)

Heavy Metals
Ecotoxicity

Heavy Metals
Human
Toxicity

Chemicals
Extractive industry
Food and drink
Landfill
Non-ferrous metal
Pulp, paper and wood

Total nitrogen Total organic
carbon (TOC)

Total
phosphorus

Electricity and heat production
Ferrous metal
Incineration with energy recovery
Livestock
Other manufacturing
Refineries

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

13 September 

Data 

IED 

contains  mandatory 

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 
NGOs,  alongside  competent  authorities,  play  a  role  in 
ensuring compliance of these permits with EU legislation. 
The 
requirements  on 
environmental  inspections,  requiring  a  site  visit  to  take 
place at least every 1–3 years, using risk-based criteria. In 
addition,  IED  enforcement  provisions  require  Member 
States 
to  determine  effective,  proportionate,  and 
dissuasive  penalties  applicable  to  infringements  of  IED-
based  national  provisions.  In  the  revised  directive,  the 
provisions set that worst infringements can be sanctioned 
by fines of at least  3% of the annual EU turnover of the 
legal person. The revised IED will also introduce a right to 
compensation for people whose health has been harmed 
by such infringements. 

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

Since  the  2022  EIR,  the  Commission  has  adopted  BAT 
conclusions on (i) ferrous metal processing, (ii) the textiles 
industry,  (iii)  common  waste  gas  management  and 

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. 

to 

In 2022, Spain received priority actions to review permits 
to ensure that they comply with the newly adopted BATC 
conclusions,  and 
strengthen  monitoring  and 
enforcement to ensure compliance with BAT conclusions. 
Spain  also  received  a  priority  action  to  address  air  and 
water  pollutant  emissions  and  the  odour  from  plants 
engaged in the intensive rearing of poultry or pigs. Spain 
was  also  asked  to  tackle  air  pollution  from  coal-fired 
power generation plants and from the co-incineration of 
waste  in  cement  plants.  There  are  no  data  available  to 
assess progress towards these priority actions. 

2025 priority actions 

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

• 

• 

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

Major industrial accidents prevention – Seveso 

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

substances, especially chemicals; 

(ii)  limit  the  consequences  of  such  accidents  for  human 

health and the environment; 

(iii) continuously improve the prevention of, preparedness 

for and response to major accidents. 

The cornerstone of the policy is Directive 2012/18/EU (the 
Seveso III Directive) (107)). 

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 (108)  and  the  report  by 

(107)  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. 

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

in September 2024. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
Spain  32 

Figure 23: Situation regarding EEPs in Spain. 2022 

2022, 

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

The information  for the public referred to in  Annex V to 
the Seveso III Directive – especially about how the public 
concerned will be warned if there is a major accident, the 
appropriate  behaviour  in  the  event  of  a  major  accident 
and the date of the last site visit – is permanently available 
for 81 % of the Seveso establishments in Spain. 

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 24. This provision on knowledge is an important 
provision of the Seveso III Directive, as awareness by the 
public of this information may  reduce the consequences 
of a major industrial accident. 

Spain on the implementation of the Seveso III Directive for 
2019–2022 (109). 

In Spain, in 2024, among the 856 Seveso establishments, 
406 are categorised as lower-tier establishments and 450 
as upper-tier establishments (UTEs), based on the quantity 
of  hazardous  substances  likely  to  be  present.  UTEs  are 
subject  to  more  stringent  requirements.  The  changes  in 
the  number  of  Seveso  establishments  are  presented  in 
Figure 22. 

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

NB: LTE, lower-tier establishment. 

2022, 

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

According to Spain, in 2022, an external emergency plan 
(EEP) was required for 434 UTEs, out of a total of 439. That 
same  year,  430  UTEs  had  EEPs,  of  which  229  had  been 
tested  over  the  previous  three  years.  The  summary  is 
shown in Figure 23. The establishment of EEPs is essential 
to allow proper preparation and effective implementation 
of the necessary actions to protect the environment and 
industrial  accident 
the  population  should  a  major 
nevertheless happen. 

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

2025 Environmental Implementation Review – Spain 

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

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,  Spain  received  a  priority  action  to  strengthen 
control  and  enforcement  to  ensure  compliance  with 
Seveso III Directive provisions, especially  those  on public 
the 
information  and  EEPs.  Data 
implementation  of  the  Directive  for  2019–2022  show 
improvement in the numbers of EEPs established for UTEs 
in  Spain,  but  an  insufficient  number  of  EEP  were  tested 
over the previous three years. 

reported  on 

2025 priority actions 

• 

• 

Strengthen  compliance  with  requirements  on  safety 
measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response in relation to 
UTEs, in particular  as regards reviewing, testing  and 
updating  EEPs,  at  intervals  of  no  more  than  three 
years. 
Ensure  access  to  transparent  and  clear  information 
towards  citizens  on  risks  and  behaviour  in  case  of 
accidents. 

Spain  33 

Mercury Regulation 

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

Measures should have been put in place in Spain to ensure 
a  socially  and  economically  sound  phase-out  of  dental 
amalgam,  including  an  adequate  reimbursement  of  the 
alternatives through the health insurance scheme and the 
training  of  dental  practitioners.  The  Commission 
is 
monitoring whether the phase-out of the dental amalgam 
has  taken  place  under  the  terms  and  conditions  of  the 
regulation.  Spain  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 (110)  requires  a 
common  approach  to  avoid,  prevent  and  reduce  the 
harmful  effects  of  noise.  The  designated  authorities  are 
responsible  for  making  and  approving  noise  maps  and 
action  plans  for  agglomerations,  major  roads,  major 
railways  and  major  airports.  Member  States  decide  on 
noise limits that are not set at the EU level. Nevertheless, 
the zero pollution action plan sets as a 2030 target a 30 % 
reduction  compared  with  2017  in  the  share  of  people 
chronically disturbed by transport noise. 

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

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

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

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
Spain  34 

the  EU.  It  can  cause  ischaemic  heart  disease,  stroke, 
interrupted sleep, cognitive impairment and stress (111). 

In  Spain,  environmental  noise  is  estimated  to  cause  at 
least  around  1 800  cases  of  ischaemic  heart  disease 
annually (112)  and  some  395 000  people  to  suffer  from 
disturbed sleep (113). 

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

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

Spain  received  two  priority  actions  in  the  2022  EIR,  to 
complete noise mapping and noise action plans. There has 
been  no  progress  on  the  first  priority  action,  on  noise 
mapping,  as  detailed  above.  Given  that  reporting  under 
the most recent reporting cycle for noise action plans was 
due in early 2025, these have not been assessed. 

2025 priority actions 

• 
• 

Complete noise mapping. 
Complete  and  implement  action  plans  on  noise 
management. 

Water quality and management 

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

Water Framework Directive 

The  Water  Framework  Directive  (WFD) (114) 
is  the 
in  the  21st 
cornerstone  of  the  EU  water  policy 
century (115).  The  WFD  and  other  water-related 
directives (116) form the basis of sustainable and integrated 
water management in the EU. They aim to achieve a high 
level  of  protection  of  water  resources,  prevention  of 
further  deterioration  and  restoration  to  good  status. 
These  objectives  are  very 
important  for  the  EU’s 
competitiveness,  strategic  autonomy  and  security,  yet 
have become even more challenging in the face of climate 
change affecting our precious water resources. 

The WFD establishes a procedural framework for reaching 
good  surface  water  ecological  and  chemical  status  and 
good groundwater quantitative and chemical status. This 
implies  monitoring  and  classification  of  all  waterbodies, 
assessment of pressures and impacts and identification of 
the  most  cost-effective  measures  to  achieve  the 
objectives of the directive. The directive dates from 2000 
and  set  an  initial  deadline  of  2015  for  achieving  its 
objectives, with the option to extend the deadline to the 
end of 2027. Every six years, Member States must report 

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

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

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

is available at: 
https://www.eea.europa.eu/themes/human/noise/noise-2. 
(114)  Directive  2000/60/EC  of  the  European  Parliament  and  of  the 
Council  of  23  October  2000  establishing  a  framework  for 

Community  action  in  the  field  of  water  policy  (OJ  L  327, 
22.12.2000, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:32000L0060. 

1), 

p. 

(115)  https://ec.europa.eu/environment/water/index_en.htm. 
(116)  This 

includes 

the 

Treatment 

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

Drinking  Water 

Directive 

and 

the 

the 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
  
Spain  35 

The most significant pressures come from diffuse sources 
of  agriculture  (mainly  nutrients)  and  point  sources  from 
urban  wastewater,  as  well  as  morphological  changes 
resulting in altered habitats. Electricity from hydropower 
accounts for 20 % of total electricity production. 

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

their  river  basin  management  plans  (RBMPs)  to  the 
Commission. They should cover river basin districts (RBDs) 
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 
has reported its findings to the European Parliament and 
to the Council on 4 February 2025 (117). 

Spain has 25 RBMPs in terms of the WFD, related to the 
corresponding  RBDs (118).  The  Spanish  RBDs  count  5470 
surface waterbodies and 804 groundwater bodies. 70 % of 
all  lake  waterbodies  are  heavily  modified  (a  significant 
increase  since 
the  second  RBMPs),  as  well  as 
approximately  17 %  of  rivers,  40 %  of  transitional 
waterbodies and 20 % of coastal waterbodies. 5 % of lake 
waterbodies are artificial. 

in 

the 

show 

changes 

ecological 
Figures 25–28 
status/potential and in chemical status of surface waters, 
and in quantitative and chemical status of groundwaters 
in  2010,  2015  and  2021.  Heavily  modified  water  and 
artificial waterbodies must reach good ecological potential 
rather than good ecological status, which  means that all 
measures must be taken to mitigate the adverse impact of 
the sustainable human development activities causing the 
waterbody  to  be  heavily  modified/artificial,  while  not 
significantly affecting these activities. 

It follows from the assessment of the third RBMPs that the 
ecological  status/potential  of  surface  waterbodies  has 
only slightly improved since the second RBMPs, with 58 % 
of  surface  waterbodies  having  good  status/potential. 
Furthermore,  the  chemical  status  remains  broadly  the 
same but with some improvement, with 90 % of surface 
waterbodies having good chemical status. 

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

status/potential  of 

surface 

(117)  Commission Staff Working Document – EU overview, Third River 
Basin Management Plans, Second Flood Hazard and Risk Maps and 
Second  Flood  Risk  Management  Plans,  Member  State:  Spain, 
accompanying the document report from the Commission to the 
Council  and  the  European  Parliament  on  the  implementation of 
the  Water  Framework  Directive  (2000/60/EC)  and  the  Floods 
Directive  (2007/60/EC),  SWD(2025)  13  final  of  4  February  2025, 

The  principal  substances  that  cause  failure  to  achieve 
good  chemical  status  are  metals  (nickel,  cadmium, 
mercury  and  lead),  followed  by  perfluorooctanesulfonic 
acid  (PFOS)  and  pesticides  (cypermethrin,  chlorpyrifos, 
hexachlorocyclohexane,  endosulfan  and  dicofol).  Among 
these,  ubiquitous,  persistent,  bioaccumulative,  toxic 
substances (mercury and PFOS) play just  a  minor role in 
others 
the 
(hexachlorocyclohexane,  endosulfan,  dicofol  and  PFOS) 
are  recognised  persistent  organic  pollutants  under  the 
Stockholm Convention listed for elimination or restriction. 

failures, 

number 

while 

of 

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

https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=SWD%3A2025%3A24%3AFIN&qid=173874
6144581 
(118)  MITECO, 

‘Demarcaciones 

hidrográficas’, 

https://www.miteco.gob.es/es/agua/temas/planificacion-
hidrologica/marco-del-agua/demarcaciones_hidrograficas.html. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
The quantitative status of groundwater bodies has slightly 
deteriorated since the second RBMPs, with 75 % reported 
to have good quantitative status. In some RBDs, however, 
the  classification  may  be  biased,  since  it  does  not  fully 
consider, as required under the WFD, the water needs of 
dependent  aquatic  and  terrestrial  ecosystems.  The  very 
severe  natural  degradation  in  the  case  of  the  Doñana 
National Park, a flagship biodiversity hotspot in the EU, has 
highlighted  the  crucial  importance  of  considering  the 
needs  of groundwater-dependent  terrestrial and aquatic 
ecosystems. 

intrusions  resulting 

The main reason for failing to achieve good quantitative 
status  is  over-abstraction,  followed  at  a  considerable 
distance  by  saline/other 
from 
anthropogenically  induced  changes  in  flow  direction, 
which  in  coastal  areas  is  caused  by  over-abstraction. 
Recent studies show that the combined impacts of climate 
change  and  groundwater  pumping  will  significantly 
decrease  natural  groundwater  recharge,  reduce  soil 
moisture  and  increase  actual  evapotranspiration,  while 
predictions  regarding  desertification  and  prolonged 
droughts are becoming more certain. 

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

The  chemical  status  of  groundwater  bodies  has  slightly 
improved  since  the  last  cycle,  with  at  least  67 %  now 
reported as having good chemical status. However, 43 % 
of groundwater bodies are at risk of failing to achieve good 
chemical status by 2027.  The main reasons for failing  to 
achieve  good  chemical  status  are  general  water  quality, 
followed  by  saline/other 
from 
anthropogenically induced changes in flow direction and 
deterioration in quality of water for human consumption. 
Nitrate,  chloride,  conductivity,  sulphates  and  pesticides 
are the main pollutants causing failure, with most of them 
also showing sustained upward trends. 

intrusion 

resulting 

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

Spain  36 

The  2022  EIR  identified  the  following  priority  actions:  (i) 
assess  new physical modifications of waterbodies in line 
with  Article 4(7)  of  the  WFD;  and  (ii)  increase  efforts  to 
reduce  nitrates  from  agriculture  in  groundwater  and 
surface  waters  where 
address  eutrophication  of 
agriculture pressure is significant. 

Spain  has  made  some  progress.  In  this  context,  it  is 
positive that the third RBMPs provide measures to address 
all significant pressures in both groundwater and surface 
water, including both environmental measures and water-
demand-related  measures.  Many  measures  aim  at 
reducing pollution from nutrients and pesticides. 

2025 priority actions 

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

• 

• 

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

•  Reduce  pollution  from  nutrients,  chemicals,  metals 

and saline discharges 

•  Better justify exemptions to the achievement of good 

• 

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

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

financing 

Floods Directive 

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

The  Commission  assessed  the  FRMPs  and,  as  above 
mentioned, on 4 February 2025 reported on both the third 
RBMPs  and  second  FRMPs  to  the  European  Parliament 
and to the Council. 

The second FRMPs in Spain have improved insofar as: 

•  Objectives  are 

to  both  measures  and 
indicators,  making  it  possible  to  verify  progress  on 
achieving objectives. 

linked 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
•  Greater  emphasis  is  put  on  the  role  of  land  use / 
spatial planning in addressing flood risks, as well as on 
nature-based solutions. 
Public awareness is considered. 

• 

However,  there  is  room  for  improvement  for  the  future 
FRMPs. 

2025 priority actions 

• 

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

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

consultation  and 

stakeholder 

• 

Drinking Water Directive 

The recast Drinking Water Directive is now applicable, and 
Member States were required to transpose its provisions 
into their national legal systems by 12 January 2023. Since 
into  force  of  the  recast  directive,  the 
the  entry 
several  delegated  and 
Commission  has  adopted 
implementing  acts  establishing  (i)  a  watch 
list  of 
substances  and  compounds  of  concern  for  drinking 
water (119), (ii) a methodology for measuring microplastics 
in drinking water (120) and (iii) an EU system for testing and 
approving materials that will be allowed to be in contact 
with drinking water (121). Member States will have to take 
into  account  when 
these  various  Commission  acts 
implementing the recast directive. 

Finally,  the  Commission  has  now  received  data  from 
Member States on the quality of drinking water in 2017–
2019.  The  quality  of  drinking  water  (supplied  by  large 
water  suppliers) 
in  Spain  does  not  give  rise  to 
concern (122). 

From  January  2026,  the  European  quality  standards  for 
PFAS  in  drinking  water  will  apply,  ensuring  harmonised 

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

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

(120)  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, 
23.4.2024, http://data.europa.eu/eli/dec_impl/2024/368/oj; OJ L, 

(121)  OJ L, 

2024/369, 

Spain  37 

Member States’ reporting of PFAS monitoring data in the 
future. 

Bathing Water Directive 

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

Figure 29  shows  that  in  2023,  out  of  the  2 275  Spanish 
bathing waters, 1 993 (87.6 %) were of excellent  quality, 
177 bathing waters (7.8 %) of good quality and 38 bathing 
waters  (1.7 %)  of  sufficient  quality.  39  bathing  waters 
(1.7 %)  were  found  to  be  of  poor  quality.  28  bathing 
waters were not classified (1.2 %). 

Detailed  information  on  the  Spanish  bathing  waters  is 
available  from  a  national  portal (123)  and  through  an 
interactive map viewer of the EEA (124). 

Figure 29:  Bathing  water  quality  per  Member  State, 
Albania and Switzerland (%), 2023 

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

in  2023,  briefing 
2024, 

Copenhagen, 

23.4.2024, 
2024/370, 
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 Spain was 
at least 99.59 % in 2017, 99.64 % in 2018 and 99.26 % in 2019. 

(122) 

(123)  Ministry of Health, NAYADE Information System. 
(124)  EEA, 

‘State  of  bathing  water’, 

EEA  website,  2024, 

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

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
Nitrates Directive 

Urban Wastewater Treatment Directive 

Spain  38 

The  Nitrates  Directive (125)  aims  to  protect  water  quality 
across  Europe  by  preventing  nitrates  from  agricultural 
sources that can pollute groundwater and surface waters 
and by promoting the use of good farming practices. 

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

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

As  explained  in  previous  EIRs,  in  2018  the  Commission 
launched  a  new  horizontal 
infringement  procedure 
against  Spain  on  the  Nitrates  Directive.  The  Commission 
decided in December 2021 to refer Spain to the Court of 
Justice  of  the  EU  for  failing  to  take  sufficient  action  on 
nitrates  pollution.  This  case  covers  most  of  the  Spanish 
Autonomous Communities. On 14 March 2024, the Court 
delivered  its  judgement  in  Case  C-576/22,  condemning 
Spain  for  bad  application  of  the  Nitrates  Directive.  The 
Commission  is  now  monitoring  the  implementation  by 
Spain of the Court judgment through the implementation 
of the necessary measures. Spain has adopted the Royal 
Decree  47/2022,  of  18  January,  on  the  protection  of 
waters  against  diffuse  pollution  caused  by  nitrates  from 
agricultural  sources,  which  is  a  positive  step  to  improve 
the  existing  difficult  situation  on  this  matter.  It  is  also  a 
Reform included in Component 3 of the RRP of Spain. 

2025 priority action 

• 

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

The  Urban  Wastewater  Treatment  Directive  (UWWTD) 
aims to protect human health and the environment from 
the  effects  of  untreated  urban  wastewater.  It  therefore 
requires Member States to collect and treat (secondary or 
biological  treatment)  wastewater  in  all  urban  areas  of 
more  than  2 000  people,  and  to  apply  a  more  stringent 
than  secondary,  with  nitrogen  and/or 
treatment 
phosphorus  removal,  to  the  wastewater  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  Spain,  the  overall  compliance  rate  was  86 %  in  2020. 
Around 450  agglomerations did not  comply  yet  with the 
requirements of the Directive. 

Figure 30:  Proportion  of  urban  wastewater  that  fully 
complied with the UWWTD, 2020 

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

Spain approved  in July 2021  the  national  Plan  DSEAR on 
wastewater,  sanitation,  water  efficiency,  saving  and 
reuse (126). This plan is a positive step, a governance tool 
for  all  the  competent  administrations  and  include  water 
investments in the entire Spanish territory. 

Despite  the  improvement  in  compliance  over  the  years, 
for  which  the  use  of  EU  funding  has  been  fundamental, 
Spain  has  experienced  significant  difficulties  in  properly 
implementing  the  UWWTD.  This  partial  implementation 
has forced the Commission to take legal actions that have 
led to rulings of the Court of Justice of the EU. 

The  European  Commission  currently  has  four  horizontal 
infringement  procedures 
in  progress  against  Spain, 
covering the agglomerations in breach of the UWWTD. 

(125)  European Commission, Nitrates Directive. 
(126)  See 

MITECO, 

‘Plan 

DSEAR’, 

hidrologica/planificacion-hidrologica/planes-programas-
relacionados/. 

https://www.miteco.gob.es/es/agua/temas/planificacion-

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
For  the  most  advanced  case  (concerning  normal  areas), 
the  Court  of  Justice  of  the  EU  issued  a  second  ruling  on 
25 July 2018 (Case 205/17), imposing for the first time in 
the  environmental  sector  pecuniary  sanctions  on 
Spain (127).  Two  other 
infringement  procedures  are 
already before the Court of Justice and awaiting the first 
ruling. 

Therefore,  it  is  essential  that  Spain  take  the  necessary 
measures and implement the necessary projects without 
delay,  to  fully  comply  with  the  requirements  of  the 
UWWTD, taking advantage of the available EU funding (i.e. 
the ERDF and the RRF). 

This  is  all  the  more  important  as  the  Directive  has  been 
revised.  The  recast  Directive  2024/3019  builds  on  the 
current  acquis  and  strengthens  existing  treatment 
standards  establishing  a  new  additional  treatment  of 
micropollutants 
in  urban  wastewater.  Other  new 
requirements  relate  to  moving  towards  the  energy 
neutrality  of  the  sector,  establishing  an  EPR  system  to 
ensure sustainable financing of micropollutant treatment 
by  the  most  polluting  industries  and  ensuring  access  to 
sanitation,  especially  for  vulnerable  and  marginalised 
groups. Spain has until 31 July 2027 to transpose the new 
Directive into its national legal system. 

The  2022  EIR  included  as  priority  action  the  need  to 
complete  the  implementation  of  the  UWWTD  for  all 
agglomerations,  by  building  up 
the  necessary 
infrastructure,  as  well  as  develop  the  potential  of  water 
reuse.  In  this  respect,  some  progress  has  been  made. 
However, there is clearly room for further efforts. 

2025 priority actions 

• 

the  necessary  measures 

Take 
full 
implementation  of  the  current  Urban  Wastewater 
Treatment  Directive,  taking  into  account  the  new 
requirements of the recast Directive. 

to  ensure 

Larges areas of Spain suffer from water scarcity. The water 
exploitation  index  plus  (WEI+),  a  measure  of  how  much 

(127)  A lump sum of EUR 12 million, and a penalty payment of almost 
EUR 11 million per six-month period of delay for the nine pending 
agglomerations. As of January 2025, Spain has already paid around 
EUR 90 million in this case, and it is still paying fines for three non-
compliant agglomerations. 

(128)  Values above 20% are generally considered to be a sign of water 
scarcity,  while  values  equal  to  or  greater  than  40%  indicate 
situations of severe water scarcity. 

(129)  European 

Environment 

Agency 

(EEA) 

https://www.eea.europa.eu/en/analysis/indicators/use-of-
freshwater-resources-in-europe-1 

(130)  EEA, Seasonal water scarcity conditions for European sub-units for 
four  quarters  of  2022,  as  measured  by  WEI+. 

the 
https://www.eea.europa.eu/en/analysis/indicators/use-of-
freshwater-resources-in-europe-1/seasonal-water-scarcity-
conditions 

Spain  39 

water  is  being  used  compared  with  the  total  renewable 
freshwater  resources  available  for  a  given  territory  and 
period,  shows  that,  especially  in  summer  months,  the 
country’s total water consumption exceeds its renewable 
freshwater resources (128). The last available data refer to 
2022 (129), the WEI+ in Spain was 33 in the third quarter of 
2022. Although in recent years the highest WEI+ value (46) 
was reached in the third quarter of 2019 and the second 
highest  value  (37)  in  the  third  quarter  of  2021.  This 
seasonal  index  at  national  level  does  not  reflect  the 
situation  at  river  basin  level  where  more  acute  water 
stress can be recorded (130). 

It is important to note that, in line with the EIR assessment, 
in  the  framework  of  the  2024  European  Semester (131), 
Spain  has  received  a  Country  Specific  Recommendation 
(CSR)  on  water  management  and  adaptation  to  climate 
change: 

“Improve  water  management  to  better  address  the 
adaptation to present and future effects of climate change 
and ensure long-term economic, social and environmental 
resilience, by improving coordination  among all levels of 
government  and  administration  and  scaling  up  existing 
solutions for drought risk reduction and sustainable water 
in  agriculture,  water  efficiency  and 
management 
infrastructure 
investments,  and  by  supporting  the 
development of nature-based solutions.” 

this 

specific 

Therefore,  Spain  should  take  the  necessary  measures  to 
comprehensive 
address 
recommendation. In this sense, Spain is already preparing 
and developing some measures in line with the Strategic 
Orientations on Water and Climate Change adopted by the 
Council of Ministers in July 2022. 

and 

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 (132), 

(131)  European  Commission,  Recommendation 

for  a  Council 
Recommendation  on 
the  economic,  social,  employment, 
structural and budgetary policies of Spain, COM(2024) 609 final of 
19 June 
2024, 
https://commission.europa.eu/document/download/60c2e201-
7e09-45fc-b9ba-
e702a11a6796_en?filename=com_2024_609_1_en.pdf. 
CSR  3 and Recital 23. 

See 

(132)  Chemicals  Strategy  for  Sustainability  and  Regulation  (EC)  No 
1272/2008Communication from the Commission to 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 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
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 (133)  provides  a  baseline 
protection for human health and the environment. It also 
ensures  stability  and  predictability 
for  businesses 
operating in the internal market. 

and 

enforcement 

Since 2007, the Commission has gathered information on 
the  enforcement  of 
the  Registration,  Evaluation, 
Authorisation  and  Restriction  of  Chemicals  (REACH) 
Regulation and the Classification, Labelling and Packaging 
(CLP)  Regulation.  In  December  2020,  the  Commission 
assessed  the  Member  States’  reports (134)  on  the 
implementation 
these 
regulations (135).  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 (136) of the two main EU 
regulations  on  chemicals  using  a  set  of  indicators  on 
different  aspects  of  enforcement.  Since  2021,  the  list  of 

lex.europa.eu/legal-
content/EN/TXT/?uri=COM%3A2020%3A667%3AFIN;  Regulation 
(EC) No 1272/2008 of the European Parliament and of the Council 
of 16 December 2008 on classification, labelling and packaging of 
substances  and  mixtures,  amending  and  repealing  Directives 
67/548/EEC  and  1999/45/EC,  and  amending  Regulation  (EC) 
No 1907/2006 
p. 1), 
L 353, 
https://publications.europa.eu/resource/cellar/c6b6a31d-8359-
11ee-99ba-01aa75ed71a1.0004.02/DOC_2. 

31.12.2008, 

(OJ 

(133)  Namely,  Regulation 

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

p. 1), 

(134)  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 

Spain  40 

chemicals  subject  to  restrictions  has  been  expanded  as 
new entries have been added to Annex XVII to the REACH 
Regulation (137). 

In  2023,  new  hazard  classes  were  added  to  the  CLP 
Regulation, and the revision of the regulation was tabled 
(published  on  20 November  2024)  (138).  The  new  hazard 
classes  cover  endocrine  disruptors  and  persistence-
related  hazards  while  the  revision  of  the  regulation 
encompasses  new  rules  on  online  sales  to  better  tackle 
non-compliances  observed  over  the  years.  Also  in  2023, 
the  Conference  of  the  Parties  of  the  Stockholm 
Convention decided to include, in its Annex A (which lists 
banned  substances),  three  new  chemicals (139).  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. 

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. 

had 

devised 

partially 

implemented 
but 
Spain 
strategies (140) for enforcement of both the REACH and CLP 
Regulations.  Of  the  17  enforcement  authorities,  12  had 
developed an individual enforcement strategy for REACH 
and 13 for CLP. Strategies were focused on raising industry 
awareness  of  the  obligations  under  REACH  rules, 
performing  enforcement  campaigns  (including  ECHA’s 

Union, 

Luxembourg, 

European 
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 

2020, 

(135) 

the 

European 

(136)  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/. 
(137)  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, 

(138)  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  (Text  with  EEA  relevance),  OJ  L,  2024/2865, 
20.11.2024, p.1 (Regulation - EU - 2024/2865 - EN - EUR-Lex) 
(139)  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. 

(140)  Final  report_REACH-CLP  MS  reporting_2020.pdf  (europa.eu), 

p. 76. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
inspection projects) and investigating complaints in order 
to reduce public health risks. 

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

Spain  41 

In  2020,  Spain  participated 
in  an  EU-coordinated 
enforcement  project  on  products  sold  online,  called 
REACH-EN-FORCE (REF)-8 (141). The report was adopted in 
November 2021, so it could not be taken into account in 
the previous EIR. 

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

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. 

Spain  participated  to  a  slight  extent  in  the  coordinated 
enforcement project (REF-8), while online sales have been 
proven  to  correspond  consistently  to  higher  non-
compliance  rates  in  checks  performed  across  the  EU,  in 
particular when related to imported products. 

In  2022,  Spain  received  a  priority  action  related  to  the 
upgrading of administrative capacities in implementation 
and  enforcement  to  move  towards  a  policy  of  zero 
tolerance of instances of non-compliance. In the absence 
of reporting since 2022, no progress has been reported. 

2025 priority actions 

•  Upgrade 

the 

capacities 

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

including 

in 

• 

• 

(141)  European Chemicals Agency, REF-8 project report on enforcement 
of CLP, REACH and BPR duties related to substances, mixtures and 
2021, 
articles 

Helsinki, 

online, 

sold 

https://echa.europa.eu/documents/10162/17088/project_report
_ref-8_en.pdf/ccf2c453-da0e-c185-908e-
3a0343b25802?t=1638885422475, p. 20. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
 
Spain  42 

4. Climate action 

increasing  targets  under  the  Effort  Sharing  Regulation; 
and  (iii)  a  revised  Regulation  for  Land  Use,  Land-Use 
Change  and  Forestry (143).  The  package  has  been  fully 
the  Member  States  have  been 
adopted,  and 
implementing the legislation. 

The  key  strategic  document  at  the  country  level  is  the 
National  Energy  and  Climate  Plan  (NECP) (144).  Spain 
submitted its updated plan in September 2024, after the 
deadline  set (145).  The  European  Commission  assessed 
the plan and the extent to which Spain has followed the 
recommendations for the draft version.  

The findings from the assessment are: 
- 

Emissions  under  the  Effort  Sharing  Regulation  will 
decrease  by  45%  in  2030  compared  to  2005,  and 
Spain will meet its target of 38%. 
The  latest  projections  show  a  gap  to  the  LULUCF 
target, meaning that current levels of removals have 
been insufficient.  
Spain  is  in  line  with  its  target  for  the  share  of 
renewable energy. 
There are still gaps in energy efficiency targets that 
must be closed. 

- 

- 

- 

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

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

the  EU  has  demonstrated 

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

Over  the  last  three  decades,  since  1990,  the  EU  has 
achieved  steady  decreases  in  its  emissions,  reaching  a 
running total in 2022 of – 32.5 % (142). 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 Spain decreased by 3 %, making it one of the 
countries with below-average decrease. 

transition. 

the  green 

The  ‘Fit  for  55’  legislative  package  reflects  the  need  to 
(i) 
speed  up 
strengthening  and  expanding  the  EU  emissions  trading 
system (ETS), with the creation of a new, second, ETS for 
transport and buildings together with a dedicated Social 
Climate  Fund  to  help  citizens  during  the  transition;  (ii) 

includes: 

It 

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

(143)  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. 

(144)  European  Commission,  ‘National  energy  and  climate  plans’, 

https://commission.europa.eu/energy-climate-change-
environment/implementation-eu-countries/energy-and-climate-
governance-and-reporting/national-energy-and-climate-
plans_en. 

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

Energy Union and Climate Action. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
The EU emissions trading system 

formal  notice  for  failing  to  fully  transpose  previous 
revisions of ETS Directives (149) into national law. 

Spain  43 

The EU ETS is the key tool for reducing  GHG emissions 
cost-effectively across all Member States. It is the world’s 
biggest carbon market, covering around 40 % of the EU’s 
total  GHG  emissions 
from  electricity  and  heat 
generation, the manufacturing industry, aviation within 
Europe (146) and, from 2024, maritime transport also. 

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

The  emissions  under  the  ETS  decreased  by  56 %  from 
2005 to 2023 in Spain. 

In  2023,  about  39 %  of  GHGs  emitted  by  Spain’s  ETS 
installations came from power generation, less than the 
EU  overall  (57 %) (147).  Of  the  total  emissions  from  all 
industry  sectors,  28 %  came  from  cement  and  lime 
production,  26 %  from  refineries,  13 %  from  metals 
processing,  11 %  from  the  chemical  industry  and  22 % 
from  other  sectors.  Since  2019,  the  power  sector  has 
registered a higher emissions reduction (34 %) than the 
industry sectors (20 %). Since 2013, GHG emissions have 
declined by 50 % in power generation and by 18 % in the 
industry  sectors.  Nearly  all  this  decline  in  the  industry 
sectors has occurred since 2019. 

From 2027, a new emissions trading system, called ETS2, 
for  buildings,  road  transport  and  additional  sectors 
(mainly  industry  not  covered  by  the  current  ETS),  will 
become  fully  operational (148).  Member  States  should 
have  notified  full  transposition  of  the provisions  of the 
revised  EU  ETS  Directive  related  to  the  new  ETS2  into 
national law by 30 June 2024. Spain did not communicate 
full transposition into national law by this deadline. The 
Commission 
infringement 
procedure  against  Spain  on  25 July  2024,  by  sending  a 
letter  of  formal  notice  for  failing  to  fully  transpose  the 
provisions  into  national  law.  In  the  absence  of  a 
satisfactory  response,  the  Commission  may  decide  to 
issue a reasoned opinion. 

therefore  opened 

an 

The Commission also opened an infringement procedure 
against Spain on 25 January 2024, by sending a letter of 

(146)  Flights  between  the  EU  Member  States  including  departing 
flights to Norway, Iceland, Switzerland, and the United Kingdom. 
(147)  EEA.  EU  Emissions  Trading  System  (ETS)  data  viewer.  EU 
Emissions  Trading  System  (ETS)  data  viewer  |  European 
Environment Agency's home page  

Effort sharing 

The  Effort  Sharing  Regulation  (ESR) (150)  covers  GHG 
emissions  from  domestic  transport  (excluding  CO₂ 
emissions  from  aviation),  buildings,  agriculture,  small 
industry  and  waste.  Emissions  from  these  sectors 
account for around 60 % of the EU’s domestic emissions. 
The  regulation  sets  the  EU-wide  target  to  reduce 
emissions  from  the  effort  sharing  sectors  by  40 %  by 
2030 compared to 2005 levels. This overall target for the 
EU  translates  to  binding  national  emission  reduction 
targets for each Member State. Spain‘s target is – 37.7 %. 

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 
fluctuations  in  emissions,  by  trading  emissions  and 
transfers from the ETS and LULUCF. 

Based  on  historical  emissions  and  the  most  updated 
projections  Spain  is  on  track  to  achieve  its  2030  ESR 
target.  Projected  emission  reduction  is  6.9  percentage 
points above its 2030 target. 

The  key  sectors  are  transport  and  buildings.  Spain  has 
taken  measures  to  reduce  emissions  in  these  sectors, 
including  through  the  development  of  national  action 
plans  to  increase  the  adoption  of  electric  vehicles, 
expand  energy  efficiency  initiatives  in  buildings,  and 
increase  investments  in  renewable  energy  and  waste 
management technologies (see below). 

The largest contributor is the domestic transport sector, 
which accounted for 45 % of all effort sharing emissions 
in 2022. Sustainable transport has yet to take off in Spain 
despite  domestic  initiatives  to  decarbonise  transport. 
Road  transport  is  the  dominant  mode  in  Spain;  trains 
provide only 4 % of freight transport, which is well below 
the  EU  average  of  16 %.  Only  0.4 %  of  Spain’s  car  fleet 
were  battery  electric  vehicles  in  2023,  and  Spain  has 
about 29 200 publicly accessible charging points, or 1 for 
every 8 e-vehicles (above the EU average of 1:10). 

The buildings sector is a significant concern for Spain as 
well.  Spain  needs  to  step  up  its  efforts  to  achieve 
meaningful  contribution  to  its  long-term  renovation 
strategy. Spain expects 14 % of savings in building energy 
consumption  in  2030  compared  with  2020.  However, 

(148)  Directive 

(https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv:OJ.L_.2023.130.01.0134.01.ENG). 
(149)  Directive - 2023/959 - EN - EUR-Lex and Directive - 2023/958 - EN 

(EU)  2023/959 

- EUR-Lex. 
(150)  Regulation 

(EU) 

2018/842 

(https://eur-

lex.europa.eu/eli/reg/2018/842).  

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
between  2020  and  2022  final  energy  consumption  in 
residential  buildings  rose  by  3.1 %.  The  share  of 
renewables in heating and cooling of buildings is still low 
(20 % in 2022) compared with the target of 35 % in 2030. 
However, in 2023 Spain was the world’s largest recipient 
of greenfield renewable projects, and Spain accounts for 
20 %  of  the  world’s  renewable  hydrogen  projects 
announced in 2022. 

Figure 34: 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. 

Spain’s  LULUCF  sector  saw  a  gradual  increase  in  net 
carbon  removals  between  1990  and  2006,  with  forests 
playing a major role. Recent years have, however, shown 
a plateau in the amount of total net removals. 

Spain‘s  target  in  2030  is  to  enhance  land  removals  by 
additional – 5.3 Mt of CO2 eq compared with the yearly 
average  of  2016–2018.  The  latest  available  projections 
show  a  gap  to  target  of  6.1 Mt  of  CO2  eq  in  2030. 
Therefore, Spain needs to apply additional measures to 
reach its 2030 target. 

Spain  44 

Adaptation to climate change 

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

Spain  is  in  all  three  regions  identified  as  hotspots  of 
climate risks most affected by climate change: Southern 
Europe, low-lying coastal regions and the Canary Islands 
as an outermost region (151). 

Spain  is  taking  action  to  build  resilience  to  climate 
impacts,  with  major  challenges  remaining  on  water 
management.  Spain  is  one  of  the  Member  States  most 
affected by droughts, and it is also vulnerable to wildfires 
and  heatwaves.  Power  generation  will  be  increasingly 
affected by changes to rainfall patterns, lower flow rates, 
higher  frequency  and  intensity  of  droughts  and  higher 
water temperatures. 

Spain adopted its climate adaptation law in 2021 and has 
national, regional and sectoral adaptation plans. 

Spain  received  five  priority  actions  regarding  climate 
action in the 2022 EIR. 

is  still 

little  progress 

There 
in  decarbonisation  of 
transport  sector  and  in  renovation  of  buildings  stock. 
Uptake  of  renewables  is  well  on  track  and  Spain  will 
probably achieve its ambitious target of 81 % renewable 
energy share in electricity production. 

In  March  2022,  the  Spanish  government  approved  a 
biogas  roadmap  for  2022–2030,  which  focuses  on 
sustainable  biogas  production,  specifically  from  waste 
and  materials  of  agricultural  origin.  The  roadmap 
includes  45  measures  to  support  the  achievement  of 
Spain’s biogas production target for 2030. 

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, 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) (152). 

(151)  EEA,  European  Climate  Risk  Assessment,  EEA  Report 01/2024, 
Publications  Office  of  the  European  Union,  Luxembourg,  2024, 
https://climate-adapt.eea.europa.eu/en/eu-adaptation-
policy/key-eu-actions/european-climate-risk-assessment.  

(152)  European  Commission,  National  energy  and  climate  plans, 

https://commission.europa.eu/energy-climate-change-
environment/implementation-eu-countries/energy-and-
climate-governance-and-reporting/national-energy-and-
climate-plans_en 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
Spain  45 

Part II: Enabling framework – implementation tools

5. Financing

 The EU budget supports climate investment in Spain with 
significant amounts in 2021–2027, with revenues from the 
EU ETS also feeding into the national budget. During 2020–
2022,  Spain’s 
reached 
EUR 6 954 million in total, with 74 % of it spent on climate 
and energy, corresponding to EUR 5 136 million. 

from  auctioning 

revenues 

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 32.6 billion per year in 
Spain. 

These  four  environmental  areas  currently  receive  total 
funding of around EUR 21.8 billion per year; thus, there is 
a gap of EUR 10.7 billion per year. 

the 

annual 

gap, 
environmental 
Of 
EUR 5 billion  concerns  biodiversity  and  ecosystems, 
EUR 2.3 billion  circular  economy  and  EUR 1.7–1.8 billion 
pollution prevention and control and water (each). 

investment 

Climate finance landmarks 

EU funding for climate action 

The EU budget supports climate action in the EU-27 with 
EUR 657.8 billion  in  the  2021–2027  budgetary  period 
across  the  various  programmes  and  funds,  representing 
an  overall  34.3 %  contribution  level.  Of  this,  cohesion 
policy provides EUR 120 billion (over half of it through the 
ERDF), the RRF 275.7 billion and CAP 145.9 billion (153). 

In  Spain,  the  EU  cohesion  policy  (considering  EU 
for 
contribution  amounts)  provides  EUR 10.4 billion 
climate action in 2021–2027 (with around 80 % of this via 
the  ERDF),  with  a  further  EUR 636 million  from  the 
European Maritime, Fisheries and Aquaculture Fund (154). 

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

European  Union, 

Luxembourg, 

2024, 

(154)  See 

the 

Cohesion 

Open 

Data 

Platform 

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

The  RFF  contributes  to  climate  finance  in  Spain  with 
EUR 65 billion  up  to  2026,  representing  39.9 %  of  the 
RRP (155). 

The  European 
(EIB)  provided 
Investment  Bank 
EUR 109.9 billion  financing  across  the  EU-27  between 
2021  and  mid-2024  to  support  energy,  transport  and 
industry  projects  that  are  aligned  with  the  EU’s  climate 
objectives. Of this amount, EUR 17.1 billion was assigned 
to Spain in the reference period (156). 

National  financing, 
system revenues 

including  EU  emissions  trading 

to  EUR 1 240 million 

Revenues  from  the  auctioning  of  emission  allowances 
under  the  EU  ETS,  which  feeds  directly  into  national 
budgets,  amounted 
in  2020, 
EUR 2 483 million in 2021 and EUR 3 231 million in 2022 in 
Spain, totalling EUR 6 954 million in the three-year period. 
In  Spain,  estimated  revenues  are  earmarked  for  energy 
and  climate  purposes  ahead  of  each  year,  so  actual 
revenues  may  differ  from  the  allocated  estimate.  All 
estimated  revenues  that  do  not  go  to  indirect  cost 
compensation  (a  maximum  of  25 %,  5.6%  in  2022,  not 
included as spent  here) are used for climate and energy 
purposes.  National  legislation  includes  a  minimum  of 
EUR 450 million for renewable energy production support 
plus a maximum of 30 % for energy transition. Revenues 
higher than estimated go to the general budget, without a 
predefined purpose (157). 

The  amount  allocated  to  energy  and  climate  purposes 
from EU ETS revenues amounted to EUR 1 084 million in 
2020, EUR 2 036 million in 2021 and EUR 2 057 million in 
2022 (budget execution data). 

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. 

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

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

(156)  A 

list  of 

financed  projects 

is  provided  by 

the  EIB 

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

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

Luxembourg, 

Union, 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
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 (158). 

therefore, 

and, 

CAP 
European Agricultural Guarantee Fund 
European  Agricultural  Fund  for  Rural 
Development (EAFRD) 

European  Maritime,  Fisheries  and 
Aquaculture Fund (EMFAF) 

Environmental financing and investments 

Other MFF 

RRF (d) (2021–2026) 

Spain  46 

7 247.1 (b) 
5 061.5 
2 185.6 

447.5 

2 732.6 (c) 

47 212 

This  section describes  Spain’s investment  needs, current 
financing  and  gaps  as 
four 
environmental  objectives  beyond  climate  objectives, 
namely  tackling  pollution,  the  circular  economy  and 
waste,  water  protection  and  management,  and 
biodiversity and ecosystems (159). 

relate 

they 

the 

to 

The environment overall 

Investment needs 

The  overall  environmental  investment  needs  to  enable 
Spain  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 are estimated to be EUR 32.6 billion per year 
(in 2022 prices). 

A  significant  part  of  the  estimated  needs,  around 
EUR 10.8 billion per year, can be attributed to the circular 
economy. Around EUR 8 billion a year each is required for 
biodiversity and ecosystems and for pollution prevention 
and control, and around EUR 5.6 billion for water (in 2022 
prices). 

Current investments 

To implement the environmental investments needed, the 
available  financing  is  estimated  to  currently  reach  an 
annual  EUR 21.8 billion  in  Spain  from  EU  and  national 
sources combined (in 2022 prices). 

Total  environmental  funding  from  the  multiannual 
financial  framework  (MFF)  is  estimated  to  reach  around 
EUR 16.7 billion  for  Spain  in  total,  during  2021–2027  (or 
EUR 2.4 billion per year). 

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

Instrument 

Cohesion policy 
ERDF 
Cohesion Fund 
Just Transition Fund 

Allocations 

6 223.7 (a) 
6042 
0.0 
181.7  

(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 I. Please note potential data changes that may have arisen 
between the EIR preparation cut-off date (31 October 2024) and 
its  publication date.  Note  that  Spain  is not  eligible  for  Cohesion 
Fund 
information: 
and 
Source 
https://cohesiondata.ec.europa.eu/2021-2027-
Categorisation/2021-2027-Planned-finances-detailed-
categorisation/hgyj-gyin/about_data. 

funding. 

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. Source: European Commission. 

Spain is the third largest beneficiary, in absolute terms, of 
the  2021–2027  EU  Cohesion  Policy.  The  support  to  the 
environment  comes  essentially  from  the  ERDF,  which  in 
Spain is organised in a large national Programme (POPE) 
and 19 regional Programmes. 

It is worth recalling that the implementation of the ERDF 
2021–2027  is  linked  to  the  fulfilment  of  the  enabling 
conditions, including the three environmental ones. Spain 
already met the nature enabling condition in 2022 when 
the  Partnership  Agreement  and  Programmes  were 
adopted.  In  2025,  Spain  has  completely  met  the  water 
enabling  condition.  However,  further  efforts  are  needed 
to comply with the waste enabling condition. 

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

support of the environment are accounted for via the tracking. 

(159)  Research,  development  and  innovation  is  accounted  for  under 
each environmental objective. The financing needs, baselines and 

gaps  estimates  are  based  on  the  Directorate-General  for 
Environment’s 
internal  analysis  (of  2024).  Throughout  this 
chapter,  specific  references are  provided to  the  most  important 
data sources used. 

2025 Environmental Implementation Review – Spain 

 
 
 
Spain also participates in various programmes of territorial 
cooperation (transnational and cross-border cooperation) 
under the ERDF in which the environmental investments 
carry  considerable  weight,  and  outstanding projects  and 
good practices can be found (160). 

integration  has  been  ensured 

Environmental 
in  the 
Partnership  Agreement  2021–2027  and  the  different 
Programmes  for  the  ERDF  and  the  Just  Transition  Fund 
through  the  application  of  the  Strategic  Environmental 
Assessment (SEA) Directive and by other means. 

The Spanish Network of Environmental Authorities, with 
the  participation  of  the  Commission  services,  plays  an 
important role in fostering environmental integration into 
EU funding in Spain (161). 

Spain,  in  addition  to  receiving  EU  funds  earmarked 
specifically  for  it  in  2021–2027,  can  also  benefit  from 
funding programmes that can be accessed at the EU level 
and which are open to all Member States. These include 
instrument  for  the  environment  (LIFE) 
the  financial 
(EUR 5.4 billion) (162),  Horizon 
Europe 
programme 
(EUR 95.5 billion) (163),  the  Connecting  Europe  Facility 
(EUR 33.7 billion) (164)  and  funds  that  can  be  mobilised 
through the InvestEU programme (165). 

Under  NextGenerationEU,  Spain  is  the  second  largest 
beneficiary in absolute terms, after Italy, of the RRF. The 
RRP  of  Spain (166)  has  a  total  budget  of  around 
EUR 163 billion (EUR 80 billion in grants and EUR 83 billion 
in loans). 

The revised RRP of Spain comprises 31 components along 
four  main  axes  (green  and  digital  transitions;  social  and 
territorial cohesion; and gender equality). It includes 109 
investments  and  102  reforms,  articulated 
in  416 
milestones and targets to be met during 2021–2026. 

The  RRP  of  Spain  supports  climate  objectives  with 
EUR 65 billion  (39.9 %  of  total),  with  an  additional 
EUR 11.66 billion (7.2 % of total) for the environment. 

(160) 

Like the RISC_PLUS Interreg project, under the POCTEP 2021-2027, 
which  is  based  on  prevention,  preparedness  and  digitisation, 
aiming to strengthen resilience to the risks of floods and droughts 
derived  from  the  impact  of  climate  change  in  the  International 
Basins of the Miño and Limia Rivers, in Spain and Portugal. It aims 
to extend and improve the RISC_ML initiative supported under the 
POCTEP 2014-2020. https://risc-plus.eu/en/  

(161)  The 

Spanish  Network 

of 

Environmental 

Authorities 

(https://www.miteco.gob.es/es/ministerio/servicios/red-de-
autoridades-ambientales-raa.html),  a  technical  forum  created  in 
1997, which has had a successful track record, was highlighted as 
a point of excellence and good practice in the 2017 EIR (country 
report and general communication). 

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

(164)  The 

Connecting 

Europe 

Facility 

for 

Transport 

(https://cinea.ec.europa.eu/programmes/connecting-europe-

Spain  47 

In  the  RRP  of  Spain,  there  are  some  components  with  a 
genuine  and  ambitious  environmental  dimension, 
covering  a  wide  range  of  environmental  sectors.  Their 
initial budgets have been increased following the revision 
of  the  plan  approved  in  October  2023,  including  the 
incorporation of the loans envelope. These are: 

• 

• 

• 

• 

‘Conservation  and  restoration  of 

Component 4 
ecosystems and their biodiversity’. 
Component 5  ‘Preservation  of  the  coastline  and 
water resources’. 
Component 3 
digital 
‘Environmental 
transformation of the agri-food and fisheries sectors’. 
Component 12 
‘Industrial  policy’,  which  has  a 
relevant  part  on  waste  management  and  circular 
economy,  and  moreover  the  circular  economy  is 
mainstreamed throughout the RRP. 

and 

There  are  also  other  components  relevant  to  the 
environment and with considerable budgets; for instance, 
components 1  and  6,  on  sustainable  urban  mobility  and 
sustainable transport (important to reduce air pollution). 
This is also the case of the other green components, more 
focused  on  energy  topics:  2  (building  renovation),  7 
(renewable  energies),  8 
infrastructure),  9 
transition  strategy)  and  31 
(hydrogen),  10 
(REPowerEU). Component 14 (tourism) is very focused on 
the  green  transition.  Component  28  (taxation)  has  a 
relevant section on improving environmental taxation. 

(energy 

(just 

Regarding also Spain’s RRP, it can be highlighted as a good 
practice the creation within the Ministry for the Ecological 
Transition and the Demographic Challenge (Subsecretaría) 
of a specific division on the implementation of the ‘do no 
significant  harm’  (DNSH)  principle (167)  to  advise  and 
support the different actors during the implementation of 

facility/transport-infrastructure_en) 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. 

(165)  The 

Fund 

InvestEU 

(https://investeu.europa.eu/investeu-
programme/investeu-fund_en) 
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. 

set 

is 

(166)  European  Commission,  ‘Spain’s  recovery  and  resilience  plan’, 
website, 

European 
https://ec.europa.eu/info/business-economy-euro/recovery-
coronavirus/recovery-and-resilience-facility/spains-recovery-and-
resilience-plan_en. 

Commission 

(167)  https://www.miteco.gob.es/en/prensa/ultimas-

noticias/2021/12/el_miteco_crea_unadivisionparaelseguimiento
delaaplicaciondelanor.html. 

2025 Environmental Implementation Review – Spain 

 
 
the  measures  included  in  the  RRP,  including  drawing  up 
guidance (168) in this regard. 

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

Spain  48 

The  EIB provided around EUR 7.1 billion in environment-
related  financial  contributions  to  Spain  in  from  2021  to 
mid-2024, most of which, EUR 6.4 billion (91 %), was in the 
area  of  sustainable  energy,  transport  and  industrial 
projects,  which  provides  significant  co-benefits  to 
reducing  air  pollution,  environmental  noise  and  other 
pollution. 

The  EU’s  total  national  expenditure  on  environmental 
protection  (operating  plus  capital  expenditure)  was 
EUR 298 billion  in  2020  and  EUR 321 billion  in  2021, 
representing around 2.2% of EU-27 GDP. In Spain, the total 
national  environmental  protection  expenditure  was 
EUR 19.4 billion  in  2020  and  EUR 21.7 billion  in  2021, 
representing 1.7 % and 1.8 % of GDP, respectively. 

Of  the  total  environmental  expenditure,  the  national 
capital  expenditure 
(investment)  on  environmental 
protection  amounted  to  EUR 54.5 billion  in  2020  and 
EUR 59.9 billion in 2021 in the EU-27, representing around 
the  national 
0.4 %  of 
environmental 
reached 
EUR 2.6 billion  in  2020,  rising  to  EUR 3.3 billion  in  2021, 
representing around 0.2–0.3 % of GDP. 

the  EU’s  GDP. 
protection 

investment 

In  Spain, 

protection 

investment 

Split  by  institutional  sector,  45 %  of  Spain’s  national 
environmental 
(capital 
expenditure) comes from the general government budget, 
with 26 % coming from specialist private-sector producers 
(of environmental protection services, such as waste and 
water  companies)  and  29 %  from  the  general  business 
sector,  whose  environmental  activities  are  usually 
ancillary  to  its  main  activities.  At  the  EU  level,  38 %  of 
environmental  protection 
from 
governments,  40 % 
specialist  private-sector 
producers and 22 % from the general business sector (169). 

investment  comes 

from 

Spain’s  total  financing  for  environmental  investment 
reaches  an  estimated  EUR 21.8 billion  per  year  (in  2022 
prices),  including  EU  funding  and  national  public  and 
national private expenditure. Of the total, the share of EU 
funds  (including  EIB  funds)  reaches  43.5 %,  with  around 
57 % national financing. The total public financing (EU plus 
national public) represents 69 % 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 10.7 billion 
per  year  in  Spain,  representing  around  0.81 %  of  the 
national GDP, close to the EU average (0.77 %). 

Source: Analysis of Directorate-General for Environment. 

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

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

Environmental 
objective 

Pollution prevention 
and control 

Circular economy and 
waste 

Water management 
and water industries 

Biodiversity and 
ecosystems 

Investment gap, per year  

% of GDP 

 % of 
total 

Million 
EUR 
(2022 
prices) 

1 707 

15.9 

0.13 

2 256 

21.1 

0.17 

 1 783 

16.7 

0.13 

4 964 

46.4 

0.37 

Total 

 10 711 

100.0 

0.81 

Source: Directorate-General for Environment analysis. 

(168)  https://www.prtr.miteco.gob.es/es/obligaciones-

(169)  Eurostat, 

’Environmental  protection  expenditure  accounts’, 

medioambientales/guias-y-normativa-relacionada.html. 

env_ac_epea. 

2025 Environmental Implementation Review – Spain 

 
 
 
Pollution prevention and control 

Investment needs 

In  pollution  prevention  and  control,  Spain’s  investment 
needs  are  estimated  to  reach  EUR 8 billion  per  year 
(including  baseline  investments)  in  2021–2027.  Most  of 
this,  EUR 7 billion,  relates  to  air  pollution  control,  to 
comply with the clean air requirements for the five main 
air  pollutants  under  the  NECD  by  2030.  The  estimated 
needs to reduce environmental noise reach EUR 2 billion 
per  year,  most  of  which  is  delivered  by  the  (same) 
sustainable  energy  and  transport  investments  that  also 
benefit clean air (170). Industrial site remediation requires 
an  estimated  EUR 243 million  per  year.  Microplastics 
pollution  and  the  chemicals  strategy  require  around 
EUR 100–200 million per year (each) (171). 

Current investments 

investment 

The  current 
levels  supporting  pollution 
prevention and control reach an estimated EUR 6.3 billion 
per  year  in  Spain  in  2021–2027.  Most  of  the  financing 
concerns  clean  air  (EUR 5.9 billion  per  year).  Protection 
from environmental noise receives around EUR 1.6 billion 
per  year,  with  a 
for  site 
remediation. 

further  EUR 63 million 

In Spain, the EU MFF provides an estimated 8.3 % of the 
clean  air  financing  (mostly  via  cohesion  policy),  with  a 
further  64 %  from  the  RRF,  adding  up  to  72.4 %  of  the 
total.  EIB  financing  contributes  13.7 %  and  national 
sources reach 13.9 % (172). 

The gap 

To meet its environmental objectives concerning pollution 
prevention  and  control  (towards  zero  pollution),  Spain 
needs  to  provide  an  additional  EUR 1.7 billion  per  year 
(0.13 % of GDP), mostly related to clean air and noise. The 
adequate 
the 
investments included for sustainable energy and transport 

implementation  of 

the  NECP  with 

Spain  49 

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 (173), 
Spain 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 

Spain’s investment needs in circular economy and waste 
(including  baseline 
reach  EUR 10.8 billion  per  year 
investments).  Most  of  this,  around  EUR 8.8 billion  per 
year, relates to circular economy measures in the mobility, 
food  and  built  environment  systems,  with  a  further 
EUR 2 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 (174). 

Current investments 

Circular economy investments across the economy reach 
around EUR 6.8 billion per year in Spain in 2021-2027, with 
a further EUR 1.8 million provided for waste management 
that does not constitute circular economy. 

Around 0.6 % of this combined financing for circularity and 
waste comes from the EU MFF, with a further 8.9 % from 
the  RRF,  adding  up  to  9.5 %  of  the  total.  EIB  loans 
identified  in  support  of  circularity  and  waste  represent 
0.4 %  of  the  total.  National  sources  provide  the 

(170)  2021 

assessment 

Phenomena 

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

Environmental 

Noise 

2023 

(171)  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). 

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

information  on  clean  air 

Common  Provisions  Regulation  Annex  I  and  the  RRF  Regulation 
Annex  VI.  Further 
tracking: 
https://commission.europa.eu/document/download/0a80484e-
2409-4749-94c6-
3b23bc6bae8f_en?filename=Clean%20air%20methodology_0.pdf 
(173)  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. 

(174)  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 – Spain 

 
 
predominant  share,  reaching  90.1 %  of 
financing (175). 

the 

total 

the  other  aspects  of  the  WFD  (water  management  and 
protection). 

Spain  50 

The gap 

To  meet  its  environmental  objectives  concerning  the 
circular  economy  and  waste,  Spain  needs  to  increase 
circular  economy 
investments  by  an  estimated 
EUR 2 billion per year, with an additional EUR 278 million 
concerning  waste  management  action,  not  belonging  to 
circular 
to 
EUR 2.3 billion  per  year,  representing  0.17 %  of  Spain’s 
GDP. 

economy.  Combined, 

amounts 

this 

Of  the  circular  economy  gap,  EUR 518 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 1.5 billion  constitutes  further  investment  need  to 
unlock Spain’s circular economy potential. 

Water protection and management 

Investment needs 

The  annual  water  investment  needs  reach  an  estimated 
EUR 5.6 billion  (in  2022  prices)  in  Spain.  This  comprises 
investment needs both for the water industry and for the 
protection  and  management  of  water.  Of  this  annual 
need,  EUR 2 billion  relates  to  the  management  of 
wastewater  (also  including  additional  costs  associated 
with  the  revised  UWWTD),  a  further  EUR 2.7 billion  is 
necessary  for  drinking-water-related  investments  and 
the  protection  and 
around  EUR 842 million 
management of water (176). 

for 

Current investments 

Water  investments  in  Spain  are  estimated  to  be  around 
EUR 3.8 billion per year (in 2022 prices) in 2021–2027. Of 
this,  EUR 751 million supports wastewater  management, 
EUR 2.3 billion drinking water and around EUR 800 million 

(175)  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). 

(176)  European  Commission, 

investment  needs  and 
‘Estimating 
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. 

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

Of  the  total  financing,  6.7 %  is  provided  by  the  EU  MFF 
(mostly  through  cohesion  policy),  with  a  further  32.4 % 
from the RRF, reaching 39.1 % combined. EIB financing is 
around  1.5 %  of  the  total,  while  the  bulk  of  financing 
comes from national sources (around 60 %) (177). 

The gap 

To meet the various environmental targets under the WFD 
and  the  floods  directive,  Spain’s  water  investment  gap 
reaches  EUR 1.8 billion  per  year  (0.14 %  of  GDP),  with 
most of it related to wastewater (EUR 1.3 billion per year). 
Drinking  water  measures 
require  an  additional 
EUR 438 million per year and the other aspects of the WFD 
around EUR 39 million per year over the existing levels of 
financing. 

Biodiversity and ecosystems 

Investment needs 

The investment needs for biodiversity and ecosystems are 
estimated to be EUR 8.1 billion per year (in 2022 prices) in 
Spain in 2021–2027. This includes the following financing 
needs: 
• 

Spain’s  Prioritised  Action  Framework  (PAF) (178), 
concerning the Natura 2000 areas: EUR 1.4 billion per 
year, mostly running costs. 

•  Additional  Biodiversity  Strategy  to  2030  costs (179): 

• 

EUR 4.6 billion per year on top of the PAF. 
Sustainable  soil  management  costs:  EUR 2.1 billion 
per year (180). 

Current investments 

The current level of biodiversity financing is estimated to 
be EUR 3.1 billion per year (in 2022 prices) in 2021–2027. 
75.8 % of this is considered direct financing to biodiversity 
and ecosystems, with a  100 % coefficient  in the tracking 
schemes. 

(178)  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 

(179)  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 

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

5 July 

final 

of 

2025 Environmental Implementation Review – Spain 

 
 
4.1 % of the total financing is estimated to come from EU 
cohesion  policy,  31 %  from  CAP,  5.5 %  from  Horizon 
Europe  and  around  2.1 %  from  LIFE.  The  EU  MFF 
altogether accounts for 45 % of the financing and the RRF 
for 8.7 %, adding up to a total of 54 % from the EU budget. 
The rest, 46 %, comes from national sources (181). 

Spain has programmed 17.5 % of its CAP budget, 4.9 % of 
its cohesion policy EU contribution amount (disregarding 
ESF+)  and  1.5 %  of  RRF  funding  for  investments  in 
biodiversity. This is just below the EU average for all three 
funds (see Figure 36). 

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

NB: ESF+, European Social Fund Plus. 

The gap 

To  meet  the  environmental  objectives  concerning  the 
protection and restoration of biodiversity and ecosystems 
and  other  relevant  cross-cutting  measures,  Spain’s 
investment gap is estimated to be around EUR 5 billion per 
year, corresponding to 0.37 % of its GDP. 

Public financial management 

Green budgeting practices 

Green  budgeting  refers  to  the  use  of  budgetary  tools  to 
achieve climate and environmental goals. Some Member 

Spain  51 

States, including Spain, already use green budgeting tools 
for  identifying  and  tracking  green  expenditures  and/or 
revenues (182).  Green  budgeting  practices (183)  provide 
increased transparency on the environmental implications 
of budgetary policies. 

The  Commission  has  developed  a  non-mandatory  green 
budgeting  reference  framework  that  brings  together 
methodologies  for  assessing  the  impacts  of  budgets  on 
climate and environmental goals (184). 

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  in 
2021 (185).  Spain  participated, 
introducing  a  green 
budgeting  methodology  and 
into  the 
it 
budgetary process in a structured way. 

integrating 

Spain  has  also  been  selected  for  the  next  round  of  TSI 
projects on green budgeting, starting in 2025, where the 
country  will  expand  peer-to-peer  learning  through  civil 
servants’ exchanges. 

In  Spain,  the  mandate  for  a  green  budget  came  from 
Law 7/2021  on  climate  change  and  energy  transition, 
which  includes  emission  reduction  targets  for  2030  and 
2050, providing predictability to guide Spanish investment 
decisions.  In  Component 29  ‘Improving  the  efficiency  of 
public  spending’,  Spain’s  RRP  includes  reform  C29.R3 
‘Alignment of the general state budget with the ecological 
transition (green budgeting)’. The first report on Spanish 
budget  alignment  with  the  ecological  transition  was 
published in 2022 accompanying the proposal of the 2023 
general State Budget (186). 

More generally regarding performance-based budgeting, 
at  the  local  level,  Barcelona  City  Council  has  been 
developing  methodologies  jointly  with  other  European 
cities to align local budgeting processes with sustainable 
development  goals  (SDGs)  as  part  of  a  2024  TSI  project 
(see chapter 6). The regional dimension of the EU Green 
Deal has also been emphasised by the Committee of the 
Regions  by  means  of  the  Green  Deal  Going  Local 
initiative (187). 

(181)  Based  on 

biodiversity 

tracking 

in 

the 

EU 

budget 

(184)  European  Commission, 

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

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

2023, 

(183)  https://economy-finance.ec.europa.eu/economic-and-fiscal-
governance/national-fiscal-frameworks-eu-member-
states/green-budgeting-eu_en. 

‘European  Union  green  budgeting 
https://economy-

2022, 

framework’, 

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

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

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

(186)  https://www.sepg.pap.hacienda.gob.es/sitios/sepg/es-

ES/Presupuestos/InformesImpacto/IAPGETE2023/Paginas/IATE2
023.aspx. 
(187)  Committee  of 

the  Regions,  https://cor.europa.eu/en/our-

work/political-priorities/green-deal-going-local. 

2025 Environmental Implementation Review – Spain 

 
 
 
Beyond green budgeting, to improve policy outcomes, the 
Commission  has  also  drawn  up  climate-proofing  and 
sustainability-proofing  guidance (188)  as  tools  to  assess 
project  eligibility  and  compliance  with  environmental 
legislation and criteria. 

Green taxation and tax reform 

Total environmental taxes amounted to EUR 20.5 billion in 
Spain in 2022, representing 1.5 % of its GDP (EU average: 
2.0 %).  Energy  taxes  formed  the  largest  component  of 
environmental taxes, accounting for 1.23 % of GDP, which 
is lower than the EU average of 1.6 %. Transport taxes, at 
0.22 % of GDP, were under the EU average (0.4 %), while 
taxes on pollution and resources, at 0.07 %, were close to 
the  EU  middle  value  (EU  average  0.08 %).  In  2022, 
environmental taxes in Spain accounted for 4.1 % of total 
revenues  from  taxes  and  social  security  contributions 
(under the EU average of 5.0 %) (189). 

It 

as 

that 

recalling 

as  well 

is  worth 
taxation, 

Therefore, environmental taxes in Spain are below the EU 
‘Increasing 
average. 
environmental 
reducing 
environmentally harmful subsidies’ was identified as one 
of the three main environmental challenges facing Spain 
in  the  previous  EIRs  (assessments  in  more  depth  can  be 
found 
issue  has  also  been 
repeatedly  stressed 
in  European  Semester  country 
reports. Shifting taxation away from labour towards taxes 
that are less harmful to growth was even included several 
years in the country-specific  recommendations (CSRs) to 
Spain. 

in  those  reports).  This 

In recent times, some progress can finally be observed on 
environmental  taxation.  Thus,  as  part  of  the  reforms 
included under the RRP, new taxes have been introduced 
on  single-use  plastics  and  waste  management  (landfill, 
incineration  and  co-incineration),  and  the  tax  on 
fluorinated  gases  has  been  reformed.  The  RRP  also 
provides  for  adopting  further  measures  in  the  field  of 
green taxation, if agreed in the context of the  wider tax 
reform.  In  this  respect,  a  Committee  of  Experts  was 
created in the context of the RRP to study the reform of 
the  Spanish  tax  system,  including  the  improvement  of 
environmental taxation (190). 

(188)  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. 

(189)  Eurostat, ‘Environmental taxes accounts’, env_eta. 
(190)  The report or White Paper on the reform of the Spanish tax system 
was  issued  by  the  Committee  of  Experts  in  March  2022.  This 
committee was highlighted as a good practice in the 2022 EIR. 

(191)  European  Commission:  Directorate-General  for  Environment, 
Candidates  for  Taxing  Environmental  Bads  at  National  Level, 

Spain  52 

Figure 37: Environmental taxes per Member State, 2022 

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

to  a  2024 

study (191),  Spain  applies 
According 
environmental  taxes  to  discourage  environmentally 
harmful behaviour in the fields of  pollutant emissions to 
air, water and soil, levies on plastics, a hunting and fishing 
tax  and  volumetric  charges  on  water  abstraction  and 
disposal. 

Green bonds and sustainable bonds 

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

During  2021–2023  combined,  Spain  issued  green  bonds 
worth  USD 57.6 billion  (EUR 48.7 billion).  Of  this,  the 
issuance 
to  USD 21.8 billion 
(EUR 20.1 billion) (192).  Since  the  inaugural  issuance  in 
September  2021,  the  Spanish  Treasury  has  tapped  the 
green bond five times. The Spanish government decided 

in  2023  amounted 

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. 

(192)  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 – Spain 

 
 
 
interministerial  working  group  to 
to  establish  an 
coordinate  the  structuring  and  monitoring  of  Spain’s 
sovereign  green  bond  programme.  Regions  have  also 
issued their own green bonds, for instance Andalusia. 

During 2014–2023, 83 % of the green bonds issued by EU 
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 %. 

issuances)  was 

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

issued  by 

Figure 38: Value of green bonds issued per Member State 
(billion EUR), 2021, 2022 and 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 (EHSs), in particular fossil fuel subsidies (FFS), is 
a  further  step  towards  achieving  the  8th  Environment 
the  enabling 
Action  Programme  objectives  and 

(193)  Article 3(h) of the 8th Environmental Action Plan. 
(194)  European  Commission,  2024  Report  on  Energy  Subsidies  in  the 
COM(2025), 

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

Union, 

Spain  53 

conditions (193). 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 EU response to the 
2021  energy  crisis  and  subsequent  increase  in  energy 
prices. 

As a direct consequence, annual FFS in the EU increased to 
EUR 109 billion in 2023 from EUR 57 billion in 2020. From 
2021 to 2023, there was a marked increase in annual FFS 
of 72 % in the EU (194). 

For  the  majority  of  the  Member  States  (16)  2022  saw  a 
peak  in  the  amount  of  overall  FFS.  A  decline  was  then 
observed  in  2023 (195).  In  particular,  FFS  for  coal  and 
lignite, natural gas and oil increased in 2022, and a strong 
increase was observed for natural gas subsidies. 

In  Spain,  the  energy  subsidies  were  broadly  stable 
between 2015 and 2020, with annual FFS ranging between 
EUR 4.7 billion and EUR 5.3 billion. After a slight decrease 
in  2020,  energy  subsidies  increased  significantly  in  2021 
and  2022  but  began  to  fall 
in  2023.  FFS  reached 
EUR 5.7 billion  in  2021  and  EUR 6 billion  in  2023  (apart 
from a temporary spike of EUR 12 billion in 2022). 

As a share of GDP, FFS in 2022 ranged from 1.8 % in Croatia 
to less than 0.1 % in Denmark and Sweden. Spain’s value 
reached 0.9 %, slightly above the EU average (0.8 %) (196). 

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

NB: RES, renewable energy source. 

Source: analysis of Directorate-General Energy 

(195)  16 Member States: BE, EE, IE, EL, ES, FR, HR, IT, CY, LT, HU, NL, AT, 

PT, RO and SE. 

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

Union, 

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

2025 Environmental Implementation Review – Spain 

 
 
 
 
Spain  54 

The EIR 2022 included in its Chapter 5 a priority action to 
adopt  and 
implement  the  envisaged  measures  on 
environmental  taxation  and  explore  further  ones  in  the 
context  of  the  upcoming  tax  reform, 
including  the 
reduction of environmentally harmful subsidies. 

Spain  has  an  overall  environmental  investment  gap  of 
around 0.81 % of GDP (close to the EU-average), signalling 
that one-third of the overall financing needs are unmet. 

Spain should take advantage of the available EU funding 
to improve environmental compliance and to develop the 
potential of the green economy for competitiveness and 
job creation. 

2025 priority action 

In  light  of  the  existing  investment  gaps,  the  following 
priority action is identified for Spain. 

•  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. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Spain  55 

6. Environmental governance 

Information, public participation and access to 
justice 

Table 3: Spain dashboard on the implementation of the 
INSPIRE Directive, 2016–2023 

Citizens  can  more  effectively  protect  the  environment  if 
they rely on the three ‘pillars’ of the Aarhus Convention: 
(i)  access  to  information,  (ii)  public  participation  in 
decision-making and (iii) access to justice in environmental 
matters.  It  is  of  crucial  importance  to  public  authorities, 
the public and businesses that environmental information 
shared  efficiently  and  effectively (197).  Public 
is 
participation  allows  authorities  to  make  decisions  that 
take public concerns into account. Access to justice is a set 
of  guarantees  that  allows  citizens  and  NGOs  to  use 
national courts to protect the environment, safeguard the 
citizens  and  ensure  accountability  of 
rights  of 
authorities (198).  It 
legal 
includes  the  right  to  bring 
challenges (‘legal standing’) (199) . 

Environmental information 

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

Spain’s  performance 
INSPIRE 
Directive is substantial and has been reviewed based on 
the country’s 2023 country fiche (200) (see Table 3). 

implementing  the 

in 

(197)  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 

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

2016 

2023 

Legend 

Effective  coordination  and  data 
sharing 

Ensure 
coordination  

effective 

■  ■ 

Data sharing without 
obstacle  

■  ■ 

INSPIRE performance indicators 

(i)  Conformity  of 
metadata  

■  ■ 

(ii)  Conformity  of 
spatial datasets   

■  ■ 

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

(iv)  Conformity  of 
network services 

■  ■ 

■  ■ 

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

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

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

Source:  European  Commission, 
https://knowledge-base.inspire.ec.europa.eu/spain_en. 

‘Spain’, 

Inspire  Knowledge  Base, 

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 

(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). 

(199)  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. 

(200)  European  Commission, 

‘Spain’, 

Inspire  Knowledge  Base, 

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

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
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 (201) 
and  the  Strategic  Environmental  Assessment 
(SEA) 
Directive (202). 

safeguards,  while  enabling 

EU  law  provides  for  a  flexible  framework  concerning 
environmental  impact  assessments.  The  aim  of  this 
framework  is  to  ensure  the  application  of  the  necessary 
speedy 
environmental 
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 (203).  Spain  has  already  taken  steps 
aiming  to  accelerate  permit-issuing  procedures  taking 
advantages  of  the  broad  flexibilities  offered  by  the  EU 
legal  framework,  such  as  the  establishment  of  one-stop 
shops and accelerated short deadlines for issuing permits 
for renewable energy projects. 

The average speed in the EU for issuing permits involving 
an  EIA  procedure 
is  20.6 months,  with  a  minimum 
duration  of  11.4 months  and  a  maximum  duration  of 
75.7 months (204).  The  duration  of  each  step  in  an  EIA 
process 
report,  public 
consultation, reasoned conclusion, development consent) 

scoping,  EIA 

(screening, 

(201)  Directive  2014/52/EC  of  the  European  Parliament  and  of  the 
Council  of  16 April  2014  amending  Directive  2011/92/EU  on the 
assessment of the effects of certain public and private projects on 
the  environment 
(OJ  L 124,  25.4.2014,  p. 1),  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014L0052. 
(202)  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. 

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

2022, 

Impact  Assessment 

(204)  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 
2024, 
https://op.europa.eu/en/publication-detail/-
/publication/8349a857-2936-11ef-9290-01aa75ed71a1/. 
(205)  European  Commission:  Directorate-General  for  Environment, 
Lundberg, P., McNeill, A., McGuinn, J., Cantarelli, A. et al., Study 

Luxembourg, 

European 

Union, 

Spain  56 

varies considerably between Member States and projects. 
Complete data for Spain are not available. 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 (205). 

In Spain, public participation in environmental matters is 
ensured  by  Law 27/2006 (206),  which 
is  the  national 
legislation  incorporating  the  three  pillars  of  the  Aarhus 
Convention into the Spanish legal system. 

Moreover,  there  are  various  tools  to  foster  public 
participation.  The  Ministry  for  the  Ecological  Transition 
and  the  Demographic  Challenge  (MITECO)  published  in 
information  and 
2021  an  online  guide  on  public 
impact 
consultation  procedures 
assessments (207). This guide provides useful information 
on the procedure for public participation, on each of the 
different steps to participate in national and cross-border 
consultations and on the outcomes that can be expected 
from them. 

in  environmental 

improve 

The Ministry has also developed SABIA, a portal that aims 
to 
the  management  of  environmental 
assessments and  public participation by pulling together 
in one place links to all SEA and EIA procedures. It provides 
a  tool  to  check  the  status  of  plans,  programmes  and 
projects undergoing environmental assessment dealt with 
by  the  national  administration (208).  Many  Autonomous 
Communities have also developed similar tools, but not all 
of them with the same degree of information. 

(206) 

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 
Law 27/2006,  of  18 July,  regulating  the  rights  of  access  to 
information,  public  participation  and  access  to 
in 
environmental  matters  (transposing  Directives  2003/4/EC  and 
2003/35/EC), 
https://www.boe.es/buscar/act.php?id=BOE-A-
2006-
13010#:~:text=Ley%2027%2F2006%2C%20de%2018%20de%20ju
lio%2C%20por%20la,medio%20ambiente%20%28incorpora%20la
s%20Directivas%202003%2F4%2FCE%20y%202003%2F35%2FCE
%29.. 

justice 

(207)  MITECO,  ‘Guía  para  la  realización  de  trámites  de  información 
pública  y  consultas  en  las  evaluaciones  de  impacto  ambiental’, 
https://www.miteco.gob.es/es/calidad-y-evaluacion-
ambiental/temas/evaluacion-
ambiental/guiaipenero21formatoarticulo25012021_tcm30-
522384.pdf. 

(208)  The SABIA portal was already highlighted as a point of excellence 
in  the  first  2017  EIR.  https://www.miteco.gob.es/es/calidad-y-
evaluacion-ambiental/temas/evaluacion-ambiental/. 

2025 Environmental Implementation Review – Spain 

 
 
on 

information  published  on  public 
However,  overall, 
information 
not 
environmental  matters 
disaggregated  and  it  is  not  possible  to  determine  which 
requests  for  information  refer  to  impact  assessments. 
There  is  a  lack  of  available  statistical  data  on  public 
participation regarding the EIA and SEA Directives. Thus, it 
is not possible to determine whether public participation 
is increasing or decreasing. 

is 

Furthermore,  public  participation  in  decision-making  is 
also ensured through the functioning of the Environment 
Advisory  Council’  (CAMA)  on  which  civil  society  groups 
such  as  the  G5  (the  Group  of  the 
five  biggest 
environmental  NGOs)  and  the  Spanish  Green  Growth 
Group are represented. 

Access to justice 

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

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

As  mentioned  in  the  2022  EIR,  the  Spanish  legal  system 
grants  the  public  (individuals  and  recognised  NGOs)  the 
possibility of bringing environmental cases to the courts. 

Associations  and  groups  that  may  be  affected  by  the 
challenged administrative act or regulation  or are legally 
entitled to defend collective rights and legitimate interests 
have legal standing. 

Depending  on  the  case,  judges  or  courts  can  review  the 
procedural and substantive legality of plans, and also acts 
of a regulatory nature, based on the request lodged by the 
plaintiff or the defendant in a lawsuit. 

However, in case of omissions and inactivity by the public 
administration,  the  public  seems  to  have  difficulties  in 

(209)  The  situation  is  likely  to  improve  as  a  result  of  the  national 
implementation plan adopted by Spain in 2022 regarding free legal 
aid for environmental NGOs in line with the Supreme Court case-
law and Aarhus Convention decision VII/8p. 

(210)  The concept is explained in detail in the European Commission’s 
2018  communication  on  EU  actions  to  improve  environmental 

Spain  57 

legal  standing  to  challenge  the  situation. 
obtaining 
Moreover,  bringing  administrative  cases  to  the  courts 
seems to be expensive sometimes and the expected cost 
may  prevent  the  public  from  taking  legal  action (209). 
Furthermore,  the  long  duration  of  the  cases  though  the 
different  judicial  instances  sometimes  poses  an  obstacle 
to  obtaining  an effective solution for the environment  if 
interim measures are not decided. 

The 2022 EIR included priority actions to (i) better inform 
the  public  about  their  right  to  access  to  justice  in 
environmental matters and (ii) ensure that the outcomes 
of judicial cases on environmental matters are effective in 
practice. The assessment of these actions is deferred to a 
future EIR. A new priority action on data on the duration 
of the EIA procedures is added. 

2025 priority actions 

• 

• 

• 

Ensure  that  relevant  information  on  EIA  and  SEA 
(including  on  public  participation 
procedures 
opportunities and on publication of final decisions) is 
electronically accessible in a timely manner, 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. 
Improve  access  to  courts  in  national  environmental 
cases by the public concerned and eliminate practical 
barriers, such as length of proceedings and excessive 
costs. 

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

Compliance promotion, monitoring and enforcement 

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

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

document 

working 

staff 

2025 Environmental Implementation Review – Spain 

 
 
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. 

Since the 2022 EIR, Spain has made further efforts in the 
field of environmental compliance assurance through the 
specialised  police  unit  Servicio  de  Protección  de 
la 
to  combat 
(SEPRONA –  Guardia  Civil) 
Naturaleza 
environmental  crime  and  a  specialised  Environmental 
Prosecution Authority (Fiscalía de Medio Ambiente). Both 
have  been  successful  in  investigating  and  prosecuting 
organised  environmental  crime  and  were  highlighted  as 
good practices in the 2019 EIR. 

The specialist environmental police force (SEPRONA) also 
gathers  information  on  the  number  of  environmental 
crimes  investigated.  That  information  is  available  in  the 
annual statistics reports published by the Ministry of the 
Interior (211). 

The  specialised  Environmental  Prosecution  Authority 
publishes  information  on  its  activities  in  general  and 
specifically  on  the  number  of  prosecutions  it  promotes. 
That information is available in the General Prosecutor’s 
annual report (212). 

Since  the  last  2022  EIR  (between  15  May  2022  and  31 
December  2024),  the  Commission  has  received  168 
complaints relating to the environment in Spain, making it 
the Member State with the highest number of complaints 
for this period, although in terms of complaints per million 
inhabitants the amount is 3.45, just above the EU average 
of  3.2  (figures  40  and  41).  The  cases  concern  alleged 
breaches  of  EU  law  in  all  the  environmental  sectors. 
Around  one  third  relate  to  the  Nature  Directives,  while 
another  significant  proportion  concerns  EIA  and  water 
cases. 

Spain  58 

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

Source: DG Environment complaints data. 

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

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

The 2022 EIR recommended that Spain (i) increase online 
information  on  the  Nitrates  Directive  and  develop 
promotion tools to help farmers comply with it; (ii) better 
inform the public and farmers about compliance with the 
Nature Directive; (iii) publish information on the outcome 
of enforcement actions and on the follow-up to detected 
breaches  on  nitrates  and  nature;  (iv)  further  improve 
cooperation among the public authorities responsible for 
combating environmental crime; and (v) raise awareness 
among citizens about tools to alert the authorities to cases 
of environmental damage, or breaches of environmental 
law. Concerning compliance  promotion, monitoring, and 
criminal  and  administrative  enforcement,  the  2022 

(211)  See the 2023 annual report ‘Anuario Estadístico del Ministerio del 
2023’, 

Interior 
https://www.interior.gob.es/opencms/es/archivos-y-
documentacion/documentacion-y-publicaciones/anuarios-y-

estadisticas/anuarios-estadisticos-anteriores/anuario-estadistico-
de-2023/ 

(212)  See Chapter III.3.3 of the 2023 annual report: Memoria 2023 de la 

Fiscalía General del Estado. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
priority  actions  are  not  assessed  here  due  to  lack  of 
systematic  information.  Similarly,  the  Commission  is  not 
aware if information for farmers is easily available online 
at  the  national  level  regarding  compliance  with  the 
Nitrates  and  Nature  Directives,  and  hence  that  2022 
priority action is not assessed. 

The new EU Environmental Crime Directive 

legislation  with 

The EU has recently strengthened its legal framework on 
tackling  the  most  serious  breaches  of  environmental 
obligations,  notably  by  the  adoption  of  the  new 
Environmental  Crime  Directive  (ECD) (213)  and  new 
sectoral 
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 

important 

for 

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

Member  States  are  required  to  transpose  the  new  ECD 
into national law by 21 May 2026 and to take additional 

(213)  Directive (EU) 2024/1203 of the European Parliament and of the 
Council  of  11 April  2024  on  the  protection  of  the  environment 
through  criminal  law  and  replacing  Directives  2008/99/EC  and 
2009/123/EC 
(OJ  L,  2024/1203,  30.4.2024),  https://eur-
lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32024L1203. 

(214)  https://www.impel.eu/en. 
(215) 

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 

(216)  https://www.environmentalprosecutors.eu/. 
(217)  https://www.eufje.org/index.php?lang=en. 
(218)  Directive 2004/35/EC on environmental liability with regard to the 
prevention  and  remedying  of  environmental  damage  (OJ  L  143, 

Spain  59 

including  by 

to  combat  environmental  crime  more 
measures 
effectively,  in  particular  through  training,  coordination, 
cooperation  and  strategic  approaches.  The  Commission 
will  provide  support, 
facilitating  the 
identification  and  sharing  of  good  practices.  Member 
States are expected to ensure the necessary resources and 
specialised  skills  required  and  they  are 
invited  to 
encourage their authorities to support and cooperate with 
the  recognised  EU-level  networks  of  environmental 
enforcement practitioners, such as the EU Network for the 
Implementation  and  Enforcement  of  Environmental 
Law (214),  EnviCrimeNet (215),  the  European  Network  of 
Prosecutors for the Environment (216) and the EU Forum of 
Judges  for  the  Environment (217).  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) (218)  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  a  legal  obligation  to  periodically 
evaluate  the  ELD.  The  ELD  has  undergone  the  second 
evaluation (219), which will be finalised in 2025, and which 
was  supported  by  an  external  study (220),  containing, 
among  other  things,  evidence,  views,  reports  and  other 
relevant information gathered from different stakeholder 
groups, including Member States. 

p. 

30.4.2004, 
content/EN/TXT/PDF/?uri=CELEX:02004L0035-
20190626&qid=1568193390794&from=EN. 

56), 

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

(219)  Commission  staff  working  document  -  Evaluation  of  the 

Environmental Liability Directive, forthcoming 2025. 

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

2025 Environmental Implementation Review – Spain 

 
 
 
indicators 

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

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

the  development  of 

From 1 May 2013 to 31 December 2021, Spain reported 28 
occurrences  of  an  imminent  threat  of  environmental 
damage  and  21  occurrences  of  environmental  damage 
under  the  ELD.  In  the  previous  reporting  period,  there 
were 12 occurrences of environmental damage reported 
under the ELD (10 land and water damage cases, 1 water 
damage case and 1 land damage case). Spain is among the 
Member  States  with  the  highest  overall  numbers  of 
reported  ELD  occurrences  and  with  an  upward  trend  of 
ELD  occurrences  between 
reporting  periods. 
Moreover,  Spain  is  among  the  few  Member  States  that 
have  most  heavily  invested  in  developing  training  and 
methodologies assisting ELD implementation. 

two 

Spain was the first Member State to introduce a detailed 
mandatory  financial  security  system  for  ELD  liabilities 
together with methodologies, guidance and other tools to 
determine the amount of financial security for individual 
operators. The mandatory financial security system covers 
the  remediation  of  land/soil,  water  and  biodiversity 
damage on an insured operator’s own site as well as the 
remediation  of  off-site  damage  that  migrates  from  the 
operator’s  own  site.  The  mandatory  system  does  not 
cover  the  costs  of  complementary  or  compensatory 

(221) 

 Commission  Notice  of  7  April  2021,  Guidelines  providing  a 
common  understanding  of  the  term  ‘environmental  damage’  as 
defined  in  Article  2  of  Directive  2004/35/EC  of  the  European 
Parliament  and  of  the  Council  on  environmental  liability  with 
regard  to  the  prevention  and  remedying  of  environmental 
damage, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:52021XC0407(01)&from=EN 

(222)  See 

the  European  Commission  web  page  on  Compact 
(https://reform-support.ec.europa.eu/public-administration-and-

Spain  60 

remediation  under  the  ELD.  Environmental  insurance 
policies that provide cover for all on-site and off-site ELD 
liabilities  are  widely  available  and  supplied  by  individual 
insurers  and  members  of  the  Environmental  Risks  Pool. 
Environmental extensions to general liability policies that 
provide cover for environmental liabilities are available on 
a  limited  basis;  mostly  they  do  not  provide  cover  for 
complementary or compensatory remediation under the 
ELD. 

The 2022 EIR recommended in relation to ELD that Spain 
increase awareness among citizens about tools to alert the 
authorities  to  cases  of  environmental  damage,  or 
breaches  of  environmental  law.  Spain  has  achieved 
substantial  progress  in  implementing  this  2022  priority 
action; for example, Spain reported on its Environmental 
Liability  Information  System  (SIRMA),  created  in  April 
2022, to gather all the information related to the Spanish 
Environmental  Liability  Law  (Law 26/2007),  as  well  as  to 
provide  access  to  all  the  documents,  guides  and  tools 
developed  to  facilitate  its 
in  Spain. 
However,  Spain  continues  to  apply  the  restrictive 
interpretation  of  water  damage  which  is  not  compliant 
with the Commission guidelines (221). 

implementation 

2025 priority action 

• 

Encourage the use of training programmes provided 
by  the  Commission  (or  developed  at  the  national 
level)  covering  the  ELD  and  its  interaction  with  the 
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 (222) initiative to enhance 
the administrative space identifies the capacity to lead the 
green transition as one of three key pillars, along with the 
public  administration  skills  agenda  and  the  capacity  for 
Europe’s Digital Decade. Compact also recognises the role 
of  the  EIR  reporting  tool  in  improving  environmental 
governance. The two main capacity-building opportunities 
for 
the  European 
Commission  are  the  TSI (223)  and  TAIEX-EIR  PEER  2  PEER 
tool (224).  The  technical  assistance  available  through  the 

the  environment  provided  by 

governance-coordination/enhancing-european-administrative-
space-compact_en). 

(223)  See 

the  European  Commission  web  page  on 

the  TSI 

(https://commission.europa.eu/funding-tenders/find-
funding/eu-funding-programmes/technical-support-
instrument/technical-support-instrument-tsi_en). 

(224)  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 – Spain 

 
 
cohesion  policy  is  subject  to shared  management  and  is 
not dealt with in this subsection. 

The Commission’s technical support instrument 

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

The  TSI  had  annual  calls  in  2021,  2022,  2023,  2024  and 
2025.  The  TSI  supported  several  environment-related 
projects in Spain during the period since the last EIR: 

• 

• 

• 

• 

Integration  of  environmental  dimensions  in  public 
finances – implementing the ‘do no significant harm’ 
(DNSH)  principle 
in  public  funding  programmes, 
Ministry  of  Ecological  Transition  and  Demographic 
Challenge (2023). 
Capital markets for a vibrant and sustainable Spanish 
economy  and  corporate  sector,  National  Securities 
Market Commission (CNMV) (2023). 
 Sustainability in Local Public Finances, Barcelona City 
Council (2024). 
informs 
Integrated 
coastal  wetlands, 
adaptive  management  of 
Consejería  de 
local  y 
prevención de incendios. Gobierno del Principado de 
Asturias (2025). 

environmental  monitoring 

fomento,  cooperación 

The Commission’s TAIEX-EIR PEER 2 PEER tool 

The Commission launched the TAIEX-EIR PEER 2 PEER tool 
in 2017. It aims to facilitate peer-to-peer learning among 
Member  States’  environmental  authorities  through 
workshops  (single  or  multi-country),  expert  missions 
(where  a  delegation  of  experts  travels  to  the  requesting 
institution) and study visits (where a delegation from the 
requesting institution travels to a host country).  Flagship 
multi-country  workshops  are  those  requested  by  the 
Commission to present new and upcoming environmental 
legislation and policy in all Member States (225). 

Workshops involving Spain are as follows: 

• 

Climate  adaptation  and  blue  infrastructure  (31 May 

Spain  61 

to 1 June 2022). 

•  Good  practices  on  noise  abatement  measures  and 

• 

• 

• 

noise mapping (26–27 September 2022). 
Circular economy (in the Irish Midlands) (4–6 October 
2022). 
Eco-management  and  audit  scheme  (EMAS)  (28–
30 September 2022). 
Future  challenges  for  air  protection  (24 November 
2022) with the Czech Presidency. 

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

•  Decentralised  bio-waste  recycling 

in  Austria  (9–

11 October 2023). 

•  Green budgeting at regional level (9 April 2024). 
•  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). 

involved 

Spain  was 
in  an  expert  mission  on  dune 
protection  in  Bulgaria  (28–29 February  2024).  Manresa 
City Council in Spain took part in a study visit on 6–8 June 
2023 on circular economy, textile industry, zero waste and 
peri-urban  organic  agriculture  in  Prato  and  Capannori 
(Tuscany). 

In  2022,  Spain  received  priority  actions  on  (i)  further 
addressing regional and local fragmentation by developing 
better  environmental  coordination  mechanisms  and  (ii) 
further  improving  its  overall  environmental  governance, 
such  as  transparency,  citizen  engagement,  compliance 
and enforcement, as well as  administrative capacity and 
coordination.  Limited  progress  has  been  made  in  this 
regard. Therefore, a similar priority action is proposed for 
2025. 

2025 priority action 

• 

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

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

of  environmental  footprint  methods  on  the  EU  market  (30  May 
2024);  Sustainable  finance  (9  November  2023);  Textile  waste 
separate collection, treatment and markets (3 October 2023); EU 
environmental  funding  and  support  (13  June  2023);  Advisory 
service for businesses to go circular (24 April 2023); Digital product 
passport implementation (6 December 2022); Public involvement 
in  planning  and  approval  of  renewable  energy  projects  (17 
November 2022); Environmental compliance and governance (14 
November  2022);  Biowaste  management  (19–20  September 
2022); and  Renewable energy projects: permit granting processes 
(13 June 2022). NB: The first flagship workshop on zero pollution 
for air, water and soil took place 9 February 2022. 

2025 Environmental Implementation Review – Spain 

 
 
 
 
Spain  62 

Annex 

2025 priority actions 

Circular economy 

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

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

• 
• 

• 

• 
• 
• 
• 

• 
• 

• 

• 

Waste management 

Complete closure of non-compliant landfills. 
Improve separate collection at source e.g. through economic instruments, investing in infrastructure for 
separate collection, sorting and recycling, and increasing public awareness. 
Increase reuse of products and scale up waste recycling infrastructure associated with the higher steps of 
the waste hierarchy. In particular, improve collection and increase treatment capacity for bio-waste. 
Improve municipal waste preparation for reuse and recycling. 
Increase the collection and recycling rate of waste electronic and electric equipment (WEEE). 
Invest in waste prevention measures to reduce the total amount of waste generated. 
Ensure  the  achievement  of  the  2025  waste  targets,  following  the  recommendations  made  by  the 
Commission in the Early Warning Reports where applicable. 

Biodiversity and natural capital 
Nature protection and restoration – Natura 2000 

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

The recovery of species  

Strengthen the integration of biodiversity actions into other policies, e.g. energy, agriculture, fisheries, 
forestry,  urban  and  infrastructure  planning  and  sustainable  tourism,  and  promote  communication 
between stakeholders. 

•  Reinforce  action  for  habitats  and  species  in  unfavourable  conservation  status,  for  example  through 
restoration measures, increased connectivity, better policy  coordination and integration, and increased 
funding. 

Recovery of ecosystems 

• 

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

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

•  Ratify  the  Protocol  for  the  Protection  of  the  Mediterranean  Sea  against  Pollution  Resulting  from  the 
Exploration and Exploitation of the Continental Shelf and the Seabed and its Subsoil (Offshore Protocol to 
the Barcelona Convention). 

Prevention and management of invasive alien species  

2025 Environmental Implementation Review – Spain 

 
 
 
 
 
 
 
 
 
• 

• 

• 

• 
• 

• 

• 

Spain  63 

• 

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

Zero pollution 
Clean air 

•  As part of the NAPCP, take action towards reducing emissions of air pollutants. 
• 

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

Industrial emissions 

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

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

Major industrial accidents prevention – Seveso 

Strengthen  compliance  with  requirements  on  safety  measures  to  prevent  major  accidents  and  ensure 
appropriate preparedness and response for UTEs, in particular as regards review, testing and update of 
EEPs; at intervals of no longer than three years. 
Ensure  access  to  transparent  and  clear  information  towards  citizens  on  risks  and  behaviour  in  case  of 
accidents. 

Complete noise mapping. 
Complete and implement action plans on noise management. 

Noise 

Water quality and management 

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

Improve the classification of water bodies and strengthen monitoring systems. 

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

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

• 

• 
• 

• 

monitoring, costs of measures). 
Improve public consultation and stakeholder involvement. 
Tackle nutrient pollution, especially nitrates from agriculture, through the implementation of the Nitrates 
Directive. 
Take the necessary measures to ensure full implementation of the current Urban Wastewater Treatment 
Directive, taking into account the new requirements of the recast Directive. 

Chemicals 

2025 Environmental Implementation Review – Spain 

 
 
 
 
Spain  64 

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

• 

• 

• 

zero tolerance of non-compliance.  
Increase involvement in the activities of the Forum for Exchange of Information on Enforcement of the 
European Chemicals Agency, including in the coordinated enforcement projects, called REF projects. 
Increase customs controls and controls of products sold online with regard to compliance with chemicals 
legislations. 

Climate action 

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

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

Environmental governance 
Information, public participation and access to justice 

• 

• 
• 

• 

• 

Ensure  that  relevant  information  on  EIA  and  SEA  procedures  (including  on  public  participation 
opportunities and on publication of final decisions) is electronically accessible in a timely manner, 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. 
Improve access to courts in national environmental cases by the public concerned and eliminate practical 
barriers, such as length of proceedings and excessive costs. 

Compliance assurance 

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

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 – Spain