Opinion of the European Economic and Social Committee – Towards 2030 – Assessment of key environmental actions to be included in the annex to the 8th Environmental Action Programme to better anchor environmental policy in society (exploratory opinion requested by the Danish Presidency)
Date: 2025-07-17
Institutions: European Economic and Social Committee
Subjects: EU environmental policy, EU programme, action programme, biodiversity, environmental protection, greenhouse gas, management of resources, pollution control measures, reduction of gas emissions, sustainable development








C_202505148EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/5148


28.10.2025






Opinion of the European Economic and Social Committee
Towards 2030 – Assessment of key environmental actions to be included in the annex to the 8th Environmental Action Programme to better anchor environmental policy in society
(exploratory opinion requested by the Danish Presidency)
(C/2025/5148)


Rapporteur: 
Lutz RIBBE






Referral


Letter from the Danish Presidency of the Council, 7.2.2025




Legal basis


Article 304 of the Treaty on the Functioning of the European Union




Section responsible


Section for Agriculture, Rural Development and the Environment




Adopted in section


25.6.2025




Adopted at plenary


17.7.2025




Plenary session No


598




Outcome of vote
(for/against/abstentions


153/3/4




1.   Conclusions and recommendations









1.1.


Following the mid-term review of the 8th Environment Action Programme (EAP), the European Commission is to look into whether to put forward a legislative proposal for an annex to the programme. The annex would include ‘a list of actions with a view to reaching those objectives, as well as a timeline for the respective actions’. The aim is to make progress on environmental policy. The Danish Presidency has asked the European Economic and Social Committee (EESC) to draw up an opinion on the subject.












1.2.


The EESC does not believe that a legislative proposal for a new annex to the EAP is absolutely essential. It is not enough to merely add more issues to the already long, detailed list of items that need to be addressed. Rather, thorough consideration should be given to a number of general principles for future environmental policy, or – to be more precise – for sustainability policy, which is known to be a symbiosis of environmental, social and economic policies.












1.3.


This opinion therefore identifies a number of key areas that the EESC has often described as crucial, even though its proposals have not been adequately taken up by policy-makers. By now it should be clear to everyone that rigorous environmental protection is an important part of the solution for a sustainable future, rather than a problem, as it is still viewed in many Member States.












1.4.


Environmental policy remains something of a ‘green niche’. Although the policy rightly tackles many of the issues at stake, it renders them incomprehensible to broad sections of the public, and seemingly also to many of those who are not environmental policy-makers, making such issues seem detached from reality. For example, when talking about a ‘need for systemic change’ or saying that ‘planetary boundaries’ have been crossed, an explanation is needed. It must be spelt out much more clearly what this actually means, how people’s and businesses’ daily lives and work situations will be affected, and what impact this will have on other policy areas. Only then will people become aware of – and feel concerned by – these problems. Unfortunately, this on its own will not fully deliver the 8th EAP or implement the environment policy.












1.5.


The EESC still sees it as a major political error that the Barroso Commission in particular did not press ahead with the sustainability strategy in place at the time. The EU later tried to make up for at least some of this with the Green Deal. However, in the EESC’s view, the Green Deal fails to give the social repercussions the consideration they deserve, meaning that it is no substitute for a sustainability strategy. It therefore reiterates its call (1) for an EU Sustainable Development Strategy 2050 which also properly addresses and integrates the social dimension of this crucial transition.












1.6.


The response being given to the need to come up with a new measure of our prosperity (Beyond GDP), as outlined in the 8th EAP, amounts to little more than theoretical and scientific discussions held in environmental circles. The EESC would like to see the Danish Presidency succeed in persuading economic and finance ministers to get involved in this discussion and put forward concrete proposals.












1.7.


Given that sustainability measures will entail ever more financial requirements in future, and that this will be accompanied by growing competition for budget resources (defence policy), current spending needs to be made more efficient, and all subsidies harmful to health and the environment must be phased out without delay.












1.8.


Policy-makers need to take scientific evidence and warnings, as well as forward-looking bottom-up initiatives, much more seriously. Setting policy targets that exceed planetary boundaries, such as the 1.5 °C climate policy target, cannot lead to a sustainable future.












1.9.


There is a need to raise awareness of sustainability issues both among the general public and across politics and government. This is complicated by the fact that communication policy is, in some cases, being successfully torpedoed by groups pursuing other interests.












1.10.


The EESC calls for civil society to play a bigger role in order to boost public support for the EU’s environmental and sustainability policies. Getting civil society systematically involved in all possible areas of daily life, including the world of work, is a must. This is the only way to make the necessary changes clear to people and to make them socially fair.




2.   Background to the opinion









2.1.


With its decision (2) of 6 April 2022, the European Parliament and the Council adopted the 8th Environment Action Programme (EAP) to 2030. The EESC had previously given its views on the Commission’s proposal (3) on the 8th EAP in its opinion of 27 January 2021 (4), making some very critical remarks about the EAP’s content and impact, as it had also done in its opinion on the 7th EAP (5).












2.2.


The EESC explained that it could ‘only see at best marginal added value’ in the proposal, since ‘the proposal focuses more on general descriptions of situations and declarations of intent than on substance and actions’, adding that it did not set out ‘specific instruments or measures’. The Committee therefore felt ‘much supported [...] in its view – one which it has been reiterating for years – that there is no lack of knowledge about what needs to be done. What is lacking is the implementation of well-known measures, often decided upon long ago, as well as political will’.












2.3.


The EESC therefore called for a ‘fundamental debate on the sense and value of the environmental action programmes’, and reiterated its call for ‘a separate “EU 2050 Sustainable Development Agenda”’ to be drawn up. The Committee drew up two key opinions setting out its thoughts on how civil society could play a more effective role here: The transition towards a more sustainable European Future – a strategy for 2050 (6) and Leaving no one behind when implementing the 2030 Sustainable Development Agenda (7). However, the Commission, the Council and the European Parliament have taken little account of the ideas and measures put forward in either opinion.












2.4.


The decision of the European Parliament and the Council did not address the EESC’s substantive concerns. However, unlike the Commission’s proposal, Article 5 of the decision did stipulate that a mid-term review should be carried out, the aim being to assess whether the Commission should put forward a legislative proposal for an annex to be added to the 8th EAP for the period after 2025, providing ‘a list of actions with a view to reaching those objectives, as well as a timeline for the respective actions.’












2.5.


The future Danish Presidency is keen to follow the debate closely and has therefore asked the EESC to draw up this exploratory opinion. The opinion ‘could assess environmental policy actions [that] the European Economic and Social Committee (...) [considers to be] of the highest importance for the EU in the years 2025-2030’, and which it deems necessary ‘to ensure that future environmental action is firmly anchored in the broader society’.




3.   General comments









3.1.


The various reports by the European Environment Agency (8), studies on whether the Sustainable Development Goals under the UN’s 2030 Agenda have been met, and the published mid-term report on the 8th EAP all make clear that, while the steps taken so far have secured some progress, they have fallen short in most environment policy fields. For example, the mid-term review of the 8th EAP concludes, among other things, that:






—


emissions must be cut more quickly in order to virtually triple the average annual reduction rate achieved over the last 10 years;










—


more needs to be done to meet the target for a net reduction in greenhouse gas emissions (GHG) resulting from land-use, land-use change and forestry (LULUCF) through carbon sinks;










—


major issues surrounding biodiversity policy persist. These include the continuing decrease in populations of common bird species, with sharp declines among farmland birds; more investment in nature is therefore needed, but the funding targets set for 2026 and 2027 may be missed;










—


the EU’s consumption footprint has gone beyond planetary boundaries, increasing by a further 4 % between 2010 and 2021 and with no let-up in land-use pressures; this is due to current consumption patterns in the food, housing and transport sectors;










—


water scarcity now affects almost a third of EU territory;










—


often it is not the legal framework that falls short but rather the way it is implemented (around 20 % of all infringement cases handled by the Commission still concern environmental policy).
















3.2.


The EESC therefore still harbours doubts, which it has expressed on several occasions, about a) whether there is the political will to act and b) how effective the EAP actually is. Action programmes without action, or the tools to carry it out, are no basis for an environmental policy. However, the EAP does identify and describe the unresolved issues to be addressed and the – to some extent – drastic situation in which environmental policy still finds itself.












3.3.


Together with the 8th EAP mid-term review, the 2025 Environmental Implementation Review (EIR) also uncovers major environmental policy shortcomings. The EESC sees the 2025 EIR as a good opportunity to identify key challenges and best practices. The review’s findings offer an important contribution to the proposed annex to the 8th EAP. The same conclusions of the various EIRs – which come up time and time again – must not come to nothing. Rather, they need to be used more effectively to update strategic policy areas and fill existing implementation gaps.












3.4.


The EESC particularly supports those points made in the EAP and accompanying documents which make very clear that a ‘step-change’ (9) is needed in many fields of action today. It quite rightly points out that such ‘[s]ystemic change entails a fundamental, transformative and cross-cutting form of change that implies major shifts and reorientation in system goals, incentives, technologies, social practices and norms, as well as in knowledge systems and governance approaches.’ (10).












3.5.


Such statements are nothing new. The Resource-efficient Europe flagship initiative (part of the then Europe 2020 strategy) and the 7th EAP already referred to a ‘significant transition in energy, industrial, agricultural and transport systems’. The EESC believes that the biggest shortcoming of (environmental) policy to date is the fact that it has essentially failed to explain how this fundamental systemic change would look in practice, what the expected impact would be on the lives of all those concerned and what steps might be needed to win over those affected. The Committee has been urgently calling for this for more than 20 years now (11).




4.   Specific comments









4.1.


The EESC does not believe that a legislative proposal for a new annex to the EAP is absolutely essential. It is not enough to merely add more issues to the already long, detailed list of items that need to be addressed. Rather, thorough consideration should be given to a number of general principles for future environmental policy, or – to be more precise – for sustainability policy, which is known to be a symbiosis of environmental, social and economic policies.





Awareness as a basis for policy action









4.2.


It is human nature for things whose impact is not necessarily felt on an immediate, personal level to be viewed as less threatening or less significant, and even for people to push them out of their minds completely. This makes political action more difficult. Two examples illustrate this:






—


There is – quite rightly – an intense debate about road deaths in society. Every year, more than 20 000 people die on Europe’s roads and nearly all of us know someone who has been directly or indirectly affected by such an accident. This makes people feel concerned by such problems, and they then approve of measures to tackle them. Heatwaves are responsible for three times as many deaths in Europe (12); in 2021 fine particulate matter caused 253 000 deaths in the EU (13) – 12 times more than the number of road deaths. For all intents and purposes, however, these are ‘anonymous deaths’. In other words, nobody knows anyone in their immediate circle who has died from that. And this has consequences for the ability to deliver a policy response, especially as the issue is largely being discussed by environmental policy-makers only, rather than by health or economic policy-makers, for example.










—


The new, threatening military security situation following Russia’s brutal invasion of Ukraine will have a serious impact on public finances. Billions of euros will be set aside in response. This is largely acceptable because the threat is clear and visible. The risk to humanity posed by climate change and biodiversity loss is also acute and significant, but less ‘tangible’ – which makes it much more difficult to respond politically with ‘hard’ measures.
















4.3.


This is especially true if politicians themselves do not really grasp the seriousness of the situation. To give another example linked to the 8th EAP: it points out in several places that ‘certain planetary boundaries’ (14) are still being crossed. The EESC has repeatedly underlined the importance of describing these planetary boundaries as accurately as possible, clearly communicating the consequences of going beyond them, and coming up with indicators to serve as a guide for policy action and to be specifically monitored. This has not happened so far and we are now paying the price.












4.4.


What is important here is to make it clear that planetary boundaries cannot be defined by policy. It is above all for scientists to identify them. This is the case with climate change, through the Intergovernmental Panel on Climate Change (IPCC), for example.
And it is up to policy-makers to draw the necessary conclusions.












4.5.


Article 2 of the 1992 Framework Convention on Climate Change stipulates that: ‘The ultimate objective of this Convention (...) is to achieve (...) stabilisation of greenhouse gas concentrations in the atmosphere at a level that prevents dangerous anthropogenic interference with the climate system’. The Paris Agreement (15) moved away from this qualitative target (compliance with planetary boundaries), adopting a politically-oriented quantitative (1,5 °C) one instead. Policy measures and how they are communicated are now geared towards this objective as a measure of success or failure.












4.6.


However, the 1,5 °C target clearly lies beyond planetary boundaries: the melting of all glaciers in Europe and the polar icecaps and the increase in extreme weather events (storms, droughts, floods, etc.) are all occurring even before the 1,5 °C target limit has been surpassed. Telling the general public that we are now (or soon will be) ‘on track’ to meet the 1,5 °C target sends out a dangerous message, as it takes the pressure off the need to act and conveys a sense of security that is entirely misplaced. It should be noted that it is not only the direct environmental and resulting economic consequences that will be dire; so far, there has been little discussion about what potential global migration flows could mean for our societies.












4.7.


More investment in environmental awareness, both among the general public and politicians, is therefore crucial, and strategic cooperation with scientists, environmental organisations, trade unions and other civil society actors is recommended in this regard, alongside accompanying educational initiatives and measures to promote them. This is all the more important given that so-called ‘social’ media, for example, is being used to spread counter-propaganda, including by political players (such as Russia, which wants to continue to sell its fossil resources and create dependencies) and sectors that wish to carry on making money using production methods that are environmentally damaging.





Economic and financial issues









4.8.


‘Growth strategies’ are always high up on the political agenda, and GDP is still a barometer of economic health. However, as made clear not least by European Environment Agency reports, economic growth has been an important driver of the negative trends in our material footprint and overall waste generation, for example. Efforts to decouple economic growth from environmental burden are under way, but have yet to fully deliver. It is therefore all the more important to have a discussion on how we assess our prosperity, i.e. the Beyond GDP debate. This is something that should actually be promoted by the 8th EAP, but in practice no discernible progress has been made that could be consistent with political (growth) strategies. This needs to change as a matter of urgency, otherwise there is a risk that we will continue to make the wrong economic policy choices and move further away from the idea of a ‘wellbeing economy’. The Danish Presidency could, for example, start a strategic debate on this when economic and/or finance ministers meet.












4.9.


Many environmental protection measures are not properly funded, something that the 8th mid-term report also makes clear. This creates discord and mistrust among those concerned. Farmers, for example, are often the ones that suffer under the conditions imposed as a result of the need to conserve nature (such as the Natura 2000 network). The policy was supposed to compensate for any obligations, damage, loss of income, etc. that it entailed. However, this has not happened, and only a fraction of the resources needed have been earmarked in public budgets.












4.10.


The EESC therefore reiterates the call it has already made several times for a specific budget to be made available, with adequate resources. The Commission’s repeated references to the possibility of theoretically drawing funds from ‘big pots’ (such as the Regional Fund) also for small-scale measures is not convincing.












4.11.


The environmental requirements of EU funds are rather formal and also fall short. The horizontal principle of sustainable development in cohesion policy is in need of structural reform so that more can be achieved. Overall, it is crucial that the funds already distributed be spent more efficiently. This could be achieved by, inter alia, channelling funds more directly to those stakeholders who deliver results. A balanced geographical distribution of funds must also be ensured.












4.12.


Better coordinated tools and stronger sanctioning mechanisms are needed to encourage Member States to make more targeted use of the environmental protection instruments already provided by the Commission and to roll out existing legislation more quickly.












4.13.


Financial needs will increase again in future in order to prevent even greater damage and more expenditure, or to promote environmental initiatives. For example, if we want to create natural carbon sinks and/or restore lost habitats for animal and plant species, then it is clear that competition with current agricultural land-use can be expected.












4.14.


Both climate and biodiversity protection measures are about ‘public goods’. However, there is no market for these. This means that the state has to create corresponding ‘public goods markets’, which can then be serviced by farmers, for example. However, it will be almost impossible to convince farmers to make the necessary changes to their production if they are merely offered financial compensation for loss of yield or for additional expenditure. The EESC has on many occasions called for ‘public goods’ to become a new, long-term and clearly predictable source of income for farmers (16). An ‘incentive component’ is a prerequisite for economic participation in a policy based on sustainability criteria.












4.15.


The upcoming EU mid-term financial planning exercise will therefore become a litmus test for this. At a time of tight budgets, and with increasing financial needs relating to the transition towards greater sustainability and increased military spending, all subsidies harmful to health and the environment need to be phased out as a matter of priority. The EESC has been calling for this for years – and politicians have also been talking about it for years – but far too little has actually been done. During what is left of the 8th EAP, some irreversible decisions must be taken in this regard.





Better public participation









4.16.


In order to ensure that public support for EU environmental policy is more firmly anchored, people’s fears and needs must be better taken into account. The EESC would once again refer to its comments on this issue in opinions SC/47 and SC/53. The opinions call for systematic participation in all possible areas of everyday life. Only then can the necessary transition be organised in a socially fair manner.












4.17.


Once again, however, policy development has been far too slow. In 2015, a decision was taken to set up the European Energy Union, paving the way for the transition away from fossil fuels. As the Commission put it at the time, it was striving for ‘an Energy Union with citizens at its core, where citizens take ownership of the energy transition, benefit from new technologies to reduce their bills, participate actively in the market, and where vulnerable consumers are protected’. The EESC has welcomed this participatory approach in many of its opinions, while often criticising the fact that it has not yet been backed up by any real action. There has been no policy response to the many EESC proposals in this regard. So it is not surprising that, although there is generally a high level of support for renewable energy, there are often major conflicts on the ground when putting related projects into practice, for example when planning the placement of wind turbines. In places where the public can actually benefit from such turbines (keyword: community energy), there is considerably less opposition.












4.18.


After 10 years of the Energy Union, the Commission is now putting forward a ‘citizens energy package’, which is expected to set out a more practical approach than before. The EESC welcomes this and will draw up a separate opinion on the matter. However, it should be noted that much civic engagement and political trust has been squandered over the past 10 years because political promises have not been kept.












4.19.


In general, policy-makers should carry out a critical analysis of their communication policies and strategies towards civil society. These are far too often top-down and one-sided, and seek to justify political choices that have been made. This is essentially also the right thing to do, but it does not go far enough. Communication is a two-way street. At the same time, the EU should learn strategically from the many bottom-up approaches and integrate them more into its policies.












4.20.


Highlighting such approaches and identifying areas where society is willing to compromise is one of the EESC’s main tasks. A positive example is the Circular Economy Platform, an initiative of the EESC.












4.21.


There are many more examples showing that structured civil society dialogue can deliver results that politicians often cannot. The Commission for the Future of Agriculture in Germany and the European equivalent, the ‘Strategic Dialogue on the future of EU agriculture’, are good examples of this. The EESC recommends making much greater use of such formats. However, this means making it clear at all times which recommendations should be taken up and put into practice and – therefore – which should not. Otherwise, there is a real risk of squandering civic engagement and public approval.






Brussels, 17 July 2025.


The President


of the European Economic and Social Committee

Oliver RÖPKE
               





(1)  Opinion of the European Economic and Social Committee on ‘The transition towards a more sustainable European future – a strategy for 2050’ (own-initiative opinion) (
OJ C 81, 2.3.2018, p. 44).

(2)  Decision (EU) 2022/591 of the European Parliament and of the Council of 6 April 2022 on a General Union Environment Action Programme to 2030 (
OJ L 114, 12.4.2022, p. 22).

(3)  Proposal for a Decision of the European Parliament and of the Council on a General Union Environment Action Programme to 2030 (COM(2020) 652 final).

(4)  Opinion of the European Economic and Social Committee on ‘Proposal for a Decision of the European Parliament and of the Council on a General Union Environment Action Programme to 2030’ (COM(2020) 652 final – 2020/0300 (COD)) (
OJ C 123, 9.4.2021, p. 76).

(5)  Opinion of the European Economic and Social Committee on the ‘Proposal for a Decision of the European Parliament and of the Council on a General Union Environment Action Programme to 2020 “Living well, within the limits of our planet”
            ’ (COM(2012) 710 final – 2012/0337 (COD)) (
OJ C 161, 6.6.2013, p. 77).

(6)  Opinion of the European Economic and Social Committee on ‘The transition towards a more sustainable European future – a strategy for 2050’ (own-initiative opinion) (
OJ C 81, 2.3.2018, p. 44).

(7)  Opinion of the European Economic and Social Committee on Leaving no one behind when implementing the 2030 Sustainable Development Agenda (own-initiative opinion) (
OJ C 47, 11.2.2020, p. 30).

(8)  
            Inter alia, the State of the Environment (SOER) reports: https://www.eea.europa.eu/soer.

(9)  
            Mid-term review of the 8th EAP, p. 8: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52024DC0123.

(10)  8th EAP, recital 4: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022D0591&qid=1744721977458.

(11)  Opinion of the European Economic and Social Committee on ‘Assessing the EU sustainable development strategy’ (exploratory opinion) (
OJ C 117, 30.4.2004, p. 22).

(12)  Mid-term review of the 8th EAP, p. 7.

(13)  Mid-term review of the 8th EAP, p. 12.

(14)  Mid-term review of the 8th EAP, p. 3.

(15)  Paris Climate Change Conference (COP 21), December 2015.

(16)  Opinion of the European Economic and Social Committee on ‘Promoting autonomous and sustainable food production: strategies for the common agricultural policy post-2027’ (exploratory opinion requested by the Belgian Presidency of the Council of the EU) (OJ C, C/2024/2099, 26.3.2024, ELI: http://data.europa.eu/eli/C/2024/2099/oj); Opinion of the European Economic and Social Committee on the ‘Reform of the common agricultural policy in 2013’ (own-initiative opinion) (
OJ C 354, 28.12.2010, p. 35).


ELI: http://data.europa.eu/eli/C/2025/5148/oj
ISSN 1977-091X (electronic edition)