COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE EVALUATION of the National Emission Reduction Commitments Directive
Date: 2025-12-01
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, EU emission allowance, EU environmental policy, air quality, atmospheric pollutant, environmental protection, pollution control measures, public health, reduction of gas emissions, transfrontier pollution

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  EN 

   EUROPEAN COMMISSION  Brussels, 1.12.2025  SWD(2025) 395 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE EVALUATION  of the National Emission Reduction Commitments Directive {SWD(2025) 394 final}  
 
 
1.  Context and objectives 

This  evaluation  assesses  the  performance  of  the  National  Emission  reduction  Commitments 
Directive (NECD)1 against five criteria: effectiveness, efficiency, relevance, coherence and EU 
added value.  

Air  pollutants  impact  human  health  and  the  environment.  They  are  emitted  from  different 
sources, and each pollutant’s effects may be felt locally or hundreds of kilometres away, due to 
the  pollutant  being  transformed  and  transported  in  the  atmosphere.  Air  pollution  policy 
addresses  this  complex  reality.  It  comprises  legislation  covering  environmental  quality 
standards2, abatement of specific emissions sources (nationally and at EU level), and the NECD, 
which tackles pollution at national level. The NECD is closely related to the Convention on 
Long-range  Transboundary  Pollution  (‘the  Air  Convention’)  and  its  protocols  under  the 
auspices of the United Nations Economic Commission for Europe (UNECE). Similar economic 
activities often affect both air pollution and climate change as well as other issues such as water 
pollution. This makes evaluating the specific role of the NECD particularly challenging. 

The NECD sets out mandatory commitments per Member State to reduce the emissions of five 
key air pollutants contributing to transboundary pollution:  

1.  sulphur dioxide (SO2)  
2.  nitrogen oxides (NOx) 
3.  non-methane volatile organic compounds (NMVOC) 
4.  ammonia (NH3) 
5.  fine particulate matter (PM2.5). 

There  are  emission  reduction  commitments  (ERCs)  to  be  achieved  by  2020  and  maintained 
until 2029, and another set of stricter commitments to be achieved by 2030 and beyond. 

This evaluation takes stock of the progress made so far and assesses whether additional efforts 
or  policies  may  be  needed  to    deliver  the  key  emission  reduction  objectives  in  2030.  The 
evaluation also addresses opportunities for cost reduction and simplification, in line with the 
Commission’s  simplification  agenda  and  commitment  to  improve  the  EU’s  sustainable 
competitiveness3.  To  this  end,  the  evaluation  informs  the  Commission’s  agenda  on  clean, 
competitive and socially fair prosperity by providing relevant insights for the implementation 
of key political initiatives, such as the  Clean Industrial Deal, the Vision for Agriculture  and 
Food, the Water Resilience Strategy and the European Ocean Pact, as well as the upcoming 
Bioeconomy Strategy.  

An external study and several public consultation activities supported the evaluation. Member 
State reporting was an important data source and included emission inventories (yearly accounts 
of the emission of air pollutants per source in a Member State), projections (expected trend of 
emissions  considering  policies  and  measures  taken  or  planned,  based  on  modelled  data), 
national  air  pollution  control  programmes  (NAPCPs,  which  provide  a  description  of  the 
Member States’ approaches to reducing pollution) and related policies and measures (PaMs). 
Member States generate these data on the basis of well-established methods developed under 
the Air Convention. 

1   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.  

2   The Ambient Air Quality Directive(s) (AAQD) sets air quality standards as regards concentration levels of 12 

pollutants in ambient air.  

3   Political Guidelines for the next European Commission 2024-2029 

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A  limitation  of  this  evaluation  and  underlying  modelling  is  the  difficulty  of  separating  the 
effects of the NECD from other related policies affecting air pollutants. Furthermore, certain 
obligations have been in place only since 2020. Necessary lags in data reporting mean that the 
evaluation had a limited time span to work with (inventory data being available up to 2023). 
The GAINS model was used to cover data gaps (2024-25) and to understand the effects and 
costs in future years of emission abatement measures already taken by Member States.  

2.  Main findings 

Effectiveness 

The NECD, alongside other EU policies affecting air quality, has been largely successful 
in  reducing  emissions  of  the  five  main  air  pollutants:  emissions  of  all  pollutants  have 
followed a downward trend in the EU since the 2005 reference year while GDP increased 
over the same period4. Out of the 135 ERCs (5 per Member State) that applied from 2020, 
Member States had attained 116 in 2020 and 126 in 2023 (the last year for which emission 
inventories are available). 

The results show variations between Member States. Based on 2023 data, 19 Member States 
met their 2020-29 ERCs for all 5 air pollutants, 7 Member States did so for 4 pollutants and 1 
Member  State  complied  with  3  of  its  ERCs.  Most  non-compliances  related  to  NH3,  with  5 
Member States failing to comply with their commitments for the 2020-29 period. 

Lessons learnt on complying with NH3 ERCs 

Over  90%  of  NH3  emissions  stem  from  the  agricultural  sector  (mainly  from  livestock  farming  and  use  of 
fertilisers). Based on reviews of Member State action and stakeholder input, obstacles to reducing emissions 
include a more limited use by Member States of eco-schemes and agri-environment-climate commitments to 
address  livestock  related  issues  under  the  common  agricultural  policy  (CAP);  the  voluntary  nature  of  CAP 
interventions that rely on farmers’ willingness to adopt the practices; and that interventions addressing NH3 can 
be  difficult  and  expensive  to  implement,  particularly  for  small  farms.  According  to  Eurostat,  small  farms 
account for 64% of all farms in the EU. This means that the sector is characterised by many small emission 
sources, which may slow down progress in reducing NH3 emissions. This calls for improving the availability 
and take-up of funding, encouraging Member State action in this area, and maintaining and – where possible – 
increasing consistency between the NECD and related instruments (in particular the CAP, the Nitrates Directive 
and the revised Industrial Emissions Directive (IED). 

Most Member States have not yet taken sufficient action to be on a linear path towards meeting 
the 2030 reduction commitments:  only 8 Member States project to reach  indicative 2025 
levels for all pollutants, with NH3, NOx and PM2.5 representing the biggest challenges. 

The  current  reporting,  review  and  enforcement  system  drove  improvements  in 
compliance over the evaluation period: 14 Member States were found to be non-compliant 
for at least one pollutant in 2020 based on the 2022 inventories. This figure dropped to 8 in 
2023 based on the 2025 inventories, and this downward trend is expected to continue. 

Coherence 

The  evaluation  found  that  the  NECD  and  related  acts  (the  Commission  Implementing 
Decision on a common format for NAPCPs and the guidance on their development) are in most 
cases  internally  coherent.  There  is  some  lack  of  clarity  on  the  timing  of  adoption  and 
submission  of  NAPCPs,  in  particular  on  their  update,  leading  to  some  variation  in  Member 
State submissions. 

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EEA NECD briefing 2024 

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Coherence between the NECD and other relevant policies is generally good and has been 
strengthened  over time,  with  policies covering a wider range of  emission sources  (e.g. the 
IED) or through strengthened rules (e.g. energy efficiency targets, Euro emission standards for 
vehicles). The evaluation found the points of incoherence indicated below. 

—  The NECD ERCs only cover a subset of ozone precursors (namely NOx and NMVOC 
but not methane), meaning that the NECD cannot meet its full potential to help achieve 
the EU air quality standards for ozone set under the AAQD. 

—  Further  integration  between  planning  tools  under  the  NECD  and  climate  and  energy 
policies (namely national energy and climate plans – NECPs) could improve synergies 
and effectiveness. 

—  Under the Renewable Energy Directive (RED), biomass is seen as a contribution to the 
renewable energy target (subject to the sustainability criteria, which, however, do not 
cover  pollutant  emissions),  even  if  the  use  of  biomass  in  small,  inefficient  heating 
appliances in households contributes to PM2.5 and NMVOC emissions. NECD policies 
and  measures  in  some  Member  States  (e.g.  information  about  correct  wood  burning, 
promoting the replacement of heating systems) and other EU policies (e.g. ecodesign 
for solid fuel local space heaters) are helping to address this issue.  

—  Given  the  challenge  of  meeting  NH3  ERCs,  and  as  livestock  farming  constitutes  a 
significant source of pollutant emissions, the revised IED provides that the Commission 
will assess the need for Union action to comprehensively address the emissions from 
rearing livestock, in particular cattle. 

Lessons learnt on further improving coherence 

Coherence issues lead to opportunities for simplification. Changing the frequency of reporting (e.g. to better 
synchronise NAPCP and NECP timelines and to build synergies with relevant upcoming plans under the Nature 
Restoration  Regulation)  would  require  amending  the  NECD,  and  the  consequences  of  some  simplification 
opportunities  improving  consistency  (e.g.  aligning  NECD  ecosystem  monitoring  with  the  Air  Convention’s 
international cooperative programmes) need further assessment. 

Ecodesign  and  energy  labelling  rules  for  solid  fuel  stoves  and  boilers,  and  energy  and  climate  policies 
accelerating  the  transition  to  renewable  and  low  pollution  heating  solutions,  can  help  address  air  pollutant 
emissions from inefficient solid biomass combustion for residential heating.  

Efficiency 

The  evaluation  could  not  isolate  the  effects  of  the  NECD  in  terms  of  abatement  costs5  and 
benefits  linked  to  emission  reductions.  Consequently,  findings  on  efficiency  encompass  the 
effects of all relevant policies, at both EU and national levels. This is due to the well-established 
consistency and synergy across EU policies. 

The  benefits  of  policies  affecting  air  quality  significantly  outweigh  their  costs,  with  a 
benefit-cost ratio of 4:1 or 13:1 (the difference between ratios is driven by the approach to 
valuing mortality effects)6. The ratio comprises information modelled in a comparable manner, 
including quantified benefits and the abatement cost.  

Emission reductions associated with additional air pollution control measures taken over the 
evaluation  period  have  an  estimated  benefit  of  EUR 372 billion  (value  of  life  year)  or 
EUR 1 180 billion (value of statistical life). These benefits stem from improvements in human 

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Investments and expenses related to adjusting activities to the requirements (e.g. businesses investing in technologies with 
lower emissions). 

6   Lower values were calculated using a value of life year (VOLY) approach. Higher values use the value of statistical life 
(VSL) approach. While VOLY expresses the value of a single additional life year, VSL considers the monetary value of 
a reduction in the risk of premature death. Standard best practice in clean air-policy assessments is to present both. 

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and environmental health, which have an impact on the economy, for example in the form of 
less working time lost to sickness and higher agricultural yields. 

The evaluation estimated that the total abatement cost associated with additional air pollution 
control measures linked to all policies (including the NECD) post 2015 is EUR 92 billion. A 
significant proportion of the cost was likely offset through EU and national funding. EU funding 
contributing directly or indirectly to improving air quality amounted to EUR 171.4 billion over 
the 2021-2025 period7.  

A representative annual administrative cost across all NECD reporting obligations amounts 
to  EUR 1 071 000  per  Member  State.  The  total  average  annual  cost  for  EU  bodies  (the 
Commission  and  the  European  Environmental  Agency  -  EEA)  is  EUR 1 960 000  (reported 
data). Yearly emission inventories represent the largest cost item for both Member States and 
the Commission – in the latter case, this concerns the review of inventories. Inventories are 
necessary to assess compliance with ERCs and with Gothenburg Protocol obligations and are 
the  basis  for  Member  State  decisions  on  additional  policies  and  measures.  Good-quality 
inventories  are  therefore  key  for  the  effectiveness  of  the  NECD.  Some  of  the  reporting 
obligations for Member States indirectly affect businesses  albeit to a very limited extent, as 
the  NECD  is  only  rarely  the  primary  or  sole  driver  for  collecting  information.  The  average 
administrative cost for businesses is low, at around EUR 100 000 per year per Member State. 
The analysis did not find that the administrative burden was passed on to SMEs. 

Lessons learnt on efficiency – opportunities for simplification and burden reduction 

Some of the simplification opportunities do not require amending the NECD. These include:  

—  simplifying and clarifying the NAPCP format, especially if Member States comply with their ERCs 

(indicative potential annual saving per Member State: EUR 7 000); 
— 
improving the user friendliness of the PaM tool (significant time saving, no quantification available); 
—  modifying  guidance  on  ecosystems  monitoring  to  focus  on  the  quality  and  comparability  of 
information and to consider potential alignment with the Air Convention’s international cooperative 
programmes on ecosystems (indicative potential annual saving per Member State: EUR 115 000); 
—  using  Earth  Observation  and  the  Copernicus  Atmosphere  Monitoring  Service  to  simplify  the 
compilation  and  verification  of  inventories,  by  further  developing  them  through  research  (no 
quantification of potential savings available). 

Other simplification opportunities require an amendment to the NECD, e.g. better aligning the timing of NAPCP 
and NECP development (indicative potential annual saving per Member State: EUR 3 400). 

Since some simplification opportunities (i.e. modifying the contents of inventories) would lead to inconsistency 
with the Air Convention, this evaluation does not recommend taking this route, unless related requirements are 
modified under the Air Convention during the ongoing review of its Gothenburg Protocol. 

There is a possibility of linking  PaMs with NECD or other EU policies  via the PaM  tool which could help 
estimate the effects of the NECD-in the future. This step would not lead to an additional administrative burden 
for Member States. 

Relevance 

The needs addressed by the NECD have developed further over the evaluation period. The zero 
pollution action plan introduced two air pollution-related targets to be met by 2030 and the 2024 
revision of the AAQD introduced more stringent air quality standards. The AAQD revision was 
informed  by  scientific  evidence,  as  summarised  in  the  2021  World  Health  Organisation  air 
quality guidelines, which confirm that for several air pollutants adverse health impacts occur at 
concentration levels below those stated in previous versions of the guidelines. Therefore there 
is still a very strong case for having a NECD that helps to keep national emissions in check 

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See clean air funding tracking 

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to  achieve  cleaner  air  in  all  EU  Member  States  and  that  addresses  transboundary 
pollution,  bringing  a  system-level  view  that  considers  the  combined  effect  of  emission 
sources. 

The evaluation showed that, to date, the current ambition level of the ERCs is insufficient to 
meet  the  2030  zero-pollution  target  for  ecosystems  or  to  meet  the  EU’s  revised  and  more 
stringent air quality limit values for PM2.5.  

The coverage of pollutants and sources of pollutants remains relevant. Agricultural measures 
set  out  in  Part  2  of  Annex  III  to  the  Directive  are  still  deemed  to  be  effective  for  abating 
ammonia emissions and are in line with current UNECE guidance on ammonia. 

Lessons learnt on the relevance of the NECD’s scope  

Further considerations on methane (a precursor to ozone) might be warranted, considering the ongoing revision 
of the Air Convention’s Gothenburg Protocol. The evaluation also suggests that excluding certain aviation and 
shipping emissions from the ERC compliance checks should be kept under review. This holds true for shipping 
in particular, given its growing relative contribution to ambient concentrations of air pollutants in port cities 
and near coasts in light of the source-to-sea nexus. Excluding certain agricultural sources of NOx and NMVOC 
emissions from compliance checks appears to have lost its relevance, given our  improved understanding of 
these emission sources and the mitigating measures in place to address them. 

EU added value 

The transboundary nature of air pollution requires action and cooperation at global, European, 
regional, national and local levels. Neither national legislation nor national jurisdiction alone 
can be effective against pollution originating in another country. The Air Convention, although 
triggering  action  beyond  the  EU,  is  less  effective  than  the  NECD,  as  it  lacks  the  strong 
enforcement mechanisms available under EU law.  

National ERCs are set for each Member State following a staged approach while leaving the 
Member  States  a  substantial  margin  to  decide  how  to  best  achieve  ERCs,  in  line  with  the 
principles of subsidiarity and proportionality. 

Lessons learnt on EU added value 

The NECD has brought significant benefits to the EU population by contributing to cleaner air in Europe and 
by  reducing  the  negative  impacts  of  air  pollution  on  human  health  and  ecosystems.  Fully  and  efficiently 
exploiting the potential of the NECD would further reinforce its added value. 

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