Client:
European Commission (DG ENV)
Focus:
This summative study explored the environmental, human health, societal and economic benefits foregone where EU environmental legislation is not implemented as planned, and targets are not met across the EU-27 Member States.
The implementation gap was based on the last historic year for which data around the state of the environment was available, and covered eight policy areas: air, noise, nature and biodiversity, water, circular economy and waste, chemicals, industrial emissions and major accident hazards, and horizontal instruments.
Purpose of Project:
The effectiveness of EU environmental legislation is largely determined by its implementation at national, regional, and local levels. Environmental legislation, when implemented and enforced, will deliver improvements for environmental health, human health, and society and the economy more broadly. Where relevant legislation is not implemented as planned and targets are not met, such benefits are foregone. Across several areas of environmental law, there is deficient application and enforcement of related EU environmental policy and targets are not being met, as illustrated by over 300 infringement cases across the EU and, in some cases, worsening environmental trends as stated by the European Commission in 2025.
The purpose of this study was to estimate the costs (or foregone benefits) of the lack of implementation of EU environmental law in the EU-27 Member States. This presented an update to estimates made in previous studies (published in 2019 and 2011), whilst capturing updates and improvements in the scope and methodology, reflecting underlying progress in available evidence and changes in EU law.
What we have delivered:
Analysis for each of the eight environmental policy areas followed a similar, overarching structure:
- Review of relevant EU environmental policies and legislation, including the most recent developments;
- Identify the targets set by these sectoral Directives and regulations (and or by linked strategies or communications);
- Assess the implementation gap, defined as the difference between the target and the actual environmental state using the most recent data available;
- Estimate of the cost of the implementation gap, by valuing the impact on human and environmental health due to the unmet targets ;
- Depict a forward look assessment, outlining how the implementation gap may evolve to 2030.
Although the eight policy areas were assessed separately, there are key interactions between them in terms of the environmental outcomes that might arise as a result. For example, action on industrial emissions inherently contributes to the achievement of air pollutant concentration targets. To produce a total gap cost across all policy areas the study has carefully considered and accounted for potential overlaps in a cross-cutting assessment.
The work has now been published and referenced within the European 4th Environmental Implementation Review.
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