Update of the costs of not implementing EU environmental law

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. This study has estimated the costs (foregone benefits) of the lack of implementation of EU environmental law in the EU-27 Member States, building on two preceding European Commission studies (COWI et al. (2019), and COWI et al. (2011)). The 'implementation gap' is defined as the difference between actual environmental status (based on the last historical year for which data is available) and the respective environmental target(s). The last historical year for which data is available varies depending on the policy area and specific target, but ranges from 2018 to modelled data for 2025. The implementation gap in this study covers eight environmental policy areas: air, noise, nature and biodiversity, water, waste, chemicals, industrial emissions and major accident hazards, and horizontal instruments. Climate and other policy areas were not included in the scope of this study. Furthermore, this study did not aim to ascertain why there is an implementation gap (e.g., lack of governance) because this is the role of individual policy evaluations and other reviews, such as the Environmental Implementation Review (EIR)1 . Instead, the focus of this study was to assess the size of the implementation gap and its effect in terms of actual costs to society. The implementation gap was assessed quantitatively for all policy areas, except for chemicals and horizontal instruments where qualitative analysis was undertaken due to the nature of the targets set in those policy areas.