Photo: ©Roman Samborskyi/

Opportunity to address gaps in the NEC directive

By: Ebba Malmqvist

The EU NEC Directive sets national targets to reduce emissions of five key pollutants. Article 13 of the directive mandates a review before the end of 2025.

The EU National Emission Reduction Commitments (NEC) Directive sets national commitments to reduce emissions of five pollutants that have significant negative impacts on human health and the environment, namely NOx, NMVOCs, NH3, SO2 and PM2.5. It is one of the legislative instruments supporting the zero-pollution ambition to achieve a toxin-free environment, as announced in the European Green Deal.
The NEC directive is particularly critical to delivering on the 2030 targets related to air pollution under the Zero-Pollution Action Plan (ZPAP) to reduce the number of premature deaths caused by air pollution by 55% and to reduce the area of EU ecosystems where air pollution threatens biodiversity by 25%, in both cases compared to 2005 levels. Article 13 in the NEC directive requires a review of the directive before end of 2025, and in Spring 2024 the European commission sent out a call for evidence. In this article we will give some input from an AirClim perspective.

In its current form the NEC Directive will most likely fail to deliver on the ZPAP and other commitments. The NEC Directive will only deliver sufficient benefits if it sets targets that are ambitious enough and establishes effective mechanisms for achieving them. We believe the NEC Directive’s goal should at least be aligned with the EU’s air quality objectives set in the Zero Pollution Action Plan. One example is that the current NEC directive does not include methane, an important ozone precursor, which is a major shortcoming and has hampered methane emission reductions. Ground-level ozone is a known pulmonary irritant that affects the respiratory mucous membranes, other lung tissues, and respiratory function. Exposure to elevated concentrations of ozone is associated with increased hospital admissions for pneumonia, chronic obstructive pulmonary disease, asthma, allergic rhinitis, and other respiratory diseases, and with premature mortality (Ebi and McGregor 2009). Ground-level ozone also damages agricultural crops and reduces yields. The economic costs of inaction are high and in 2019, the economic losses due to the impacts of ground-level ozone on wheat yields totalled EUR 1,418 billion across 35 European countries (ETC/ATNI, 2021). Wheat yield losses were highest in France, reaching EUR 350 million, followed by EUR 280 million in Germany, EUR 140 million in Poland and EUR 130 million in Türkiye. In fact, most countries faced losses of several million euros. The health costs are even greater. Today the NEC directive addresses nitrogen oxides and VOCs but does not address the important ozone precursor – methane. Without the addition of methane, ozone targets will be hard to reach. So, this will not be a challenge where farmers are united as it will be a battle of wheat against meat.

Excess nitrogen from air pollution (NOx and NH3), is still a serious threat to ecosystems in Europe. This is evident from a status report by the Coordination Centre for Effects (CCE) that was published in 2022. It is noted that critical loads for eutrophication were exceeded in 61 per cent of all ecosystem areas. Most affected are regions with intensive livestock rearing (CCE, 2022). This problem has also been shown in a recent EEA report of the air quality in Europe 2022, which presents a fall of only 12% since 2005. The Zero-Pollution Action Plan has set a 2030 target of a 25% reduction from 2005 levels, so this shows that the NEC directive has not been efficient enough in contributing to this target (EEA, 2022).

In Europe, fine particulate matter air pollution (PM2.5) caused 412,000 premature deaths in 2020, and of these 238,000 were at the levels above WHO 2021 air quality guidelines for PM2.5 of 5 µg/m3 (EEA, 2022). Furthermore, there are millions of air pollution-related new cases of asthma, COPD, acute respiratory infections, lung cancer, stroke, myocardial infarction, hypertension, diabetes, dementia, and other mental health disorders, as well as aggravations of these diseases in already ill persons each year. Reduced air pollution would give the freedom back to chronic lung patients (asthmatic children and adults, chronic obstructive lung disease patients and lung cancer patients), for whom air pollution in cities exacerbates their diseases and presents a barrier to being outdoors and moving freely. The NEC targets have not managed to halve the numbers of premature mortality in line with the ZPAP. Inclusion of important heavy metals such as mercury in the NEC would also be highly beneficial for health and ecosystems.

Coordination Centre for Effects (CCE), 2022, CCE Status Report 2022,
European Environmental Agency (EEA). 2022. Report no. 05/2022. Air quality in Europe 2022.
ETC/ATNI Report 17/2021: Wheat yield loss in 2019 in Europe due to ozone exposure

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