HEAL response to public consultation on NEC Directive evaluation 

HEAL has given input to a consultation assessing the EU NEC Directive, a key instrument in the EU clean air framework, which requires member states to cut emissions of five key air pollutants. In our response, we urge for a stepping up of EU member states implementing the law, for greater coherence in the EU’s policy framework, and for strengthening health prevention efforts. Now is the time to set the EU on the path for ambitions emission reductions after 2030.   

Air pollution is the greatest environmental threat to health in the European Union and beyond. Everyone is vulnerable to the health impacts of air pollution, which causes hundreds of thousands of premature deaths and costs hundreds of billions of euros every year in the EU. As evidenced by the latest science, air pollution can be harmful even at “low” levels. 

The NEC Directive sets national reduction commitments for key air pollutants that have a significant negative impact on human health and the environment and requires EU member states to monitor and report on the emissions of these pollutants. These air pollutants are sulphur dioxide (SO2), nitrogen oxides (NOx), non-methane volatile organic compounds (NMVOC), ammonia (NH3) and fine particulate matter (PM2.5). 

The European Commission ran a public consultation  for the review of the NECD which closed on 26 November 2024. 

HEAL identifies major effectiveness, coherence and compliance gaps in the current NECD. These gaps should be urgently addressed to remedy several shortcomings in health prevention, close loopholes and tackle new pollution developments. We also consider it key to set the EU on the path for ambitious emission reductions after 2030, as part of the zero-pollution objective.  

HEAL has submitted a response to the public consultation highlighting that to increase health and economic benefits, it is key to:  

Step up on EU member states implementing the directive (which has major shortcomings):  

• Follow the latest scientific findings 

• Increase the level of ambition by accelerating the binding pace of emissions reduction, as well as strengthen enforcement  

This will result in greater effectiveness in protecting everyone’s health and set member states on track for compliance by 2030. 

Strive for greater coherence in the EU legal framework: 

• Ensure stronger linkages between the NECD and Ambient Air Quality Directive (AAQD), especially through aligning the calculation of annual national reduction obligations with attainment of AAQD limit and target values by 2030.  

This will result in the NECD becoming a key instrument to contribute to the success of the revised AAQD and cleaner air and prepare the EU’s clean air framework for the post 2030 period. 

Strengthen health prevention efforts to reduce emissions of key air pollutants and precursors: 

• Close the loopholes by including reduction obligations for methane (CH4) emission, ending subsidies of ammonia (NH3) emitting practices 

• Withdraw the labelling of biomass burning as renewable source of energy 

This will result in decreased concentrations of PM2.5, ozone and ammonia and reduce the corresponding health burden. 

Find the full response here