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Logika Group Leads Support Study for the European Commission’s Evaluation of the NEC Directive

04-12-2025

Logika Group is proud to have led the support study for the European Commission’s evaluation of the National Emissions reduction Commitments (NEC) Directive (2016/2284).

Logika Group is proud to have led the support study for the European Commission’s evaluation of the National Emissions reduction Commitments (NEC) Directive (2016/2284). The work was commissioned by DG Environment and delivered in collaboration with our project partners: RPA Europe, Aether, IIASA, Mike Holland and AERU. 

Two detailed reports have now been published by the Commission’s Publications Office as part of the evaluation package. Study supporting the evaluation of Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants (NEC Directive) - Publications Office of the EU and Study supporting the evaluation of Directive (EU) 2016/2284 on the reduction of national emissions of certain atmospheric pollutants (NEC Directive) - Publications Office of the EU.

The evaluation was a major topic at this week's Fifth EU Clean Air Forum (1–2 December 2025), where the NEC Directive and the future of Europe’s wider clean air ambitions were a central focus of discussions. 

The NEC Directive is one of the EU’s key legal frameworks for controlling air pollution. It aims to reduce national emissions of: 

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

The Directive came into force on 31 December 2016, replacing Directive 2001/81/EC. It introduced: 

  • Emission Reduction Commitments (ERCs) expressed as percentage reductions against a 2005 baseline 
  • Targets for 2020–2029, and more ambitious reductions for 2030 onward 
  • Updated obligations for Member States, including national air pollution control programmes and monitoring requirements 

The study directly supported the Commission in assessing whether the Directive is functioning as intended. 

Our work included: 

  •  Comparing the benefits and costs of the Directive: We assessed how the health and environmental benefits of reduced air pollution compare with the costs of implementation across Member States. 
  •  Identifying opportunities for simplification and reduced administrative burden: Particularly relating to: 

- Ecosystem monitoring and reporting 

- National Air Pollution Control Programmes (NAPCPs) 

- Alignment with reporting under the UNECE Air Convention 

  • Reviewing coverage of key emission sources: Including assessing whether sectors currently outside the scope — manure management, agricultural soils, aviation and maritime — should be considered for inclusion. 
  • Assessing the implementation of emission-reduction measures in agriculture: We explored both mandatory and optional measures and examined why voluntary measures have shown significantly lower uptake.
  • Conducting wide-ranging stakeholder consultation: Capturing perspectives from Member State authorities, industry, NGOs, academics and other expert organisations. 

Key Findings from the Evaluation 

 1. Administrative burdens can be reduced:

The Directive contains several obligations that create workload for Member State authorities. The study identified several potential simplification options which could deliver savings. 

2. Benefits consistently outweigh costs:

The evidence base linking air pollution exposure to negative health impacts continues to grow. Our analysis found benefit-to-cost ratios ranging from 4:1 to 13:1 for the additional emissions controls implemented between 2016 and 2025. 

3. Agriculture remains critical to ammonia reduction:

With 93% of NH₃ emissions coming from agriculture: 

- Mandatory measures are widely implemented 

- Voluntary measures show low uptake — reasons remain unclear and may relate to cost, perceived effectiveness, or suitability 

4. Further debate is needed on sources currently excluded:

There is mixed evidence and stakeholder opinion on whether additional sectors should be brought into the Directive’s targets. 

A Robust Evidence Base for the EU’s Next Steps 

This evaluation provides the European Commission with the evidence it needs to reflect on the achievements and challenges faced of one of Europe’s most important air quality laws. 

Logika Group is pleased to have led this major evaluation study, bringing together deep technical expertise, rigorous analysis and wide stakeholder engagement to help shape the next phase of EU air pollution policy. 



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