EC Energy Union Summer Package: A weak Effort Sharing Regulation Proposal & the healthcare sector

On July 20th, the European Commission released its proposal for the Effort Sharing Directive (ESD) for the period 2021–2030. The proposal was released as part of the Commission’s Energy Union summer package, which also includes a proposal for addressing greenhouse gas (GHG) emissions from the Land Use, Land Use Change, & Forestry (LULUCF) sector, and a Communication on the decarbonisation of transport.

The ESD has become the Effort Sharing Regulation (ESR). The ESR covers emissions from sectors not covered by the EU-Emissions Trading System (EU ETS), including: buildings, transport, waste management, and agriculture. In 2014, these sectors made up nearly 60% of total EU emissions.1

The ESR covers emissions from many sectors that contribute to the overall emissions of the health sector. The regulation will affect activities related to healthcare, such as: building’s energy efficiency, transportation, agriculture, and waste practices, and will influence national polices which will, in turn, determine the ‘greenness’ of policies implemented in the health systems across Europe.

Weak Effort Sharing Regulation Proposal

The 2030 Climate & Energy Framework sets an economy-wide domestic GHG emissions reduction target of at least 40% by 2030 compared to 1990. Working towards this end, the ESR proposal sets emission reduction targets of 30% compared to 2005, and ETS sectors by 43%.

Image: Eric Schmuttenmaer via Flickr CC

In the ESR proposal the Commission set targets for each Member State, which, when combined, must make up the 30% emissions reduction target of the ESR sectors. Environmental groups are widely dissatisfied with the ambition of the ESR target, and are calling for a higher target of at least 45% in order for the EU to comply with the Paris Agreement’s objective of limiting warming to well below 2ºC.2 However, this dissatisfaction is not only due to the low ambition of the target, but also to the presence of many loopholes and flexibilities for member states, which greatly undermine the regulation’s capacity to reach this weak target.

Through a combination of the many loopholes, the proposed regulation can actually lead to a surplus of emissions in the ESR sectors, and many countries operating under the directive will be able to actually increase their emissions from present levels.

Carbon Market Watch has identified the different loopholes of the Effort Sharing Regulation, and calculated the obstacles that these flexibilities will create for the EU to meet its climate targets. Find out more about these consequences on their website here.

The healthcare sector & ESR

While implementing ambitious national climate policies across all member states is undeniably complex due to the vastness of socio-political and economic differences, what remains constant across every nation is the health sector’s responsibility to “do no harm”.  

This is a moral obligation of the healthcare sector. As a sector whose emissions’ are widely covered by the ESR, health systems have the opportunity to lead the way towards raising the ambition of this policy instrument and influencing ESR sectors to meet their targets. 

HCWH Europe calls on the European health sector to get ahead of the policy process, raise its own climate ambition, and reduce its carbon footprint by adopting renewable and energy efficient buildings and transportation systems, implementing sustainable waste management schemes, and developing green procurement policies for all its goods and services.


Read more

  • Click here to access all of the documents relating to this proposal from the European Commission.
  • Read more about EU Member States 2030 Climate Targets on CAN Europe’s analysis “No cheating from the start” 
  • Read the joint letter to President Juncker on LULUCF & Starting Point in the non-ETS sectors here
  • Read more on Climate, Energy & Green Building in the European Healthcare Sector here
  • Read more on Sustainable Procurement in the European Healthcare here
  • Read more on Sustainable Food in the European Healthcare Sector here
  • Read more on Waste Management the European Healthcare Sector here