The new European Commission headed by Ursula von der Leyen was appointed in December 2019 with bold and ambitious plans to address climate change and cross-cutting environmental issues that contrasted sharply with the Juncker Commission. Yet, within a few months of the publication of its environmental agenda, the COVID-19 pandemic profoundly changed the political and economic context, leading the Commission to re-frame its environmental agenda in the proposed recovery plan in May 2020. The far-reaching language of the Political Guidelines concerning the European Green Deal (EGD) as the EU’s environmental agenda demonstrates the extent of the Commission’s ambition. The Commission President described the EGD as ‘Europe’s hallmark’ and ‘man on the Moon moment’, which should lead the EU in becoming the ‘first climate-neutral continent’ by 2050 (European Commission Press Release (2019) and Political Guidelines 2019). Likewise, the EU regards itself as a global leader in the climate change response and a vanguard in increasing the ambition of other countries to combat climate change and promote sustainable development. The EU also aims to become a frontrunner in clean technologies, research and innovation. Finally, it is a new growth strategy that should ‘transform the EU into a fair and prosperous society, with a modern resource-efficient and competitive economy’ (EGD 2019, p. 2).

This ambitious agenda diverges from the preceding Juncker Commission’s political agenda which failed to include a specific political priority regarding the protection of the environment or climate change. Instead, environmental issues had been addressed in the context of creating new jobs and boosting growth and investment. By contrast, the Political Guidelines for 2019–2024 unveil the EGD as the Commission’s environmental agenda separate from its economic priority ‘An Economy that Works for People’ (Political Guidelines 2019). However, the EGD still represents an important vehicle for economic growth to be delivered through a set of ‘deeply transformative policies’ (EGD 2019), which poses questions about the EU’s ability to balance economic prosperity while addressing environmental issues and delivering social justice. The EU plans to achieve economic growth by encouraging business and industry to build a clean and circular economy. This requires a well thought-through approach to all aspects of the circular economy model that lies at the heart of the EGD and ensuring that this model is well tuned to address the full range of environmental objectives and consequences of economic growth. As the circular economy model promotes the extended life cycle of a product, including its recovery, recycling and reuse, the EU’s ‘sustainable products’ policy advocated by the EGD forms an integral part of it. For example, a policy to recycle or reuse products will require an equally ambitious EU chemical strategy in order to avoid the presence of harmful chemicals in products.

Likewise, the EGD is predominantly focused on climate change while the Commission views other environmental issues primarily as climate change related. As stated in the EGD, it is ‘the Commission’s commitment to tackle climate change and environmental related challenges’ (EGD 2019, p. 2). It is not surprising that climate change features as the main focus of the EGD. Its language makes it clear that the need to address climate change was a response to public pressure, in particular from younger generations, as demonstrated by the school climate strikes inspired by Greta Thunberg in 2019. This sense of urgency is evident in the Political Guidelines where the Commission made a pledge to act quickly to address several urgent climate change issues within its first 100 days in office. The Commission’s proposed European Climate Law, presented in early March 2020, prescribes net zero greenhouse gas emissions by 2050 as a legally binding target (COM(2020) 80 final). All member states with the exception of Poland agreed to this target. The Commission also plans to review the EU’s GHG emission target for 2030 by increasing it in a responsible way to ‘at least 50% and towards 55% compared with 1990 levels’ (COM(2020) 80 final).

However, the proposal does not provide sufficient clarity as to how these targets will be achieved as it only makes reference to ‘a trajectory for achieving climate neutrality’ (COM(2020) 80 final) rather than setting out specific targets from 2030 with the aim of reaching the 2050 target. A good model to follow is set out in the 2008 UK Climate Act which prescribes a carbon budget approach whereby the Government has a duty to set an emission target every five years for each budgetary period (s.4). A similar approach might involve setting EU carbon budgets rather than relying on member states’ obligation to produce national energy and climate plans (NECPs). The Commission also plans to extend the scope of the Emission Trading Scheme to the maritime sector, traffic and construction, as well as reducing free emission allowances allocated to airlines and introducing a carbon border tax (Political Guidelines 2019). The COVID-19 situation has changed the context of those plans, and there have been calls for carbon price floors in response to the falling price of fossil fuels.

Some environmental issues raised in the EGD are not necessarily related to climate change but are often the outcome of EU and nationally-driven economic policies such as air or water pollution. Addressing them within the context of climate change may create an impression that they are secondary to climate change. Nonetheless, the Commission is equally ambitious with regard to these environmental problems: the Commission’s ‘zero pollution ambition for a toxic-free environment’ (EGD 2019) will be critical for the preservation of water, soil and air quality. However, a zero pollution target seems an extraordinarily ambitious and potentially unattainable objective, which questions the feasibility of this policy. Likewise, the Farm to Fork policy that should result in a ‘fair, healthy and environmentally-friendly food system’ (EGD 2019, p. 11) addresses climate change impacts on both food security and sustainability, as well as pollution from food production. However, the feasibility of effectively delivering this policy may be in question, as the EGD acknowledges that Common Agricultural Policy (CAP) reform will be delayed until the beginning of 2022. CAP is a key dependency in promoting sustainable and ecological agriculture by incentivising farmers to adopt more sustainable practices. Moreover, reform of CAP is closely linked to the Commission’s proposal ‘to reduce significantly the use and risk of chemical pesticides, as well as fertilizers and antibiotics’ in the Farm to Fork Strategy (EGD 2019, p. 12). A good illustration is the regulation of pesticide use as one method of promoting sustainable practices which, to be fully realised, required an ambitious EU-wide pesticide reduction target coupled with changes to CAP strategic plans. This policy is also related to the EU’s plans to restore biodiversity. There were concerns that due to COVID-19, the Commission’s review of its 2020 Work Programme would lead to delays in publishing the Farm to Fork Strategy and affect the setting of new pesticide targets but the Commission published the Strategy in May 2020 setting out its plans for a 50% overall reduction in the use of both chemical pesticides and more hazardous pesticides by 2030.

In order to deliver on these bold promises, the new Commission President established a new organisational structure. Von der Leyen wants to create a strong Commission that ‘will walk the talk’ and ‘focus on task and not hierarchies’ (European Commission Press Release 2019). The new Commission clearly intends to distance itself from the Juncker Commission’s approach of focusing on ‘bigger issues’ and avoiding the regulation of ‘smaller issues’ that did not add value. However, the new organisational structure still follows the top-down approach introduced by Juncker with some minor changes. Political priorities are fixed by the President and entrusted to eight Vice-Presidents who will ‘steer and coordinate each of the Commission’s priorities’ (Working Methods, p. 7). This is to be achieved via six Commissioners’ Groups aligned with six priorities for the new Commission, largely mirroring the projects teams established by the Juncker Commission. The EGD group is chaired by the Executive Vice-President for the EGD and brings together the Commissioners for: Agriculture; Health and Food Safety; Environment, Oceans and Fisheries; Energy; Transport; and Cohesion and Reforms (Commission Decision 2019). In practice, this means that Commissioners entrusted with the environmental portfolio or any cross-cutting issues will have to liaise with the Executive Vice-President for EGD before putting an initiative to the College of Commissioners. As was the case with the Juncker Commission, this top-down approach based on fixed political objectives may diminish the scope for individual initiative by each Commissioner and the creativity of the Directorates General proposing new policies and legislation to Commissioners. There is a trade-off between greater coherence and political direction and the creativity of Commission officials.

Von der Leyen also made significant changes to the allocation of portfolios relevant for addressing environmental issues. This was important because here Juncker had been criticised, especially for merging the climate change portfolio with energy. Von der Leyen entrusted the environmental portfolio to Virginijus Sinkevičius, the Commissioner for Environment, Oceans and Fisheries. After prompting from the European Parliament, the inclusion of ‘oceans’ in the portfolio title signals the importance given to this issue and it is aligned with the EU’s commitment to a sustainable ‘blue economy’ and ‘healthy and resilient seas and oceans’ (EGD 2019). She also created a separate Energy Commissioner in response to criticism that Juncker faced and the need to address energy issues separately from climate. Another organisational novelty is the introduction of dual roles entrusted to three out of eight Executive Vice-Presidents who, in addition to coordinating the work of respective Commissioners’ Groups, also manage particular policy areas. With regard to environmental issues, Commissioner Timmermans is responsible for the EGD and is also entrusted with the climate change portfolio. This may seem logical as the EGD is primarily focused on climate change and cross-related issues, so this institutional arrangement should bring greater coherence and ownership in delivering this goal. However, the delivery of these objectives will greatly depend on the capability of individual Commissioners to manage these vast portfolios.

In order to boost its environmental credentials and demonstrate its commitment to delivering the EGD, the Commission wants to become a role model for other institutions. It will be a ‘Green Commission’ dedicated to reducing its own environmental impacts as an EU institution. This aim will be executed through the Environmental Management System (EMAS) and the implementation of circular economy principles in green public procurement (The Working Methods 2019). The Commission is also keen to contribute to the EGD by preparing its own Action Plan for implementing the EGD objectives and becoming climate neutral by 2030 (EGD 2019). More importantly, sustainable development is central to the Commission’s policymaking. Mission letters sent to each Commissioner recognise their responsibility to deliver the United Nations Sustainable Development Goals (UNSDG) within their own portfolios. Equally, the EGD forms an integral part of the Commission’s efforts to implement UNSDGs (EGD 2019). To that end, all EU actions and policies feed into the delivery of the EGD and have to be aligned with the Commission’s green oath to ‘do no harm’. This is significant as there was criticism of lack of recognition of sustainable development and the principle of integration in the Juncker Commission’s initial mission statements, which were subsequently changed under pressure from Green 10 and other environmental NGOs.

Finally, the implementation of this ambitious Programme requires a significant investment that will need to come from the EU budget, public and private funds but also from substantive ‘greening’ of national budgets. To that effect, the Commission plans to deploy €1 trillion in sustainable investments within the Sustainable Europe Investment Plan over the next decade. The Just Transition Mechanism forms an integral part of this Plan, aiming to include regions and sectors that are most affected by the green transition. This Fund was strongly supported by some of the carbon intensive economies in Central and Eastern European countries who opposed the 2050 target without the establishment of appropriate financial mechanisms to allow countries’ smooth transition.

At the start of the COVID-19 pandemic, there were concerns that environmental protection would be secondary to economic recovery. However, from the outset, there was a strong political message from EU institutions that any post COVID-19 economic recovery package would have an environmental focus. Moreover, there is a sentiment within the Commission that the post 2008 financial crisis stimulus was a missed opportunity to embed environmental objectives, which should not be repeated. Several major European companies are also pushing for EGD and their preferences were clearly articulated at the 2020 Petersburg Climate Dialogue. This culminated in the Commission’s recovery plan and adjusted work programme which was unveiled at the end of May 2020. As part of support to member states to recover from the crisis in a way that is environmentally sustainable, the Commission is proposing various budgetary measures, including strengthening the Just Transition Fund to €40 billion. While some member states, particularly high carbon economies such as Poland, were not initially enthusiastic, the proposal has broad support in principle from member states including, crucially, France and Germany. The biggest obstacle to its implementation will not be a lack of focus on environmental issues but difficult negotiations on budgets and the terms and process of allocating recovery funds. These questions will need to be resolved before the recovery plan is approved by the European Council. Despite this initial impetus, the scope and ambition of the EGD will be tested by the new political and economic circumstances generated by the pandemic.