A Commission Staff Working Document (SWD) published on 23 July 2026 evaluates Germany's implementation of the EU Nitrates Directive (91/676/EEC) for the period 2020-2023, finding that 25.3% of groundwater monitoring points exceed the 50 mg/l nitrate limit and that eutrophication persists in coastal waters. The document provides recommendations to reinforce measures in high-concern zones and align the action programme with Water Framework Directive deadlines.
The SWD covers Germany's whole-territory approach, which has applied mandatory measures since 1994, and assesses the amended action programme (Düngeverordnung) introduced in 2020. Key changes include stricter fertiliser application rules near watercourses, adjusted closed periods, and enhanced record-keeping. Germany designates nitrate-polluted 'red zones' and phosphorus-polluted 'yellow zones' with additional restrictions. The document notes that an infringement case against Germany was closed in June 2023 after the country designated high-concern zones.
26.6% of monitoring points are classified as hotspots (≥50 mg/l or 37.5-49.99 mg/l with increasing trend). Regional disparities are significant, with the highest hotspot percentages in Rheinhessen-Pfalz (62.5%), Düsseldorf (57.1%), and Trier and Bremen (50.0%). Surface water shows no exceedance of the 50 mg/l nitrate limit, but 76.4% of stations are eutrophic or could become eutrophic, a slight decrease from 76.6%. Coastal and marine waters are 100% eutrophic.
Controls during 2019-2022 covered about 3.6% of farms, with non-compliance found in 20.7% of inspected farms. The SWD recommends reinforcing measures for areas with high or increasing nitrate concentrations, considering phosphorus limitations, improving inter-sectoral cooperation, and promoting best practices and innovation. The document is based on Germany's reports submitted via Reportnet 3 for the 2020-2023 period.
German farmers face continued regulatory pressure, especially in red zones with stricter fertilisation rules. National authorities must implement the recommendations, potentially requiring further amendments to the Düngeverordnung. Environmental groups may view the findings as insufficient progress, while water utilities benefit from ongoing efforts to reduce nitrate pollution. The European Commission will monitor follow-up actions, and further legal steps could arise if improvements are not sustained.