Implementing EU energy and climate governance: Germany and Sweden as frontrunners?

The EU has adopted important elements of the climate and energy framework for 2030. This policy landscape includes the Governance Regulation, adopted as part of the Clean Energy for All Europeans package (CEP) in 2018^1,2 Knodt et al. 2020). A core element in the Governance framework is the regular production of National Energy and Climate Plans (NECPs). The process is interactive, with dialog with the European Commission (hereafter: Commission) intended to lead to changed and improved plans.

The Governance Regulation emerged in the negotiations for the 2030-targets in 2014 when it became clear that there was no majority for binding national targets for renewable energy (RE) and energy efficiency (EE) among EU member-states³. The NECP process has been seen as a mechanism for ensuring that the EU achieves its overall targets for emissions reductions and RE, and also its non-binding EE target. The 2030 framework marks a shift from the 2020 framework, in that the latter included binding targets on both the national and European levels.

In the soft–hard governance typology put forward by Terpan⁴, the binding obligations represent ‘hard governance’, while the governance regulation, specifying national contributions for each member-state, is considered as a form of ‘soft governance’ in the EU.

The Governance Regulation does not specify national targets for renewable energy and energy efficiency. Instead, Article 4 requires that each Member State shall set out its contribution to the Union’s targets for renewable energy and energy efficiency in the NECP. For renewable energy, it states a formula for how ‘national contributions for the share of energy from renewable sources in gross final consumption of energy in 2030’ shall be calculated (Governance Regulation, Annex II). For energy efficiency, ‘Member States shall express their contribution in terms of absolute level of primary energy consumption and final energy consumption in 2020, and in terms of absolute level of primary energy consumption and final energy consumption in 2030, with an indicative trajectory for that contribution from 2021 onwards. They shall explain their underlying methodology and the conversion factors used’ (Governance Regulation, Article 4, b) (1). The Commission eventually assesses whether the national contributions for renewable energy and energy efficiency are sufficient to reach the Union’s 2030 targets. If deemed insufficient, it calls for the Member State to increase the ambition in their assessment of the NECP of the respective Member State.

However, the enforcement mechanisms for these contributions include a comprehensive framework based on regular communication and reporting to the Commission, which has been described as possible ‘harder soft governance’ (HSG)^2,5,6. The ‘harder’ elements are part of the enforcement process with the Commission as a third-party actor, and where key mechanisms involve the formal requirement to justify reaction/non-reaction to Commission recommendations, and ‘naming and shaming’, i.e. highlighting inadequate national follow-up⁷. Specifically, Articles 31 and 32 serve as ‘gap-fillers’: one addresses the ambition gap in case a member-state makes an insufficient contribution to achieving the European RE target, while the delivery gap filler aims to monitor whether the member-states provide their promised contributions in a timely manner – and what to do if this is not the case.

So far, little is known about the implementation and enforcement of this complex and new policy, which might even be called ‘experimental governance’⁸, but is rooted in several earlier EU policies such as monitoring mechanisms and the European Semester^6,9. Given this novelty and complexity, there is a need for in-depth case studies of NECP implementation¹⁰. We argue that basically inductive case studies of the first round of national policy implementation offer a good approach to narrowing this knowledge gap.

Hence, in this article we discuss NECP implementation in the first round of establishing NECPs 2017–2020 in two traditional climate-policy frontrunners in the EU: Germany and Sweden. Börzel (2002) considers six countries (Germany, the Netherlands, Denmark, Austria, Sweden, and Finland) as “pace-setters” within energy, climate and environmental policies; i.e. member states that are actively pushing EU policies at the European level. A recent study of NECP implementation using the Europeanisation framework by Börzel (2002) argues that Germany and Sweden belong to the group of countries characterised as “pace-setters” with regard to their energy and climate strategies (Maris & Flouris, 2021). Both countries belonged to the core group of more ambitious countries during the negotiations on the Governance Regulation³. Germany led the group of ‘more ambitious’ member states³, p. 145.

As the Governance framework is explicitly an interactive process where the plans are meant to be improved and changed during the implementation process, we ask: how and why did the national energy and climate plans change in our two focus-countries throughout the process? The study is based on qualitative interviews and document analysis of relevant publicly available documents and media articles.

A key finding is that these two climate frontrunners have not perceived the NECP process as particularly important for national policy-making. After some rounds with feedback from the Commission, both countries implemented their NECPs without much ado. The consultation process did not receive much attention, and the targets and measures preferred by the Commission were based on policies that had been under development independently of the Governance Regulation. However, in terms of actual policy-making, the process had greater implications for Sweden. Swedish actors generally expressed skepticism towards the entire framework, whereas Germany, which already governed its climate and energy policy through detailed plans and measures, strongly supported this governance approach.

Our findings largely support the framing of the EUs Governance regulation as ‘harder soft governance’, where the detailed NECP processes compensate for the lack of nationally binding targets for renewable energy and energy efficiency. Both Germany and Sweden developed NECPs very much in line with the preferences of the Commission, with national contributions sufficient to achieve the overall European targets. However, as noted, this was not primarily a result of the iterative process with the Commission, but was due to factors that include national policy ambitions and policy styles and procedures.

Process-tracing and qualitative interviews

A central methodological tool in this study is qualitative process-tracing analysis, with examination of academic books and articles, relevant government reports and communications, reports from think-tanks and NGOs, news articles from digital news services and newspapers, and interviews with selected stakeholders and analysts in our two case-countries (see list in the Annex 1). All interviews were conducted through a video conference tool (Microsoft teams or zoom) and sound recordings were made. However, it proved rather difficult to gain access to interviewees. The responsible (coordinating) ministry for the NECP process in Germany refused to grant permission for a formal, recorded interview. In both countries, very few NGOs/interest organisations were ‘ready to give interviews. According to the stakeholders with whom we spoke, this was because the topic was not a general priority.

We also conduct a ‘focused structured’ comparison between processes in Germany and in Sweden see¹¹, seeking to collect similar information for both countries and to compare them along the same dimensions. Ideally, more and differing countries should have been included in our sample. The implications of this point are further discussed in the Conclusion.

Analytical framework

First, we examine to what extent, and how, the NECPs in our two focused countries have been changed. The degree of change can be roughly measured by a comparison between the initial draft NECP and the finalized plan. We assess qualitatively what has been changed in the plans and whether this was in line with the instructions from the Commission. As noted, the Governance framework and the NECPs are to address five important dimensions of the Energy Union: decarbonization (greenhouse gas reduction and renewables); energy security; energy efficiency; internal energy market; and research, innovation and competitiveness. As we are primarily interested in the role of the NECP as a way of compensating for the lack of national targets, we focus on targets and policies for renewable energy and energy efficiency.

Second, we investigate the explanatory factors behind the changes and planning dynamics witnessed in our two countries. As this process is meant to be an iterative one, it makes sense to discuss factors likely to shape such EU-national interactions, keeping in mind that this can be seen as a case of ‘harder soft governance’ and not simply the standard national implementation of EU policy. Here we distinguish between factors that, on the one hand, indicate basic similarity in planning dynamics and changes made of NECPs in our two focused countries—and, on the other hand, factors that point towards differences in planning dynamics and NECP change.

Previous research categorises Germany and Sweden as traditional climate-policy frontrunners in the EU. Both countries also belonged to the core group of ‘more ambitious countries’ during the negotiations for the Governance Regulation³. Hence, we see previous climate policy positioning in the EU as a first factor inducing similarity as to NECP implementation: rather smooth implementation of the Governance framework and full commitment to indicative RE targets.

A second factor inducing similarity as to NECP implementation can be found at the EU level, where Commission NECP guidelines and deadlines are common for all EU countries. The procedure for providing feedback to national NECP drafts is also fundamentally similar, with all plans receiving 10 or 11 requests from the Commission for further clarification. Hence, we see the basically similar EU context as a second factor expected to induce similarity in NECP implementation.

However, there are also several factors that indicate differing NECP implementation. A first such factor is the size of the economy and the place of the country within the EU context. As highlighted by liberal intergovernmentalist theory, EU policies are often in line with the preferences of the strongest member-states^12,13. As the EU member-state with the largest population and the strongest economy, Germany is highly influential in EU policy processes. In comparison, Sweden is more of a small state in EU politics, and presumably has less room for ‘going alone’ against the preferences of the Commission. Thus, we would expect Germany to give less weight to Commission inputs for changing its NECP than Sweden and hence differing NECP implementation.

A second factor which can be expected to induce difference concerns the match or mismatch between EU policy and national policy-making styles. This approach has a long history in the field of EU studies (compare the overview in Treib¹⁴ pp. 9–10, with for instance the more recent contribution of Schmidt¹⁵). This literature highlights how the regulatory style and design of EU policy can clash with dominant policymaking styles in the member-states. Schmidt’s 2020 study highlights how the tradition of parliamentary sovereignty in the UK contrasts with the prevailing policymaking mode in the EU, and how this mismatch drove much of the politicization of UK EU-membership.

Although both Sweden and Germany were positive to developing an EU Governance framework, they differ in their traditions of governing national climate and energy policies. Sweden has pursued a strategy focused on cost-efficiency, with priority to economic policy instruments such as carbon taxes, the EU Emissions Trading Scheme (ETS) and RE certificate trading scheme for the electricity sector. This cost-efficiency approach also means that sectoral targets have been avoided, except for transport¹⁶.

By contrast, Germany has a long tradition of developing detailed policy plans, and has defined both an economy-wide and sectoral emissions targets for 2030, through the German Climate Act. In 2019, Germany adopted the ‘Climate Action Programme 2030’, which specifies the policies and measures needed to meet the sectoral targets. Overall, the Governance framework, obliging member-states to develop detailed sectoral plans and to include an associated impact assessment in the NECPs, resembles the German policy-style more than Sweden’s energy and climate policy. Thus, we expect smoother NECP implementation in Germany than Sweden, as the Governance framework matches the German policymaking style better than the Swedish one.

Germany: governance initiator with certain challenges

The German Government was very satisfied with the general approach and content of the Governance Regulation. Germany “strongly advocated this regulation”¹⁷, p. 16, authors translation and German policy officers were heavily involved in preparing the Commission’s legislation proposal³. Germany’s history of specifying detailed policies and measures for energy and climate policy align well with the NECP, which obliges all member-states to develop a detailed plan.

Within renewable energy, Germany has also pursued a detailed steering approach, with quantified targets and deployment pathways for various RE technologies by 2030¹⁸. Thus, Germany has pursued a policy style in line with the principles of ‘technology development’ rather than cost-efficiency¹⁹. According to one Swedish interviewee, the Governance Regulation was an example of typical ‘German governance style’ (Interview 4).

Two years before the Governance Regulation was finalized, Germany adopted a plan for sectoral emission reductions: the ‘Climate Action Plan 2050’²⁰. The plan set an overall emissions reduction target for Germany for 2030, as well as sectoral sub-targets for the main sectors: electricity generation, industry, transport, buildings and agriculture. With the German Climate Change Act, these targets became legally binding. The ‘Climate Action Plan 2050’ obliged the German Government to specify an instrument package to ensure that targets were achieved. This work started in spring 2017, coordinated by the Ministry for the Environment (BMU) (Interview 6).

During the entire process of drafting and adopting both the Climate Action Plan, the thereof resulting Climate Action Programme (adopted 2019) and the NECP, the German Government consisted of a coalition headed by Angela Merkel and the Christian Democratic Union (CDU/CSU), which governed together with the Social Democratic Party (SPD) (totaling two legislative periods, 2013-2021). SPD held the responsibility for the Ministry of Economic Affairs and Energy until 2018, after which they were replaced by CDU/CSU, whereas SPD was in charge of the Ministry for the Environment throughout both legislative periods. This provided a large degree of party-political stability during the period of drafting, revising and finalising the NECP.

Germany submitted its draft NECP on 20 December 2018, in good time before the deadline. The Ministry for Economic Affairs and Energy (BMWi) was in charge of coordinating the NECP process, but many other ministries and agencies were involved. The 143-pp. German draft NECP was structured in line with the Commission’s template. The draft NECP included the national strategies, targets and policies which had already been adopted at the time. Germany had set a 30% RE target as share of gross final energy consumption in 2030. In connection with the EE target, involving 30% reduction compared to 2008, it was noted that new targets were yet to be decided along with the revision of the Government’s energy-efficiency strategy.

During the process of developing the NECP, Germany adopted several new climate plans and acts which were included in the ‘Climate Action Programme 2030’; policymakers and stakeholders focused on these national policy processes. However, the Programme negotiations had not been finalized by the end of 2018, which was the deadline for submitting the draft NECP to the Commission. The draft plan therefore built on a long list of existing policy ‘packages’ and already-adopted legislation²¹, p. 20–25.

Several of these policies were already rather old and had become insufficient in light of the updated climate targets in the Climate Action Plan 2050. New legislation would have to be developed, with new instruments and strategies for renewables, coal phase-out, grid expansion and energy efficiency. Among the policies already in place for renewable energy and energy efficiency was the Renewable Energy Sources Act, which since 2000 had been the main instrument for expanding of renewable energies in the electricity sector. The Energy Efficiency Strategy for Buildings outlined the main targets and policies for the buildings sector.

As to energy security, the plan listed Germany’s various measures for maintaining and improving supply security for gas, petroleum and electricity. Moreover, the German Government did not use the term ‘energy poverty’ as a specific concept, but it followed a ‘comprehensive approach’ to combatting poverty and social inequalities.

Initially, the NECP process did not receive much attention among the German public. Representatives of the German Government and German stakeholders generally perceived the NECP process as less important than the ongoing national policymaking processes (Interview 6). In the draft, the German Government emphasized that the targets and climate action were nationally driven and that they would work to reach their national objectives ‘independently’²¹, p. 30.

The Commission’s assessment of the German draft NECP included a list of 11 points in a four-page assessment report²². The recommendations from the Commission and the assessment of the final NECP are listed in Supplementary Table 1. Most of the points called for specification of the concrete policies and measures for achieving Germany’s targets and contributions. As noted, the draft NECP built on existing legislation, some of which was already several years old. It was hardly surprising that the Commission recommended Germany to take action to identify and provide detailed and quantified policies.

Germany organized a public consultation with national stakeholders and neighboring countries after submission of the draft plan in the period 14.06-02.08.2019. Altogether 104 organizations, including companies, interest organizations, NGOs and foundations, submitted responses. Several of our interviewees hold that German policymakers had been focusing on the development of national policies, so the NECP process received scarce attention (Interviews 5, 6). NGOs and RE interest organizations expressed massive criticism of the draft plan—both because it was perceived as insufficient to meet the Paris Agreement, and because of low renewable energy ambitions^23,24.

Interest organizations were also not pleased with how the consultation process was managed: with no information from the Ministry, the organizations had to find out how to participate (Interview 5). Moreover, as the consultation took place during the summer break of 2019, many organizations had limited capacity to organize an adequate response²³. Thus, the organizations felt the consultation was largely pro-forma: something the Ministry was obliged to do, but preferably without too much attention (Interview 5).

After lengthy negotiations, the Climate Protection Program 2030 was adopted in September 2019. It included a comprehensive set of policies and measures that could be included in the final NECP, as well as an assessment of the expected effect of these measures. An important instrument here was a CO₂ price in the transport and heating sectors from 1 January 2021, to be transformed into an emissions trading scheme in 2026²⁵.

Other important measures were the energy-efficiency strategy and the decision to phase out coal-power and increase the deployment of renewables. The official strategy, adopted in December 2019, included Germany’s energy-efficiency target for 2030 as well as distinct measures for buildings, industry, transport and agriculture (BMWi, 2019). The Coal Exit Act, adopted in July 2020, called for the closure of all coal-powered plants by 2038 at the latest²⁶. Germany’s emissions reduction target for 2030 was made law with the adoption of the Climate Act in December 2019²⁷. It specified an overall emissions target as well as binding targets for the industry, power production, buildings, transport and land-use sectors. With all these policies in place, the parts that had been missing in the draft NECP could be included in the final plan.

Germany submitted its final NECP on 10 June 2020^28,29—after a delay of almost six months. The final NECP counted nearly 200 pages; like the draft, it was structured with one political-strategical part and one analytical part.

We now turn to the 11 points in the Commission’s response to the draft NECP, how these points were addressed in the final NECP and the Commission’s final assessment. The first three points which addressed the non-ETS emissions, policies to meet the RE target and energy efficiency, were sufficiently covered with the new policies and targets; the Commission considered them ‘fully’ or ‘largely’ addressed. The German RE target remained unchanged, but had already been deemed ‘sufficient’ in the draft NECP. The energy-efficiency target was improved compared to the draft NECP and was rated ‘sufficiently ambitious’. Also points 7, 9 and 10 were ‘fully’ or ‘largely’ addressed.

However, according to the Commission, points 4, 5, 6, 8 and 11 were only ‘partially addressed’. Point 4, on energy security plans, was criticized as vague; point 5, on the electricity market, lacked information on core market indicators. Point 6, on research, innovation and competitiveness, was deemed only partially addressed, because of ‘few dedicated policies and measures’ for achieving the long-term objectives. For point 8, on electricity transmission infrastructure, only ‘generic and not quantified’ information was provided on the funding of infrastructure investments. Finally, point 11, on just and fair transition aspects, was criticized for lacking quantified information and a dedicated assessment of energy poverty.

Further, several gaps in Germany’s long-term strategy were notified to the Commission on 2 January 2020³⁰, p. 9: ‘Germany now refers to climate-neutrality in its Climate Act, but the long-term strategy lacks many elements required under Article 15 of the Governance Regulation.’

Overall, however, the Commission concluded that Germany’s final NECP ‘largely addresses the Commission’s recommendations’. Germany had improved all points raised by the Commission and had met the minimum EU requirements for both GHG emissions reduction (in non-ETS sectors), RE and energy efficiency. The ambition for non-ETS emissions reduction and energy efficiency had been increased from the draft to the final plan, but Germany was substantially delayed in submitting the final plan. And finally, Germany was praised for its comprehensive list of policies and measures and a scenario calculation showing the resulting impact, especially for the non-ETS sector.

Figure 1 shows the timeline for the NECP-process in Germany together with other policy developments in the period.

Main stages in the German NECP process

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Sweden: Governance skeptic and recalcitrant implementer

All our Swedish interviewees indicate the existence of fundamental skepticism to the design of the governance framework in the form adopted. Several interviewees found it too fine-grained and concerned with details—a point related to the cost-efficiency approach dominant in Swedish energy policy in recent decades¹⁶. Therefore, a framework more focused on overarching and fewer issues—more of a rather brief strategy plan—was seen as preferable (Interviews 1, 2, 4).

During most of the process of drafting and adopting the NECP, Sweden has been governed by a Social Democratic minority government. Although in minority, this has provided some basic stability to the NECP process, and we have not come across any information that party politics has influenced the course of the NECP process. The process has been headed by the Infrastructure Ministry.

The Swedish government started working on the plan in 2017, in parallel with the final negotiations on the Governance Regulation in Brussels. Guidelines for the national processes were clarified gradually, but discussions in the Technical Working Group in the EU proved useful. Overall, our interviewees note the heavy time-pressure. Although the draft plan was based mainly on pre-existing legislation, some new information was collected by the Swedish Energy Agency, including some energy modeling. The parts of the draft NECP which required most work were the parts without much information available, like figures for research; competitiveness, energy poverty and cyber security: issues that perceived as difficult to quantify and measure (Interviews 1, 2). One interviewee noted that the Commission’s vision seemed to be that the Governance process would drive national policy, but, given the somewhat rushed process, this was not deemed possible, at least in this first round of the NECPs (Interview 1).

A rather brief public consultation process conducted in 2018 yielded some 40 responses. ENGOs had many comments, calling for a more ambitious renewable energy target. However, one interviewee recalls that the work on the plan failed to attract public attention in Sweden: it went totally ‘below the radar’ (Interview 4). This was also because most stakeholders did not view the NECP as an important document, partly because Sweden was seen as already being ahead of most other countries, not least in renewables (Interviews 1, 2).

Sweden carried out some notable early communications with the Commission. Even though the deadline was the end of 2018, there was a technical platform for uploading an early draft – just to get a feel of how to respond to the requirements in the Governance framework. The Swedish government did that, even though the draft was far from complete. In fact, the Commission had many comments to the rough draft. Our interviewees note that there was interest from other member-states about this dialog (Interviews 1, 2).

As to content, the draft plan was delivered on time and was rather brief (79 pages). Structured in line with the Commission’s template, the draft plan identified several ambitious targets for 2030: First, a 63% emissions reduction for non-ETS sectors compared to 1990, corresponding to 59% reduction compared to 2005. According to the 2018 ESR, Sweden’s target was a 40% reduction compared to 2005—an ambition far above the EU’s legal requirement. Moreover, Sweden did not report a RE target, but an ‘indicative trajectory for share of renewable energy sources in gross final consumption’³¹. The Commission was not pleased, as they wanted each member-state to specify a target. Noting that they did not have technology-specific targets for RE deployment, and implicitly referring to the Swedish policy style, the Swedish Government wrote that it ‘believes it is more cost efficient to deploy the renewable technologies which the market deems most profitable instead of determining the share of each technology beforehand’³¹. For energy efficiency, a new target was presented: 50% energy-intensity reduction compared to 2005, as well as the specific target of reducing emissions from domestic transport by 70% (2010).

As its long-term strategy, Sweden notified its target of net zero GHG emissions (1990) by 2045. A key ingredient in the policy framework was the Climate Act which entered into force in 2018, including an independent review body. Section three, outlining ‘policies and measures’, highlighted the cost-efficiency approach, with emphasis on the use of ‘general economic instruments’³¹, p. 15.

Section four described the current situation as to emissions and key societal drivers and presented projections up to 2040 with existing policies and measures for the focused dimensions. However, there was no detailed analysis, with projections, on how the annual targets were to be reached. Finally, an Impact Assessment including cost estimates was announced, but was not included.

The Commission’s initial response came in the form of a 16-pp. assessment report³² and a factsheet (See Supplementary Table 2 for an overview of the Commission’s recommendations). Key requests included a call for specification of policies and measures to achieve Sweden’s RE target; stronger efforts to reduce final energy consumption; and clarification of the costs/investments needed to achieve the stated objectives and how to phase out energy subsidies.

The development of the final NECP was organized somewhat similar as the first round. The Energy Agency tasked with providing new data, and a new round of public consultation followed, consisting of an information meeting in August 2019 and 36 written responses from societal stakeholders. These responses were generally deemed useful, with ENGOs again calling for higher ambitions, and energy companies providing more technical inputs (Interviews 1, 2). But as to the main domestic forces shaping the final plan, this seems to have involved mainly further deliberations by the governmental agencies, like making an Impact Assessment.

A main difference was that the final NECP was substantially more voluminous than the draft NECP: more than twice as long and filling close to 200 pages. Particularly the section on ‘’Policies and measures’ had been expanded substantially and was now longer than the whole draft NECP.

Overall, the Commission noted that Sweden’s final NECP ‘largely addressed’ most of the Commission’s recommendations. We will now give special attention to the decarbonization issues in focus: targets and policies for achieving emissions reductions and enhancing renewables and energy efficiency. Starting off with decarbonization, the ambitious non-ETS target was confirmed—but the Commission’s main criticism concerning LULUCF accounting and strategy was only ‘partially addressed’. The final NECP merely stated that Sweden would ‘follow the same LULUCF guidelines as other member states’: no specific strategy was put forward. As achievement of the overall climate target depends on LULUCF accounting, the actual ambition of the target could not be evaluated.

As to renewables, the Commission had called for a specification of policies and measures for achieving the 65% RES target. Several policies were identified as key implementing measures, although the Commission noted several details that were missing with regard to the implementation framework, and therefore assessed this point as ‘largely addressed’³³.

As to energy efficiency, the ambition in the final NECP had not changed from the draft plan. The target remained a 50% energy-intensity reduction compared to 2005. The Commission was not completely convinced here and listed this appoint as ‘partially addressed’.

With regard to other issues the Swedish response was variously received by the Commission. The recommendation to reinforce regional (Nordic) cooperation and broaden it to include the Baltic states was evaluated as ‘fully addressed’, but there were also matters where the Commission was not satisfied. This was to some extent the case for the clarification of energy subsidies—and how to phase them out. This was not included as a specific section in the final plan, and no deadlines were adopted for phasing out energy subsidies. Particularly noteworthy was the case of how to achieve stated objectives in a just/fair way. This issue, briefly touched upon in the added Impact Assessment, was not given much attention in the plan itself.

Overall, our analysis and the interviews conducted indicate that the Swedish government took the inputs from the Commission rather seriously and made significant efforts to improve the Swedish NECP accordingly. ‘The process involved some pressure on the Government, yes, of course’ (governmental actor: Interview 2). As to the ambition level in the Swedish plan, there was no change between the draft and final plan. This is not surprising, since the level was generally higher than required – but Sweden also failed to provide important information about LULUCF accounting, which is essential for ESR target achievement.

On the whole, we find a certain reluctance throughout the process; there was little willingness to go ‘all the way’ in following up the Commission inputs, as the framework was perceived as too detailed and rigorous. Moreover, the Swedish plan reflects what can be seen as ‘Swedish policy style’: a cost-efficiency approach, with less focus on concrete policies and measures, no specific RE target for 2030, and no sectoral targets for specific RE technologies. As the indicative trajectory for RE was substantially above the EU’s minimum requirement, the Commission accepted this as Sweden’s contribution.

Figure 2 shows the timeline for the NECP-process in Sweden.

Main stages in the Swedish NECP process

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Summing up main insights from the case studies, we find notable similarities and differences with respect to the development process of the plans, degree of changes from draft to final NECPs, and whether the plans contribute to ensuring achievement of the EU targets.

As to similarities, we find that the governance framework had an effect for the development of the plans: both Germany and Sweden altered their plans significantly over time, and the Commission’s assessments had an impact on the contents and format of the final NECP. In Germany, non-ETS emissions reduction and energy-efficiency targets were ratcheted up, and a comprehensive set of new policies and measures was included. For both countries, the final plans included significant extensions of the section on ‘policies and measures’ and an impact assessment. These substantial changes indicate that an important goal for the Governance framework –dialog and improvement of plans, and further specification of policies and measures to achieve national RE and EE contributions – was achieved.

However, we can also note some important differences between the processes in the two countries. The German plan was more detailed as to policies and measures than the Swedish one—also likely a result of the fact that the Governance regulation corresponds to what can be seen as a German policy style to a much larger degree. Germany therefore matched the required level of detail for its NECP. On the other hand, Sweden was timelier, submitting its plan only a few days after the deadline for the final plan. Moreover, somewhat different types of clarifications and changes were made: Germany fine-tuned some important overall goals and targets, while the main changes made by Sweden involved tweaking some policies and measures.

Explaining the similarities and differences across our two cases requires a more in-depth scrutiny of the policy processes. In section two we suggested that the two countries’ histories and traditions as climate policy frontrunners and the fact that the EU context was in principle similar for both countries could help us explain similarities in NECP dynamics. This finds some support. Overall, the two countries performed quite well, and their final NECPs were evaluated as ‘largely addressing’ the Commission’s recommendations^30,33—whereas, for most EU member-states, the Commission noted that its recommendations were only ‘partially addressed’.

Our expectation that climate-policy frontrunners would prepare NECPs that comply with the requirements of the regulation is fulfilled and further substantiates the analysis put forward in Maris and Flouros (2021) who placed Germany and Sweden in the NECP ‘Pace-Setting’ group. However, we find that, for both countries, this was not primarily a result of EU legislation, but rather national policy-making. Germany raised its ambitions for the non-ETS sector and energy efficiency between the draft and final NECP – but this was due primarily to new policies and measures adopted in the Climate Action Program 2019. Although Sweden did not change its ambition during the NECP process, its national contributions have remained well above the minimum requirement for meeting the joint EU target – however, with some uncertainty due to unspecified LULUCF accounting rules.

Although the governance process was not considered very important for national policy in our two cases, interviewees confirm that this might be different for other, less ambitious countries. In the words of one German stakeholder:

…it might very well be the case that the governance regulation and NECP has an effect for Eastern European countries, who are in a very different situation. Here, it could be an instrument to make these countries improve their plans and policies. (Interview 5)

Moreover, the Swedish Government highlighted the mechanism of the joint European RE target as an important reason for not submitting an overly ambitious target – thereby indicating the EU policy an efficient tool to force less ambitious countries to do more (Interview 2).

Differences as to the specific timing of the NECP processes within the two countries’ overall policy cycles must also be taken into consideration. In Sweden, much policy was already in place when the NECP process started—so waiting for policy clarification is not a main reason why the initial Swedish NECP was rather brief and tentative. This was very different in the German case. Here, the main explanation for the big differences between the draft and final NECP was that, for the latter, the Government had agreed on a large ‘package’ of climate and energy instruments and measures that could be included in the final NECP. These instruments were lacking at the time when the draft NECP was submitted, which explains why the German draft plan was rather thin.

Among the German stakeholders, the NECP is not perceived as an instrument which drives the German policy processes to ensure Germany meets its contribution to the European targets. ‘It is rather the other way around, that the discussions and developments in Germany drive the European discussion’ (Interview 5). Correspondingly, the main aim of interest organizations and stakeholders was to influence the national policy debates, rather than trying to make the Government increase its share of the overall European targets. The Ministry for Environment described the Climate Action Programme 2030 as a purely national process, evolving from the national way of governing climate action with sectoral targets and measures (Interview 6). The work with establishing the new national legislation was carried out in parallel with the NECP process, and not directly linked to the NECP.

Interest around the NECP in the German public debate was rather low, although interest organizations could use it to a certain extent to create political pressure. Moreover, the German Government did not accord much priority to the consultation process. It was conducted without putting much effort into it and with very short deadlines for stakeholders to respond. Although the Government stated their support for the NECP process, this was perceived as an exercise they would do because they were obliged to. The EU NECP process does not appear to have had much impact on the national policy process in Germany. Although some scholars have argued that pressure from EU policy drives German climate policy³⁴, or at least influences German policy strongly (Leiren & Reimer, 2018), the case examined here supports the view that German climate policy is rather driven by national processes. One of our interviewees pointed to the dominant position of Germany in the EU, and that Germany had been pushing for the governance regulation to overcome the ‘free-rider problem’ when there are no binding national targets for renewable energy and energy efficiency (Interview 7).

The most important difference between the cases examined here is the national climate and energy policy styles, which affect the entire process and the final NECPs. This relates back to the discussion about match/mismatch with EU policies presented in our initial analytical framework: the German policy style is characterized by detailed, sectoral targets and measures for technology development, whereas Sweden pursues a cost-efficient approach, dominated by general economic instruments like carbon pricing and taxes. This difference is particularly evident in attitudes towards the governance regulation, with Germany expressing firm support¹⁷ and Sweden being rather dissatisfied with the final regulation (Interview 1).

Skepticism appears to be a likely central explanation for the initial rather ‘shallow’ Swedish NECP. Moreover, the final Swedish plan failed to specify policies and measures with the required level of detail. For example, in the assessment of Sweden’s renewable energy strategy, the Commission noted: ‘the final NECP still lacks details on the initiatives planned to overcome the administrative burden, on promoting enabling frameworks, as well as on specific measures to ensure the long-term sustainability of biofuels’ (European Commission, 2020b, 5). Swedish actors saw this as a process more to communicate overall policy signals than specifying numerous details.

This is different in the case of Germany. The German NECP provided detailed information due to the adopted Climate Action Programme 2019. As the EU Commission noted: ‘Germany largely addressed the recommendation to provide detailed and quantified policies and measures to enable the country to achieve its target contribution [on renewables], and to put forward trajectories and specific measures to meet the transport target.’ (European Commission, 2020a,5). Germany was indeed a central frontrunner in establishing a Governance framework at the EU level and implemented a system basically designed in the preferred way.

On the other hand, the interaction with the Commission appears to have been slightly more influential vis à vis ‘recalcitrant Sweden’ than ‘Governance-positive’ Germany. This may have something to do with Germany’s generally being more of an established political heavyweight in the EU than ‘small-state’ Sweden. But the clear impression is still that domestic factors were more important. Over time, Swedish actors acquired a deeper understanding of this process and what to be aiming for. Also important was the development of domestic policymaking during the course of the process. For instance, the impact assessment used was lifted from pre-existing legislation (the Climate Law).

What are then the main take-aways from these case studies considering the ‘harder’ soft governance perspective? The quite substantial changes of the NECPs mean that an important goal for the Governance framework was achieved in these cases and lends support to the notion that the iterative process with the Commission with publishing and assessment of draft reports is important for increasing national ambitions and ensuring compliance with indicative national contributions, and that the NECP process may hence drive target achievement on the EU-level.

However, although interaction with and recommendations from the Commission were not without importance in either of the cases, this interaction cannot be seen as the main driver of change. This may imply that the ‘harder’ soft governance element is not as ‘hard’ as it may seem at a first glance. In part, this can be attributed to the fact that this was the first round in this iterative framework, and significant time-pressure was involved. But some of it can also be attributed to different attitudes towards this framework – particularly with Sweden still preferring a framework less focused on policy-making details. We assume that such reluctance may well apply to more EU countries than Sweden and should be taken into consideration in subsequent rounds of NECP updates.

One striking finding is that, although the German government was a frontrunner and pusher in negotiations on the Governance Regulation, in the end, Germany paid scant attention to the NECP development nationally. ‘Reluctant’ Sweden appears to have devoted more time and resources to following up the framework. As noted, this may have something to do with the general position of the two countries in the EU system, with ‘heavyweight’ Germany often acting more independently, while smaller states such as Sweden find less room for maneuver. This aligns well with our expectation that differences in general national position and ‘weight’ in the EU could help explain the partly differing NECP dynamics. It also lends support to the notion that the governance regulation does impose some ‘harder’ elements, but that these might have a stronger effect for smaller member states.

Whether the governance regulation can compensate for nationally binding EE and RE targets, hence qualifying as effective ‘harder soft governance’, would necessarily involve the study of all NECPs and the development over time. However, our findings lend support to the argument that this new regulation has some strong ‘soft governance’ elements that EU member-states will make efforts to fulfill. The resources made available from the Commission to follow up the NECP process and the consequences of non-compliance to the Commission’s recommendations through ‘naming and shaming’ also point in this direction.

Further research should look more systematically at more ‘challenging’ cases in the EU. Our two cases must be seen as ‘easy’ cases; both comparatively wealthy countries with substantial administrative capacity, both of which complied with the feedback from the Commission in their final NECP to a significant degree. This might be very different for countries with weaker administrative capacities than Germany and Sweden. Furthermore, although we have started clarifying the role of governmental organization and the role of party politics for the NECP processes we see further research on these issues as important for a better understanding of NECP dynamics and their possible practical improvements ahead.

Reporting summary

Further information on research design is available in the Nature Research Reporting Summary linked to this article.