The paper analyses the implementation of the second multi-annual agreement for energy efficiency concluded in the Netherlands with industrial sectors for the period 2002-2010. It aims to investigate whether the multi-annual agreement MJA2, as a voluntary instrument, is sufficiently stimulating behavioral change at the target group level, and sustained transformation of production and management patterns towards significant gains in energy efficiency. The analysis uses a Structure-Conduct-Performance analytical framework for implementation processes in order to: (a) analyze the setting of implementation, actor roles, attitudes and interactions; (b) discuss emerging obstacles and positive experiences with the implementation of the three core policy instruments envisaged: energy management system, process efficiency measures, and 'expansion themes' measures. Based on this policy recommendations are formulated regarding voluntary agreements in general, using the Structure-Conduct-Performance framework of implementation analysis, and regarding how the implementation process of MJA2 in particular could be improved. (c) 2006 Elsevier Ltd. All rights reserved.