Brussels, 23 June 2023
EREF emphasises that we absolutely need ambitious EU 2040 climate and energy targets,
in form of substantial emissions reductions and clear and science-based agreement on
remaining carbon budgets. This can be achieved mainly through significantly higher
shares of renewable energies, which will be the dominant sources of electricity, and
through direct and indirect electrification also for other end-uses, such as heating &
cooling and road transport. Exploiting untapped potentials of energy efficiency
improvements will have to be the other pillar of the transformation towards carbon
In this respect, EREF cautions to bet on Carbon Dioxide Removal (CDR) technologies.
While acknowledging innovation and research into CDR technologies is important, we
should focus on avoiding GHG emissions wherever possible, rather than relying on future
solutions that include carbon removal (or storage). Current CDR pilots are still unable to
remove CO2 on a large scale and are far from being economically viable. Emphasizing
CDR technologies thus risks greenwashing and directing investments away from more
effective and readily available solutions. Focussing on removal and storage will mainly be
an extended lifeline for fossil fuels and ultimately results in huge amounts of stranded
investment, instead of providing investment security and guidance towards the various
renewable energy and energy efficiency solutions.
Instead, EREF encourages decision-makers to prioritize nature-based solutions for carbon
removal such as ecosystem restoration, reforestation, regenerative agriculture and
sustainable land management. All of these can enhance carbon sequestration, conserve
biodiversity, improve water quality, and limit the risks and frequency of natural disasters.
By integrating nature-based solutions into climate policies, the EU can promote resilient
ecosystems and sustainable development.
EREF advocates the 2040 emission reduction target to be set at a minimum of 90% to
95%, compared to 1990 levels. This level of ambition will set Europe on track towards net-
zero and accelerate decarbonisation across all sectors, mostly energy, transport, buildings,
agriculture, and industry. By setting a high bar, the EU will inspire other regions and nations
to follow suit, ensuring a collective effort towards a sustainable and resilient future.
EREF calls for a legally binding definition of remaining Carbon Budget to ensure
transparency and accountability for the EU and each Member State. This definition should
include clear milestones for 2035 and 2040 and enable a robust monitoring and reporting
mechanism that allows for stock-taking and progress evaluation and the consequent
introduction and implementation of stronger measures in case of shortcomings. National
roadmaps for emissions reductions will help Member states to align their policies and
actions, which are formulated under the National Energy and Climate Plans (NECPs), with
the EU’s overall objectives and thus facilitate a cohesive and effective approach to climate
EREF believes that for actual achievement of an ambitious 2040 GHG-reduction target it is
indispensable to also define and enact ambitious targets for the share of renewable
energy. We recommend a target of at least 80% renewable energy in the gross final energy
consumption by 2040 including sector sub-targets (industry, heating and cooling,
transport, etc.). The electricity sector should aim at 100% renewable energy by then, with
the other sectors following soon afterwards.
To achieve the necessary ambition the current governance system should be revised to re-
install legally binding national targets for each Member State. In contrast to the current
NECPs, taking individual responsibility of Member states would result in more effective
implementation and enforcement of the climate and energy targets. Mandatory national
targets would increase investments through better long-term planning and security among
investors and project developers in renewable energies.
To support the needed efforts and to help policy development, EREF calls on the European
Commission to model at least one 100% renewable energy scenario using all available
renewable energy technologies. The impact assessments and modelling should include
the existing real costs of renewables rather than be based on higher assumptions as this
was done in the past. The scenario should further address additional topics such as
excess and waste heat, as well as the need for increased system flexibility and
decentralised infrastructures that are designed to support substantive renewable energies
Fossil or nuclear based technologies should no longer be promoted in EU markets and
systems. New investments and support schemes for both technologies must be phased
out within the next few years in order to avoid lock-in effects and delayed decarbonisation.
Nuclear and other inflexible baseload be phased out as soon as possible, as it is not
compatible with an energy system based on very high shares of renewables, particularly
including variable and dispatchable renewables.
The preparations for the EU 2040 climate targets should emphasize steps towards full
decarbonisation of hard-to-abate sectors for the last decade before reaching net-zero by
2050 the very latest.
In parallel, energy efficiency must be prioritized to maximize the effectiveness of energy
use. Setting ambitious targets and enacting and implementing enabling legislation and
regulation for energy efficiency will contribute to emission reductions and long-term