Brussels, 4 June 2025
EREF strongly recommends the Commission to propose a 2040 climate target of at least
-90 to -95% greenhouse gas emissions reduction compared to 1990 levels in line with the
recommendations from the European Advisory Board on Climate Change. This target must
focus on domestic reductions and a linear reductions pathway from 2030 via 2035 to 2040.
The 2040 target is not only a necessary milestone on the path to climate neutrality by 2050
– it is also an important strategic economic instrument. It provides long-term visibility for
investment, supports the development of a resilient European industry and strengthens
Europe’s energy sovereignty. By reinforcing the green transition, the target helps mitigate
future crises, reduce dependencies and create quality employment across all regions
and sectors.
The 2040 target should be complemented by a clear and credible 2035 target of 75%, building
on an at least linear trajectory towards 2040, to ensure alignment across policy instruments
and give necessary regulatory certainty to industrial actors and investors.
EREF is concerned about the increasing political attention given to mechanisms that risk
weakening the clarity and integrity of the target. A non-linear emissions trajectory would
shift efforts to later years and undermine investment signals. The use of international offset
credits effectively lowers the domestic ambition, potentially significantly below -90% and
raises questions regarding certification and oversight. Carbon sinks, whether natural or
technical, may play a role – but only if they are additional, limited, do no harm, scientifically
verifiable and transparently accounted for. Sector-specific flexibility may be considered,
provided it does not replace overall binding national reduction trajectories expressed in
absolute terms.
The 2040 target will also require a structured and realistic implementation pathway,
with intermediate milestones and robust monitoring mechanisms. Effective monitoring of
progress, early identification of challenges and timely adjustment of policy and investment
efforts are necessary, including 2040 targets for renewable energy and efficiency.
As negotiations on the EU’s 2040 climate architecture continue, EREF urges the European
institutions to prioritise real and timely domestic reductions, strengthen investor confidence,
and avoid undermining ambition through intransparent or at least difficult-to-monitor
mechanisms. A robust and science-based target must be the basis for a reliable policy
framework, a stable investment environment and a successful Clean Industrial Deal.
For more information, please contact
Prof. Dr. Dörte Fouquet
Director
doerte.fouquet@eref-europe.org
Dirk Hendricks
Secretary General
dirk.hendricks@eref-europe.org