Brussels, 2 July 2025
EREF welcomes the Commission’s proposal to include a binding 2040 climate target of at least -90% greenhouse gas emissions reduction compared to 1990 levels in the European Climate Law. This is an important step to maintain the EU’s trajectory toward climate neutrality by 2050 and provide direction for Member States’ investments into Europe’s sovereignty and resilience.
However, EREF regrets that the proposed “flexibilities” risk undermining the target’s clarity, credibility and, above all, its function as strategic signal for green investment across Europe.
In particular, the option to meet up to 3% of the target via international carbon credits from 2036 onwards weakens the domestic focus of EU climate policy and raises concerns around oversight, additionality, and certification. As emphasised by the European Scientific Advisory Board on Climate Change (ESABCC), such offsets risk diverting capital from future-proof technologies and high-quality projects within the EU and should not be included in the Union’s domestic reduction trajectory and targets. Offsets can be relevant contributions to global climate protection, but they must be implemented in addition, not as a substitution for domestic GHG reductions.
EREF also warns against the proposed integration of permanent carbon removal technologies, such as direct air capture (DAC), into the EU’s carbon market. While development of removals is necessary to address residual emissions in the long term, they must not displace real mitigation through proven, available measures such as renewable energy and energy efficiency. A successful transition will require both; but must be led by real reductions.
To improve transparency, protect climate ambition, and send clear signals to investors, EREF strongly supports the Advisory Board’s recommendation to introduce a separate 2040 target for gross greenhouse gas emission reductions.
EREF calls on the co-legislators to uphold the scientific basis of the proposal, maintain a clear focus on domestic, real emission reductions, and ensure that any flexibility options do not erode the target’s integrity, and its environmental and economic function. Mounting geopolitical challenges and the urgent need to attract investment into future-proof industries demand it: the 2040 target must serve as a credible policy anchor – enabling Europe to double down, not delay, its transition.
For more information, please contact
Prof. Dr. Dörte Fouquet
Director
doerte.fouquet@eref-europe.org
Dirk Hendricks
Secretary General
dirk.hendricks@eref-europe.org