Consultation response on national targets and flexibilities and the use of international credits

Carbon Gap has submitted two responses to the European Commission's call for evidence on the post-2030 climate framework

Here's what we're calling for: 

Our modelling with VTT shows the EU will need at least 100 Mt CO₂/year of permanent carbon removal and around 350 Mt CO₂/year from the land sector by 2040. Those volumes do not materialise without binding national targets. Separate targets, for LULUCF and for permanent CDR, because the two differ too fundamentally in permanence and function to be treated as interchangeable.

On flexibility: a framework that allows countries to buy their way out of domestic action is not a flexibility mechanism. It is a delay mechanism. Flexibilities must be capped, conditional, and governed — not a structural feature of how targets are met.

On international credits specifically: our new International Credits Calculator challenges the assumption that credits are straightforwardly cheaper than domestic action. They are not always cheaper. And where a higher cost is justified, it should be because credits drive European climate leadership, not because they substitute for domestic cuts. We recommend the EU plan for full domestic delivery of the 90% target, with credits reserved for ambition beyond that level or as a genuine safety buffer, procured centrally rather than unilaterally by Member States.

The 5% ceiling in the European Climate Law is a maximum, not a target. Locking in a fixed percentage now, before the pilot phase, before Article 6 markets have demonstrated supply at scale, would be premature.

The decisions made in this consultation will shape whether Europe's climate architecture drives transformation or enables delay. We hope our submissions help inform that design.