No targets, no clarity: EU’s flexibility pursuit leaves carbon removals in a limbo
In the name of political flexibility, the proposed European Climate Law leaves a critical question unanswered: How much must come from actual emissions cuts, permanent carbon removals, and land-based sinks?
The European Commission’s proposed revision of the Climate Law sets a net 90% reduction target for 2040. Yet in the name of political flexibility, the proposal leaves a critical question unanswered: How much must come from actual emissions cuts, permanent carbon removals, and land-based sinks?
Separate targets: clarity sacrificed for compromise
For over a year, scientists, industry, civil society, and the Commission’s own Scientific Advisory Board have urged to clearly define reductions and removals contributions.
“For the carbon removal sector, separate targets aren’t a caprice – they’re essential to secure billions in investments needed to build capacity for net-zero,” says Anna Costova, Associate Policy Lead. “Flexibility might win political favours today, but targets are the indispensable starting point for credible CDR policy – especially with time so short.”
The proposal’s commitment to integrate permanent removals into the EU Emissions Trading System (ETS) to compensate for residual emissions from hard-to-abate sectors explicitly recognises CDR’s role in industrial decarbonisation. But the ETS revision will take several years to adopt, leaving the sector in a limbo about the volumes required by 2040.
At the same time, separate targets ensure that CDR growth doesn’t interfere with deep emissions cuts. Our new policy brief, released today, finds the EU will need between 100 and 280 MtCO₂ of permanent removals per year by 2040, depending on how fast emissions fall. The connection is clear: the faster we cut emissions, the less we will need removals – but without them, net-zero is out of reach.
The findings also confirm that no single CDR method can deliver these volumes on its own. A portfolio approach is essential to spread cost and risk, and set up clear, separate policy frameworks.
International credits: flexibility or integrity gamble?
The proposal would also allow international carbon credits under Article 6 of the Paris Agreement to count toward the 2040 target, up to 3% of 1990 emissions.
“There’s currently no guarantee Article 6 can deliver the level of integrity needed,” says Rodica Avornic, Policy Director. “Before diving headfirst, the Commission must thoroughly assess its impact. If used at all, international credits must remain minimal, subject to stringent conditions, and be limited to permanent removals.”
Next steps: towards credibility
The Danish Presidency aims to secure a Council agreement by 18 September. While speed is vital to meet the EU’s 2035 NDC deadline, it must not come at the cost of credibility. The EU must adopt separate, enforceable targets for removals alongside emissions cuts — or risk drifting off the path to net-zero.
Our modelling shows that separate targets are not only necessary but achievable. The report offers practical insights to guide policymakers in defining these targets without delay, ensuring Europe’s path to net-zero is both credible and effective.