Feedback to the public consultation on the European Climate Law amendment

Carbon Gap supports the 90% emissions reduction target for 2040 in the revised European Climate Law. This target is foundational as it sets the trajectory to achieving the EUs 2050 climate neutrality and subsequent net negative emissions. The Communication on the 2040 climate target and the European Scientific Advisory Board on Climate Change both affirm that reaching this target requires not only deep emissions reductions but also a rapid scale-up of carbon removals. We welcome the opportunity to provide feedback to the Commission’s proposal. Our recommendations are outlined below:

• Distinct contributions of gross emissions reductions, permanent removals and temporary (land-based) removals towards the net 90% target, with separate accounting.
• Recognise the need for CDR incentives beyond the EU ETS integration
• Allow international carbon credits for increased ambition and higher levels of transparency as required by the Paris Agreement. Any reliance on international credits needs to follow clear guardrails.