Consultation on the EU’s interim emissions reduction target for 2040

Until 24 June 2023 the European Commission is consulting to gather views on the EU’s climate target for 2040.

Since the Communication of the European Green Deal in late 2019, there have been a raft of significant new legal and policy measures and the re-evaluation of all existing law through the lens of achieving climate neutrality by 2050. At the heart of the European Green Deal is the European Climate Law, which establishes the framework for achieving climate neutrality by 2050 and a binding intermediate emissions reductions target of at least 55% (compared to 1990 levels) by 2030. However, the European Climate Law requires the Commission to make the trajectory from 2030 to 2050 more granular and to propose a 2040 climate target in 2024. This target will then feed into revised targets under the Paris Agreement to be tabled as part of the COP process.

The power to decide the level of the EU’s 2040 interim climate target will ultimately lie with the EU Member States and the European Parliament. However, the results of this public consultation will be analysed as part of an impact assessment report and may be influential and persuasive in determining the target to be adopted.

The consultation questions

The questions cover several issues relating to the EU’s climate ambition for 2040, including

1. Whether the pace of pursuing climate neutrality up to 2040 should accelerate, be consistent with the current pace, decelerate or whether it should be country specific.
    
2. Whether the net emissions reduction target should be:
   1. Up to 65% (a small increase compared to the 2030 reduction target)
   2. Between 65% and 70%
   3. Between 75% and 80% (following the average trajectory between the 2030 and 2050 targets)
   4. Between 80% and 90%
   5. More than 90% (close to reaching climate neutrality already in 2040)
3. The role that carbon removals should play in the setting of the target (i.e. whether a net emissions figure is appropriate or whether there should be separate GHG emissions and GHG removals targets).
    
4. Ranking the relative impact of different challenges and factors in the achievement of the EU’s net zero target.
    
5. Differences between different sectors, including the ability to do more to reduce GHGs, how soon they are expected to achieve climate neutrality first, and the capacity to innovate and access finance for climate neutrality.

The consultation is not limited to questions directly pertaining to the 2040 target and invites the public to offer their views on their own personal contributions in the journey to climate neutrality (including their awareness of climate change and climate action, their view on the relative importance of changes needed to achieve climate neutrality and their willingness to take personal actions to fight climate change) and the general impacts of the climate crisis.

The remainder of the consultation is addressed predominantly to “people with expert knowledge”, but all individuals are permitted to respond. The queries include those on:

1. The future role of various instruments including:
   1. An EU-wide carbon pricing instrument
   2. The Carbon Border Adjustment Mechanism
   3. The Effort Sharing Regulation
   4. The role of carbon pricing and non-carbon pricing instruments for agricultural emissions and land-based removals
2. Agricultural emissions and climate policies
    
3. Carbon removals
    
4. Carbon capture and use or storage
    
5. Energy technology solutions
    
6. Local and regional implementation of the European Green Deal
    
7. Social and sectoral impacts of climate change policies

Comment

The consultation does not include a proposed figure for the net zero reduction target for 2040, which could be anything above the 2030 target of 55%. The responses will inform the next legally binding commitment from the end of 2030 (this present decade termed the decisive decade).

The expert questions indicate that the EU is keen to explore how present and prospective EU measures such as emissions trading schemes can work with third country measures. Expansion of schemes to cover more activities such as agriculture or more sectors within the carbon border adjustment mechanism are also queried. The role of carbon removals will be of interest to many including the relative contribution of nature-based removals in the land sector and industrial removals. Ideas on the roles of different forms of technology which can be applied and associated barrier to scale and the impact of further decarbonisation on business models and energy pricing are invited.

This is a key consultation and an opportunity to inform the next suite of investment and change in the EU which will have significant extra territorial implications.