EU

In October 2023, the EU submitted a revised NDC to the UNFCCC (Spain and the European Commission, 2023). Its target of reducing emissions by at least 55% below 1990 levels by 2030 (incl. LULUCF and international aviation) is the same as the previous NDC from December 2020. However, the EU has increased its land sector target by 85 MtCO₂e which is what enables the EU to assert that it will overachieve its 55% target. The CAT rates this updated target as ‘did not increase ambition’ because it does not lead to a lower emissions limit (excl. LULUCF and international aviation) compared to the previous NDC.

Compared to the previous NDC update in 2020, this NDC update clarifies that only CO₂ emissions from flights within the European Economic Area, departing flights to Switzerland and departing flights to the United Kingdom are included in the goal.

The EU’s 2030 NDC is not close to the 1.5°C limit when compared to modelled domestic pathways. It remains far behind on its fair share contribution to the 1.5°C limit and needs to substantially increase its support for emissions reductions abroad and climate finance.

In February 2024, the European Commission proposed a 2040 target of a 90% net GHG emissions reduction below 1990 levels. The CAT quantifies the 2040 target to be 660 MtCO₂e (excl. LULUCF) or an 85% reduction from 1990. While the 2040 target does align with what would at least be needed domestically to be aligned with 1.5°C compared to modelled domestic pathways, the CAT believes that the EU should adopt at least a 95% reduction below 1990 levels (incl. LULUCF) by 2040 seeing as it is is failing to contribute its fair share to global climate action.

In its updated NDC submission from October 2023, the EU kept the same headline target of reducing emissions by at least 55% below 1990 levels by 2030 (incl. LULUCF and international aviation) as in its submission from December 2020 (Spain and the European Commission, 2023).

The updated NDC has increased the EU’s target for LULUCF removals to 310 MtCO₂e up from 225 MtCO₂e. The increase in the LULUCF sink is what enables the EU to assert that it will overachieve its 55% target (European Parliament, 2022). However, if the EU were to use the additional 85 MtCO₂e towards achieving its 2030 target – rather than the 225 MtCO₂e referenced in the European Climate Law – then this would decrease the emissions reductions needed in other sectors. The CAT does not view this submission as representing an increase in ambition.

Other than the increase in the LULUCF sink, the most recent EU NDC update includes a summary of regulatory developments, and the main domestic policies adopted in view of the new climate target agreed to in December 2020. It also clarifies that only CO₂ emissions from flights within the European Economic Area, departing flights to Switzerland and departing flights to the United Kingdom are included in the target. Based on this clarification, the CAT considers international aviation to be included in the EU’s NDC, but not international maritime emissions. Please see the Assumptions tab for more details on the quantification of the EU’s 2030 NDC.

The EU had previously submitted an update to its NDC in December 2020 (Germany & European Commission, 2020). The 2020 update provided a strengthened 2030 emissions reduction target of “at least 55%” compared to the first NDC’s target of “at least 40%” (Latvia and the European Commission, 2015). The inclusion of the land sector slightly weakens this target compared to its 2016 NDC, however, the inclusion of aviation strengthens it.

According to the Commission’s modelling reflecting the “Fit for 55” package, the EU’s emissions would amount to 2.2 GtCO₂e in 2030, excluding LULUCF and international aviation^[1] (European Commission, 2021a). As of the end of 2023, the EU has all the “Fit for 55” legislative framework in place to meet its “at least 55%” target. These policies still fall short of the domestic reductions needed to be consistent with limiting warming to 1.5°C. Domestic emission reductions of at least 62% (excl. LULUCF and international aviation) from 1990 are needed to make the EU’s effort compatible with 1.5°C, while currently the EU’s target results in a 52% (excl. LULUCF and international aviation) reduction from 1990.

The EU is expected to submit an updated NDC with a target for 2035 at COP30 in 2025, but will likely folllowing the adoption of its 2040 target. Based on modelled domestic pathways, the CAT would recommend a 2035 emissions reduction target of at least 74% excluding LULUCF, or a 78% reduction including LULUCF below 1990 levels, along with substantially increased climate finance. The European Commission suggests deriving the EU’s 2035 NDC from a linear trajectory between its 2030 and 2040 targets. The CAT would advocate for a non-linear trajectory based on 1.5°C compatible pathways, as delayed climate action only makes limiting warming to 1.5°C more difficult.

[1] The numbers provided in the scenario use Global Warming Potential from IPCC AR5. For the sake of comparability with other countries assessed by the Climate Action Tracker the number 2.256 MtCO₂e is translated to AR4 resulting in 2.244 MtCO₂e.

* Before September 2021, all CAT ratings were based exclusively on fair share and only assessed a country’s target.

Target development timeline & previous CAT analysis

• 21.05.2024: EU's Green Deal improved its climate performance: a 1.5°C pathway is close
• 06.02.2024: EU Commission's proposed 2040 target not quite 1.5°C compatible, pre-2030 action is key
• 06.02.2024: EU CAT Assessment
• 18.12.2020: EU Member states submitted to the UNFCCC a stronger 2030 domestic emissions target
• 11.12.2020: EU Member states agreed on a stronger 2030 domestic emissions target

The CAT rates NDC targets against each country’s fair share contribution to global climate change mitigation, considering a range of equity principles including responsibility, capability, and equality. The CAT also rates NDC targets against indicative national emissions from global least-cost emissions pathways (called modelled domestic pathways). For assessing targets against the fair share, we consider both a country’s domestic emission reductions and any emissions it supports abroad through the use of market mechanisms or other ways of support, as relevant.

The EU does not intend to use market mechanisms and will achieve its NDC target through domestic action alone. We rate its NDC target against both global domestic pathways and fairness metrics.

On October 2023, the EU submitted an updated NDC. The target of reducing emissions by at least 55% below 1990 levels by 2030 (incl. LULUCF and international aviation) is the same as the previous NDC from December 2020. However, the EU has increased its land sector target by 85 MtCO₂e implying that it is aiming to reduce net emissions by more than 55%. Excluding LULUCF and international aviation, the target equates to 52% below 1990 levels.

The CAT rates this target as “Insufficient” when compared to the level of emissions reductions needed within the EU’s borders. The “Insufficient” rating indicates that the EU’s NDC target in 2030 needs substantial improvements to be consistent with limiting warming to 1.5°C. If all countries were to follow EU’s approach, warming would reach over 2°C and up to 3°C.

The CAT’s assessment of the EU’s total fair share contribution takes into account its emissions reduction target and its climate finance.

When measured against a fair share emissions allocation, we rate the EU’s NDC target as “Insufficient”. The “Insufficient” rating indicates that the EU’s NDC target in 2030 needs substantial improvement to be consistent with limiting warming to 1.5°C. The EU’s target is at the least stringent end of what would be a fair share of global effort, and is not consistent with the 1.5°C limit, unless other countries make much deeper reductions and comparably greater effort. Some of these improvements should be made to the domestic emissions target itself, others could come from supporting additional emissions reductions achieved in developing countries in the form of finance. If all countries were to follow the EU’s approach, warming would reach over 2°C and up to 3°C.

The EU’s international climate finance is rated “Insufficient” and is not enough to improve the EU’s fair share rating.

The EU’s international public climate finance contributions are higher than those of most other governments, but we still rate it “Insufficient.” The EU has committed to increasing its climate finance, but contributions to date have been low compared to its fair share. To improve its rating, the EU needs to ramp up the level of its international climate finance contributions post-2020 and accelerate the phase-out of fossil fuel finance abroad. In its concluded negotiation position for the upcoming CO29, the EU neglects to address the need for significantly scaled-up financial support for developing countries, a key factor for enabling ambitious climate action and ensuring a fair global transition.

In 2022, the EU and its member states provided EUR 28.5 bn to developing countries (Council of the European Union, 2023a), but contributions still fall short of its fair share contribution. The EU remains committed through 2025 to the USD 100 bn collective goal of climate finance for developing countries, but the USD 100 bn goal itself is insufficient for the post-2020 period. The EU has not made clear how much its planned international climate finance contributions will be in the coming years.

The Sustainable Finance Disclosure Regulation Framework (SFDR) was established to promote transparency in sustainable investments to support informed investment decisions. However, this has failed due to broad and vague definitions of what constitute green investments. For example, European investment funds labelled as ”green” under the SFDR have been directed towards major coal firms outside the EU, including the US, China and India, amounting to EUR 65 million as of April 2024 (Civillini & Rodriguez, 2024).

In February 2022, European Commission published a complementary climate-delegated act to its Taxonomy Regulation (Council of the European Union, 2022a), which states that energy generation from fossil gas and nuclear should be classified as transition activities: activities that cannot yet be replaced by low carbon alternatives but that do contribute to emissions reduction.

At COP29, the EU has reaffirmed that international public climate finance be focused on delivering on the New Collective Qualified Goal (NCQG). However, the EU has not indicated how much finance the bloc is ready to commit and has added a prerequisite to expand the number of contributors part of its position (CAN Europe, 2024).

Further information on how the CAT rates countries (against modelled pathways and fair share) can be found here.

New 2040 target proposed in February 2024

In February 2024, the European Commission proposed a 2040 target of a 90% net GHG emissions reduction below 1990 levels (European Commission, 2024c). After the elections for the European Parliament, President von der Leyen reaffirmed support for the 90% target (von der Leyen, 2024a), which represents the least ambitious end of the 90-95% range initially recommended by the ESABCC (European Scientific Advisory Board on Climate Change (ESABCC), 2023). Based on the assumptions in the EU’s Impact Assessment for the 2040 target (European Commission, 2024a), we quantify the target as an 85% emissions reduction from 1990 or 660 MtCO₂e by 2040 (excluding LULUCF but including industrial removals from DACCs and BECCS). This means that the EU will rely on increasing its LULUCF sinks to achieve the remaining 5–10%. The EU seems unlikely to be able to achieve the upper end of the range because even with its most ambitious LULUCF sink the EU would only able to reach a 94% total emissions reduction in 2040 from 1990.

Net zero target

In April 2021, the European Union adopted its Climate Law, setting into law the objective of collectively achieving “climate neutrality by 2050.” The objective of achieving climate neutrality by 2050, as agreed in the European Council’s conclusions from December 2019, has further been included in the EU’s LTS submitted to the UNFCCC in 2020.

The EU’s climate neutrality – or, essentially, net zero – target is “Acceptable” in terms of its architecture, transparency and scope, including a legally-binding review and assessment process.

At present, a clear separation of the contributions from emissions reductions versus removals is missing, although this is an element that is required of the forthcoming 2040 target. There is room for improvement in the target’s scope, as the Climate Law currently does not clearly state that international aviation and maritime transport emissions are included, and an explanation of why net zero by 2050 constitutes a fair contribution is lacking.

The full analysis is available here.