USA

This is a short assessment of the United States’ 2035 NDC. The full analysis will follow in January.

The United States' new 2035 target, officially submitted to the UNFCCC by the outgoing Biden Administration, sends a clear signal that the new NDC can act as a guiding document for subnational entities to continue climate action even if the federal government were to withdraw the NDC and/or leave the Paris Agreement, as promised by President-elect Trump.

The target, while an important milestone in reaching net zero emissions by 2050, is not in line with the Climate Action Tracker's 1.5˚C compatible modelled domestic pathways.

The United States officially submitted its updated Nationally Determined Contribution (NDC) on December 19, 2024. In this submission, the government establishes a target to reduce emissions by 61–66% in 2035, compared to 2005 levels. The 2035 target covers all sectors, including land use, land use change, and forestry (LULUCF), and considers all greenhouse gas emissions. The newly-submitted NDC does not set targets for specific greenhouse gases, but anticipates a reduction of methane emissions by 35% below 2005 levels in 2035.

While the updated NDC is an important milestone in reaching net zero emissions by 2050, the proposed 61–66% reduction target in 2035 is not in line with the Climate Action Tracker’s (CAT) modelled domestic pathways for limiting warming to 1.5°C. To be compatible with 1.5°C, the US needs to reduce emissions by 80% in 2035 including LULUCF, below 2005 levels. The NDC also leaves the door open for the use of controversial voluntary carbon markets under Article 6 of the Paris Agreement.

A set of national and subnational measures support the NDC’s emissions reductions target. At the national level, the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA), as well as revised regulatory standards in key sectors, enable climate action by subnational and non-state actors. Under the CAT's current policy projections, US emissions will decline, but not fast enough to reach the 2030 and newly-proposed 2035 targets, which means that new policies will have to be implemented.

The updated NDC acknowledges the important role of subnational climate action; the revision was drafted in consultation and cooperation with state, territorial, Tribal, and local governments. The 2035 target is underpinned by and further builds on existing subnational emissions reductions measures, such as renewable portfolio standards (RPS), which are responsible for approximately half of the country’s renewable energy capacity buildout since 2000.

By collaborating with subnational governments, the federal government positions the NDC to act as a guiding document for subnational entities to continue domestic climate action, even if the federal government were to leave the Paris Agreement and officially withdraw the NDC.

In such a scenario, subnational and non-state actors need to slow the rollback of climate policies at the federal level and raise the ambition of climate policies at the subnational level to keep the 2035 target within reach. In any case, emissions in the US will likely continue to decline as many sectoral transformations are already underway and reinforced by global energy trends.

We will publish a full analysis of the newly submitted NDC in our 2035 Climate Target Update Tracker early in 2025.