How the EU Can Strengthen Its Post-2030 Climate Agenda

The EU has committed itself in March 2026 to cutting net greenhouse gas emissions by 90% compared to 1990 levels by 2040, and reaching full climate neutrality by 2050. The policies that the EU implements to achieve these targets matter just as much as the numbers themselves, which  UBA recommends to be more ambitious.

The main recommendations in short:

Raise the 2040 target to 95% in future review processes. The EU's 2040 climate target allows up to 5% to be met through international carbon credits, leaving a domestic reduction requirement of at least 85%. This would translate into a staggering gap as it would mean that EU net emissions in 2040 could be up to 50% higher than they would be without such credits. A weak target would lead to a reluctance to invest in green technologies in the EU during the 2030s and foster corresponding lock-in effects in the fossil fuel sector, while forcing the bloc to aim for unrealistically steep emission reductions between 2040 and 2050. Furthermore, a more ambitious target would better align with Europe's historical responsibility for GHG emissions and reinforce its role as a leader in the global fight against climate change. Consequently, UBA continues to recommend a genuine 95% domestic net reduction target by 2040.

Don't rely on international carbon credits to achieve the EU climate targets. The EU plans to use Article 6 credits from the Paris Agreement to cover up to 5% of its 2040 climate target.UBA warns about the risks: high-quality credits will likely be scarce and expensive, and past experience with similar schemes — such as the Kyoto Protocol's Clean Development Mechanism — revealed serious problems with oversupply and poor quality. In addition, accepting lower-quality credits would undermine both EU credibility and the climate goals of the countries selling them. Credits can help support climate action abroad, but are not a reliable substitute for domestic effort.

Cut emissions first — do not rely on carbon removals. Carbon removal technologies such as bioenergy with carbon capture and storage (BECCS) and direct air capture and storage (DACCS) are central to the European Union’s pathways for achieving the EU climate targets, but today they barely exist: BECCS, for example, is projected to remove just 4 million tons of CO₂ by 2030 — a fraction of what the EU plans require. Furthermore, they come with distinct risks, such as high energy and biomass consumption. Therefore, UBA warns against banking on a many-fold scale-up of these technologies by 2040 and underlines the importance of prioritizing emission reduction with separate targets for gross emission reduction and removal types, prioritizing here natural CDR (ideally as nature-based solutions). Without this, industries could delay their decarbonization by assuming that future carbon removal technologies will bail them out.

Strengthen the EU ETS 1 — and don't delay EU ETS 2. A credible and robust CO₂ price is the backbone of Europe's decarbonization strategy. To achieve this, it is important to set an ambitious and stable cap until 2040 that reflects the overall climate target, avoid a slower phase-out of free allocation, and prevent any further delay in the introduction of the EU ETS 2. This ensures a robust and cost-efficient target achievement and creates a strong CO₂ price signal required to effectively incentivize the required emissions reductions in the covered sectors. Furthermore, it is essential to ensure that the EU Carbon Border Adjustment Mechanism (CBAM) aid the industry from carbon leakage and the recycling of auction revenues effectively support sectors in their transformation, while promoting a broad, economy-wide decarbonization and ensuring a socially just transition.

Fix the Effort Sharing Regulation — it's already falling short. The ESR sets binding national emission reduction targets for buildings, transport, agriculture, and waste — sectors covering 60% of EU emissions. But current projections show the EU will only achieve a 31% cut by 2030, against a required 40%. Germany alone is expected to accumulate a shortfall of around 200 million tonnes of CO₂ equivalent in 2021–2030. UBA calls for automatic gap-closure mechanisms and a harmonised EU-wide monitoring system. Under current rules, reviews don't even begin until 2028 and 2033, far too late to implement corrective measures.

Scale up renewables, green hydrogen, and energy efficiency — fast. Before Russia's invasion of Ukraine, the EU imported 56–60% of its energy, with 45% of its gas coming from Russia alone. REPowerEU has cut the latter to around 15% — but the structural vulnerability remains. UBA calls for binding energy efficiency targets for 2040 (the 2030 targets expire and no new targets have been proposed), a major scale-up of renewable energy, and faster electrification across all sectors. 

Make the transition fair — or risk losing public support. Higher carbon prices hit low- and middle-income households the hardest unless they are compensated. In Eastern and South-Eastern Europe in particular, these households rely more heavily on fossil fuels for heating and transport. UBA urges targeted support programmes, a stronger and extended Social Climate Fund, and the redistribution of ETS revenues to citizens, for example through income support and subsidised access to heat pumps, building energy-efficiency upgrades, and e-mobility, similar to France's "social leasing" programme for electric vehicles.

Think beyond Europe's borders. Even under its most ambitious scenarios, the EU's emissions pathway will exceed its fair share of the global carbon budget. Therefore, expanding EU support for international climate action is critical and must be scaled up in the future. The EU should use trade, finance, and development policies consistently to support emissions reductions worldwide — and play a leading role now that the United States has stepped back from the Paris Agreement, a moment the paper describes as both a challenge and an economic opportunity. Furthermore, the EU must ensure that domestic emission reductions are not offset by higher emissions abroad (carbon leakage). To that end, the Commission should identify these risks and implement robust measures to prevent them. Article 6 mechanisms offer an additional tool to aid global mitigation efforts.

UBA's message is simple: the legal framework for the overall 2040 goal is in place, but the policies that the EU implements to achieve these targets matter just as much as the targets, which UBA recommends to be more ambitious. All relevant implementation rules will be negotiated in the coming months – the EU needs sharper targets, tougher enforcement, and real coherence across sectors and Member States. The 2030 goals are the bridge to 2040 and 2050 — and that bridge is already showing cracks. It’s high time to fix them.