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How EU’s delayed 2040 emissions target statement / NDC looks like a Trumpian fudge* during tense global negotiations (7)
The EU published a watered-down 2040 emissions targets and some indication of its 2035 target, fudging some key numbers …. like its use of UN carbon credits in those two years.
*Trump-like EU fudge is here (the deal that’s not a deal):
“An economy-wide net emissions reduction target by 2040 compared to 1990, including an adequate contribution of high-quality international credits under Article 6 of the Paris Agreement in a way that is both ambitious and cost-efficient, leading to an indicative contribution of an economy wide net reduction of between 66.25-72.5% in GHG emissions by 2035 compared to 1990. The range for the indicative target in 2035 is based on indicative linear trajectories from, on the one hand, the EU’s climate targets for 2030 and 2050, and, on the other hand, the EU’s climate target for 2030 and the 2040 climate target from the position of the Council of the European Union.”
CarrZee initial reaction:
The cut of about 70% in 2035 vs 1990 seems weak vs expected 90% in 2040. EU carbon allowances might fall (not investment advice).
I’m saying 70% seems weak because it is about 15 percentage points tighter than the 55% in 2030….yet the shift to the 90% in the five years through 2040 is a 20 percentage-point shift.
Emissions will get harder and harder to cut as countries get closer to net zero.
So you could say the lack of ambition is quite astonishing, when viewed against what economists say is ideal.
A global cap on emissions every year is ideal … not just “cherry picked” years such as 2040.
Single-year fudge
See this for the bit on single year (there was no mention of the word “single” in the prior NDC update):
Having a single-year target in 2040 would dramatically cut demand for carbon credits because countries/companies may not need to buy them for other years. This goes against the idea of a “carbon cap” …which to me at least … implies emissions are capped every year.
This might be some kind of negotiation tactic … flagging that the EU might not necessarily provide the carbon finance to emerging nations, unless they get on board with tight global carbon markets.
By being vague, the EU is making sure it’s not damaged by President Trump’s anti-woke negotiation stance.
On the other hand …Europe has a lot to give into the negotiation if Trump starts to soften his climate stance. The same could be said of the BRICS countries, which also seem to be playing harder “climate ball”.
Mr Trump’s overseen substantial election defeats Nov. 5 in the USA, adding to the pressure on him to become more woke if he wants his son to run and win the presidency for the Republicans in 2028.
Earlier reporting of the “deal / no deal” seems wrong, but I might be missing something….msg mathew@carrzee.net…full press release below contains the 5% figure for % of 1990 emissions that can be used to meet the EU NDC …the NDC doc does not have this number (yet) and that’s what counts legally speaking.
Once these numbers become legally binding and clear, the futures market in UN carbon credits can start trading, in theory.
Eg politico — 5% international carbon credits or not?
….ChatGPT workings for what they are worth — this captures the confusion in a lot of the reporting of the EU target news:
Good — I pulled the official NDC/Council text plus reporting and did the arithmetic. Short answer first, then the detail + sources.
Short answer (two likely interpretations)
If the EU allows up to 5% of the 2040 net emissions to be met with international credits (the way some press described the late deal), that equals ≈ 23.5 MtCO₂e in 2040. If the allowance is instead a percent of the 1990 base-year emissions (the Commission originally proposed 3% of 1990 emissions in 2036–2040), that equals ≈ 141 MtCO₂e (3% of 1990) — or ≈ 235 MtCO₂e if the figure is 5% of the 1990 base.
How I got those numbers (transparent, step-by-step)
1990 base (EU total net GHG in 1990) — Technical Expert Review (TERT) gives the EU 1990 base as 4,699,405 ktCO₂-eq → 4,699.405 MtCO₂-eq. Net 2040 target — a 90% net reduction vs 1990 implies 10% remaining of the 1990 base: 10% × 4,699.405 Mt = ≈ 469.94 MtCO₂e (net in 2040). (This matches public summaries which put the net-2040 level at ~450–470 Mt.) Percent-of-what ambiguity — the policy debate/news has two different ways of expressing allowable credits: The Commission’s proposal talked about a limited contribution expressed as a percent of 1990 emissions (the Commission earlier proposed 3% of 1990). Later reporting about the Council/ministerial discussions mentioned countries pushing for up to 5% (France reportedly wanted 5%), and press outlets reported agreement that would allow up to 5% in practice. The Council NDC submission text itself describes an “adequate contribution of high-quality international credits” but does not in the published PDF fix the numeric ceiling — so the exact legal number can vary by final legislative text. Arithmetic (explicit) 3% of 1990 = 0.03 × 4,699.405 Mt = ≈ 141.0 MtCO₂e. 5% of 1990 = 0.05 × 4,699.405 Mt = ≈ 235.0 MtCO₂e. 3% of net-2040 (≈470 Mt) = ≈ 14.1 MtCO₂e. 5% of net-2040 (≈470 Mt) = ≈ 23.5 MtCO₂e. (I double-checked the math to avoid arithmetic slipups.)
What these different numbers mean in practice
If the percent is applied to the 2040 net target, an allowance of 3–5% implies a small annual use in 2040 (≈14–24 Mt in that single year). If the percent is applied to the 1990 base, the allowed quantity is much larger (≈141–235 Mt) — and press/analysis pieces often convert such a rule into a cumulative demand over a multi-year window (e.g., Commission/analysts have modelled cumulative credit demand 2036–2040 or through 2049 under linear trajectories). Oeko and others showed that such an approach could create hundreds of millions of tonnes of demand across the 2036–2040/2040–2049 periods.
Sources (key documents & reporting)
Council / EU NDC submission (5 Nov 2025) — official text (Council annex / NDC). TERT review (gives 1990 base = 4,699,405 kt CO₂-eq). Commission 2040 communication & Impact Assessment (summary numbers; net 2040 ≈ 450–470 Mt). Reporting on the credit-share debate (3% proposal by Commission; France pushing 5%; Carbon Pulse / Reuters / Argus coverage). Policy analyses that convert percent rules into cumulative credit demand (Oeko, Ecologic, etc.).
Bottom line and next steps
If you want a single, conservative figure for “credits used in 2040”: use ≈ 23.5 MtCO₂e (that’s 5% of the net-2040 level). If you want the larger interpretation (percent of 1990): use ≈ 141 Mt (3% of 1990) or ≈ 235 Mt (5% of 1990) — but note that those are much larger and are often treated cumulatively over years.
——-
Press release from EU
2040 climate target: Council agrees its position on a 90% emissions reduction
Today, the Council has reached an agreement on amending the European climate law (ECL), introducing a binding intermediate climate target for 2040 of a 90% reduction in net greenhouse gas (GHG) emissions, compared to 1990 levels. This new target is a crucial step towards the EU’s long-term goal of achieving climate neutrality by 2050.
The amendment also sets out some areas of flexibility and key elements for the 2040 target and for the post-2030 climate framework. These will steer the Commission’s future legislative proposals to enable member states to hit the 2040 target while supporting European industry and citizens throughout the transition.
Today, we have adopted a 90 percent climate target for 2040 with broad support from the member states. The target is rooted in science and at the same time, it combines our competitiveness and security. This is important for the future of Europe – and it shows that even in challenging times, we can stand united. The target sets a clear direction years ahead for our policies, industries and investments. With this in hand, we are ready to build a stronger, more competitive and secure EU.
Lars Aagaard, Denmark’s minister for climate, energy and utilities
The text agreed today sets out the Council’s position for the upcoming negotiations (‘trilogues’) with the European Parliament that will shape the final text of the legislation.
Main changes agreed by the Council
The Council has maintained the binding 90% reduction of net GHG emissions by 2040 proposed by the Commission. However, it has made some adjustments to reflect concerns about the EU’s competitiveness, the need for a just and socially balanced transition, uncertainty related to natural removals and the diverse national circumstances across member states. These changes were also informed by the strategic guidance provided by EU leaders in the European Council conclusions adopted on 23 October 2025.
Scope for flexibility for the member states
The Commission’s proposal included three flexibility options, to be appropriately reflected in future Commission legislative proposals for achieving the 2040 target. The Council further clarified these areas of flexibility, which include:
the possibility to use high-quality international carbon credits to make an ‘adequate contribution’ towards the 2040 target, quantified as up to 5% of 1990 EU net emissions, from 2036 onwards, including a pilot period for the period 2031-2035
a role for domestic permanent carbon removals under the EU emissions trading system (ETS) to compensate for residual hard-to-abate emissions
enhanced flexibility within and across sectors and instruments to support the attainment of targets in simple and cost-effective ways, allowing member states to address shortfalls in one sector without compromising overall progress
Elements for the post-2030 framework
The amendment to the European climate law proposed by the Commission also establishes a series of principles and conditions that the must be taken into account in developing the post-2030 policy framework to enable member states to achieve the 2040 target and to ensure a fair, cost-effective and socially balanced transition that drives investment. While the Council’s position maintains many of the elements included in the Commission’s proposal, it further develops them, including by:
placing a greater focus onstrengthening the competitiveness of the EU’s economy and industry, as well as on simplification and reduction of administrative burden
clearly emphasising the need for a just transition and taking into account different national circumstances
fostering innovation and the deployment of safe, scalable technologies across all sectors in a technologically neutral manner, while ensuring that energy efficiency remains a central principle
enhancing support for energy security, focusing on renewable energy solutions, energy affordability and grid modernisation to secure the EU’s energy supply
supporting investment and innovation, through both public and private sector funding and ensuring access to innovative technologies across member states
addressing the realistic contribution ofcarbon removals to overall emission reductions, while accounting for the uncertainty associated with them
focusing on the long-term protection and enhancement of natural carbon sinks and biodiversity, addressing the impacts of climate change and natural disturbances on land use and forestry
Review of the target
The Council’s position also introduces a biennial assessment to track progress towards intermediate targets based on the latest scientific evidence, technological advances and the EU’s global competitiveness.
Member states further elaborated and strengthened the review clause of the existing European climate law. Among other things, the review will cover the status of net removals at EU level in relation to what would be required to achieve the 2040 target and the evolving challenges to – and opportunities to improve – EU industries’ global competitiveness. The review will also take into account the evolution of energy prices and their impact on industries and households.
Based on the findings of the review and where appropriate, the Commission will have to propose a revision of the climate law. This may include adjusting the 2040 target or other additional measures to strengthen the enabling framework, namely to secure the EU’s competitiveness, prosperity and social cohesion.
ETS2 postponement
The Council also introduced a provision to postpone the entry into application of the EU emissions trading system for buildings and road transport (ETS2) by one year, from 2027 to 2028.
Next steps
The Council presidency will start negotiations with the European Parliament once the latter adopts its position, with a view to agreeing on the final text of the amendment.
Background
First adopted in 2021, the European climate law provides the legal foundation for the EU’s long-term climate policies, in line with the Paris Agreement. It sets a binding economy-wide climate neutrality target by 2050 and a 2030 objective of reducing net emissions by at least 55%. It also provides for the establishment of an intermediate climate target for 2040.
After publishing the communication ‘Europe’s 2040 climate target’ in February 2024, the European Commission put forward a proposal on 2 July 2025 to amend the European climate law to set a 2040 target.
More recently, in October 2025 the European Council provided strategic guidanceon the way forward to establish a target for 2040. In particular, leaders emphasised the need for a balanced approach that would preserve and boost the EU’s competitiveness, while ensuring the social fairness of the transition. They also emphasised the need to take into account the uncertainties of natural removals. The European Council additionally called on the Commission to further develop the necessary enabling conditions to support European industry and citizens in achieving the 2040 target.
