Climate Leadership Coalition (CLC) welcomes the European Commission’s proposal for Climate Law as a key component of the European Green Deal to reach climate neutrality by 2050. The Commission’s Climate Law proposal with the goal of climate neutrality by 2050 will improve the long-term legal predictability that is required to enable massive investment from companies.

CLC would like to present the following remarks for consideration before closing the legislative package of the Green Deal:

  • CLC proposes further clarification of the target: to define an EU-level carbon budget for the net-emissions up to 2050 as part of the impact assessment for the possible increase of the 2030 target.
  • CLC points out that the Climate Law does not take into account the climate impacts of imported goods into the Union and hence member states. According to the Global Carbon project, the contribution of imports has been reported as significant since 1990, Figure 1. In the future, when EU climate policies will tighten, the contribution of imports may grow. CLC proposes objectives, measurements and measures, if needed, to manage the issue. The best way to tackle this is to push for a global coalition that works together on the implementation of the Paris agreement.

  • The Commission’s proposal does not address what should happen post 2050. If there will be a future need to reach a future state where removals of greenhouse gases exceed emissions, the objectives for this should be developed well before 2030 in order to develop additional carbon sinks and new technology to generate utilisation of CO2 and negative emissions on time. Progress in carbon utilisation and removal technologies might also provide the necessary boost for additional emission reductions in the EU already in the 2020 – 2050 timeframe, i.e. achieving climate neutrality earlier than predicted.
  • The Commission’s Climate Law proposal does not include international offset or trading opportunities either. CLC views that enabling the use of credible offset mechanisms or transfer of allowances (in line with Article 6 of the Paris Agreement and its subsequent guidance) that would help offset the ‘residual emissions’ would bring valuable flexibility, increasing the likelihood of meeting the target level despite the risks of loss of carbon sinks in the LULUCF sector or due to unpredicted technological obstacles. For example, in Sweden there is a strategy proposal and a discussion to include option1 to use offset mechanisms as part of the national policy towards climate neutrality by 2045. Enabling trade across borders and the use of credible offset mechanisms would also enable important co-financing of low carbon projects and programmes, and secure continuity of established low-carbon schemes in the developing economies as well as encouraging new countries to take such schemes into use.

CLC would appreciate it if the legislative package of the Green Deal would include and enable these elements.

More information: Jouni Keronen, jouni.keronen(at), tel. +358 50 453 4881.

Climate Leadership Coalition (CLC) is a non-profit organisation committed to the pursuit of carbon-neutrality through the sustainable use of natural resources. The purpose of CLC is to promote the sustainability of businesses, city planning strategies and activities of research organisations towards more sustainable and resource efficient models. CLC enhances its members’ ability to respond to the threats posed by climate change by sharing information, ideas and best practice solutions. We make proposals to governments and other stakeholders to harness the market economy in a more sustainable direction and to attract sufficient investments for such a transition. CLC believes that green transition can be economically beneficial, and therefore financeable, and that early adapters can benefit and become more profitable. CLC currently has 64 organisational and 25 private members (as at March 2020).