Consultation Response: Amendments to the European Climate Law

Carbon Balance Initiative welcomes the opportunity to respond to the EU’s proposal to amend the EU Climate Law by introducing an intermediate 2040 target. We commend the Commission’s proposal of a net 90% emission reduction target by 2040 but emphasise that further strengthening is needed to align with scientific advice, provide a credible pathway to climate neutrality by 2050, and enable a transition to net-negative emissions thereafter. While we recognise the essential role of removals, strict conditions must apply; emission reduction must remain the priority, and any removals used to balance fossil emissions must rely on geological-timescale storage.

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To maximise ambition, clarity, and integrity, we recommend three areas of strengthening:

• We recommend establishing disaggregated accounting for emission reductions, permanent removals, temporary removals, and passive sinks.

• We strongly encourage limiting reliance and safeguarding the integrity of international credits under Article 6, adopting the Oxford Principles for Responsible Engagement with Article 6.

• We propose clarifying legislative definitions and encourage a precautionary approach to minimise flexibilities in the use of removals and cross-sector compensation.