Recommendations for the EU Climate Law amendment
On 15 September 2025, Zero Emissions Platform (ZEP) responded to the European Commission’s public consultation on the EU Climate Law amendment. Drawing on insights from a broad range of technical experts in the industrial carbon management community, our recommendations support an ambitious target and a robust implementation framework.
About the consultation response
Establishing a 2040 target is an essential milestone to keep the European Union (EU) on track for climate
neutrality by 2050 and net-negative emissions thereafter, while also supporting European industrial competitiveness in a net-zero economy. By setting an ambitious target, the EU can reaffirm its leadership in climate action.
The proposal acknowledges the key role of industrial carbon management in achieving the 2040 target and in strengthening industrial resilience. It highlights the need to deploy and scale up clean technologies and low-carbon solutions, such as carbon capture and storage (CCS), carbon capture and utilisation (CCU), and carbon dioxide removal (CDR). Specifically, it acknowledges the credible and transformative nature of permanent carbon removal technologies, such as direct air carbon capture and storage (DACCS) and biogenic emissions with carbon capture and storage (BioCCS).
Our recommendations support an ambitious target and a robust implementation framework.
Key recommendations
Adopt separate targets for greater transparency and integrity
The EU should adopt distinct, science-based targets for greenhouse gas emission reductions, permanent carbon removals, and temporary removals, respectively. This would better reflect the different roles that each can play to counterbalance fossil CO2 emissions.
Set safeguards to compensate for legislative uncertainty
The EU should clarify as soon as possible whether the listed flexibility will be adopted and specify what safeguards will be introduced, both to preserve a high level of climate ambition and to guarantee transparency and integrity.
Preserve the EU ETS integrity by limiting scope expansion
Any potential inclusion of CDR credits into the EU ETS should be restricted to DACCS and BioCCS, together with robust MRV, proven permanence, and alignment with the EU ETS architecture to avoid mitigation deterrence and market destabilisation.
Restrict the use of international carbon credits
Should the use of international carbon credits be allowed to count towards the EU 2040 climate target, clear guardrails should be set so that only permanent removals of the highest quality are eligible, in very limited volumes, and in line with EU standards.
Leverage EU competitiveness in industrial carbon management
A strong EU 2040 climate target and industrial competitiveness can mutually reinforce each other. By leveraging its leadership in industrial carbon management, the EU can advance climate goals, support employment, and stimulate innovation.