Framework for achieving climate neutrality

1 Ref. Ares(2025)7944319 - 22/09/2025 16 September 2025 IETA Feedback to European Commission Public Consultation - Climate Law Review The International Emissions Trading Association (IETA) welcomes the European Commission’s proposal to establish the EU 2040 climate target and to review the Climate Law.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The cogeneration sector is committed to building a resilient, decentralised and carbon-neutral European energy system by 2050. The EU must support ambitious, but realistic and evidence-based, emissions reduction pathways based on a technology inclusive approach to secure important investments in climate solutions in the coming years.

SHORT 200 WORD VERSION BELOW Oatly – Response to the European Commission Proposal on the EU 2040 Climate Target Introduction Oatly welcomes the Commission’s proposal to amend the European Climate Law by setting a binding 2040 climate target.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Commissions proposal for the 2040 climate target prioritises ambition over economic reality, placing additional strain on businesses already struggling with high energy costs, regulatory burdens and an uneven global playing field. Eurochambres calls for a pragmatic and business-friendly approach that aligns climate ambition with industrial competitiveness.

The European Peat Alliance welcomes the possibility for feedback for the European Climate Law amendment. The Peat Alliance represents European peat producers, with a distinct focus on the production of horticultural peat for professional and hobby growers. Horticultural peat is a vital component in the professional production of vegetables, berries, flowers, forest tree seedlings, and herbs.

UNICA welcomes the European Commissions proposal to set a binding 2040 climate target of a 90% net reduction in emissions and fully supports the ambition for technological neutrality, fairness, and cost-effectiveness. Brazilian ethanol is one of the most sustainable and scalable biofuels globally, certified as Low ILUC risk and fully compliant with ICAO-CORSIA standards.

Galp acknowledges the Commissions initiative to set an EU 2040 climate target and considers the introduction of intermediate milestones as a valuable step to ensure a clear, ambitious, and achievable pathway. Such a pathway must balance climate ambition with pragmatism, while safeguarding Europes security of supply and energy independence.

European Climate Law amendment – Consultation 17 September 2025 The European Federation of Engineering Consultancy Associations (EFCA) has member associations in 27 countries, representing more than 10,000 companies from the European engineering consultancy industry and related fields.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Pohjolan Voima (PVO), one of Finlands largest energy producers, thanks the European Commission for the opportunity to contribute feedback on the amendment to the European Climate Law to include the EU's 2040 Climate Target.

Comments on Proposal for 2040 Climate Target Mary S. Booth, PhD Partnership for Policy Integrity September 17, 2025 Contents Introduction and summary ................................................................................................................ 2 Approach ..........................................................................................................................................

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

To achieve climate neutrality by 2050, the EU will need to scale both domestic and international carbon dioxide removal (CDR). While the EU's 2040 Climate Target is commendably ambitious, current policy frameworks underutilise the potential of high-integrity CDR solutions emerging from the Global South. The Global South CDR Coalition makes the case for integrating international CDR into the EU Climate Law.

Rubicon Carbon Supports the EUs 2040 GHG Reduction Target with Flexibilities and the Inclusion of Carbon Credits in the EU ETS Summary points Rubicon Carbon supports the EUs 2040 target and strongly recommends the inclusion of market mechanisms (i.e.

To achieve climate neutrality by 2050, the EU will need to scale both domestic and international carbon dioxide removal (CDR). While the EU's 2040 Climate Target is commendably ambitious, current policy frameworks underutilise the potential of high-integrity CDR solutions emerging from the Global South. The Global South CDR Coalition makes the case for integrating international CDR into the EU Climate Law.

EURIMA response to the European Commission’s Amendment to Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality EURIMA welcomes the Commission’s proposal to amend the European Climate Law to include a 2040 climate target, an essential milestone to keep the EU firmly on track towards climate neutrality by 2050.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Entrepreneurs CEA-PME, as representative of the interests of our 1.5 million only voluntarily associated SME and Mid-Caps all over the continent, has been very doubtful about the European Commissions proposal to set a statutory target of -90% emissions reduction by 2040, since it has been under discussion.

September 2025 European Climate Law amendment - 2040 targets feedback As a world leader in gases, technologies and services for Industry and Health, Air Liquide is present in 60 countries with approximately 66,300 employees and serves more than 3.8 million customers and patients. Oxygen, nitrogen and hydrogen are essential small molecules for life, matter and energy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

From growing, representing the whole value chain in the field of sustainable mobility and renewable fuels in Spain, we welcome the opportunity to participate in this amendment of the European Climate Law and welcome the proposal to set a binding intermediate climate target for 2040, providing predictability and certainty for industry and investors on the path to climate neutrality in 2050.

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2040 target - We fully support the EUs ambition to remain a driving force in global decarbonisation efforts and to reduce net greenhouse gas emissions by 90% by 2040 compared to 1990 levels. Sticking to these commitments is essential to provide a strong and credible signal for current and planned investments in low-carbon technologies.

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy plants in operation in Europe. It seeks to promote the technologies which recover both energy and materials from non-recyclable waste that would otherwise end up in landfills.

CurrENT welcomes the European Commissions intention to propose a binding Union target for 2040 in accordance with Article 1 of the EU Climate Law, as well as the amendment of Article 4, which sets the climate target as a reduction of net greenhouse gas emissions (emissions after deduction of removals) by 90% compared to 1990 levels.

Group De Ceuster (GroupDC) is a Belgian family-owned company, founded in 1966. Today, we operate in more than 105 countries with 13 production sites and over 800 employees. We are a European leader in plant care, biosciences, and animal care, committed to advancing sustainable agriculture through innovative, science-based solutions.

The proposal is, in fact, a measure along the lines of the European Green Deal, continuing its ideological approach, with little focus on a concrete transition that has little to do with maintaining European production capacity. Please consult the annex for more details.

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Statkraft supports an ambitious climate reduction target of at least 90% of domestic emissions by 2040 in line with the advice from the Commissions own scientific advisory board. The EU is a global leader on climate and Statkraft supports a strengthening of policies in line with the Paris goals and in line with reaching the 2050 target.

Unem’s reply to the Climate Law consultation. Policies need to be strengthened through transparency and enabling conditions for the 2040 climate objective. Mr Unem welcomes the proposal to set an ambitious climate target for 2040 of a net 90 % reduction in greenhouse gas emissions compared to 1990 levels, but the current regulatory framework does not sufficiently clarify the distribution of residual emissions across…

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Technip Energies (T.EN), technology and engineering provider, welcomes the opportunity to contribute to this consultation. Being committed to the European net-zero trajectory, we support the establishment of a 2040 emissions reduction target in the European Climate Law.

Enagás fully supports the establishment of a robust and forward-looking legislative framework to deliver the 2040 climate target. The company is committed to playing an active role in the decarbonisation of the European economy through the development of renewable hydrogen infrastructure, the transformation of existing assets, and the deployment of innovative solutions across the energy value chain.

Integration between technological and nature-based solutions Restricting the concept of permanence only to geological or long-term storage technologies narrows the range of possible solutions, limits scalability, and may delay immediate progress.

Response to EU Consultation, September 2025 Ref. Ares(2025)7944240 - 22/09/2025 Emergent Supports the 2040 GHG Reduction Target with Flexibilities and the Inclusion of Carbon Removals in the EU ETS Overview As Emergent Forest Finance Accelerator (Emergent), we strongly support including flexible market mechanisms such as carbon credits, to ensure the 2040 target is achievable in a costeffective manner, while…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Ensuring the EUs 2040 Climate Target has a strong and legally binding target is essential to ensure climate goals are achieved and communities in the EU are protected from further global heating and its impacts on health, food security, and economic risk.

Liquid Gas Europe submits this response to the proposed amendment of the European Climate Law introducing a 2040 greenhouse gas reduction target. Achieving a 90% reduction by 2040 will only be possible if the policy framework enables all effective decarbonisation solutions within a coherent, predictable, and technology-neutral structure.

Bioenergy Europe welcomes the Commissions proposal to amend the Climate Law with a 2040 target of at least 90% net GHG reduction, recognising it as a crucial milestone to remain on a science-based path to climate neutrality by 2050 and to safeguard the EUs credibility under the Paris Agreement.

Finnish Energy (ET) welcomes the Commissions proposal to achieve 90% net emission reductions by 2040 compared to emissions level in 1990. Finlands own goal is to achieve carbon neutrality by 2035. Achieving this goal requires all zero and low carbon energy solutions, including renewables, nuclear, energy efficiency, storage, CCS, CCU, natural carbon removals, geothermal, hydro-energy, and other current and future…

CO2 Value Europe is the European association representing the Carbon Capture and Utilisation (CCU) community in Europe and working for the recognition of CCU as an essential pathway to reach EU climate goals in 2030, 2040 and 2050. As a CCU community, we support the 2040 climate target proposal.

Hydro is pleased to contribute to the European Commissions consultation on the proposed amendment to the European Climate Law, including the 2040 climate target (COM(2025)524 & SWD(2025)524). As a fully integrated aluminium and energy company with operations in over 18 European countries and more than 18,000 employees, Hydro supports the EUs ambition to reach net zero by 2050 and is committed to achieving this goal…

We, European youth organisations, welcome the European Commission's formal proposal to amend the EU Climate Law to include a 2040 target of 90% net greenhouse gas emissions reductions following months of delays and speculation. However, as stated in our previous reaction, we believe that more ambition is needed in line with scientific advice.

The European Waste-to-Energy sector, together with the whole waste management industry in Europe, is ready to engage in increased efforts to realise the CO2 savings potential of a more circular economy towards 2040 and beyond.

A Climate Act must phase out the production and use of fossil fuels. This also makes Europe independent of energy imports, strengthening Europe. Climate policy should not be based on CDR technologies or carbon offset programs. The necessary carbon removal must be based on the restoration and expansion of nature and foreststhat is, on nature-based solutions.

UFE supports the adoption of an ambitious and growth-friendly EU climate target for 2040, provided it is underpinned by a credible and pragmatic framework that safeguards European industrial competitiveness. The effectiveness of the target will depend entirely on Europes capacity to implement it.

- Nordenergi fully supports an ambitious EU climate target and the intermediate 2040 target of 90 percent emission in line with the 1,5-degree target set by the Paris Agreement. Efforts to limit climate change must accelerate and the 2040 target will pave the way toward the EU goal of climate neutrality 2050.

Key messages from Renewables Norway: We support a 2040 climate target of 90% emission reductions to reach climate neutrality in 2050. An ambitious climate policy is needed to meet the 1,5-degree target of the Paris agreement. Regulations should be based on market-based principles - carbon pricing through ETS should remain the key instrument. Care should be taken when introducing international credits.

The 2040 climate ambition calls for an industrial revolution, but Europe is not yet equipped with the means. The European Union has proposed a climate target of -90 % net emissions by 2040. This approach represents an unprecedented transformation in just 15 years for the industry, including the steel industry.

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CEFS, the European Association of Sugar Manufacturers, represents at once an agricultural and an industrial sector. Beet sugar manufacturing is characterised by high energy- and trade-intensity, making it a carbon leakage sector under the EU Emissions Trading System (ETS). Sugar is the second largest energy user and the second largest CO2 emitter within the agri-food sector (after animal feed).

Sysav, owned by 14 Swedish municipalities, supports the proposed 2040 climate target of a 90% net emissions reduction compared to 1990, viewing it as essential for aligning with the Paris Agreement and maintaining a 1.5°C pathway. A clear interim target will accelerate early emission cuts, drive innovation, strengthen EU competitiveness, enhance energy security, and reinforce the EUs global leadership.

The Food and Beverage Carton Alliance (FBCA) supports the proposal by the European Commission to amend the EU Climate Law with a 2040 interim greenhouse gas reduction target by 90% compared to 1990 levels. We consider a legally binding, intermediate target to be vital to mitigating the impact of climate change while providing the necessary long-term policy stability and legal certainty the industry needs to direct…

Hydrogen Europe welcomes the opportunity to comment on the proposed amendment to the European Climate Law. The European hydrogen industry agrees with the European Commissions strong ambition, standing by its commitment to a 90% emission reduction by 2040, compared to 1990 levels.

Deutscher Naturschutzring, umbrella organization for environmental groups in Germany, welcomes the Commissions proposal for an urgently needed emissions reduction target for 2040. At the same time, we critically note that the proposed level of ambition falls short of scientific recommendations and the EUs fair share of global climate action.

ADAC e.V., with over 22.4 million members, is the largest automotive club in Europe and promotes the mobility of its members as a non-economic association and recognised consumer association. The focus is on help, protection and advice in the event of a breakdown, accident, illness and home settings. In addition, ADAC e.V. is strongly committed to transport safety, consumer protection and the environment. ADAC e.V.

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EUROFER paper: the 2040 climate target requires an industrial revolution, but its enabling conditions are not there yet The debate on the 2040 targets offers the opportunity for a reflection on the contribution of the EU climate policy to the objectives of the Clean Industrial Deal and more broadly on EU’s role in the global arena.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Union of Agricultural Producers and Forest Owners MTK thanks for the opportunity to comment the Commissions proposal for the European Climate Law amendment. MTK supports the EU overall climate target for 2040.

Position Paper EU climate target for 2040 September 15th, 2025 EdEn welcomes the EU public consultation in view of establishing a 2040 climate target. As regards the proposed objective for 90% of GHG emission reduction by 2040, EdEn would like to point out the very high level of ambition that such an objective would represent.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

From the ÖGB’s point of view, it is essential that climate policy follows clear predictability and clear intermediate targets for 2040 make an important contribution to this. In this context, companies and employees need to be able to rely on policy objectives in order to be able to make investment decisions, including decisions on their education and training.

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Anew Climate Response to EU Consultation on the European Climate Law Amendment Introduction Anew Climate LLC (“Anew”) is one of the largest climate solutions companies in North America, with an expanding presence in Europe and growing offices in Germany, Spain, and Hungary.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Assotermica’s comment to the public consultation on 2040 climate target ASSOTERMICA – Associazione produttori apparecchi e component per impianti termici is the Italian association federated with Anima Confindustria that represents manufacturers of appliances and components for environmental climatic comfort.

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CAN Europe’s feedback to EU Commission call for evidence European Climate Law amendment on EU 2040 climate target The proposed 2040 climate target lags behind a science-aligned and fair EU contribution. Both the Commission’s own Impact Assessment and the ESABCC recommend a 90-95% net domestic target, and indicate that higher ambition levels are most beneficial and better reflect equity principles.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eurofuel, the European Liquid Heating Fuels Association, supports the EU's climate target for 2040 and the goal of achieving climate neutrality by 2050. Renewable liquid heating fuels are a proven, scalable, and socially equitable solution that must be integral to Europe's energy transition.

The PRI welcomes the European Commissions proposal to target a 90% reduction of net GHG emissions by 2040. More than 150 companies, investors and organisations call for a target of at least 90% to decarbonise the economy and strengthen its competitiveness, innovation, and resilience to shocks and energy security.

While the European non-ferrous metals (NFM) industry is committed to EUs climate objectives, an ambitious 2040 target will require a massive transformation of energy-intensive industries in just 15 years. Achieving an ambitious target will depend on breakthrough technologies, significant investments and a supportive policy framework, including financial support to create viable business cases for each sector…

Representing manufacturers of European heating systems, the European Heating Industry (EHI) welcomes the opportunity to share its views on the EU Commissions proposal to amend the European Climate Law to include the 2040 Climate Target.

AECC appreciates the opportunity to comment on the proposed amendment to the European Climate Law which will set the overarching direction of EU climate policy. We share the European Commissions commitment to advancing decarbonisation, and welcome the proposal to set an ambitious interim target that will allow us to reach carbon-neutrality by 2050.

Iberdrola welcomes the ECs initiative to review the European Climate Law and its ambition to reduce emissions by 90%, which sets the EU on a clear trajectory to achieving net-zero emissions by 2050. However, the proposed target could be improved by distinguishing the contributions from gross emissions reductions, land-based sequestration and permanent removals to ensure full accountability of the target, and by…

We are grateful for the opportunity to submit our position on the proposed changes to the European Climate Law. We would like to emphasize that the greenhouse gas emission reduction targets for 2040 will play a key role in the competitiveness of the EU's energy-intensive industry.

UPEI, the voice of European independent energy and mobility suppliers, welcomes the opportunity to provide its comments to the proposed amendment to the European Climate law. We support the setting of an intermediary target between those set for 2030 and 2050, as it helps create a unified legal framework for Member States and economic stakeholders.

IFIEC Europe, calls for a realistic and innovation-aligned 2040 climate target that supports industrial transformation without compromising Europes competitiveness. The target must be conditional on enabling factors and designed to avoid irreversible deindustrialisation. See our position in attachment.

Renova is a waste and recycling company owned by ten municipalities in Sweden. We run our waste collection fleet of about 280 heavy vehicles on fossil free fuel since 2015. We sort out recyclable material from waste and offset it on a recycling market. Waste that is not suitable for recycling, goes to our Waste-to-Energy (WtE) plant in Göteborg. Non-combustible and non-recycable waste is landfilled.

FIA Region I recognises the urgent need to reduce greenhouse gas emissions across all sectors, including transport. Climate change poses serious long-term risks to both the environment and the resilience of mobility systems. However, climate policies must be designed to be technologically feasible, socially equitable, and consistent with the right to affordable and accessible mobility for all citizens.

Overall target and domestic action: Uniper fully supports the European Unions ambition to remain a key driving force in global decarbonization efforts and the fight against climate change. In this role, the EU must lead by example, foster international cooperation, drive the development and maturation of clean technologies while supporting its competitiveness agenda.

The full nucleareurope contribution is available in attachment. In July 2025, the European Commission issued its proposals to amend the European Climate Law and set an EU climate target for 2040. Nucleareurope welcomes this proposal and calls for an ambitious, pragmatic, and technology neutral framework to support net-zero investments.

Europes chemical and life sciences industry faces structural challenges from high energy costs, regulatory uncertainty, and declining competitiveness. A -90% emissions target by 2040 risks irreversible deindustrialization, as it is misaligned with innovation cycles and industrial investment horizons.

The Cool Heating Coalition, the civil society voice on heating and cooling, welcomes the setting of a 2040 target for the EU. To ensure this target delivers real and effective greenhouse gas emission reductions, we strongly recommend that the Commission take the following points into account: - Heating and cooling should be clearly referenced in Article 5(4) of the European Climate Law as a key sector relevant to…

We consider that the proposed target for 2040 falls short of a fair and science-aligned contribution, compared to the recommendations of the Commission’s own Impact Assessment and ESABCC, which point to a net household target of 90-95 %. It also reflects the demand of civil society for more ambitious targets, capable of generating greater benefits and responding to equity principles.

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The 90% emission reduction target must be treated as a baseline, not the end point. To turn ambition into investable reality, Europe needs interim checkpoints, sectoral safeguards for buildings, and financing frameworks that crowd in private capital at scale. Without these, the path to 2050 neutrality risks being delayed and more costly.

The Federation of Finnish Enterprises represents almost 70 000 Finnish micro, small and medium-sized enterprises (SMEs) through local chapters and around 36 000 through trade associations. We support enshrining a robust 2040 target in the Climate Law to keep the EU on a credible path to climate neutrality by 2050.

The Finnish Food and Drink Industries Federation (ETL), representing food industry in Finland, welcomes the opportunity to respond to the European Commissions consultation on the proposed amendment to the European Climate Law. The European Commission proposes a 90 percent reduction in the EU's net emissions by 2040.

The IEEP welcomes the proposed EU net 90% emissions reduction target for 2040 while expressing concern regarding key elements that diverge from the Commissions recommendation for the target from February 2024, notably the incorporation of international credits and the absence of distinct targets for emission reductions and carbon removals.

The German Biogas Association welcomes the European Commissions proposed target to reduce greenhouse gas emissions by 90% by 2040 compared to 1990 levels. However, the option to meet up to 3% of the target via international carbon credits from 2036 onwards weakens the domestic focus of EU climate policy and raises concerns around oversight, additionality, and certification.

This is feedback on the amendment to the European Climate Law to include the 2040 climate target, which would put the EU firmly on a path towards climate neutrality by 2050. It comes from the National Centre for Emission Management (KOBiZE, Poland).

GEVO VIEWS ON THE EU’s 2040 CLIMATE TARGET As a producer of sustainable aviation fuel (SAF) using the Alcohol-to-Jet (AtJ) pathway, Gevo is following closely the development of the EU’s climate and low-carbon fuel policy as well as other measures aimed at facilitating the kinds of major green investments that are needed for deep decarbonization of the EU’s transport sector.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Sirk Norge (the Norwegian Recycling and Circular Economy Association) fully supports the proposed Union 2040 climate target. Several EU countries are already lagging behind on the 2030 targets. A stringent 2040 target will help ensure that countries uphold their national efforts to cut emissions, rather than delaying action and postponing transitions in favor of the Effort Sharing Regulation.

POSITION PAPER September 2025 Cefic Position Paper on the European Commission’s 2040 Climate Target proposal The European chemical industry supports the objective to reach carbon neutrality by 2050 by stimulating investments into the European economy.

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These are Ferns observations on the proposed EU Climate Law Amendment: - As the ESABCC observed, a 90-95% domestic reduction by 2040 is feasible and aligned with Europes strategic interests. The European Commission failed to align its initial proposal on this scientific recommendation, and Member States are now weakening it further.

‘Alignment with existing regulations The proposed change to the 90 % emission reduction target does not itself provide tools for its actual implementation’. It is necessary first to ensure the consistency of EU legislation (EED, EPBD, ETS, RED, etc.). Stable regulatory framework is vital to the transformation of the heating and energy sector.

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We consider the European Commissions proposed 2040 target to be insufficient to set the EU on a clear path to climate neutrality and ensure climate action takes place with the urgency that is required. The clear recommendation from the European Scientific Advisory Board on Climate Change (ESABCC) for a 90-95% domestic emissions reduction target must be respected and enacted without further delay.

Carbon Engineering’s response to the “European Climate Law Amendment” proposal for regulation We appreciate the opportunity to provide feedback on the European Commission's proposed amendment to the European Climate Law (Regulation (EU) 2021/1119) to set a European Union (EU) climate target for 2040.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

15th September 2025 EDF's position paper on the European Climate Law amendment EDF fully supports the European Union’s climate ambition and is committed to achieving net-zero emissions by 2050. As the world’s largest producer of electricity with zero direct CO₂ emissions 1 - thanks to its nuclear and renewable assets - EDF advocates for a strong 2040 climate target aligned with the EU’s 2050 neutrality goal.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The proposal for a regulation amending Regulation (EU) 2021/1119 defines as its aim the contribution to the EUs path to climate neutrality. While we, the Centre for Research on Multinational Corporations (SOMO), welcome the Commissions effort to mitigate climate change, we are also very concerned with the proposed inclusion of carbon removals and offsets in the regulation.

The Horizon Europe project BEATLES (Co-creating Behavioural Change Towards Climate-Smart Food Systems, 20222026) seeks to transform agri-food systems and accelerate the shift to Climate-Smart Agriculture (CSA) and smart farming technologies.

Carbon Balance Initiative welcomes the opportunity to respond to the EUs proposal to amend the EU Climate Law by introducing an intermediate 2040 target. We commend the Commissions 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…

Pohled ČPS na návrh nařízení Evropského parlamentu a Rady, kterým se mění nařízení (EU) 2021/1119 o rámci pro dosažení klimatické neutrality Český plynárenský svaz (ČPS), vědom si mezinárodních závazků ČR a EU v oblasti klimatu, podporuje snahu o snižování emisí, ale nemůže podpořit navrhovaný cíl pro rok 2040 a upozorňuje na nutnost jeho redefinování tak, aby byl prakticky dosažitelný.

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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

C40 Cities welcomes the proposal to amend the European Climate Law to set a 2040 target. This is a crucial opportunity to give certainty for governments, businesses and citizens on Europes pathway to climate neutrality. The urgency is clear: Europe faces record heatwaves, floods and wildfires with devastating consequences for people, economies and ecosystems.

Bioenergia ry the Bioenergy Association of Finland - supports consistent progress towards the 2050 climate neutrality target in setting the EU's 2040 climate target. Despite the energy crisis and war, the EU cannot afford to jeopardize its long-term net-zero target but must proceed decisively towards it in the medium term as well.

The situation of European industry, and in particular the European aeronautics industry, has changed significantly in recent years. This has led in particular to the COVID-19 pandemic and international conflicts. While the pandemic has triggered the largest historical crisis in civil aviation, international conflicts continue to contribute to disruptions and uncertainties in European and global aviation.

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CLC supports the 90% emission reduction target by 2040 CLC welcomes the Commissions proposal to include a 90% GHG emissions reduction target by 2040 in the Climate Law. The 2040 emissions reduction target should be adopted before COP30 in Belém to demonstrate the EUs support for the multilateral climate action.

We strongly oppose the proposed 90% climate target for 2040 as this would directly endanger existence of the steel sector in the EU, with all the social, economic and strategic consequences. No ambitious goals should be set until enabling conditions for decarbonisation are in place. Please, read more in the attached position.

Our organisation is a global Ecofeminist network with offices in Germany, France and the Netherlands, we work jointly with over 250 members and partner organisations for the transition to a sustainable future. We oppose the proposal for increasing offsetting through climate credits.

Stockholm Exergi would like to emphasise the critical importance of the 2040 target in sending a clear message to investors, other market actors, citizens and Member States parties and legislators. The political signal sent by the 2040 climate target is fundamental for Europes ability to reach net-zero by 2050.

DENSO is a global mobility supplier that develops electrification, powertrain, thermal, mobility electronics, and advanced devices advanced technology and components for nearly every vehicle make and model on the road today. In Europe, DENSO operates across 36 locations in 15 European countries, employing more than 13,000 people, and has a consolidated revenue of 3.9 billion.

Shell1 commends the EU’s continued climate leadership and efforts to achieve climate neutrality by 2050. We support the focus on delivering an investment-driven agenda that advances both decarbonisation and economic growth as set out in the Clean Industrial Deal. Our own target is to become a net-zero emissions energy business by 2050.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The proposed 2040 climate target lags behind a science-aligned and fair EU contribution. Both the Commissions own Impact Assessment and the ESABCC recommend a 90-95% net domestic target, and indicate that higher ambition levels are most beneficial and better reflect equity principles.

Dow’s priorities for industry decarbonization in the European Union Open public consultation concerning the 2040 European Climate law amendment 15 September 2025 Dow is one of the world's leading materials science companies, serving customers in high-growth markets such as packaging, infrastructure, mobility and consumer applications.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Comments from the Union of Farmers’ Unions Public consultation on the proposal for a Regulation amending Regulation (EU) 2021/1119 to establish a binding climate target of 90 % net emission reduction for 2040. We share the concern about climate change and the need for a roadmap towards climate neutrality.

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Zero Emission Platform (ZEP) welcomes the European Commissions proposal to establish a 2040 climate target and commends the 90% emissions-reduction ambition. By setting an ambitious target, the EU has the opportunity to demonstrate that climate leadership can drive industrial competitiveness in a carbon-neutral economy.

Member of European Chemical Industry Council CEFIC Warsaw, 15.09.2025 PIPC/102/2025 Polish Chamber of Chemical Industry position on the amendment of the European Climate Law and the proposal of the 2040 climate target On 2 July 2025, the European Commission presented a proposal to amend the European Climate Law and to set the EU climate target for 2040 – a 90% net reduction in greenhouse gas emissions compared to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

2025 In considering what the EU target for 2040 should be what is a needed is a disciplined and hard approach to reviewing, and implementing, corrections to adapt the existing framework to the changed global socioeconomic realities. This is an important moment for the EU and the world.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

September 2025 SSAB feedback on the European Climate Law amendment public consultation SSAB is committed to our transformation journey and is currently investing more than €5 billion to transform our Swedish steel production system.

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DAFC finds that the Commission's proposal for a 2040 climate target of a 90% reduction in emissions compared to 1990 is ambitious but agrees that it is necessary to maintain focus and pace in the work to reduce greenhouse gas emissions and thus mitigate climate change. Agriculture must also continue to contribute to ensuring the necessary reductions.

Recently, in its opinion, the International Court of Justice stressed that climate change poses an existential threat to humanity and to nature as a whole. Compliance with human rights is not possible without effective climate and environmental protection.

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Floene welcomes the opportunity to respond to the European Commission's (EC) public consultation on the Union-wide binding climate target of a 90% net reduction in greenhouse gas emissions by 2040, relative to 1990 levels. As Portugal's leading gas distribution group, Floene serves over 1.1 million consumption points - residential, commercial, and industrial - covering 72% of the national market.

Via Upload Date: 15 September 2025 Subject: European Climate Law amendment Dear Madam or Sir, SEFE, an international energy company, ensures the security of supply and drives the decarbonisation of its customers and trading counterparts. SEFE’s activities span the energy value chain, from origination and trading to sales, transport and storage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ePURE, representing European producers of renewable ethanol from crops, waste and residues, supports the Commissions intention to set up an intermediate target to reach a 90% greenhouse gas emission reduction by 2040 and reach climate neutrality by 2050.

Thank you for the opportunity to contribute to this public consultation. Envien Group welcomes the European Unions ambition to strengthen its climate policy and set a clear trajectory toward climate neutrality. However, we believe that this ambition must be pursued through a realistic, inclusive, and technologically neutral framework that respects the diversity of national circumstances and supports all viable…

STX Group supports the EUs binding target to reduce net greenhouse gas emissions by 90% by 2040, emphasizing the need for a comprehensive policy framework that combines carbon removals, international credits, renewable fuels, and energy efficiency to achieve cost-effective and competitive decarbonization.

FuelsEurope welcomes the European Commissions consultation of stakeholders on the proposal for a Regulation to amend the European Climate Law to include the 2040 climate target. This target marks a critical milestone in the EUs climate ambition and will require a coherent and robust policy framework across all sectors. As committed partners in the energy transition, we fully support the EUs climate objectives.

The VDMA represents 3600 German and European mechanical and plant engineering companies. The industry stands for innovation, export orientation and SMEs. The companies employ around 3 million people in the EU-27, more than 1.2 million of them in Germany alone. This makes mechanical and plant engineering the largest employer among the capital goods industries, both in the EU-27 and in Germany.

Cepi represents the European pulp and paper industry and gathers, through its 19 member countries, almost 850 pulp, paper and board mills of which some 140 biorefineries across Europe, directly employing about 175,000 people to reach 95 billion turnover in Europe in 2024. Currently, it is estimated that the pulp and paper industry invests over 5 billion annually, primarily in clean energy solutions.

EuLA, the European Lime Association, represents European non-captive lime production through its 24 covered Member States (companies & national associations). Lime is one of the essential building blocks of modern industry.

Nordic Family Forestry Alliance (NSF) takes note of the Commission proposal to reduce the Unions net greenhouse gas emissions by 90 % compared to 1990 levels by 2040. Nordic family forest owners strongly support the decarbonization of the European economy, aligning two major ambitions: the urgent reduction of our Unions dependency on fossil fuels and fossil-based materials, as well as the creation of an enabling EU…

European Environment Agency, Transport and environment report 2021, Decarbonising road transport — the role of vehicles, fuels and transport demand, EEA Report No 2/2022 2 European Environment Agency, Transport and environment report 2020, Train or plane?, EEA Report No 19/2020 3 European Commission, Statistical Pocketbook 2020, tables 3.2.12, 2.3.3 and 2.2.3 4 European Environment Agency, Rail and waterborne — best…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The 2040 climate target requires an industrial revolution, but its enabling conditions are not there yet. To reverse the current deindustrialisation trend, rather than an abstract debate on macro targets, political capital should be invested in delivering on the following enabling conditions, some of which have been laudably recognised in the Steel and Metals Action Plan: an effective solution to global steel…

The solar thermal sector supports the proposed 2040 target of a 90% net reduction in greenhouse gas emissions. This ambition is essential to meet the EUs climate neutrality goal by 2050. However, we are concerned about measures that could weaken the targets impact, such as the use of international carbon credits.

The National Federation of Public Works (FNTP) considers that the European Commission’s proposal to reduce greenhouse gas emissions by 90 % by 2040 compared to 1990 is not appropriate. Indeed, the European Climate Law already enshrines in legislation the objective of a climate-neutral European Union by 2050. Companies are already taking all necessary measures to comply with this objective.

Filed in French · English published by the European Commission

ZERO welcomes the European Commissions initiative to include a 2040 climate target within the European Climate Law, as an essential milestone between 2030 and 2050. However, as currently framed, the proposed target of a 90% net reduction in greenhouse gas emissions by 2040 does not fully reflect either the urgency of the climate crisis nor the EUs fair contribution to the 1.5°C limit of the Paris Agreement.

EFIEES is the voice of private energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating & cooling networks.

Unlocking the 2040 Climate Goals Developing a technology-open and competitive policy framework When defining the EU’s 2040 GHG reduction trajectory, it is essential to align climate objectives with Europe’s competitiveness agenda. Above all, decarbonisation must reinforce Europe’s industrial base to ensure the EU continues to thrive on the global stage.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Climate Law amendment with the 2040 climate target is an important step towards climate neutrality by 2050. It is an opportunity to ensure that the European climate framework is sustainable, long-term oriented and sufficient. BPIE would like to highlight the significance of the building sector within the European Climate Law amendment and the road to achieving the 2040 climate target.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European forest owners support the decarbonization of the European economy, aligning two major ambitions: the urgent reduction of our Unions dependency on fossil fuels and fossil-based materials, as well as the creation of an enabling EU policy framework to support the European bioeconomy for a sustainable economic transition and enhancing the EUs strategic autonomy.

To set the EU on track to 2050, the upcoming post-2030 framework needs to prioritise heating and cooling decarbonisation, phasing out fossil fuels, in full coordination with the implementation of the energy efficiency first principle. This was pointed out by 15 Member States in May 2024, echoing the call of 18 European organisations.

PRESS RELEASE – 04 July 2025 Brussels, 04 July 2025 – The ceramic industry expresses its concerns regarding the EC proposal setting the CO2 emissions reduction target for 2040 at 90%, that seems unrealistic for EU manufacturing in the absence of immediate alternative decarbonisation solutions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We speak as children and young people already losing loved ones, health, homes, and futures to the climate crisis, and for those whose lives will be defined by this climate law. We demand that the EU leads the way and protects young and future generations by going further than this proposal. The EU Climate Law should not only be technically ambitious but also socially just and explicitly child-centered. 1.

Carbon Gap supports the 90% emissions reduction target for 2040 in the revised European Climate Law. This target is foundational as it sets the trajectory to achieving the EUs 2050 climate neutrality and subsequent net negative emissions.

The Czech association of owners of municipal, private and ecclesiastical forests (SVOL) stresses that the European Commission’s proposal to reduce EU net greenhouse gas emissions by 90 % by 2040 compared to 1990 levels must go hand in hand with the creation of an EU support framework to support the European bioeconomy for sustainable development.

Filed in Czech · English published by the European Commission

AFEP, MEDEF, France Industrie Press Release : Achieving Europes decarbonisation requires the immediate launch of a globally competitive agenda The European Commission proposes to create a legally binding target to reduce net greenhouse gas emissions by at least 90% by 2040 compared to 1990 levels.

BeZero Carbon strongly supports the European Commissions proposal to introduce a target to reduce the EUs net greenhouse gas emissions by 90% by 2040. Setting ambitious interim targets is vital if the EU is to deliver on its long-term goal to achieve net zero emissions by 2050. However, this is set against a backdrop of wavering political and public support for decarbonisation.

ERS ELF Response to the Consultation on the Amendment of the European Climate Law. The European Respiratory Society (ERS) and the European Lung Foundation (ELF) appreciate the efforts made by the European Commission on the proposal to amend Regulation (EU) 2021/1119 (the European Climate Law) which aims at including a 2040 climate target.

LTO Nederland is the Dutch Agriculture and Horticulture Organisation, which represents more than 30.000 Dutch farmers and horticulturists. LTO The Netherlands shares the importance of a clear European path towards climate neutrality by 2050. The inclusion of a binding EU target for 2040 in the Climate Law contributes to predictability for entrepreneurs, citizens and public authorities.

Filed in Dutch · English published by the European Commission

AFEP, MEDEF, France Industrie Press Release : 2040 CLIMATE TARGET Achieving Europes decarbonisation requires the immediate launch of a globally competitive agenda The European Commission proposes to create a legally binding target to reduce net greenhouse gas emissions by at least 90% by 2040 compared to 1990 levels.

Thank you for contributing to the consultation. From the perspective of the magnesia sector, we refer to our position with two key recommendations for the enforceability of Objective 2040: recognition of permanent internal removals as EU ETS rights and administrative simplification as a guiding principle to speed up permits and investments (including CCUS and CO infrastructure).

Filed in Spanish · English published by the European Commission

Stand: 01.08.2025 VCI-Stellungnahme Vorschlag der EU-Kommission für ein EU-Klimaziel 2040 Es ist zielführend, dass die Erreichung des EU-Klimaziels 2040 grundsätzlich mit Flexibilitäten ausgestattet werden soll.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The current proposal by the EU Commission for a 2040 intermediate climate target is aimed exclusively at implementation by EU member states. Other targets that have already been adopted apply to commercially active companies. These different targets pursue the overarching goal, but differ in terms of implementation, requirements, and calculation.

The Global CCS Institute (the Institute) supports the European Commissions proposal to amend the European Climate Law, to include a new, legally binding intermediate climate target of a 90% reduction in net greenhouse gas (GHG) emissions by 2040, compared to 1990 levels.

Please find attached the position role of the Spanish Cement Manufacturers Grouping (OFICEMEN) in response to the public consultation on climate target 2040. The recognition of permanent internal removals as EU-ETS rights and the explicit inclusion of administrative simplification as a guiding principle are proposed in order to enhance legal clarity and enforceability of the framework.

Filed in Spanish · English published by the European Commission

AFEP, MEDEF, France Industrie Press Release 2040 CLIMATE TARGET Achieving Europes decarbonisation requires the immediate launch of a globally competitive agenda The European Commission proposes to create a legally binding target to reduce net greenhouse gas emissions by at least 90% by 2040 compared to 1990 levels.

The 2040 Climate target is a crucial milestone to succeed in achieving climate neutrality and respecting the Paris Agreement. Reaching the 2040 climate target will require profound structural changes across key sectors, and this transformation must be fair.

The 2040 climate target requires an industrial revolution, but its enabling conditions are not there yet The debate on the 2040 targets offers the opportunity for a reflection on EU climate policy and more broadly on EUs role in the global arena.

Drax Group plc welcomes the European Commissions proposal for a binding EU-wide target to reduce net greenhouse gas emissions by 90% by 2040, establishing a clear and ambitious pathway toward climate neutrality by 2050. Meeting this target will require transformative policies and investment conditions that strengthen the EUs competitiveness while attracting the innovation and capital needed to scale solutions.

The ČEZ Group recognises the urgent need to address climate change linked to ongoing global warming. Therefore, it bases its long-term activities on a responsible approach to the environment, its employees and society as a whole. The energy sector is rapidly changing towards a zero-emission future, which poses a significant challenge in terms of transforming energy sources and locations.

Public Consultation on the European Climate Law amendment 1/6 12 September 2025 Executive summary In the context of Europe’s evolving climate and energy strategy, the Commission’s proposal to reduce greenhouse gas emissions by 90% by 2040 marks an important milestone on the path to climate neutrality by mid-century.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Tradewater welcomes the European Commissions proposal to amend the European Climate Law, establishing a binding EU-wide target of a 90% reduction in net greenhouse gas (GHG) emissions by 2040 compared to 1990 levels. This amendment reaffirms the EUs leadership in ambitious domestic decarbonisation while recognising its broader role in supporting global mitigation efforts.

Solvays climate protection program For Generations Solvay fully supports the objectives of the Paris Agreement to limit global warming by ideally 1.5 degrees Celsius. For that reason Solvay introduced its own climate protection program For Generations with ambitious goals incl. carbon neutrality by 2050. Intermediate goals are a 30% reduction of GHG emissions (Scope 1+2) and a 20% reduction (Scope 3) by 2030.

Europe claims to be a frontrunner in climate action; a level plating field for companies is still not in sight. The longer this remains, the less there are incentives to invest in the EU due to the lack of competitiveness for large parts of industry (cf. Draghi report, 2024). Green production is not only economically viable through the availability of renewable electricity and green hydrogen.

Filed in German · English published by the European Commission

The Carbon Capture and Storage Association (CCSA) is pleased to provide a response to the European Commissions consultation on the amendment to the European Climate Law. The CCSA brings together a wide range of specialist companies across the spectrum of Carbon Capture, Utilisation and Storage (CCUS) technology, as well as a variety of support services to the energy sector.

Make Carbon Removal Count In Europe's 2040 Climate Targets. The European Climate Law (ECL) is central to shaping EU climate policy up to 2050. Its ongoing revision to set a 2040 target is a crucial opportunity to strengthen ambition and provide clear direction for market actors.

The European Environmental Bureau welcomes this opportunity to provide feedback on the proposal for a 2040 climate target. The EU must stay the course toward climate neutrality and time is of the essence. The sooner we cut emissions, the greater the benefits and the lesser the damage.

The European Biogas Association (EBA) welcomes the European Commissions proposed target to reduce greenhouse gas emissions by 90% by 2040 compared to 1990 levels. This reaffirms the EUs determination to tackle climate change and shape our path after 2030, to ensure the EU reaches climate neutrality by 2050. Biogases, and their co-products, are uniquely positioned to support this transition.

The European Climate Law is the cornerstone of climate action in the EU and its member states. In light of the recent opinion from the International Court of Justice ICJ and the relentless progression of disastrous effects from climate change, the policymakers should recognize their important role while amending the Law and setting the future targets.

Gas Distributors for Sustainability (GD4S) welcomes the opportunity to provide feedback on the proposed amendment to the European Climate Law. Gas Distributors for Sustainability (GD4S) represents major gas distribution system operators (DSOs) from nine EU Member States France, Greece, Ireland, Italy, the Netherlands, Poland, Portugal, Romania and Spain and the UK, supplying more than 60 million customers and…

CONFEBUS took note of the opening of this public consultation. Please find attached a document with the comments taking into account the view of bus transport as a key tool for achieving the EU’s climate objectives set out in Regulation (EU) 2021/1119.

Filed in Spanish · English published by the European Commission

Consultation Response from Kystrederiene The Norwegian Coastal Shipowners Association Kystrederiene, representing a large share of the Norwegian short sea and coastal shipping sector, welcomes the European Commissions proposal to amend the European Climate Law and set a binding Union-wide 2040 climate target.

FEEDBACK PAPER Ref. Ares(2025)7637227 - 12/09/2025 Datum 2025-09-12 Swedenergy feedback regulation of the European Parliament and of the Council amending Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality Swedenergy collects and gives voice to around 400 companies that produce, distribute, sell and store energy.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached PKEE's feedback. Key messages: PKEE represents major investors in Polands energy transition and over 18 million energy consumers. We support a just, responsible, and transparent transition that ensures citizens' trust. Achieving climate goals cannot jeopardise EU energy security or competitiveness, especially in todays unstable geopolitical and economic environment.

VIK-Feedback to the European Climate Law Amendment Ref. Ares(2025)7635996 - 12/09/2025 De VIK-Feedback to the European Climate Law Amendment VIK German Association of industrial energy consumers welcomes the efforts of the EU Commission on European law amendment and would like to use the opportunity to provide feedback on the regulation establishing the framework for achieving climate neutrality.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Vattenfall fully supports the proposed EU 2040 climate target of -90 % net reduction of the GHG emissions by 2040 (vs. 1990 levels) as a necessary milestone along the EUs journey towards climate-neutrality by 2050.

Waste Sweden supports the proposal for a binding 2040 target of at least 90 % reduction in net emissions, but would like to stress some crucial prerequisites for the target to have a real impact. The waste sector, including energy recycling, is today a source of emissions, mainly due to the plastic content of residual waste.

Filed in Swedish · English published by the European Commission

The proposed 2040 target is not aligned with best available scientific evidence nor a fair contribution to the global effort to reduce GHG emissions. Community Law & Mediation is concerned about the proposed flexibility in how the target can be met. If adopted, it risks eroding the strength of the EUs climate policy framework and commitment to rules-based international order.

The European Climate Laws proposed 90% net emissions reduction by 2040 is an important step, but under current conditions, it risks accelerating deindustrialisation, raising costs, and weakening Europes competitiveness. Europes energy-intensive industries are already under pressure from high energy costs, global subsidies, and structural overcapacity abroad.

négaWatt has been providing expertise on decarbonisation issues for twenty+ years, for France and more recently for Europe, including with the publication of the CLEVER scenario with a network of partners from civil society and academia across Europe in June 2023. CLEVER is based on the aggregation of national scenarios for 30 European countries.

Topsoe is a global provider of technology and solutions for the energy transition. Headquartered in Denmark, we are one of the very few companies to offer end-to-end solutions for low-carbon and renewable hydrogen, ammonia, methanol, renewable diesel, and sustainable aviation fuel (SAF) production.

The European Dairy Association (EDA) welcomes the opportunity to provide feedback on the Commissions proposal for the EU 2040 climate target. The dairy sector supports the EUs ambition to achieve a 90% reduction in GHG emissions by 2040. The European dairy sector is committed to contribute to the 90% reduction goal.

CLG Europe welcomes the proposal to include a 90% GHG emissions reduction target by 2040 in the Climate Law. As outlined in the Draghi report, decarbonisation is a key driver of economic growth when integrated into a comprehensive policy framework.

While the reaffirmation of the 90% emission reduction target for 2040 is welcome and necessary, proposed amendments raise concerns about potential loopholes that risk undermining this ambition: the proposed use of international credits after 2036, sectoral flexibility and the possible integration of permanent removals into the EU ETS.

UNIFE, the European Rail Supply Industry Association, represents European train builders and rail equipment suppliers. The association advocates for 129 of Europes leading rail supply companies from SMEs to major industrial champions that are active in designing, manufacturing, maintaining, and refurbishing rail transport systems (trains, metros, trams, freight wagons), subsystems, and related equipment.

The Government of the Canary Islands, through its instruments, in particular the Canary Islands Climate Action Strategy (https://www.gobiernodecanarias.org/medioambiente/descargas/Cambio_climatico/Estrategia-Canaria-Accion-Climatica/boc-a-2023-104-1735.pdf), has set the regional target of reducing greenhouse gas (GHG) emissions by 90 % compared to 1990 emissions by 2040.

Filed in Spanish · English published by the European Commission

The revision of the EU Climate Law sends a good political signal in terms of commitment to climate neutrality on the continent. However the current proposal lacks sufficient regulatory clarity and incentives for the scale-up of CDR which is crucial for achieving net-zero emissions and net negativity beyond 2050.

Europe is currently the fastest-warming continent, with escalating climate risks that require immediate and decisive action. As it stands, the European Commissions proposed 2040 target is inadequate to set the EU on a clear path to climate neutrality and ensure climate action over the coming decades.

The European Commissions recent proposal to set a 90% net emissions reduction target by 2040 is welcomed by cities. They believe that it is a bold and essential step toward achieving the legally binding objective of climate neutrality by 2050 as established in the EU Climate Law. European Mayors strongly support this level of ambition.

Neova Group is Europes leading peat producer, transforming peat into high-value products such as growing media, biostimulants, activated carbon, and animal feed additives. Neova conducts responsible peat production in areas previously drained for agriculture or forestry and characterised by low biodiversity.

The Regional Government of the Azores considers it essential that the post-2030 architecture explicitly identifies the specificities of island and outermost regions, such as the Autonomous Region of the Azores, given the greater complexity and cost of implementing mitigation measures in archipelagic and remote territories, even though the formal targets are attributed to the Member State and not to the region.

Filed in Portuguese · English published by the European Commission

Orgalim, representing the European technology industry sector, thanks the Commisison for the opportunity to share its views. We wish to provide three main messages as feedback on the Commission's proposal for amending the EU Climate Law: 1.

The European State Forest Association (EUSTAFOR) welcomes the opportunity to contribute to the European Commissions feedback consultation on the 2040 climate target. In particular, we would like to highlight the critical and complex role of the Land Use, Land-Use Change and Forestry (LULUCF) sector, with a focus on forests, their management and providing renewable materials, enhancing carbon sinks, as well highlight…

The Swedish Forest Industries (SFIF) welcomes ambitious climate targets and emphasizes the importance of implementing them in a realistic way with the help of transparent and accurate impact assessments from the EU Commission and Member States. The SFIF urges the EU Commission to accelerate the phase-out of fossil-based materials and energy with EU climate policy while safeguarding EU competitiveness.

Novela evropského právního rámce pro klima Hospodářská komora České republiky (HK ČR) vítá možnost vyjádřit se k návrhu nařízení Evropského parlamentu a Rady, kterým se mění nařízení (EU) 2021/1119 o rámci pro dosažení klimatické neutrality. HK ČR dlouhodobě podporuje myšlenku postupné dekarbonizace hospodářství.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The U.S. Grains & BioProducts Council (USGBC; former U.S. Grains Council) thanks the European Commission for the opportunity to provide feedback on the important topic of the European Climate Law amendment. The USGBC feedback is included in a separate file provided with this response.

Bigger climate benefits and energy savings can be gained from coupling the biogas and geothermal sectors. This will allow geothermal wells to be drilled much shallower, reducing well costs, and to produce artificially hot reservoir fluids for power production. The biogas will be converted to hydrogen providing a large volume to market (refer to attached paper) with total carbon CCS in the geothermal reservoir.

SCHP CR position on climate targets for 2040 On 2 July 2025, the European Commission proposed, in accordance with Article 4(3) of Regulation (EU) 2021/1119 of the European Parliament and of the Council of 30 June 2021 establishing a framework for achieving climate neutrality and amending Regulation (EC) No 401/2009 and Regulation (EU) 2018/1999 ("European climate legal framework"), the Union's climate target for…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Commission proposes to set a binding 2040 climate target by amending Regulation (EU) 2021/1119 (European Climate Law). The target is to reduce net greenhouse gas emissions by 90 % by 2040 compared to 1990 levels. Among other things, as of 2036, it is foreseen to allow limited international credits (CO allowances for emission reductions achieved in third countries under Article 6 of the Paris Agreement).

Filed in German · English published by the European Commission

The Association of Austrian Land and Forest Owners takes note of the proposed amendments to the European Climate Law, setting a net emission reduction target of 90 % by 2040, compared to 1990. We support this ambition, pointing out that to reach this target, the crucial decarbonisation of value chains through building up bioeconomy needs an enabling policy framework for the nature-based sector.

ICLEI Europe welcomes the European Commissions proposal to amend the European Climate Law by introducing a binding target of a 90% net reduction in greenhouse gas emissions by 2040 compared to 1990 levels. A robust and ambitious 2040 target will provide the long-term policy stability that cities and regions need to accelerate public investment and action towards climate neutrality and resilience, with and for all…

Position of the Association for District Heating of the Czech Republic on Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2021/1119 establishing the framework for achieving climate neutrality Prague, September 8, 2025 The Commission asked for feedback on Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2021/1119…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

WePlanet welcomes the EU Commission's initiative to adopt climate targets for 2040 and achieve carbon neutrality by 2050. This is a major opportunity to strengthen Europes energy independence from imported fossil fuels. As highlighted in the Draghi Report and the Clean Industrial Deal, securing energy is crucial: Europes dependence on fossil fuel imports is one of the main causes of high and volatile energy prices.

Triodos Bank welcomes the proposed 90% net reduction target for 2040, which we see as a bold and necessary intermediary step in the right direction. Ambitious and clear targets are necessary to secure long term investments in sustainable industries.

Climate change is a major challenge of our time. Nobody can deny the urgency to act to protect our environment and prepare for the future. However, the way we build this action is just as essential as the lobjective itself. I would like to draw attention to an increasing risk: a punitive ecology, which imposes uniform standards and constraints without taking into account the realities on the ground.

Filed in French · English published by the European Commission

Natuur & Milieu strongly supports setting the EU on a 1.5°C-consistent pathway. The climate crisis and current geopolitical reality require a high, binding, and inflexible 2040 reduction target, supported by a separate, transparent carbon removal target. This separation is essential to ensure that uncertainties around carbon removal do not delay the urgent emission reductions we need.

SBP recognises the importance of robust greenhouse gas reduction targets and the role of mechanisms such as the CBAM in supporting global climate ambitions. SBP acknowledges the continued designation of biomass as a sustainable, zero-rated fuel source and its potential contribution to the transition from fossil fuels to a circular bioeconomy and will aim to work within any climate targets set by relevant…

Carbon-Free Europe welcomes the Commissions proposal to set a binding EU target of a 90% reduction in net greenhouse gas emissions by 2040 compared to 1990 levels. This ambition is essential to keep Europe on track for climate neutrality by 2050 and to provide predictability for citizens, industry, and investors.

In view of the European Commissions initiative to amend the European Climate Law, see attached a briefing setting out T&Es key recommendations for a 2040 EU climate target that accelerates and deepens the process started with the European Green Deal and its objective to decarbonise the continent by 2050.

While fully supporting the EUs long-term climate objectives and recognising the importance of setting an ambitious intermediate target as a milestone towards climate neutrality by 2050, it is pivotal to stress that the achievement of such ambition must be grounded in technological neutrality, sector coupling, and respect for national specificities, avoiding ideologically driven approaches.

The Council of European Municipalities and Regions (CEMR) welcomes the opportunity to respond to the European Commission's consultation on the revision of the EU Climate Law. As the oldest and broadest European association of Local and Regional Governments (LRGs), we highlight the urgent necessity of upholding the EUs climate ambition through the 2040 targets, and the key role of local administrations in carrying…

Please find attached the position and text amendments from Negative Emissions Platform (NEP). NEP is a Brussels-based partnership of European and international organisations focused on carbon removals. Our members are primarily technology companies, but also include project developers, investors, carbon marketplaces, and buyers of carbon removals.

BASF welcomes the opportunity to provide feedback on the Commission's proposal for the European Climate Law amendment. For BASF climate protection is a key task and an essential part of our strategy. We support the objective of the Paris Agreement to limit global warming to ideally 1.5 degrees Celsius.

The "Associació per a la Promoció del Transport Públic" (PTP) welcomes the European Commissions proposal to amend the European Climate Law and establish a binding EU-wide climate target for 2040. We strongly support the ambition to reduce net greenhouse gas emissions by at least 90% compared to 1990 levels by 2040, as an essential step on the pathway to full climate neutrality by 2050 and to maintain EU leadership…

In the view of the Wiener Stadtwerke Group, the Commission’s proposal for a revision of the European Climate Law and the related 2040 climate target is a positive and necessary step to pave the way to EU climate neutrality by 2050. The Commission’s proposal supports the clear objective stated by both the City of Vienna and the Wiener Stadtwerken to be climate neutral in Vienna by 2040.

Filed in German · English published by the European Commission

EDP recognizes the importance of this initiative and fully supports the underlying objectives of the EU Climate Law. Global action is key to achieve the Paris Agreement goals and the EU must be a role model, driving increased climate protection inside and outside its borders. We support the 2040 climate target, as well as the decarbonization of the energy system by setting ambitious renewable energy targets.

Eurelectric response to consultation August 2025 Eurelectric represents the interests of the electricity industry in Europe. Our work covers all major issues affecting our sector. Our members represent the electricity industry in over 30 European countries. We cover the entire industry from electricity generation and markets to distribution networks and customer issues.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Climate Law amendment (2040 target) / Orano’s answer to the call for feedback (open from 21 July to 15 September 2025) by the European Commission Orano EU Office Rue d’Idalie, 9-13 BEL – 1050 Brussels Orano welcomes the European Commission's proposed amendment to the European Climate Law (Regulation (EU) 2021/1119 of 30 June 2021) to set an intermediate GHG emissions reduction target of -90% by 2040…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Institute for Agriculture and Trade Policy (IATP) Europe welcomes the EUs efforts to make its 2040 climate target legally binding. Europe is the worlds fastest-warming continent. Climate extremes, especially drought, are already costing farmers billions per year and will only get more frequent and more severe without strong action to cut climate pollution.

From the perspective of the Austrian Federal Economic Chamber (WKO), the proposed 90% target for 2040 would represent an abrupt and disproportionate reduction step between 2030 and 2040, which is neither economically viable nor technically justified. Therefore, the 90% target for 2040 is not supported.

VdW Bayern supports the goal of climate neutrality. However, we reject the newly planned blanket target of a 90% reduction in CO2 emissions by 2040, because experience shows that this will lead to political pressure to introduce unaffordable, uneconomical and socially unbalanced measures to reduce greenhouse gases.

Gas Networks Ireland welcomes the opportunity to respond to the European Commissions consultation on the proposed amendment to the European Climate Law [Regulation (EU) 2021/1119] which introduces a binding EU-wide target to reduce net greenhouse gas (GHG) emissions by 90% by 2040 compared to 1990 levels.

The EU must send a strong signal to the industry by coupling climate targets with a GHG strategy and enabling tools that scale up clean energy, create certainty, and secure Europe's position as a global leader in green shipping.

The document titled Climate-Digital Synergies for a Trusted Trade Framework presents a strategic policy proposal to the European Commission, advocating for the integration of digital and climate objectives through the establishment of the European Trade Indexes Registry (EUTIR).

Fruits, vegetables, flowers, and plants climate-neutrally grown. That is our ambition for 2040. Our growers are eager to rapidly reduce their dependence on fossils through scaling the production of renewables and improving energy efficiency. Decarbonising our energy-intensive sector is at the heart of our future competitiveness as it reduces our footprint, tackles high energy costs, and boosts Europes sovereignty.

Please find attached PGE's feedback. Our key messages: 1) Europe needs to both maintain its competitiveness and boost its defence capabilities. Implementing the climate target into the EU ETS will increase the costs of carbon allowances and, in turn, the energy prices, further burdening the EUs industry.

GdW supports the goal of climate neutrality. However, we reject the newly planned blanket target of a 90% reduction in CO2 emissions by 2040, because experience shows that this will lead to political pressure to introduce unaffordable, uneconomical and socially unbalanced measures to reduce greenhouse gases.

27 August 2025 Fransylva feedback on the EC communication on the European Climate Law amendment (2040 target) Fransylva takes note of the Commissions proposal to reduce the Unions net greenhouse gas emissions by 90 % compared to 1990 levels by 2040.

The Institut für Stahlbetonbewehrung e.V., representing German reinforcement manufacturers and processors of reinforcing steel, supports the domestic industry in implementing the EU climate targets. In principle, it is to be welcomed that the EU is taking a pioneering role and setting clear goals and targets. At the same time, however, the EU must also urge other states and communities to follow its lead.

Innargi, one of Europes leading developers and operators of geothermal heat plants for district heating, welcomes the European Commissions proposal for at least a 90% reduction in greenhouse gas emissions by 2040 compared to 1990 levels.

Business & Science Poland (BSP) emphasises that achieving the EUs 2040 climate target will require a cost-effective and technology-neutral pathway to net-zero emissions. We present the attached set of proposals, prioritising the simplification of legislation and the promotion of global competitiveness. The target for 2040 should serve as the foundation for designing new policies and revising existing ones.

On 2 July 2025, the European Commission published a proposal to amend the European Climate Law. Under the law, the European Union and its Member States committed to achieving climate neutrality in 2050. The European Climate Law also established the first intermediate target of reducing net greenhouse gas emissions by at least 55% by 2030 and obliged the European Commission to propose a subsequent intermediate…

Statement by Letisko Košice, a.s. Airport Košice, a.s. on the proposal by the European Parliament and the Council to amend Regulation (EU) 2021/1119 European Climate Law The proposed amendment to the European Climate Law, introducing a 90% emissions reduction by 2040, represents a disproportionate and unrealistic escalation of obligations.

E3G welcomes the European Commissions proposal for 2040 intermediate net reduction in greenhouse gas emissions -90% relative to 1990 levels. This interim milestone will put the EU on course towards climate neutrality by 2050 and gives predictability on the way forward.

We thank the European Commission for the opportunity to provide feedback on the proposal for the European Unions 2040 climate target. We make the following proposals for setting and achieving the climate target. 1. We support the 90% greenhouse gas emissions reduction target in the European Union by 2040 compared to 1990.

The Czech Confederation of Industry and Transport (SP ČR) strongly rejects the European Commission’s proposal for a 90 % reduction in greenhouse gas emissions by 2040 compared to 1990. This ambitious objective is considered unrealistic by the SP ČR and risks causing significant additional costs to the Czech industry when applied to the Czech Republic, endangering its global competitiveness and dramatically weakening…

Filed in Czech · English published by the European Commission

The Federal Association of Glasindustrie e.V. (BV Glas) welcomes the long-term orientation of EU climate policy. Setting an intermediate climate target for 2040 is an important signal of predictability and investment certainty.

Filed in German · English published by the European Commission

Rückmeldung zum Vorschlag für eine Verordnung - COM(2025)524 Das wesentliche Element des Vorschlags zur Änderung des EU-Klimagesetzes besteht in der Definition eines Zwischenziels für das Jahr 2040, also die Präzisierung der CO2Emissionsminderung um 90% gegenüber 1990 in der Mitte des 20jährigen Zeitraums von 2030 – 2050.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The already palpable climate emergency and the war of the oil- and gas-rich dictatorship Russia against Ukraine show: the continued reliance on fossil fuels is unsustainable. Europes coal, oil, and gas consumption is a major contributor to the climate emergency and a key enabler of illiberal tendencies in fossil fuelrich countries. It is thus a central cause of oppression, corruption, and wars.

WWF welcomes the Commissions proposal to adopt an EU 2040 climate target. Adopting this target is an important step towards achieving the climate-neutrality objective, and creates certainty and predictability for Member States, industries, investors and citizens. However, WWF is concerned about the lack of ambition of the climate target.

VDZ views the proposed legislation by the Europan Commission on the EU climate target for 2040 with mixed feelings: On the positive side, the proposal shows a little more pragmatism with regard to recognised measures for achieving the target, the handling of negative emissions in the EU ETS, and the recognition of CO2 reductions outside the EU.

Thank you for the opportunity to comment on the proposed amendment to the European Climate Law, particularly the establishment of a 2040 climate target. Support for Increased Ambition I strongly welcome the EUs proposal to set a binding 2040 target of at least a 90% net reduction in greenhouse gas (GHG) emissions compared to 1990 levels.