Legal framework for the possible use of international carbon credits towards the 2040 EU climate law target

Carbon Management Europe (previously known as Zero Emissions Platform) welcomes the opportunity to provide feedback on the (limited) use of high-quality international carbon credits to achieve the EU 2040 climate target, as proposed in the revised Climate Law. Carbon Management Europe is the official advisor to the European Union on industrial carbon management.

The EU should not use international carbon credits to meet its 2040 emissions reduction target, but should rely wholly on domestic emission reductions. To keep temperature rise to 1.5°C requires urgent action addressing the root cause of the climate crisis chiefly the production and use of fossil fuels curbing emissions at their source.

This initiative aims to clarify how the limited use of high-quality international carbon credits, as proposed in the revised Climate Law, can best support flexibility and efficiency in how to achieve the EU’s 2040 climate target.

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European Entrepreneurs CEA-PME acknowledges the Commissions initiative to clarify the role of international carbon credits in the EUs 2040 climate framework, while stressing the need for a cost-efficient, flexible and globally coherent approach that safeguards European competitiveness. Limiting the use of international carbon credits too strictly risks reducing access to cost-effective decarbonisation options.

CI supports the EU's 2040 target, and the use of a limited number of international carbon credits (up to 5%) to meet that target. A 90% domestic target for reducing emissions is both feasible and affordable for the EU, with multiple well documented benefits to European security and competitiveness.

The World Bank Group considers that allowing a limited use of international carbon credits toward the EUs 2040 climate target can be an effective instrument. It can help mobilize climate finance at a critical time, generate development co-benefits, and provide flexibility in achieving EU climate objectives, while creating incentives for increased ambition in developing countries.

MAIRE Group, a global company specializing in cutting-edge technologies enabling energy transition, welcomes the opportunity to comment on the possibility of using international carbon credits towards the EUs 2040 climate goal. The company strongly supports the contribution of international carbon credits to the European targets and believes that Europe should open itself to global mitigation efforts.

International Credits (Article 6) should be excluded from ETS1. In todays complex geopolitical and economic landscape, some flexibility in the climate target for 2040 on the EU level, such as allowing the use of some international emission reduction credits, is understandable to ensure broad support from the public. However, 5% should be maximum cap and the contribution from IC could in the end be lower than 5%.

PUR is pleased to submit the attached position paper in response to the European Commissions Call for Evidence on the legal framework for the possible use of international credits towards the EUs 2040 Climate Law target. We hope the Commission finds these remarks constructive and relevant as it considers how to design a framework that supports environmental integrity, climate ambition, and realworld delivery.

re.green | Contribution to EU Call for Evidence on International Credits re.green is a nature-based solutions company operating at scale in Brazil, developing Afforestation, Reforestation, and Revegetation (ARR) projects that combine carbon removal with measurable biodiversity and community outcomes. We submit six recommendations. A. Accept credits across all three integration points.

Rainbow welcomes the opportunity to respond to the consultation. This attached position paper supports our contribution to the European Commission's questionnaire on the use of international carbon credits. The position paper sets out the case for integrating high-integrity international credits into the EU's post-2030 climate framework as a complement to not a substitute for accelerated domestic action, drawing on…

The International Swaps and Derivatives Association (ISDA) and the Association for Financial Markets in Europe (AFME) (together, The Associations) welcome the opportunity to provide feedback on the inclusion of high-quality international credits within the EUs 2040 climate framework. We believe that a robust, transparent, and liquid carbon market is essential to channel private capital toward global decarbonisation.

The update of the EU Climate Law has now entered into force. Bioenergia ry the Bioenergy Association of Finland believes that reducing emissions must be at the core of implementing the EU Climate Law. The use of international emission units must be enabled within the framework of the EU Climate Law as part of the implementing legislation.

This comment intends to address the possible use of international carbon credits to fulfill the EUs 2040 Climate targets. However, it aims to insist that international credits, if used to fulfill the EUs climate targets, should be issued and awarded under criteria that are the same and/or equivalent to EU criteria and best international practice to avoid risks of greenwashing and fraud.

Deutsche Bank AG welcomes the opportunity to provide input on the potential use of international carbon credits under the EUs 2040 Climate Law. We support the EUs ambition to reduce greenhouse gas emissions by 90% by 2040 compared to 1990 levels and to achieve climate neutrality by 2050.

BeZero Carbon welcomes the opportunity to respond to the consultation. This attached position paper supports our contribution to the European Commission's questionnaire on the use of international carbon credits. The position paper sets out the case for integrating carbon ratings into the EU's approach to international credit procurement, drawing on evidence and case studies from today's carbon market landscape.

We support the EUs 2040 climate targets, as well as the possibility of using up to 5% international carbon credits towards their achievement. It is essential that only high-quality carbon credits are eligible, meeting robust criteria including permanence, and transparent monitoring, reporting, and verification, with strong safeguards to ensure environmental integrity and avoid double counting.

With reference to a call for evidence held by the European Comission on the Legal framework for the possible use of international carbon credits towards the 2040 EU climate law target, attached please find position of Polish Association of Heat Energy (Polskie Towarzystwo Energetyki Cieplnej).

Gold Standard is please to submit the attached feedback to the EU Commission on the potential use of international credits towards the EU's 2040 target, which we believe can be managed in a rigorous way while making an important contribution towards the low-carbon sustainable development of the EUs partner countries.

What the EU does with regards to climate policy, has a significant knock-on effect on UNFCCC member states around the world. They look towards the EU for best practice when developing Nationally Determined Contributions (NDCs). It is therefore important that EU climate policy shows the way forward by being in line with science, i.e.

The permanence of international credits should match the target they are used for. When used for to meet the targets in the LULUCF-sector, they could be from either permanent carbon capture or from nature-based solutions. When used to meet the targets of ESR-sector, they should be from permanent carbon capture and follow the same logic as when benefiting domestic carbon capture.

ZERO argues that EU climate neutrality should be achieved through deep domestic emission reductions. To align with 1.5 °C and equity criteria, the EU should reach carbon neutrality by 2040 (net zero emissions), underpinned by gross reductions of at least 92 % compared to 1990. 1.

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Equinor welcomes the opportunity to reply to this call for evidence. This attached document complements Equinors responses to the European Commissions questionnaire on the use of international carbon credits (ICCs) towards the EUs 2040 climate target. It sets out Equinors overarching principles and provides additional context to ensure that our responses are interpreted in a coherent and consistent manner.

We welcome the opportunity to contribute to this consultation. International credits should be integrated into EU climate programs to help achieve the target 90% domestic net emissions reduction by 2040, and we support a contribution of 5% net emission reductions from international credits, rather than "up to" 5%.

CLC welcomes the opportunity to contribute to the consultation on the inclusion of international credits in the EUs 2040 target. We support the EUs 90% emission reduction target for 2040, and the use of a limited number of international carbon credits (up to 5%) to meet that target.

As a development organization working with local partners in more than 80 countries, we are deeply concerned that the EU wants to include international credits into the EU 2040 climate framework. As carbon markets under the UNFCCC were not only designed to offer cost-effective solutions to reduce emissions but to foster sustainable development in the host country of the projects, Human Rights, and development…

Thank you for the opportunity for the American Forest Foundation (AFF) to provide feedback regarding the Call for Evidence pertaining to the Legal Framework for the Possible Use of International Carbon Credits Towards the 2040 EU Climate Target. AFF is a leading NGO carbon project developer dedicated to high-integrity forestry projects.

As a company with a mission to restore Nature at a large-scale to high integrity standards, aDryada applauds the European Unions 90% reduction by 2040 Climate Target. We also welcome the European Commissions decision to introduce the flexibility mechanism of reaching up to 5% of the target with international credits, provided that they are of high integrity, since: It can ease the cost of decarbonization on European…

1) The EU should focus on reducing its absolute emissions by 90% by 2040, without reliance on removals. Emphasis on net zero risks providing an excuse for continued high levels of emissions, especially when all removals strategies involve significant risks and uncertainties, and are so prone to overinflated and fraudulent emissions reduction claims.

We welcome the European Commissions initiative to design a framework for the use of international carbon credits to support the EUs 2040 climate target. Aligning the EU ETS with the Paris Agreement (Article 6) can enable scalable and cost-efficient carbon removals, while ensuring environmental integrity and robust governance.

The Dutch Spark strongly supports the use of international carbon credits as part of the EU's 2040 climate framework, provided these credits meet high standards of climate integrity, transparency, and social impact.

BDEW welcomes the opportunity to comment on the legal framework for the possible use of international carbon credits towards the 2040 EU climate target. Due to the limited space available in the questionnaire, BDEW submits this complementary document to present the position of the German energy and water industries in more detail. Please find attached BDEWs complementary position paper.

The Better Cotton Initiative (BCI) is the world's largest cotton sustainability programme, working with over 2.9 million farmers across 22 countries to improve environmental, social, and economic outcomes in cotton production.

Governments should allow rail projects in LICs and LMICs to be funded under Article 6 of the Paris Agreement and support the development of carbon finance market regulations for rail. Due to the large scale emissions that would be avoided from new rail projects in low income countries' and lower middle-income countries' governments should consider rail as climate mitigation projects under Article 6 of the Paris…

The EUs 90% net greenhouse gas (GHG) emissions reduction target by 2040 requires a policy framework that is both environmentally robust and economically viable for energy-intensive industries. The revised European Climate Law explicitly foresees a limited and conditional use of high-quality international credits (up to 5% of 1990 emissions) to complement domestic action.

You can find below Bellona Europa's recommendations. Use credits as a strategic reserve/ emergency exit, separate from domestic compliance pillars Establish centralised EU-level management (e.g., via the European Commission) Ensure that spending on credits is not counted towards international climate finance or development aid commitments Preserve the integrity of the ETS by excluding international credits from…

The Climate Area of the Florence School of Regulation welcomes the opportunity to provide its feedback on the revision of national targets and flexibilities in the EU climate policy framework after 2030. Our attached analysis suggests that international carbon credits can provide some flexibility in achieving climate targets, but only if their integration into the policy framework is carefully designed.

Iberdrola welcomes the ECs initiative to clarify how a limited use of high-quality international carbon credits (ICCs), as proposed in the Climate Law, may best support flexibility and efficiency in the achievement of the EUs 2040 climate target.

ENGIE welcomes the opportunity to contribute to the Europeans Commission consultation on the role of international carbon credits in the EUs 2040 climate policy framework. To achieve the intermediary 2040 climate target and carbon neutrality by 2050, Europe requires swift, transformative action across all sectors.

Transport & Environment (T&E) welcomes the opportunity to respond to the public consultation launched by the European Commission on the potential role of international carbon credits in the EUs 2040 climate target. Please, see attached our suggestions.

In strict compliance with its ethical charter, AFEN coordinates its work with European and international stakeholders in order to promote convergence of standards in the EDC sector, while ensuring that the strategic priorities and industrial interests of the French carbon dioxide removal sector are upheld.

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The Polish Electricity Association (PKEE) welcomes the opportunity to contribute to the consultation on the design of the legal framework for the possible use of high quality international carbon credits (ICC) towards the 2040 climate target under the European Climate Law. The detailed position is set out in the ATTACHED DOCUMENT.

RWE strongly supports the establishment of a robust EU framework allowing the limited use of highquality international carbon credits toward the EUs 2040 climate target. The 90% net-reduction target is ambitious and appropriate, yet residual emissions in hardtoabate sectors cannot be appropriately eliminated domestically by 2040.

Envien Group welcomes the opportunity to contribute to the Call for Evidence on the possible use of international carbon credits towards the EUs 2040 climate target under the European Climate Law. As a leading biofuels producer operating in the region of Central and Eastern Europe and operating under the EUs sustainability, climate and regulatory framework, we appreciate the Commissions efforts to assess whether and…

Executive summary Delivering the ambitious target of climate neutrality by 2050 and the proposed 2040 intermediate target will require a post 2030 climate policy framework that is environmentally robust, economically feasible and capable of attracting investment in Europes industrial base.

The option of utilising up to 5% of international credits to help meet the EUs 2040 climate target needs to be designed extremely carefully in order to avoid mitigation deterrence. The EU Scientific Advisory Board advised in June 2025 that a 90-95% reduction is possible domestically and thus while investments ahead of time are necessary to unlock additional climate mitigation such investments should be treated as…

Important questions on project building and integration of international certificates into the EU climate architecture and Germanwatch leitmotiv proposals: International CO2 allowances should be used as a tool for global climate cooperation and ambition-enhancing. Generally: Possible areas of use for Article 6 (current, i.e.

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As stated in the Commissions questionnaire on the inclusion of international credits, Expert Section, Question 1, international credits effectively substitute for domestic climate change mitigation. Climate action should not be outsourced.

We reject the use of international carbon certificates to achieve the EU’s climate target of 90 % emissions reduction by 2040. Such an approach contradicts the scientific evidence and recommendations of the EU Climate Advisory Board (ESABCC), which provides for a reduction of at least 90-95 % that needs to be delivered within Europe.

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The EU should not allow the use of international carbon credits towards its 2040 climate target. Evidence consistently shows that such credits lack environmental integrity, with persistent issues of weak additionality, over-crediting, and conflicts of interest in verification. Their use risks undermining the EUs climate ambition and delaying necessary domestic emission reductions.

Messages from Finnish Food and Drink Industries Federation: Climate goals, food security, and the competitiveness of companies must be aligned. EU's climate policy should promote competitiveness and food security of European food production while achieving international climate goals. Policies aimed at reducing emissions must be long-term and predictable.

Please find attached an Annex supporting the feedback provided in the consultation questionnaire. It clarifies the reasoning behind selected inputs, as the limited space available in the questionnaire did not allow these elements to be fully explained.

The Baden-Württemberg Ministry of the Environment, Climate and Energy is critical of the possibility of acquiring international credits of up to 5 % of 1990 emissions when meeting the EU 2040 target (90 % reduction compared to 1990 greenhouse gas emissions).

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Climate Action Platform - Africa (CAP-A) supports the inclusion of international carbon credits as a limited, high-integrity flexibility mechanism to support delivery of the EUs 2040 climate target. This should complement not substitute for strong domestic mitigation.

eAgronom is a leading European platform for farm management and carbon farming. We serve 3,500 customers across 10 countries, covering 2.5 million hectares of farmland. Of this, 1.3 million hectares are enrolled in our soil carbon programs, generating certified carbon farming units under Verra VM0042 and the EU Carbon Removal and Carbon Farming Regulation (CRCF).

eAgronom is a leading European platform for farm management and carbon farming. We serve 3,500 customers across 10 countries, covering 2.5 million hectares of farmland. Of this, 1.3 million hectares are enrolled in our soil carbon programs, generating certified carbon farming units under Verra VM0042 and the EU Carbon Removal and Carbon Farming Regulation (CRCF).

eAgronom is a leading European platform for farm management and carbon farming. We serve 3,500 customers across 10 countries, covering 2.5 million hectares of farmland. Article 6 flexibility makes sense. Reaching the 2040 target of 90% net emissions reduction through domestic action alone would impose costs that are politically and economically hard to sustain.

eAgronom is a leading European platform for farm management and carbon farming. It serves 3,500 customers across 10 countries, covering 2.5 million hectares of farmland. Of this, 1.3 million hectares are enrolled in eAgronoms soil carbon programs, designed to generate certified carbon units under Verra VM0042 and the EU Carbon Removal Certification Framework (CRCF).

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. We believe that international carbon credits must follow strict rules and criteria to ensure they are high quality, verifiable and bring additional benefits to mitigating climate change.

In this submission, MISA, an international Alliance of Tanzanian Maasai community members, grassroots organisations, lawyers, priests and researchers, alongside international human rights and faithbased organisations, outlines the risks associated with carbon credit projects, focusing on Maasai communities in northern Tanzania.

Imperative Global Solutions Pte Ltd (Singapore) is a project developer that designs, develops, owns and operates large-scale nature-based carbon credit projects in emerging markets, certified under Verra's VM0047 (ARR) methodology with ICVCM Core Carbon Principles eligibility.

Submitted by Residual, a carbon project developer with an active project pipeline in the United States, Australia, Brazil and Colombia. We design, de-risk and commercialise carbon projects across emission reductions and removals. Our team pairs commercial development capability with deep scientific credibility.

The Nature Conservancy supports the EU's 2040 target, and the use of a limited number of international carbon credits (up to 5%) to meet that target. Reducing emissions must remain a priority, and the aim of the EUs climate policy framework post 2030 should be to ensure that the EU meets its long term, Paris-aligned climate objectives.

Statkraft fully supports the net 90 percent emissions reductions target for 2040. Carbon pricing through a strong ETS must be a core instrument to achieve this target. The EU ETS has proven to be an effective climate policy tool. Weakening the ETS presents investor uncertainty, in addition to possible sunk costs. The EU ETS provides significant revenues. In 2024 they amounted to 38.8 billion euros.

The German Banking Industry Committee welcomes the European Commissions initiative to establish a legal framework for the potential use of international carbon credits under the European Climate Law. Given the 2040 target of reducing net greenhouse gases by 90% and the planned limited use of high-quality international credits of up to 5%, we believe this initiative is both timely and systemically important for…

We welcome the opportunity to respond to the European Commissions Call for Evidence on the possible use of high-quality international credits under Article 6 of the Paris Agreement. This submission draws on the Florence School of Transnational Governance - Climate's research, including our Policy Brief Towards an EU Strategy on International Carbon Credits (STG 2026/09, attached).

Sylvera welcomes the amended European Climate Law to enable the use of high-quality international carbon credits to contribute up to 5% of 1990 Union net emissions towards achieving the EU's 2040 climate target.

Airbus welcomes the European Commission's intention to gather feedback, in order to clarify how the limited use of high-quality international carbon credits, as proposed in the revised Climate Law, may best support flexibility and efficiency in how the EUs 2040 climate target is achieved. Please find attached the detailed feedback from Airbus.

Exolums supports the EUs 2040 climate target and climateneutrality goal, while strongly advocating for a pragmatic and competitivenesspreserving compliance framework. The core message is that highquality international carbon credits, pooled and governed at EU level, should be allowed in a limited and controlled manner to complement domestic decarbonisation during the transition period.

We welcome the opportunity to respond to the European Commissions Call for Evidence informing an Impact Assessment on the possible use of high-quality international credits under Article 6 of the Paris Agreement.

1. The 90% 2040 target should be met through domestic action. In line with the European Scientific Advisory Board on Climate Change, a fully domestic pathway to 90% net emissions reductions by 2040 is within reach. International carbon credits should complement not substitute domestic action and should be reserved for ambition beyond 90% or as a hedge against unforeseen shortfalls. 2.

The Union of Farmers’ Unions, in the context of the call for evidence on the possible use of international carbon credits for climate objective 2040, stresses the need for their possible incorporation to take into account, as a priority, their implications for agricultural activity.

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The European Banking Federation supports the development of a European legal framework for the limited and complementary use of international emission credits that can support global decarbonization financing and contribute to a cost-efficient and politically durable European climate framework - provided they remain strictly supplementary, meet the highest integrity standards and are embedded in a transparent…

Please see the attached files: - A letter with EDF's policy recommendations - Two policy papers: * International credits in the EU: credit quality criteria and implications for the EUs purchasing strategy (EDF and The Nature Conservancy, May 2026) * Buying the 5%: Funding, Governance and Market Design for the EUs International Credit Purchases (EDF, May 2026)

Key considerations for the use of international credits under Article 6 of the Paris Agreement by the EU Key message 1: The EU should only use international credits towards its NDC - that come from activities that can unequivocally show additionality. - that are issued against a baseline that is below business as usual and which declines over time.

The Climate Alliance Switzerland is an association bringing together over 160 civil society organisations calling for ambitious and fair Swiss climate policy. Several experts within the Climate Alliance have strong expertise in carbon markets as independent observers, since Switzerland and other Swiss Actors have been strongly engaged in these markets early on and are continuing their early adopter role under…

Due to the 4,000-character limitation of this submission form, we are unable to provide our full feedback within this section. We have therefore included our detailed response in the attached document and kindly request that it be taken into consideration.

The International Emissions Trading Association (IETA) welcomes the opportunity to contribute to the European Commissions consultation on the role of international carbon credits in the EUs 2040 climate policy framework.

As an international carbon crediting standard recognized for integrity and with roots in compliance markets, the Climate Action Reserve provides the following comments in support of the European Commission's proposal to include international credits in the post-2030 climate framework and 2040 targets as a cost-effective pathway for the EU that simultaneously supports ambitious global mitigation actions.

Asteria supports the mobilisation of international carbon credits as essential to achieving climate neutrality. Most emissions linked to French and European consumption fall under Scope 3 and are global as they are embedded in global value chains.

Cascade Climate welcomes the opportunity to provide feedback on the possible use of international credits towards the EU's 2040 Climate Law Target. Our interest is in ensuring that any international credits used toward the EU's climate target reflect high environmental integrity.

The Beyond Alliance welcomes the opportunity to contribute to this Call for Evidence on the use of international credits toward the EU 2040 climate target. Please find our detailed response in the attached letter.

The Carbon Business Council is a global coalition that brings together carbon removal companies and strategic partners under a shared goal: ensuring carbon removal scales with integrity and durability. The attached submission welcomes the use of high-integrity international credits towards the 2040 EU climate target and propose that the EU should establish a dedicated role for carbon dioxide removal (CDR) within its…

We welcome the amended European Climate Law to enable the use of high-quality international carbon credits to contribute up to 5% of 1990 Union net emissions towards achieving the EUs 2040 climate target. This provides a pathway for the EU to pursue greater, cost-efficient climate ambition, while enhancing flexibility in meeting its climate target and strengthening cooperation with third countries.

We welcome the opportunity to provide input on the potential use of international carbon credits towards the EUs 2040 climate target. While we recognise the intention to enhance cost-efficiency and support global climate action, we see several important risks that should be carefully addressed.

Bregal Spheres Response to the Call for Evidence on the Legal Framework for the Possible Use of International Credits towards the 2040 EU Climate Law Target Bregal Sphere is the impact investing arm of Bregal Investments a global private equity platform encompassing direct investment and fund-of-funds strategies, with over 19 billion in assets under management and a team of over 250 professionals across London, New…

International credits should not be included in the EU ETS, instead focus should be in linking with similar cap and trade systems Certified international carbon credits were part of the ETS system from 2005 to 2020 but removed due to their negative impact on long-term decarbonisation and innovation, and with questionable efficacy as quality was hardly assessed in a robust way.

We welcome the opportunity to contribute to this consultation on the inclusion of international credits in the 2040 EU Climate law target. International carbon credits can play an important role in supporting climate goals in a cost-effective way within a high integrity framework particularly in hard to-abate sectors where domestic mitigation options may be more limited or expensive in the near term provided their…

The use of international carbon credits is especially strong in two cases: - if the carbon credits come from Europe itself, it will als support becoming more competitive, predictability and will create a more stable market - if the carbon credits are nature based and come from Europe, there is a direct solution for the private funding of the restoration law.

Mombak is a multi-pathway carbon removal company based in Brazil, developing both technology-based (Enhanced Rock Weathering) and nature-based (Afforestation, Reforestation, Revegetation ARR) projects. We submit six recommendations. ---- A. Accept credits across all three integration points. International credits should be eligible under the EU ETS, ESR, and LULUCF Regulation.

We reject the use of international emission allowances to meet the EU’s target of 90 % emission reductions by 2040. This approach contradicts the scientific advice of the ESABCC, which calls for a reduction of at least 90-95 % without any flexibilities.

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FairClimateFund (NL company) strongly supports the European Commissions policy to allow up to 5% of the 2040 carbon emission reduction targets to be met through high quality carbon credits, provided these credits meet high climate integrity, high transparency, and high social impact criteria for carbon markets. They must also include benefit sharing with communities in their transition to clean cooking.

TIC Council welcomes the European Commission public consultation on how high-quality international carbon credits, as proposed by the Climate Law, may best support flexibility and efficiency in achieving 2040s climate target. For international carbon credits to be successfully embedded in the EUs targets, they need to be credible, measurable, and tradable.

Note: the following response is to be read together with the accompanying PDF that was attached, which contains sources and citations and develops our position in more detail. When carrying out its impact assessment, the Commission should consider that any option allowing the EU to rely on international credits to facilitate the achievement of its 2040 climate target is problematic for the following reasons: 1.

Sir / Madam, MSCI would like to thank the European Commission for providing us an opportunity to respond to the call for evidence on legal framework for the possible use of international carbon credits towards the 2040 EU climate law target. Please find attached our response to the call for evidence. If there are any clarifications required on our submission, you may please reach out to me.

The National Centre for Emissions Management (KOBiZE) welcomes the opportunity to submit its views on the legal framework concerning the possible use of international carbon credits towards the European Union 2040 climate law target, as set out in the attached policy brief.

Outokumpu strongly supports a robust and predictable EU Emissions Trading System (ETS) as a cornerstone of Europes climate policy and industrial competitiveness, generating economic growth and employment in Europe. We welcome the Commissions commitment to the climate targets for carbon neutrality by 2050 and at least 90% greenhouse gas emission reduction by 2040.

Please find attached the position of Uniper on the use of International Carbon Credits under the EU Climate Law: Key Messages: 1. Uniper supports a cautious and welldesigned use of international carbon credits as a complementary instrument to domestic decarbonisation, helping to balance climate ambition, competitiveness and affordability. 2.

CAN Europe has repeatedly argued that, to align with the 1.5°C temperature limit and equity, the EU could and should achieve domestic net zero emissions by 2040 at the latest, based on at least 92% gross reductions compared to 1990 levels. This should also be based on the EU achieving at least 65% gross (76% net) emission reductions by 2030, and at least 82% gross (94% net) domestic emission.

The use of international carbon credits towards the EUs 2040 climate target would undermine ambition, risk environmental integrity and delay the urgent, structural transformations required to meet the Paris Agreements 1.5°C target, all while increasing the overall cost of decarbonisation. Achieving climate neutrality by 2040 without the use of credits is feasible and necessary (CAN, 2024).

Humundi, drawing on its long experience of development partnerships in Africa and Latin America with rural communities and peasant organisations, opposes the development of international credits by Europe. This approach amounts to outsourcing climate responsibility, rather than fully assuming Europe's historical role as a major emitter of greenhouse gases.

We, a coalition of organizations active in the carbon market, welcome the European Union's decision to allow the use of up to 5% international carbon credits toward the 2040 target of 90% net GHG emissions reduction. We urge the Commission to seize this moment to establish a clear role for high-integrity carbon removal credits within that framework.

This submission is provided by Tradewater in response to the European Commissions consultation on the legal framework for the possible use of international carbon credits towards the EUs 2040 climate target. Tradewater supports the inclusion of high-integrity international credits as a complementary mechanism to domestic decarbonisation.

EDP recognizes the importance and fully supports the underlying objectives of the recent amendment to the EU Climate Law, setting a 2040 EU climate target of 90% reduction in net greenhouse gas (GHG) emissions, compared with 1990, while allowing 5% of international carbon credits as well as EU based permanent carbon removals to compensate for residual hard-to-abate emissions.

FuelsEurope welcomes the European Commissions consultation of stakeholders on the legal framework for the possible use of international carbon credits towards the 2040 EU climate law target, as recognising international credits supports global climate goals and contributes to more cost-effective decarbonisation options.

The Business for CBAM Coalition believes international carbon credits should not be allowed for either CBAM or ETS1 compliance due to the following reasons (see the attached PDF for the full position paper): 1. Credits would divert scarce resources away from EU industrial decarbonisation at a time when funding in Europe is already tight. 2.

BASF SE response to the European Commissions consultation on the legal framework for the possible use of international carbon credits towards the 2040 EU climate law target BASF welcomes the opportunity to contribute to the Commissions consultation on the possible role of international carbon credits in meeting the EUs 2040 climate target.

BusinessEurope believes that global carbon markets are crucial to lay the ground for a global carbon price in the medium to long term, as well as mobilise investments in climate mitigation in a cost-efficient manner and add private climate finance to public efforts.

PGE Polska Grupa Energetyczna S.A. welcomes the opportunity to provide its feedback on the possible use of international carbon credits. Please find our feedback attached. Key messages: 1) Climate change is a global challenge that requires coordinated international action. The European Union has demonstrated strong leadership in emission reduction.

Our detailed position is set out in the attached paper. It covers the EU Quality Seal framework, the case for a centralised reverse auction from 2031, MSR and LRF calibration, and a novel pre-2031 credit-backed front-loading mechanism that we believe deserves serious consideration. We encourage reviewers to read it in full.

The submission argues that the European framework for international carbon credits should be aligned with Article 6 of the Paris Agreement, ensuring regulatory predictability and avoiding excessive barriers that could limit the participation of developing countries.

International carbon credits can play a key role to promote global trade of CCU-based materials that feed into European manufacturing activities, while accelerating the defossilisation of chemical value chains. The chemical industry uses carbon as a production feedstock, in substances or mixtures that are necessary to produce e.g. polymers, advanced materials, construction products, etc.

As stated by the European Scientific Advisory Board on Climate Change (ESABCC) in 2023, the European Union must achieve a minimum 90% reduction in domestic greenhouse gas emissions by 2040 to fulfill its commitments under the Paris Agreement.

Business & Science Poland supports the possible use of high-quality international carbon credits towards the 2040 EU climate target, provided they are introduced within a clear, limited and credible legal framework. International credits can serve as a pragmatic complement, especially in sectors where further emission reductions are particularly costly or technologically difficult.

The legal framework for international carbon credits shows that the EU does not consider its own 2040 climate targets to be achievable with the existing toolbox itself. Europe needs its own climate strategy based on the bioeconomy, wood products and the circular economy. Correct incoherent disincentives in ETS, CBAM, LULUCF and Nature Restoration Law. The full text of our opinion is attached.

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The European Marine Board (EMB) welcomes this initiative to clarify the use of high-quality international carbon credits for the EUs 2040 climate targets. The Ocean absorbs approximately 25% of all annually emitted CO2 from human activities (~10.5 gigatonnes CO2/year), and is the largest dynamic carbon reservoir on Earth, holding around 37,000 billion tonnes of carbon.

The German Sawmill and Wood Industry Federation (Deutsche Säge- und Holzindustrie Bundesverband e.V.) welcomes the opportunity to comment on international credits for achieving climate targets. From an industry perspective, a possible legal framework for international carbon credits can make a limited contribution to making the transition towards the EU’s 2040 climate target more flexible and to alleviating the…

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IRT Wrocław (Poland) In July 2025, the Commission proposed an amendment to the European Climate Law (COM(2025) 524 final) establishing a legally binding target of reducing net greenhouse gas emissions by 90% by 2040 compared to 1990 levels. This is intended to ensure a credible and stable path towards achieving climate neutrality by 2050.

The use of international carbon credits is one of the few tools available in the fight against climate change. At this historic moment, the EU needs to use all the tools at its disposal, avoiding endless analysis in search of perfect solutions that probably do not exist.

Legal Framework for International Carbon Credits towards the 2040 EU Climate Law Target This submission strongly supports establishing a robust legal framework for high-quality international carbon credits towards the EU's 2040 climate target. Why this framework is necessary The EU's 90% net reduction target is the right ambition.

1. Introduction and General Stance BBVA welcomes the opportunity to provide feedback on the inclusion of high-quality international credits within the EUs 2040 climate framework. As a leading financial institution committed to achieving Net Zero by 2050, we believe that a robust, transparent, and liquid carbon market is essential to channel private capital toward global decarbonization.

I have many years of experience in the voluntary carbon credit market as the founder of Madaprojects, an Italian benefit company that develops carbon offsetting projects in developing countries, focusing on so-called community-based projects.

Filed in Italian · English published by the European Commission

A limited and carefully governed mechanism allowing Member States to use a small share of high-integrity international carbon credits toward the EUs 2040 climate target would improve economic efficiency without weakening climate ambition.

The European Physical Society has recently published a Position Paper on Energy: its main message is "Given the decarbonisation level that the EU has already reached, and points (i)-(iv) above, we recommend shifting priorities to enhance security of supply, affordability and sustainability of the energy system, considering the following points".