Revision of national targets and flexibilities in the EU climate policy framework after 2030

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.

Canopée calls for a post-2030 EU climate framework that gives priority to the protection and restoration of natural carbon sinks, especially forest sinks. LULUCF targets must remain national, legally binding, specific and separate from gross emission reductions and permanent removals.

Building on the Effort Sharing and Land Use, Land Use Change and Forestry Regulations, this initiative will assess how national climate targets can incentivise action and enable reaching the EU’s 2040 climate target, including the Union’s flexibilities and enabling measures.

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1. In our submission, we point out that adjusting targets and creating flexibilities in the Climate Policy Framework post 2030 can be interpreted as decreasing regulation and maintaining fossil fuel dependence. In order to achieve an independent and flexible EU we need to break free from the fossil-fuel market and so we can decouple our energy system from crises caused by war and trade disruption. 2.

Please see the full feedback in the attachment. The Nordic Family Forestry Alliance (NSF) welcomes the opportunity to contribute to the call for evidence on National targets and flexibilities in the EU climate policy framework after 2030. For 80 years, Nordic family forest owners have cooperated to shape resilient and robust forests to tackle climate change.

European Entrepreneurs CEA-PME acknowledges the Commissions initiative to review national targets and flexibility mechanisms in the EU climate policy framework beyond 2030, while highlighting that the current system risks creating market distortions, uneven burdens across Member States, and limited global impact, potentially harming EU industry.

MAIRE Group, a global company specializing in cutting-edge technologies enabling energy transition, welcomes the opportunity to share its view on how national targets and flexibilities should evolve in the EU climate policy framework post-2030. The company's contribution can be found in the document attached.

Italgas supports the European Commissions proposal to reassess national targets and flexibilities in the EU climate framework beyond 2030. New targets can drive stronger action by encouraging investment and measures to cut greenhouse gas emissions, reinforcing EU-wide climate efforts and delivering wider benefits such as cleaner air, sustainable land use, greener cities and improved wellbeing.

The Estonian Chemical Industry Association (ECIA) represents companies operating in Estonias chemical sector. We welcome the opportunity to contribute to this consultation. Post-2030 climate policy framework development needs to be coherent and realistic. To keep overall transition costs manageable it also needs to be economically feasible and capable of sustaining investment in Europes industrial base.

Eurogroup for Animals welcomes the opportunity to provide feedback on the EUs framework for national climate targets. It will be important to set national climate targets for agriculture and food. National emissions reduction targets for agriculture will give a clear picture of where the EU is heading in the long term and provide predictability when farmers make investment decisions.

The attached paper sets out FNADE's position on the post-2030 revision of the Effort Sharing Regulation (ESR) and the broader EU climate framework towards 2040. It calls for the preservation of binding national targets for non-ETS sectors to ensure fair and accountable contributions by Member States.

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 association underlines the importance of EUs emissions trading systems in implementation of the EU Climate Law.

The European Agroforestry Federation (euraf.net) offers this document in response to the EU Climate Policy Consultation, closing on 4/5/26. It underscores the role of agroforestry as a critical, yet underutilized, lever for achieving the European Unions 2050 climate-neutrality targets.

To achieve the EUs 2040 climate target credibly and cost-efficiently, the policy framework must ensure that mitigation and removals can be delivered where they are most effective. The current separation between ESR, LULUCF and emerging market mechanisms limits this and increases overall system costs.

Finnish Energy (ET) welcomes the EUs decision 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 net-zero…

Lantmännen supports the European Commission's ambition to strengthen the EU energy and climate policy post-2030 in order to boost EU investment, competitiveness, resilience, energy security, and implement the newly adopted 90% GHG emissions reduction objective of the EU Climate Law by 2040.

National targets and flexibilities in the EU climate policy framework after 2030 Green Transition Denmark (GTD) proposes a major reshuffle of the legislative framework securing achievement of the EU 90% climate target for 2040.

The 2040 framework will succeed for carbon farming if and only if it generates compliance-grade demand to match the supply that the CRCF is provisioning. Separate national targets for emissions and removals, a durability-based redefinition of permanence, layered demand channels deployed in parallel, mutual MRV recognition, and a domestic-first rule for international credits together provide the architecture…

See full feedback in attached document. Key supporting points outlined by ISCIA: 1. ISCIA supports the use of international carbon credits toward Member State targets ISCIA supports Member State flexibility to use high-quality international credits toward their post-2030 national targets.

RECOMMENDATIONS FOR THE IMPACT ASSESSMENT ON POST-2030 NATIONAL TARGETS FEANTSA calls on the Commission to ensure that the Impact Assessment for the revision of national targets and flexibilities after 2030 fully integrates social fairness, distributional impacts, and investment constraints faced by vulnerable households.

To achieve the EUs 2040 climate target in a cost-efficient and credible way, the framework must ensure that mitigation and carbon removals can be mobilised at scale. This requires alignment between national targets, market instruments and land-based delivery. A central challenge is the lack of a predictable long-term demand signal for carbon removals.

The EUs climate policy framework needs to be designed for at least 90% domestic emissions reductions and aiming for climate neutrality by 2040. It should first and foremost be effective and fair in reaching climate, environmental, and social objectives. Therefore, simple, cost-effective, and competitive cannot be the guiding principles.

ePURE - the European Renewable Ethanol Association- represents bioethanol producers from crops, wastes and residues all committed to sustainable transition towards zero-emission mobility and sustainable bio-based solutions.

Energy Efficiency for Europe 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.

National targets and flexibilities in the EU climate policy framework after 2030 review The European Respiratory Society (ERS) , representing clinicians, scientists, and allied professionals in more than 160 countries, and the European Lung Foundation (ELF), a patient-led organisation that works internationally to bring patients and the public together with healthcare professionals to improve lung health and advance…

You can find below Bellona Europa's recommendations. On the design of the post-2030 climate package: Design the post-2030 package, including national targets, to achieve 90% net domestic emission reductions by 2040 Keep the separation between the reduction of fossil fuel and industrial process emissions (ETS & ESR) and the management of land sinks (LULUCF).

Transport & Environment (T&E) supports the continuation and strengthening of binding national climate targets beyond 2030 as a core pillar of the EUs climate and energy architecture. While EU-level carbon pricing under the EU Emissions Trading System (ETS) has proven effective in driving cost-efficient emissions reductions, it should be complemented by additional measures to ensure the delivery of the EUs climate…

The German Forestry Council (DFWR) welcomes the review of national targets and flexibilities in the EU climate policy framework after 2030. A future framework must ensure a cost-efficient and resilient pathway towards climate neutrality by 2050 while fully reflecting the biophysical realities of the LULUCF sector.

SVDU (Syndicat National du Traitement et de la Valorisation des Déchets Urbains et Assimilés) brings together the main operators specialising in the energy recovery of household and similar waste. Its members operate waste treatment facilities and recover energy from more than 13 million tonnes of residual waste. Located across 110 sites in France, they employ 3,000 people.

Iberdrola welcomes the Commissions initiative to revise national targets and flexibilities after 2030. Updating the Effort Sharing Regulation (ESR) is timely to ensure delivery of the EUs 2040 climate target ( 90% net emissions vs. 1990) and maintain a credible path to climate neutrality by 2050.

Stora Enso welcomes the opportunity to respond to the Call for Evidence regarding National targets and flexibilities in the EU climate policy framework after 2030 (review). Our recommendations are: 1. Ensure the forest sector is not used to compensate for lack of emissions reductions in other sectors. 2. Create realistic LULUCF trajectories for the forestry sector. 3. Support the multifunctional role of forests. 4.

Airlines for Europe (A4E) is Europes largest airline association, bringing together 16 airline group members that account for over 80% of European air traffic. A4E welcomes the opportunity to provide feedback on the post-2030 climate framework, emphasizing that while we remain fully committed to the EUs 2040 and 2050 climate targets, the revision of national targets and flexibilities must prioritize the global…

ZERO advocates for a substantial increase in the EU’s domestic ambition and a governance framework that ensures environmental integrity, accountability, and consistency between targets and public spending. To align with 1.5 °C and equity principles, the EU should aim for domestic neutrality by 2040, based on deep gross reductions: at least ~ 65 % by 2030 (76 % net), ~ 82 % by 2035 (94 % net) and a net reduction of…

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The Federation of Swedish Farmers (LRF) represents 120,000 members and 60,000 enterprises in agriculture and forestry. It is Swedens largest small business organisation, including cooperatives like Södra, Mellanskog, Norra Skog, Lantmännen, and Arla. LRF is also a member of Copa-Cogeca, CEPF, and NSF.

The European State Forest Association (EUSTAFOR) welcomes the opportunity to contribute to the public consultation on national targets and flexibilities in the EU climate policy framework after 2030. EUSTAFOR represents 40 European state forest companies, enterprises, and agencies for whom sustainable forest management (SFM) and sustainable wood production are core responsibilities.

The Polish Electricity Association (PKEE) welcomes the opportunity to contribute to the consultation on the revision of national targets and flexibilities in the EU climate policy framework after 20301. As highlighted in the Commissions Call for Evidence, the forthcoming revision must support the achievement of the provisionally agreed 2040 climate target while ensuring fairness, cost-efficiency and resilience…

The regions of East and North Finland welcome the EU's updated Climate Law with an interim 90 % emission reduction target for 2040. To achieve this target, we believe it is essential to take a bottom-up approach and pay attention to the regional differences and strengths within the members states. We believe that setting national targets can help ensure this in a tailored way that is socially just.

RWE welcomes the European Commissions initiative to revise national targets and flexibilities within the EU climate policy framework beyond 2030. EU-wide, market-based approaches remain the most efficient way to achieve emissions reductions and maintain a level playing field across Member States.

In order to ensure climate protection in the EU in a sustainable manner, a robust, nature-friendly and economically viable set of rules with binding national and sectoral emission reduction targets is needed by 2040, guided by an ambitious and science-based greenhouse gas budget.

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The European Forest Coalition consists of like-minded forest owners, forest cooperatives, and forest and wood industries from around Europe. Together we know that European forests and wood products play a crucial role in building a stronger European bio-economy. Please find our feedback in the enclosed document.

Slovenia believes that the achievement of the goal of climate neutrality by 2050 is crucial for prosperity in the EU, that is why it adopted the Climate Law which sets an even more ambitious national target of reaching climate neutrality by 2045.

The forestry and wood sectors make a significant and often underestimated contribution to climate action. In Austria, this contribution has accumulated to around 990 mio. tonnes of CO since 1990, which have been removed from the atmosphere or not additionally emitted due to active forest management. This effect results from the increase in forest growing stock (from approx. 900 Mio. m³ in 1990 to about 1.2 bn.

We welcome the opportunity to contribute to the Commission review of national targets and flexibilities in the EU climate policy framework after 2030. The Horticultural Peat Initiative supports the objective of a credible, science-based land-use framework that contributes to EU climate targets while remaining workable for Member States and land-based sectors providing essential resources and materials for European…

With our 200 000+ members, Svenska Naturskyddsföreningen (Swedish Society for Nature Conservation) has repeatedly argued that, to align with the 1.5°C temperature limit and equity, the EU could and should at minimum achieve domestic net zero emissions by 2040 at the latest, based on at least 92% gross reductions compared to 1990 levels.

Revision of national targets and flexibilities in the EU climate policy framework after 2030 An effective post-2030 framework is essential to support the EU's 2040 climate target and climate neutrality by 2050. Growing Media Europe (GME) recognises the need for further action after 2030, particularlyconsideringthe declining EU carbon removal sinksand the need to strengthen incentives for Member States to reduce…

The EUs post-2030 climate framework must ensure effective technology neutrality in practice, enabling all solutions delivering verified emissions reductions to contribute across Effort Sharing Regulation (ESR) sectors, including in rural and off-gas-grid areas where viable and cost-effective decarbonisation pathways are essential.

FEAD welcomes the possibility to contribute to the EU climate policy framework after 2030 and emphasises the importance of incorporating in this framework the promotion of the circular economy a key element currently absent from the call for evidence. When the Commission published its Communication on the 2040 climate target it emphasised the significance of the circular economy to achieve the EUs climate goals.

Climate Action Platform - Africa (CAP-A) strongly supports the use of flexibility mechanisms as a core component of the EUs 2040 climate framework. Member States face materially different abatement costs, residual emissions profiles, and access to domestic removals.

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.

Response from Swedish Wood Fuel Association National targets and flexibilities in the EU climate policy framework after 2030 review Swedish Wood Fuel Association welcomes the opportunity to provide input on the design of national targets and flexibilities in the EU climate policy framework beyond 2030. The Association supports the EUs 2040 climate target as a necessary step towards climate neutrality by 2050.

eAgronom Feedback 4: 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 feedback 3: 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 feedback 2: 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 feedback 1: 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).

Envien Group welcomes the opportunity to contribute to this public consultation on national targets and flexibilities in the EU climate policy framework after 2030. As a leading biofuels producer operating in the region of Central and Eastern Europe, we appreciate the Commissions efforts to engage stakeholders in shaping a post 2030 framework that ensures the effective achievement of climate objectives while…

The ETS is the cornerstone of the EUs climate policy, on which companies rely when planning and implementing capital-intensive investments. In the upcoming revision of the system, the fundamental design should be maintained to safeguard the predictability and stability that companies rely upon when making significant investments. But there is undoubtedly room for improvement.

The Health and Environment Alliance (HEAL) welcomes the opportunity to contribute. HEAL, its members, and the wider health community have consistently underlined that the climate crisis is a health crisis, and that public health needs to be at the centre of climate mitigation, resilience and preparedness efforts.

CEPF welcomes the opportunity to contribute the ongoing call for evidence around the role of forestry and forests in the EU climate policy framework beyond 2030. National targets and flexibilities set strong links with the ongoing evaluation of the LULUCF Regulation: the main component of the EU climate policy architecture setting the role of forests and forestry in climate change mitigation on the road to achieve…

When designing the post-2030 package, the European Commission must keep the long-term trajectory towards net-zero by 2050 at the latest and net-negativity thereafter in sight. Maintaining legally binding targets and robust progress reporting is necessary to ensure contributions by each member state.

Statkraft supports the EUs proposed 90% emissions reduction target for 2040 and calls for a post2030 framework based on robust governance, integrated longterm planning, a binding electrification target, additional renewable and cleanenergy targets, targeted regulatory measures, and predictable carbon pricing through a strong ETS. This will provide the necessary clarity to guide longterm investments.

SGI Europe urges that the new EU climate architecture, together with the upcoming Clean Industrial Deal, must decisively reinforce the role of Services of General Interest (SGIs). By prioritising technology neutrality, local governance, and infrastructure resilience, the EU can ensure that the journey toward the 2040 climate target is both industrially competitive and socially just.

European Shipowners | ECSA (ES|ECSA) welcomes the opportunity to contribute to the Commission's call for evidence on the revision of national targets and flexibilities in the EU climate policy framework after 2030, in particular with regards to the Effort Sharing Regulation (ESR). Please find enclosed our answer.

Citizens Climate Europe (CCEU) welcomes the EUs ambitious climate target of reducing net greenhouse gas emissions by 90% by 2040 and the opportunity to provide input in setting national targets. CCEU, a citizens organisation, advocates for rising and predictable carbon prices in close association with direct payments to citizens to address cost pass-through and to support citizens in transitioning towards low-carbon…

Exolum welcomes the European Commissions initiative to revise national targets and flexibility mechanisms in the EU climate policy framework after 2030 and supports the EUs 2030, 2040, and 2050 climate objectives.

To unlock the potential of the food and farming sector to deliver climate action and assist with meeting national targets, the future legislative framework should: (1) Set an EU-wide emissions reduction target for agriculture and mandate the development of Member State level sectoral targets.

As a global business organisation representing leading actors in the EU and international carbon markets, IETA welcomes the European Commissions efforts to explore how national targets can drive climate action, including the role of flexibilities and EUlevel enabling measures. Please see the full response attached.

the application of linear criteria or the allocation of disproportionate burdens compared to other sectors. In relation to land use and carbon removals, the potential of the agricultural sector is recognised, but the need to consider the high variability and uncertainty associated with climatic factors beyond the producer’s control is emphasised.

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The Estonian Forest and Wood Industries Association feedback on the EU climate policy framework after 2030. To achieve the EUs 2040 climate goals, the post-2030 architecture must be flexible, dynamic, and grounded in rigorous scientific analysis.

We welcome the opportunity to provide feedback on this topic. With the goal to boost competitiveness and security of renewable energy supply, Europe needs to shift its strategy towards an enabling framework, acknowledging the important role of actively managed forests and wood products, rather than adding restrictions and burdens for the providers of renewable, sustainable raw materials and fuels.

The Association of Finnish Cities and Municipalities (AFCM) advocates a framework in which binding national trajectories remain the central force driving domestic decarbonisation, complemented by a limited set of carefully designed flexibilities to improve cost efficiency and long term political viability. A wide range of mitigation measures can enhance supply resilience and increase cost efficiency.

The Beyond Alliance welcomes the opportunity to contribute to this Call for Evidence on national targets and flexibilities in the post-2030 climate policy framework. Please find our detailed response in the attached letter.

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.

CEWEP, Confederation of European Waste-to-Energy Plants, is the umbrella association of the operators of Waste-to-Energy (incineration with energy recovery) plants in Europe. Our members are committed to ensuring high environmental standards, achieving low emissions and maintaining state of the art energy production from remaining waste that cannot be recycled in a sustainable way. CEWEP contribution attached.

As ESWET, representing the technology suppliers behind 95% of Europe's Waste-to-Energy (WtE) plants, we welcome the opportunity to present our vision for the EUs post-2030 climate framework. We believe that WtE is not merely a waste management solution but a critical pillar of the circular economy and a proven driver of decarbonisation, essential to achieve the objectives of the climate policy framework after 2030.

Snam, a leading European energy infrastructure operator, welcomes the European Commissions initiative to establish a post-2030 climate framework. We believe that a successful climate policy framework should be pragmatic and sensitive to the diverse industrial and economic realities of Member States, including their specific energy infrastructure.

The EU needs binding national and sectoral emission reduction targets for 2040. National targets are a key pillar of EU climate policy: They create legally binding requirements for Member States and ensure their responsibility under the Paris Agreement.

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We welcome the review of national climate targets after 2030 in the context of the EU 2040 climate target and climate neutrality by 2050. A clear, ambitious yet realistic European framework is crucial, as Austria’s future targets depend to a large extent on the revision of the Effort Sharing Regulation (ESR).

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The Enel Group welcomes the European Commissions consultation on the design of the post2030 national climate targets framework and the opportunity to contribute to the reflection on how national frameworks can effectively support the delivery of the EU 2040 climate objective.

Örebro County considers it important that all Member States contribute to the EU’s 2040 climate target and that there is a simple and effective monitoring and enforcement mechanism to do so. All Member States need to contribute to the targets, but there also needs to be flexibility on how to do this where Member States can decide how to allocate emissions nationally.

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Bioenergy Europe, the European association for the bioenergy sector, welcomes the opportunity to provide feedback on the National Targets and Flexibilities in the context of the post-2030 framework. We fully support the Commissions efforts to update the energy policy infrastructure for the decade ahead.

Federation of Finnish Enterprises (Suomen Yrittäjät) represents approximately 70,000 Finnish SMEs through local chapters and 36,000 through trade associations. We welcome the opportunity to contribute to this impact assessment. We support a coherent post-2030 climate target framework. Long-term regulatory predictability is what unlocks private capital at scale and keeps total transition costs manageable.

The energy efficiency framework is a key tool for achieving the EU’s climate objectives, but its development must ensure that energy efficiency works as a genuine ‘energy efficiency first’ tool, not merely as a complementary tool.

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The 20302040 decade will be decisive for putting the EU on a credible path to climate neutrality. Achieving the proposed 90% net emissions reduction target by 2040 will require not only accelerated emissions cuts, but also the rapid scale-up of carbon dioxide removal (CDR). The policy framework designed in this decade will determine whether Europe can deliver both in a timely and cost-effective way.

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 by 2035.

The agreement on an ambitious climate target of a 90% reduction in greenhouse gas emissions by 2040, compared to 1990 levels, is an important step towards climate neutrality by 2050. It will also provide investment certainty for the European nuclear industry, provided that the framework to reach it remains technology neutral.

While we consider the review of the post-2030 targets to be necessary, we call for a fundamental revision of the current LULUCF framework. Our key criticism is directed against a policy that prioritises forests as passive carbon pools rather than promoting active management and the associated avoidance of fossil emissions.

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The Haga Initiative welcomes the Commission’s work to develop a robust and ambitious post-2030 framework to ensure emission reductions that move the Union towards implementing the 2040 and 2050 targets. In addition, it underlines that in times of geopolitical turmoil, ambitious climate action, fostering the transition of the green economy and boosting competitiveness, offers the EU a stronger strategic autonomy…

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This submission is provided by Tradewater in response to the European Commissions call for evidence on national targets and flexibilities in the EU climate policy framework after 2030. Tradewater supports a framework that maintains binding national trajectories as the primary driver of domestic decarbonisation, while incorporating limited and well-designed flexibilities to enhance cost-effectiveness and political…

PGE Polska Grupa Energetyczna S.A. (hereinafter: PGE) welcomes the opportunity to provide its feedback on the revision of national targets and flexibilities in the EU climate policy framework after 2030. The discussion on the post 2030 climate targets must be firmly anchored in the current geopolitical reality, including heightened security risks, volatility of global energy markets and the need to safeguard…

EDP supports the European Commission (EC) commitment to achieve 90% reduction in net greenhouse gas (GHG) emissions by 2040, compared with 1990, moving towards a fully decarbonised energy system. The present consultation represents a critical opportunity to ensure that the governance architecture remains effective, credible and investable in delivering these objectives.

The European Organisation of the Sawmill Industry (EOS) has prepared a comprehensive feedback, herewith attached, to the initiative. Below , we outline some key elements of our contribution: 1. The LULUCF framework should be made more flexible, dynamic and realistic, with a clear focus on substitution effects and strengthening the bioeconomy.

Please find attached FEDENE's feedback on the consultation. FEDENE brings together six professional associations that work to improve energy efficiency and building services, decarbonize heat and cold production using renewable and waste heat, in cities, housing, the tertiary sector, and industry.

The Finnish Union of Agricultural Producers and Forest Owners (MTK) would like to emphasize the role of sustainable forest management and a strong bioeconomy sector for achieving the EU climate targets after 2030. MTK welcomes the agreed target for climate mitigation by 90% by 2040.

Celanese welcomes the European Commissions preparation of the post-2030 EU climate framework. As a global chemical and specialty materials company with significant European industrial operations, and as a pioneer of commercial-scale Carbon Capture and Utilisation (CCU) technology, we submit this contribution to advocate for a framework that is ambitious, technologically neutral, and genuinely inclusive of all…

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.

Business & Science Poland supports a post-2030 climate framework providing Member States with meaningful flexibility in how national targets are delivered. The framework should better reflect different starting points, energy mixes, access to low-carbon technologies and the relative costs of transition across Member States.

The European climate targets for 2040 can only be achieved if the LULUCF targets are adapted to the real climate risks in the forest. A policy that focuses on more carbon storage in existing stocks and less forest management jeopardises forest stability, sufficient growth and the supply of raw materials, and at the same time jeopardises the achievement of objectives.

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The European Marine Board (EMB) welcomes this initiative to review the EU climate policy framework for the post-2030 period and to consider how national climate targets can incentivise action and ensure achievement of the EU 2040 climate target. EMB is the leading European think tank in marine science policy, representing over 10,000 scientists and technical staff around Europe.

The German Sawmill and Wood Industry Federation welcomes the review of national targets and flexibilities after 2030. The consultation document itself recognises that the realistic contribution of natural removals can only be assessed by taking into account significant uncertainties and that deficits must not come at the expense of other sectors. This is precisely why the future LULUCF framework needs to be adapted.

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AnimalhealthEurope, the association representing the manufacturers of veterinary medicines, vaccines and other animal health products, welcomes the possibility to provide feedback to the public consultation on the review of the National targets and flexibilities in the EU climate policy framework after 2030.

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Contribution submitted by BridgeWorks International (France) BridgeWorks International welcomes the European Commissions initiative to revise national targets and flexibilities in the EU climate policy framework beyond 2030.

Flexibility, technology readiness and investment cycles Achieving the 2040 target requires flexible and cost efficient implementation mechanisms that reflect technology readiness levels, industrial investment cycles and infrastructure constraints. Linear reduction pathways risk forcing premature deployment of immature technologies (e.g. large scale hydrogen use) that are not yet available or economically viable.

Avoid implicit transfer of LULUCF underperformance to industry The 2040 climate target must ensure that shortfalls in natural carbon removals (LULUCF) do not translate into stricter or unrealistic emission reduction obligations for industry.

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".