Carbon Market Watch

Carbon Market Watch welcomes the European Commission’s proposal for a European Climate Law that will enshrine the EU’s climate neutrality target into law. However, the proposal for a Regulation falls short on the timeframe needed to deliver this goal, and lacks improvements which would impact climate action in the near term. We would like to make the following suggestions for improvement: 1.

Carbon Market Watch (CMW) welcomes the European Commission’s proposal for a European Climate Law (CL) to enshrine the EU’s climate neutrality target into law. CMW also welcomes the proposed functions of the CL as: 1) pushing for climate mainstreaming in all policies and, 2) setting the EU target in line with the scientific consensus on climate change.

The science is clear that we will need to remove carbon from the atmosphere this century in order to keep global heating below 1.5°C. However, removals must be supplementary to and not a substitute for emission reductions, while differentiating between real and false removal solutions remains crucial.

If done well the CRC-M can determine what is actually CDR or not, and keep false solutions out of this field. Time and resources are scarce and must be invested in real removals, and not in CCU and temporary storage. These may have climate benefits, but that does not make them equal to CDR.

The EU ETS carbon price supports the investment signal for the power sector to lower its consumption of fossil fuels and switch to renewable energy sources, but thats not the case for industrial stationary installation: the continued allocation of free emission allowances has contributed to the limited decarbonisation of steel, cement and chemicals sectors, which remain the major sources of EU industrial CO2…

Green Claims Directive: Open Consultation Carbon Market Watch’s response to the Green Claims Directive public consultation Introduction Carbon Market Watch welcomes the opportunity to provide feedback on the proposed Green Claims Directive (GCD).1 Misleading and unsubstantiated green claims are widespread and must be addressed.

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

The Carbon Border Adjustment Mechanism (CBAM) could offer a better hope of decarbonisation in energy-intensive industries than free allowances, and could create a first-mover advantage for EU industry in the global race to decarbonisation.

Carbon Market Watch fully supports efforts to price GHG emissions, within and outside the EU. The EU ETS has been successful for certain sectors, but has failed to incentivise large scale decarbonisation of European industry, in part because of its excessive measures to guard against the hypothetical risk of carbon leakage.

The regular update of the benchmarks values for free allowances under the EU ETS is a necessary step to ensure that the last years of the free allocation system are fully coherent with the aim of a full phase-out by 2034 for all sectors, and provide the investment signals necessary to funnel funding into industrial decarbonisation.

The revision of the EU Emissions Trading System (ETS) represents a huge opportunity to strengthen the Directive to ensure it is in line with the 1.5˚C target under the Paris Agreement. However, the European Commission’s proposal includes two major shortcomings that should be reconsidered.

The upcoming revision of the EU Emission Trading System represents a crucial opportunity to strengthen the Directive and ensure it contributes to the goals of the Paris Agreement. Carbon Market Watch believes that the upcoming review should include the following elements. 1.

Aviation and shipping fuels do need to be taxed. The climate crisis is urgent, and the IPCC Special Report on 1.5°C makes it abundantly clear that global GHG emissions need to drop by 45% at least this decade. Fossil fuel consumption from international transport is a significant contributor to climate breakdown.

Carbon Market Watch welcomes the opportunity to provide feedback on the ETD revision. Several aspects of this directive are crucial to set the EU on a pathway compatible with the Paris Agreement’s objectives. Carbon Market Watch supports the revision of the Directive, in particular with regard to the aim of “aligning taxation of energy products and electricity with EU energy and climate policies with a view to…

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.

Carbon Market Watch is concerned with the willingness of the European Commission to allow for domestic and international credits to account as carbon price paid in a third country. Not only this represents a discrepancy with the current EU ETS architecture, but sets a dangerous precedent that incentivises the establishment of crediting schemes with no qualitative safeguards. Our feedback is in the document attached.

Carbon Market Watch welcomes the opportunity to provide feedback on the European Commission's proposal for the revision of the Industrial Emissions Directive. The revision of the Industrial Emissions Directive (IED) represents a huge opportunity to strengthen the directive to ensure it fulfills the objectives of the European Green Deal and effectively addresses the negative impact of industrial emissions on the…

Carbon Market Watch fully supports the comprehensive feedback provided by the European Environmental Bureau to the inception impact assessment and welcomes the opportunity to give specific views on how the Industrial Emissions Directive (IED) should be revised to support industrial decarbonisation in a complementary manner to the EU Emission Trading System.

Carbon Market Watch welcomes the opportunity to provide input on the draft certification methodologies. Unfortunately, schemes as these carry many issues: They fail to address the root cause of nature destruction. The EU should first ensure that existing public funding schemes and policies actually guarantee nature-positive action.

Carbon Market Watch welcomes the opportunity to respond to the LULUCF proposal. We would suggest improvements in three main areas: 1. AFOLU pillar Combining non-CO2 agriculture emissions from the ESR with land-based sinks from the LULUCF under an AFOLU pillar is problematic for several reasons: A. It will not incentivize emissions reductions in the agriculture sector, where progress has been slow.

Carbon Market Watch - Response to Inception Impact Assessment on LULUCF Regulation Carbon Market Watch (CMW) supports increasing the climate ambition of the LULUCF Regulation so it can promote climate action, while providing much needed co-benefits in other environmental fields (especially biodiversity and restoration of ecosystems). CMW also supports the feedback from Climate Action Network Europe and Fern. 1.

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.

Carbon Market Watchs response focuses on the role of carbon dioxide removals planning and reporting within the Governance Regulation framework. Carbon Dioxide Removals (CDR) are measures and technologies that draw down carbon from the atmosphere and store it over relevant time horizons, so the removed CO2 can no longer contribute to climate breakdown.

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.

There is no way around it: the EU LULUCF carbon sink is shrinking. The European Scientific Advisory Board on Climate Change (ESABCC) confirmed that the EU net sink has been declining rapidly over the last 10 years, decreasing by 2021 to a third of its 2005 total (ESABCC, 2024).

The aviation sector continues to benefit from important privileges in the EU, despite its significant climate impacts. EU policies should be revised to ensure that the aviation sector pays a fair price on its GHG emissions, thereby enforcing the polluter pays principle.

The revision of the EU ETS represents a huge opportunity to strengthen the Directive to ensure it is in line with the 1.5˚C target under the Paris Agreement. However, the Commission proposal includes two major shortcomings that should be reconsidered. The EU wide 55% greenhouse gas reduction target by 2030 is incompatible with the goals of the Agreement, and it should be upgraded to 65%.