
On 2 July 2025, the European Commission announced their new intermediate climate goal for 2040. The Commission proposed an amendment to the European Climate Law, which would enable the EU to set an intermediary binding climate target for 2040 that aims for a 90% reduction in greenhouse gas (GHG) emissions by 2040.
According to the Commission, the proposals announced in July 2025 were a sign of the ironclad commitment within the EU to slashing emissions. By providing a key 2040 milestone towards achieving climate neutrality by 2050, this would also help mobilise action on the EU’s pre-existing targets of cutting GHG emissions by at least 55% by 2030. The 90% target, however, is lower than the 90-95% range, with no flexibilities, recommended by the EU’s official scientific advisors. This Just the Facts provides an overview of the process which has surrounded negotiations between July and December 2025.
What has changed since the Paris Agreement?
This year we mark ten years of the Paris Agreement; a legally binding international treaty on climate change. The Paris Agreement set out a goal to limit the global average temperature to below 2°C, but with commitments to limit increases to 1.5 °C. Countries are required to set their own climate commitments under a model of Nationally Determined Contributions (NDCs), which are updated every 5 years. The success of the Paris Agreement relies heavily on transparency and effective monitoring and reporting. What is key to the Paris Agreement is that the goals to reduce GHG emissions cannot be decreased over time. However, its targets are implemented via “peer pressure” rather than enforced.
Similar to other parties to the Paris Agreement, the EU also submits an NDC on behalf of the bloc and member states. Following its first NDC in 2015, it submitted updated NDCs in 2020 and another NDC in 2023, in conjunction with its adoption of “Fit for 55” legislative package outlining its target of a 55% reduction in net GHG emissions by 2030. Ahead of COP30, on 5 November 2025, the EU submitted its updated NDC for 2030 and beyond. The EU’s updated NDC reiterates commitments of achieving a net reduction of 55% in GHG emissions by 2030 as well as an indicative target of 66.25% to 72.5% by 2035.
2040 climate target negotiations
On 5 November, the Council of the EU agreed to its negotiating position, maintaining the Commission’s proposal of a 90% reduction in GHG emissions and adding further emphasis on some aspects of the Commission’s proposal. Notably, the Council included additional “flexibility” for member states to reach the 2040 target including the use of up to 5% international carbon credits from third countries or carbon offsetting as a means to contribute to its climate target. This contrasts with the Commission’s proposal of only allowing 3% of carbon offsetting to be eligible to contribute to the EU’s targets.
On 13 November the European Parliament also agreed it’s negotiating mandate; agreeing on a proposal that was less ambitious than the Commission’s, but one that was closely aligned to that of the Council. Despite the watered-down proposal agreed by the Parliament, it did request additional safeguards to be put in place to ensure quality and accountability in relation to the use of carbon credits. The negotiations on the Parliament’s position were hampered by far-right and some centre-right (EPP) MEPs pushing to scrap the 2040 target altogether, forcing centre-left political groupings to compromise on some aspects of the proposal.
Carbon credits would allow the EU to finance emissions’ reduction projects outside of the EU or buy reduction certificates relating to emissions’ decreases in other regions outside of Europe to count towards the EU’s own targets.
The EU Commissioner for Climate, Wopke Hoekstra argued ‘“The planet doesn’t care where we reduce emissions — that is just the logic of physics”. However, other groups, including many civil society organisations, view carbon credits as problematic for a number of reasons, including the fact that the EU, as a historical high emitter with significant capacity, should do more domestically, rather than transfer its obligations to countries with lower emissions and less resources. It is notable therefore that there exists no global system which guarantees the credibility of carbon credits.
What difference does it make anyway?
The Council’s position on the proposed amendments to the Climate Law, also includes putting in place a more robust review mechanism. This would entail biennial assessments monitoring progress towards intermediate climate targets and would allow for ‘re-adjustment’ of commitments if they are deemed to be impacting the EU’s economy. This could open the way for the weakening of the EU’s dedication to reaching Net-Zero by 2040. These provisions, which could potentially facilitate lowering the 2040 target, are contrary to the Paris Agreement obligations which require greater climate ambition over time.
The Council also proposed to delay, by one year, a new Emissions Trading Scheme (ETS2) around transport and buildings that had been due to come into effect in 2027, which according to EEB risks undermining the EU’s 2030 targets. On 10 December, after trilogue negotiations, the Council of the EU and the Parliament reached a provisional agreement on the 2040 target and the amendment of the Climate Law. However, climate campaigners are worried about how these ‘flexibilities’ could weaken the EU’s climate policy, with Antonine Oger, Executive Director of the Institute for European Environmental Policy, stating that in the face of other EU priorities such as defence, competitiveness and security, references to the environmental crisis, climate and sustainability have seemingly become a ‘lesser priority’. Others have raised the potential damage to Europe’s credibility as a leader on climate issues. Member of the European Parliament (MEP) Lidia Pereira commented that “It is a responsibility of the European Union to show that you can decarbonise and grow, but this is an effort that has to be shared.”
What does Ireland think?
Ireland’s Climate Minister Darragh O’Brien welcomed the agreement between EU Climate Ministers on the 2040 target, saying that he was particularly happy about the role the Irish Government had played a role in securing the amendment to European Climate Law, which included ‘recognition of the particular characteristics of our agriculture sector, the importance of maintaining energy affordability and security, and the need to ensure social cohesion as we continue the transition to a climate-neutral economy.’
Hannah Daly, Professor of sustainable energy at University College Cork responded that Minister O’Brien was engaging in ‘wishful thinking’ regarding Ireland’s compliance with EU climate laws, and that the state could face costs ranging from €8 billion to €26 billion after 2030 if ‘Ireland continues on its current path, failing to cut emissions significantly this decade.’
Following Micheál Martin’s speech at COP 30 Friends of the Earth Ireland’s CEO said, ‘Despite what the Taoiseach has said in Bélem, Ireland is not on track to reduce emissions in accordance with national and EU obligations.”










