Last week, the European Commission launched its mammoth package of legislative proposals aiming to implement the EU Green Deal and deliver the promises made under the European Climate Law. The package aims to reduce net emissions by at least 55% until 2030, with a capped contribution from the land sink, and is a key policy milestone for making Europe the first climate-neutral continent by 2050.  

To reach those goals, the package will need to deliver substantial investments in innovation and enable the infrastructure developments needed for meeting a 2030 target in line with the Paris Agreement while keeping Europe on track for net-zero by 2050. 

As the pathway to net-zero becomes clear across the sectors, attempts to introduce creative emissions accounting – greenwashing, rather than real emissions reductions – multiply. Policymakers will face increasing pressure to allow loopholes to that end. Devils will as ever be found in the details, and European civil society needs to be geared up for the required scrutiny.   

Our initial assessment indicates that the proposal is ambitious in some aspects but falls short of the climate goals in others.  

On the one hand, emission reduction targets have been increased, new renewable energy targets have been set, safeguards to avoid double counting have been put in place, and funding mechanisms for decarbonisation have been strengthened and expanded, including a departure point from the unsustainable free emission allocations for EU industries with the CBAM proposal. We congratulate the European Commission on its hard work and evidence-based approach in this respect.  

On the other hand, the proposal allows for the continued support for fossil fuels and wastes, unsatisfactory treatment of biomass, potential accounting loopholes, and fails to set targets for resources and infrastructure needed to achieve climate neutrality (e.g., renewable electricity deployment and the required investments in our electricity grids to enable its direct, efficient use wherever possible).   

The resources supporting our future economy and welfare are not equally distributed – some Member States have a very high potential for low-cost RES, others have easy access to offshore CO2 storage. Without enabling, border-crossing infrastructure like smart electricity grids, hydrogen pipelines and CO2 transport infrastructure providing access to permanent CO2 storage for industry, the functioning of the EU Single Market will be at risk. The European Institutions now need to recognise this great challenge and do much more to coordinate and facilitate the timely roll-out of such industrial decarbonisation infrastructure, with free and fair access across the Single Market. 

Some of the assumptions in the Scenarios for the “Fit for 55” policy analysis regarding Renewable Fuels of Non-Biological Origin (RFNBO) are problematic. For instance, it is assumed that only fossil CO2 will be used for CO2 utilisation (CCU) products until 2040, which will simply continue to increase the concentration of GHGs in our atmosphere. Moreover, no additionality is assumed for the renewable electricity used for RFNBO production after 2035, which could, as shown in one of our recent assessments, be detrimental for the decarbonisation of the power sector. 

This briefing outlines our assessment of the package and provides broad recommendations on how to improve its implementation and the revision of the files it contains. In other words, it is an initial analysis, based on our key areas of expertise, including heavy industry, mobility and climate accounting, of related topics as they emerge across the different legislative files of the package.  

We are looking forward to working with EU policymakers to both improve on the points mentioned here, and to safeguard the constructive elements of this package.  

Find the scoreboard assessment here:

Bellona Europa Fit for 2030 Climate Scoreboard(pdf)