On July 2^nd 2025, after over one year of delays, the European Commission published its legislative proposal to amend the European Climate Law and establish a 2040 climate target. This proposal comes just before the European Union prepares to submit its updated Nationally Determined Contribution (NDC) with a 2035 target to the UN by September 2025, ahead of COP30 in Brazil, in line with commitments under the Paris Agreement.  

The European Climate Law, agreed in 2020, is the framework law which establishes the overarching legal framework under which other climate policy must operate. It is primarily known for establishing the world’s first legally binding climate neutrality goal across multiple countries, for establishing the European Scientific Advisory Board on Climate Change (ESABCC), and for establishing the target to reduce emissions by net 55% by 2030 compared to 1990 levels. 

But this crucial moment is about more than fulfilling procedural obligations. The climate targets for 2035 and 2040 will define Europe’s environmental, economic and geopolitical strategy, and will signal whether the EU remains committed to become the first climate-neutral continent of the world.  

While the reaffirmation of the 90% target for 2040 in the proposal is both welcome and necessary, the recently published proposed amendments introduce concerning possible loopholes which would dilute the target from inside.

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