Policy Consistency for Climate in the European Union
Posted on October, 23 2023
While the EU has made progress in recent years on cutting emissions, the accelerating climate emergency requires much more rapid action in all sectors, and for all EU policies to be pulling in the same direction.
In this context, it was extremely important that the European Commission was required under the EU Climate Law to assess, together with the State of the European union, whether “Union measures” are consistent with reaching climate neutrality and, where inconsistencies are found, to “take the necessary measures in accordance with the Treaties”. However, it is very regrettable to see that the European Commission didn't conduct a proper and comprehensive policy gaps assessment and then failed to address counterproductive EU policies.
Based on the outputs of a series of stakeholder workshops, organised with the support of Transport & Environment and E3G and drawing on analysis by the Ecologic Institute, WWF has identified the following EU policies as particularly inconsistent with EU climate goals, meaning that they are actively hindering rapid decarbonisation.
Based on the outputs of a series of stakeholder workshops, organised with the support of Transport & Environment and E3G and drawing on analysis by the Ecologic Institute, WWF has identified the following EU policies as particularly inconsistent with EU climate goals, meaning that they are actively hindering rapid decarbonisation.
- EU bioenergy policies. Although the justification given for them is explicitly climate-based, bioenergy policies in the revised Renewable Energy Directive will continue to incentivise the burning of trees and crops for energy, and on balance are therefore likely to be accelerating climate change rather than slowing it down. The harm they cause is magnified because of the extent to which they are relied upon in other EU policies, for example the ETS, the ESR, ReFuelEU Aviation, FuelEU Maritime and the sustainable finance taxonomy.
- Large parts of the Common Agricultural Policy (CAP), in particular those which encourage the consumption and production of animal products, that maintain practices that lead to high emissions of soil carbon, or that prevent the restoration of land and resulting carbon sequestration benefits.
- The Energy Taxation Directive, on the grounds that at present, and pending the outcome of negotiations on its revision, it in practice prevents the effective taxation of aviation kerosene.
- The inclusion of fossil gas and nuclear in the Sustainable Finance Taxonomy, which is encouraging investment in new fossil gas-fired and nuclear plants. This in turn is diverting available financial resources from technologies which are genuinely low carbon and/or provide cheaper and faster means of cutting emissions.
- Free allocation of emissions allowances under the EU Emissions Trading System (ETS). This ongoing failure to apply the ‘polluter pays’ principle to heavy industry has resulted in little to no change in industry emissions, or investment in less polluting industrial processes, and even under the revised ETS looks set to cost nearly half a trillion euro in forgone revenues over the 2021-2030 period.
- “Flexibility” (i.e. offsetting) between the Land Use, Land-use Change and Forestry (LULUCF) sector and the sectors covered by the Effort Sharing Regulation (ESR). Net removals in the LULUCF sector are hard to measure and not necessarily permanent, and cannot be treated as tonne-for-tonne equivalent to fossil fuel emissions or non-CO2 emissions in the agriculture sector.
