Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa

The submission argues that South Africa's draft second NDC lacks sufficient ambition and fails to reflect the 'highest possible ambition' required by the Paris Agreement. It proposes more stringent emission targets—350 Mt CO2e for 2025-2030 and 248 Mt CO2e for 2031-2035—based on 'fair share' calculations and the best available science. The document highlights legal risks under the South African Constitution, the Climate Change Act, and NEMA, while criticizing the Department of Forestry, Fisheries and the Environment (DFFE) for a non-transparent process that delayed the release of the underlying technical report. It further calls for a stronger focus on phasing out fossil fuels, enhancing climate adaptation for vulnerable groups, and incorporating climate justice principles from the Presidential Climate Commission's recommendations.

• The submission contends that the draft NDC's mitigation target ranges—350 Mt CO2e to 420 Mt CO2e (2026 to 2030) and 320 Mt CO2e to 380 Mt CO2e (2031 to 2035)—are 'unsafe, unambitious, inadequate' and do not represent a meaningful progression from previous targets.
• Based on various 'fair share' studies and the Presidential Climate Commission (PCC) analysis, the document proposes specific mitigation targets of 350 Mt CO2e for the 2025-2030 period and 248 Mt CO2e for 2031-2035.
• The authors argue that the draft NDC is legally deficient and may conflict with the South African Constitution, the National Environmental Management Act (NEMA) 'duty of care', and the Climate Change Act 22 of 2024, thereby exposing the state to litigation risk.
• The submission criticizes the DFFE's public participation process, specifically noting that the underlying technical report by the Energy Systems Research Group (ESRG) was released only one day before the submission deadline.
• The document highlights economic risks associated with low climate ambition, specifically the threat of carbon border adjustments like the EU's Carbon Border Adjustment Mechanism (CBAM), which could impact South African exports due to the country's fossil-fuel intensive energy systems.
• The submission calls for the NDC to explicitly name the harms of fossil fuel production and combustion and to incorporate the PCC's recommendations on climate justice, including restorative, distributive, and procedural justice.
• Regarding adaptation, the document expresses concern over regulatory delays in the Climate Change Act and emphasizes the need to address climate migration, refugees, and the health impacts of toxic air pollution.

APA

Centre for Environmental Rights (2025). Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa. https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779

Chicago

Centre for Environmental Rights. Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa. 2025. https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa |date=29 August 2025 |url=https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrights2025written, author = {{Centre for Environmental Rights}}, title = {{Written submission on Draft Second Nationally Determined Contribution for the Republic of South Africa}}, institution = {Centre for Environmental Rights}, year = {2025}, month = aug, url = {https://cer.org.za/wp-content/uploads/2025/09/Life-After-Coal-comments_Draft-Second-NDC_29-August-2025.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }