Legal framework for the possible use of international credits towards the 2040 EU climate target under the European Climate Law

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Carbon Market Watch advises the European Commission against incorporating international credits into the EU's 2040 climate target. The organization argues that such a move would ignore scientific advice for 90-95% domestic emission reductions, violate the spirit of Article 6 of the Paris Agreement, and expose the EU to significant financial and reputational risks. The document highlights systemic failures in carbon credit integrity, including over-crediting and human rights violations, and estimates that relying on credits for 5% of the target could result in EU emissions being 50% higher than a fully domestic target, costing up to €49.7 billion.

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  • The use of international credits contradicts scientific recommendations from the European Scientific Advisory Board on Climate Change and over 2,000 scientists, who advocate for a 90-95% reduction in domestic emissions by 2040 without relying on flexibilities.
  • Relying on international credits for up to 5% of the EU's 2040 target could lead to EU emissions being 50% higher than if the target were entirely domestic, with estimated costs reaching €49.7 billion (at €70 per credit).
  • The document asserts that the EU is treating Article 6 of the Paris Agreement as a 'flexibility mechanism' rather than a tool to 'allow for higher ambition', which undermines the bloc's credibility as a global climate leader.
  • Carbon credit markets suffer from widespread integrity issues, including a lack of additionality, over-crediting, and failures in permanence guarantees, as well as violations of the rights of Indigenous Peoples and local communities.
  • The organization warns that purchasing international credits creates a recurring financial dependency and may crowd out necessary domestic investments in decarbonization and fossil fuel independence.
  • Evidence provided in the document suggests that many carbon projects significantly overstate their benefits; for example, one analysis of a cookstove project in Myanmar found it poised to issue 26 times more credits than scientific literature supports.

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APA
Carbon Market Watch (2026). Legal framework for the possible use of international credits towards the 2040 EU climate target under the European Climate Law. https://carbonmarketwatch.org/wp-content/uploads/2026/04/CMW-feedback-to-call-for-evidence-on-international-credits-in-2040-target.pdf
Chicago
Carbon Market Watch. Legal framework for the possible use of international credits towards the 2040 EU climate target under the European Climate Law. 2026. https://carbonmarketwatch.org/wp-content/uploads/2026/04/CMW-feedback-to-call-for-evidence-on-international-credits-in-2040-target.pdf.
Wikipedia
{{cite press release |author=Carbon Market Watch |title=Legal framework for the possible use of international credits towards the 2040 EU climate target under the European Climate Law |date=18 March 2026 |url=https://carbonmarketwatch.org/wp-content/uploads/2026/04/CMW-feedback-to-call-for-evidence-on-international-credits-in-2040-target.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{carbonmarketwatch2026legal, author = {{Carbon Market Watch}}, title = {{Legal framework for the possible use of international credits towards the 2040 EU climate target under the European Climate Law}}, publisher = {Carbon Market Watch}, year = {2026}, month = mar, url = {https://carbonmarketwatch.org/wp-content/uploads/2026/04/CMW-feedback-to-call-for-evidence-on-international-credits-in-2040-target.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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