LOOPHOLES IN THE 2030 EFFORT SHARING DECISION

The report identifies four primary loopholes in the proposed 2030 Effort Sharing Decision (ESD) that could undermine the EU's climate goals. These include the use of land use offsets (LULUCF), the inflation of carbon budgets based on 2020 targets, the use of surplus EU ETS allowances, and the carry-over of unused carbon permits ('hot air'). Collectively, these loopholes could result in the EU emitting 4.7 billion tonnes more CO2-equivalent than pledged, potentially allowing emissions to increase rather than decrease between 2021 and 2030.

• If all identified loopholes were included in the 2030 ESD, the EU could be allowed to increase emissions rather than cut them, potentially releasing 2.3 billion tonnes of CO2 equivalent more between 2021 and 2030, resulting in a total of 4.7 billion tonnes more CO2-equivalent than the 2030 climate pledge.
• The integration of land use, land use change, and forestry (LULUCF) carbon removals into the 2030 framework could allow some countries to reduce their emission cuts in sectors like agriculture and transport, potentially leading to 1.35 billion tonnes of additional CO2 equivalent emissions.
• Calculating national carbon budgets based on 2020 targets rather than real emissions levels could inflate the EU's carbon budget, potentially allowing an extra 751 million tonnes of CO2 equivalent to be emitted.
• The use of surplus allowances from the EU Emissions Trading System (EU ETS) to meet national ESD targets could lead to an additional 300 million tonnes of CO2 being released between 2021 and 2030.
• Allowing the carry-over of unused carbon permits, known as 'hot air' (estimated at 1.5 billion tonnes of unused permits plus 750 million tonnes of credits from third countries), into the post-2020 period could result in an additional 2.25 billion tonnes of CO2 equivalent being released.

APA

Carbon Market Watch (n.d.). LOOPHOLES IN THE 2030 EFFORT SHARING DECISION. https://carbonmarketwatch.org/wp-content/uploads/2016/05/ESD-Two-Pager_Loopholes_Infographic_FINAL.pdf

Chicago

Carbon Market Watch. LOOPHOLES IN THE 2030 EFFORT SHARING DECISION. n.d. https://carbonmarketwatch.org/wp-content/uploads/2016/05/ESD-Two-Pager_Loopholes_Infographic_FINAL.pdf.

Wikipedia

{{cite report |author=Carbon Market Watch |title=LOOPHOLES IN THE 2030 EFFORT SHARING DECISION |url=https://carbonmarketwatch.org/wp-content/uploads/2016/05/ESD-Two-Pager_Loopholes_Infographic_FINAL.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{carbonmarketwatchndloopholes, author = {{Carbon Market Watch}}, title = {{LOOPHOLES IN THE 2030 EFFORT SHARING DECISION}}, institution = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2016/05/ESD-Two-Pager_Loopholes_Infographic_FINAL.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }