Leaning on Uncertainty

The document argues that while the European Commission's impact assessments are detailed, the resulting policies are opaque and rely on optimistic, potentially unfeasible projections for carbon dioxide removals (CDR). It identifies critical risks, including the overestimation of Direct Air Carbon Capture and Storage (DACCS) capacity, the potential for Bioenergy with Carbon Capture and Storage (BECCS) to undermine land sinks, and a lack of transparent financing roadmaps. The report further criticises the introduction of international carbon credits in final proposals without prior impact assessments, which may reduce domestic ambition.

• There is a significant disconnect between the European Commission's detailed scientific impact assessments and its final policy proposals, which simplify complex data into opaque 'net' targets that conflate emission reductions with carbon removals.
• The EU's 2040 climate target projections for Direct Air Carbon Capture and Storage (DACCS) are significantly higher than the feasibility estimates provided by the European Scientific Advisory Board on Climate Change (ESABCC). For 2040, the Commission's central scenarios (S2 and S3) project 15-42 MtCO2eq from DACCS, while the ESABCC estimates only 0-7 Mt.
• The European Commission's final proposal for the 2040 target introduces the use of international carbon credits (up to 5% of 1990 EU net emissions) starting in 2036, despite this option not appearing in the initial impact assessment or target communication.
• Heavy reliance on BECCS to compensate for potential DACCS failures could severely damage the EU land sink. A sensitivity analysis indicates that increased woody biomass demand for BECCS and biofuels could decrease LULUCF net removals by approximately 100 MtCO2-eq in 2040.
• The EU lacks a comprehensive financial roadmap for engineered removals and land sink expansion, relying instead on fragmented mechanisms like the Innovation Fund and a proposed 'EU Buyers' Club' for certified credits.
• Current EU strategies for CO2 transport infrastructure are underdeveloped and vague, with most transport expected to occur via 'alternative' methods to the coast for offshore storage.

APA

Orth, D. (2026). Leaning on Uncertainty. Carbon Market Watch. https://carbonmarketwatch.org/wp-content/uploads/2026/04/Leaning-on-uncertainty-European-Union.pdf

Chicago

Orth, Daniel. Leaning on Uncertainty. Carbon Market Watch, 2026. https://carbonmarketwatch.org/wp-content/uploads/2026/04/Leaning-on-uncertainty-European-Union.pdf.

Wikipedia

{{cite report |last1=Orth |first1=Daniel |title=Leaning on Uncertainty |publisher=Carbon Market Watch |date=April 2026 |url=https://carbonmarketwatch.org/wp-content/uploads/2026/04/Leaning-on-uncertainty-European-Union.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{orth2026leaning, author = {Orth, Daniel}, title = {{Leaning on Uncertainty}}, institution = {Carbon Market Watch}, year = {2026}, month = apr, url = {https://carbonmarketwatch.org/wp-content/uploads/2026/04/Leaning-on-uncertainty-European-Union.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }