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NGO letter for ENVI committee on CBAM vote
The letter advocates for a CBAM that covers all high-emitting sectors and indirect emissions from the start, a faster phase-out of free ETS allowances to incentivize green investment, and the earmarking of CBAM certificate revenues for climate mitigation and adaptation in least developed countries.
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Document type: Statement
Joint NGO statement
A joint statement from NGOs urging the Economic and Financial Affairs Council (ECOFIN) to implement the Carbon Border Adjustment Mechanism (CBAM) as a direct alternative to EU ETS free allowances and indirect cost compensation to maintain decarbonisation incentives.
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Document type: Statement
Open letter: A bold and transformative Social Climate Fund is needed, now more than ever
An open letter calling for a transformative Social Climate Fund (SCF) to address energy poverty and climate goals in Europe, arguing that the fund must have a flexible, non-capped budget linked to ETS revenues and carbon prices to ensure a just transition.
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Document type: Statement
OPEN LETTER regarding the use of offsets in the EU ETS
The letter expresses concern that 555 million carbon offset credits were surrendered into the EU ETS between 2008 and 2011, costing an estimated €5.9bn. The signatories argue that these offsets stifle domestic action, support business-as-usual coal and large hydro projects in the CDM, and allow for 'hot-air laundering' through Track 1 Joint Implementation, thereby threatening the environmental integrity of EU climate policies.
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Document type: Statement
Carbon Market Watch response to Inception Impact Assessment on the EU ETS
Carbon Market Watch proposes a comprehensive strengthening of the EU ETS, including increasing the Linear Reduction Factor to reach zero emissions by 2040 and increasing the Market Stability Reserve intake rate to 36% from 2024. The organization advocates for the full auctioning of emission allowances, earmarking 100% of revenues for climate action, and extending the system to include international maritime transport and waste incineration. Conversely, it argues against including road transport and buildings in the ETS and opposes the inclusion of Carbon Dioxide Removal (CDR) credits.
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Document type: Statement
The energy-intensive industry lobby and the EU ETS
The briefing argues that energy-intensive industry lobbies in the EU use 'discourses of climate delay' to protect their financial interests, specifically by securing free emission allowances. While these sectors publicly support 2050 climate neutrality, the document claims they actively oppose short-term EU ETS reforms, such as increasing the Linear Reduction Factor or phasing out free allocations. The author asserts that the industry's narrative regarding 'carbon leakage' lacks empirical evidence and serves as a justification for windfall profits. The briefing further details how technical factors in the free allocation formula (BM, HAL, CLEF, and CSCF) are manipulated by lobbyists to maintain high levels of free permits, thereby undermining the 'polluter pays' principle and delaying industrial decarbonisation.
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Document type: Briefing
The impact of the Paris agreement on the EU’s climate policies
The policy brief outlines seven areas where the EU should enhance its climate policies following the Paris agreement. Key recommendations include increasing the 2020 emission reduction target to 30%, revising the 2050 low-carbon roadmap to meet the 1.5°C objective, and adopting 5-year ambition cycles. It also calls for the phase-out of free pollution permits for industry, the inclusion of aviation and maritime sectors in the EU ETS, and the use of the Sustainable Development Mechanism to finance emission reductions in developing countries without relying on offsetting.
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Document type: Policy brief
O N E U K A L L O W A N C E the future of uK Carbon Pricing
Sandbag argues that a standalone UK ETS would be dysfunctional due to its small size and vulnerability to volatility and speculation. The organization recommends that the UK either remain part of the EU ETS or implement a carbon tax with a floor based on the average EU ETS price. Key proposals include expanding carbon pricing to fossil gas and fugitive methane, ending the zero-emissions treatment of large-scale biomass burning, and distributing carbon revenues to citizens as a 'climate dividend'.
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Document type: Report
Climate of Cooperation
The report evaluates the Effort Sharing Regulation (ESR), concluding that its -30% target for non-ETS sectors is insufficient to meet Paris Agreement goals and may only result in a 26.6% reduction due to flexibilities. It advocates for project-based transfers of Annual Emission Allocations (AEAs) to ensure additionality and avoid carbon lock-in in lower-income Member States. Specific opportunities for such projects are identified in the building, waste, and gas sectors of Bulgaria, Romania, and Hungary.
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Document type: Report
Playing With Fire
The report identifies 67 planned coal-to-biomass projects in the EU that could increase biomass consumption by 607 PJ per year, potentially tripling the current levels of biomass burnt in coal power plants. This expansion would require approximately 36 million tonnes of wood pellets annually, which is similar to current global production. The authors argue that these projects are expensive, rely on public subsidies, and risk accelerating climate change because the CO2 emitted during combustion is not reabsorbed quickly enough to meet Paris Agreement targets. The report highlights that five countries—Finland, Germany, Ireland, Spain, and the Netherlands—are responsible for most of this potential growth, with the Netherlands accounting for 25%.
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Document type: Report
Whose views count? Business influence and the European Commission’s High Level Groups
The report finds that the majority of the seven examined High Level Groups are either corporate-controlled or unbalanced in favor of industry, leading to policy recommendations that prioritize industrial competitiveness over environmental and social standards. It highlights a lack of democratic legitimacy and inconsistent transparency, calling for the dissolution of industry-controlled groups and the establishment of more equitable consultation mechanisms.
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Document type: Report
Microsoft Word - FoEE_ETS_Final
The document critiques the EU-ETS for its failure to deliver necessary CO2 cuts due to over-allocation of permits, price volatility, and the use of offsetting. It argues that the system has become a profit-making tool for industry while increasing energy costs for consumers. Friends of the Earth Europe proposes replacing or supplementing the EU-ETS with binding national climate laws, mandatory energy savings targets, higher renewable energy goals, and a shift toward CO2-based taxation and direct public financing for emissions reductions.
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Document type: Report
Les marchés du carbone à la CdP25 à Madrid: une menace pour les gens, la politique et la planète
The document critiques carbon markets, specifically 'cap and trade' and 'carbon offsetting', as mechanisms that allow major polluters to avoid reducing emissions at the source. It highlights the failure of the EU ETS and the Clean Development Mechanism (CDM), noting that global emissions continue to rise. The briefing emphasizes the severe impacts on indigenous peoples and local communities, citing REDD as a driver of land grabbing and forced displacement. It specifically warns against the implementation of Article 6 of the Paris Agreement, which could institutionalize these markets, and calls for a transition to agroecology and a just energy transition instead.
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Document type: Briefing
Governance of the EU-Wide Phase-Out of Fossil Fuel Subsidies by 2020
The EU has established a framework to phase out fossil fuel subsidies by 2020, including a legal obligation to end hard coal mining subsidies by 2018. While the EU has reduced its own direct budgetary support and some member states have implemented tax reforms, significant challenges remain. The document highlights a tension between official commitments and actual practice, noting that some countries may use transparency measures to avoid eliminating a broad range of subsidies. A significant portion of coal-related fiscal support in countries like Germany, Spain, and the Czech Republic has been redirected toward just transition measures for workers and site rehabilitation.
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Document type: Case study
Czechia: Country Election Risk Assessment
The report identifies a complex threat landscape for the 2025 Czech elections, where foreign actors—primarily Russia and China—exploit domestic polarization and economic grievances. Key risks include the use of AI-generated deepfakes, the proliferation of pro-Kremlin Telegram networks, and narratives targeting the legitimacy of the new postal voting system. While Czechia's decentralized electoral infrastructure is considered resilient, the report highlights critical gaps in regulatory strength, specifically the delayed implementation of the EU Digital Services Act (DSA) and inadequate oversight of third-party campaign financing.
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Document type: Report
From Waste to Traffic Fuel (W-Fuel)
The W-Fuel project investigated the feasibility of producing biomethane from locally sourced biodegradable waste, sludge, manure, and energy crops in northern Estonia. The study focused on two pilot sites: the Hinnu pig farm in Harju County and a proposed plant in Rakvere, Lääne-Viru County. Findings indicate that while CHP production may be more commercially profitable due to existing feed-in tariffs, upgrading biogas to biomethane for transport fuel is more socially and environmentally beneficial, particularly when accounting for the EU Emissions Trading Scheme (EU-ETS). The report also provides detailed biomass availability forecasts for 2020 and recommends specific waste prevention measures and governmental support schemes to facilitate the transition to gaseous renewable fuels.
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Document type: Report
FRAMING STRANDED ASSET RISKS IN AN AGE OF DISRUPTION
The report argues that the sustainability transition creates 'creative destruction' where new technologies and business models render existing assets economically unusable. It proposes a three-step methodology: identifying disruptions and scenarios, testing for negative growth dynamics, and mapping asset-type implications. Applying this to Europe, the authors identify up to €750 billion in assets at risk across three sectors. The European electricity sector serves as a historical case study, having suffered €130 billion in impairments between 2010 and 2015. In the automotive sector, up to €243 billion is at risk due to the combined impact of electric vehicles, autonomy, and car sharing. The apparel industry faces risks primarily in real estate and intangible brand value due to e-commerce and supply-chain ESG issues. The report concludes that traditional ESG analysis is insufficient and must be integrated with financial value assessments to capture non-linear disruption risks.
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Document type: Report
The German Fast-Start Finance Contribution
Germany exceeded its Fast-Start Finance (FSF) pledge for 2010-2012, providing EUR 1.29 billion for climate action in developing countries. The funding was split roughly evenly between bilateral and multilateral channels, with a primary focus on mitigation (45%) and REDD+ (26%), while adaptation received 28%. Most resources were allocated to Africa (34%) and Asia (29%). Germany is noted for publishing a specific definition of "new and additional" finance, counting funds committed above a 2009 baseline or generated via EU ETS auctioning revenues. The paper recommends increasing adaptation support, improving reporting on actual disbursements, and diversifying funding sources beyond emission-trading revenues.
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Document type: Research paper
Greenhouse Gas Mitigation in Australia
The report finds that Australia's current climate policy framework, including the Clean Energy Future package and the Large-Scale Renewable Energy Target, enables the country to meet its international commitment to reduce emissions by 5-25 percent from 2000 levels by 2020. However, it identifies significant risks, including policy uncertainty stemming from political disagreement over the carbon-pricing mechanism and an over-reliance on purchasing international permits rather than achieving domestic reductions.
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Document type: Report
Greenhouse Gas Mitigation in the European Union
The report evaluates the European Union's progress toward its '20-20-20' targets and its long-term 2050 goals. While current policies are expected to lead the EU to surpass its 2020 greenhouse gas reduction and renewable energy targets, the report finds that additional measures are necessary to achieve the 2020 energy efficiency target and the 2050 greenhouse gas reduction goal.
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Document type: Report