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Austria aims for climate neutrality by 2040, relying on industrial carbon removals (up to 6.3 Mt CO2eq) and land sinks, yet lacks a legally binding national climate law. While the 2024 Carbon Management Strategy (CMS) provides a transparent roadmap, significant delivery risks exist regarding the technical feasibility and timing of CO2 transport and storage infrastructure. Furthermore, there is high uncertainty regarding the long-term performance of the LULUCF sector and a lack of safeguards to prevent BECCS deployment from degrading the natural land sink.

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.

Finland relies on Bioenergy with Carbon Capture and Storage (BECCS), biochar, and land sinks to reach its 2035 carbon neutrality target, but faces significant delivery risks. The government has disregarded scientific advice from the Finnish Climate Change Panel to moderate logging levels to restore the declining land sink, which currently shows rising net emissions. While the government is pursuing BECCS, it lacks domestic geological storage and must rely on international transport and storage, which are constrained by limited capacity in Northern Europe. Furthermore, current financial allocations for BECCS are significantly lower than the estimated needs to achieve projected removal volumes.

The French government's strategy for climate neutrality relies on a combination of vulnerable land sinks and industrial carbon dioxide removal (CDR) technologies. While France has binding gross-emission-reduction targets, its land sink has declined by more than 20 Mt CO2eq over the last decade due to a forestry crisis. To compensate, the Draft Third National Low Carbon Strategy (SNBC3) increases reliance on industrial removals, including Direct Air Capture and Carbon Storage (DACCS) and Bioenergy with Carbon Capture and Storage (BECCS). However, the report finds that projections for these technologies are inconsistent and lack foundational assessments regarding energy demand, land-use impacts, and domestic CO2 storage capacity. Furthermore, France plans to increase wood harvesting to 60 million m3 by 2030, which may further erode the forest carbon sink.

The document examines Ireland's climate strategy, highlighting a systemic over-reliance on carbon dioxide removals (CDR) and afforestation to bridge gaps in emission reductions. It identifies significant delivery risks for industrial removals like BECCS, which may not be operational until the mid-2030s, and notes that afforestation targets are consistently missed. The report criticizes the lack of transparency regarding residual emissions and the potential for 'temperature neutrality' goals to lower overall climate ambition.

The report finds that Italy's long-term climate strategy prioritises carbon removals and capture technologies over structural emission reductions, creating a risk of mitigation deterrence. While Italy aims for carbon neutrality by 2050, it lacks national legislation to enforce this goal and relies on EU-level targets. The study highlights significant transparency gaps, noting that industrial carbon dioxide removal (CDR) technologies like BECCS and DACCS are often conflated with carbon capture and storage (CCS). Furthermore, the report warns that planned increases in forest harvesting to 40-45% by 2030 could shrink or eliminate the land sink, despite government goals to restore it to a historic maximum of 45 Mt CO2eq by 2050.

The document argues that Norway's climate strategy relies on uncertain land-sink removals and international offsets rather than feasible domestic emission reductions. It identifies systemic deficiencies in impact assessments, a lack of separate LULUCF targets beyond 2030, and a conflict of interest where geological storage sites are evaluated based on their potential to interfere with future petroleum activity. While some industrial removal projections are cautious, the report notes a lack of binding limits on international credits and significant gaps in biomass sustainability evaluations.

The report finds that European governments are increasingly integrating carbon dioxide removals (CDR) into their climate strategies, often as a substitute for deep emission reductions. Analysis of the European Commission and six countries reveals a pattern of 'overreliance,' characterized by fragmented planning, a lack of feasibility assessments for engineered removals, and land-sink projections that ignore climate risks or contradict existing forestry policies. The report warns that betting on uncertain future technologies and unstable land sinks risks delaying essential decarbonization and undermining climate targets.

The report argues that temporary CRCF units from carbon farming are currently of low quality due to insufficient management of non-permanence and additionality risks, making them unsuitable for offsetting emissions. It assesses proposed EU agri-food policies—including an Agricultural Emissions Trading System (AgETS) and Mandatory Climate Standards (MCS)—concluding that allowing these units as offsets would undermine environmental integrity. The authors recommend shifting toward activity-based payments, either through a reformed Common Agricultural Policy (CAP) or other public funding mechanisms, to promote carbon farming without the integrity risks associated with result-based crediting.

The report evaluates Moldova's progress toward climate neutrality by 2050, identifying 'Some Progress' in most sectors but 'Little Progress' in zero pollution. Key challenges include heavy reliance on energy imports, outdated building stock, linear waste management, and a significant financing gap, while enablers include EU accession aspirations and international donor support.

The document advocates for separating carbon dioxide removal (CDR) from general climate goals to avoid 'mitigation deterrence,' where the hope of future CDR technologies slows current emission reductions. It proposes a three-pronged approach: binding targets for gross emission reductions, biosequestration in natural sinks, and permanent technological removal. While the EU currently uses 'net' targets for 2030 and 2050, the author suggests the upcoming 2040 target proposal is an ideal opportunity to formalize this separation.

The report evaluates the integration of permanent carbon removals—specifically BioCCS and DACCS—into the EU ETS. It identifies a critical tension: while direct integration can drive deployment and maintain market liquidity as the emissions cap approaches zero, it risks 'abatement deterrence' where removals substitute for necessary emissions reductions. The authors warn that without supply controls, BioCCS deployment could exceed sustainable biomass limits, potentially harming biodiversity and LULUCF carbon sinks. To mitigate these risks, the report recommends a gradual integration strategy that maintains the gross emissions cap, implements technology-specific supply controls, and introduces differentiated allowances. It also emphasizes that the EU ETS alone is likely insufficient to incentivize high-cost technologies like DACCS or to achieve net-negative emissions post-2050, necessitating additional public funding tools and long-term policy frameworks.

The report, produced by the CO2ol Down project, argues that the current EU Climate Law fails to differentiate between temporary biogenic sequestration and permanent carbon removals. It proposes specific legislative amendments to ensure that permanent removals are used only to compensate for residual emissions and that biogenic sequestration is managed for ecosystem resilience rather than as a primary tool for climate neutrality. The proposal suggests establishing separate targets and trajectories for emissions reductions, biogenic sequestration, and permanent removals to avoid mitigation deterrence.

The document examines how discrepancies between NDC accounting and IPCC standards lead to an overestimation of land-based carbon sequestration, potentially reducing the global carbon budget by 15-18%. It highlights that current NDC pledges for land-based removal involve approximately 1 billion hectares, which the author claims is impossible without threatening food security and biodiversity. Furthermore, the briefing critiques IPCC Integrated Assessment Models (IAMs) for ignoring land tenure, human rights, and the declining ability of natural sinks to store carbon under rising temperatures, suggesting that sustainable removal potential is up to 79% lower than IPCC estimates.

The document defines carbon dioxide removal (CDR) as the physical extraction of CO2 from the atmosphere and its permanent storage. It argues that CDR must be a complement to, not a substitute for, aggressive emission reductions (over 90%). The guide evaluates six negative emissions technologies and practices (NETPs)—including Bio-CCS, DACCS, and biochar—while critiquing current EU policies for failing to distinguish between permanent removals and temporary biological sequestration. It advocates for a diversified portfolio of CDR methods, rigorous life-cycle accounting, and a governance framework based on the 'planetary boundaries' to avoid ecological trade-offs.

The Climate Action Tracker (CAT) argues that current 2030 climate targets and policies are insufficient, projecting end-of-century warming of 2.5°C to 2.7°C. To maintain the 1.5°C goal, the document asserts that governments must enter 'emergency mode,' peaking global emissions before 2025 and halving them by 2030. It outlines four essential elements for 2035 NDCs: ambition based on sectoral benchmarks, scaled-up climate finance for developing nations, credibility through the elimination of fossil fuel subsidies and exploration, and transparency via absolute economy-wide targets that separate land-use sinks and carbon removals from domestic reductions.

Carbon Market Watch argues that the draft Article 6.4 sustainable development tool prioritizes national legal requirements over international standards, which undermines the mandate for robust social and environmental safeguards. The organization calls for a structured consultation of at least one month with rights-holders, including Indigenous Peoples, and recommends that the tool mandate the application of safeguard criteria rather than making them optional. Key concerns include the artificial time boundary of monitoring impacts only during the crediting period and the limitation of recognizing Indigenous legal systems only when they are consistent with national legislation.

The proposal aims to address the lack of coordination between climate, biodiversity, and development strategies in the Democratic Republic of the Congo (DRC). It proposes a 24-month project to create a 30x30 investment strategy that integrates biodiversity conservation with climate mitigation and adaptation, specifically focusing on the rights and engagement of Indigenous Peoples and Local Communities (IPs and LCs). Key activities include spatial modelling to identify priority conservation areas, policy alignment analysis, the development of a business plan for 30x30 implementation, and the submission of a technically sound GCF project concept note.

The document argues that treating wood burning as renewable energy has led to forest degradation, high CO2 emissions, and public health risks. It outlines the legal requirements of RED III and urges Member States to use their discretion to phase out biomass subsidies, implement the cascading principle, and adopt stricter sustainability criteria to protect European forests and the climate.

An open letter from a coalition of academics, NGOs, and businesses calling for a 'firewall' in EU climate policy to prevent carbon removals and land sequestration from being used as substitutes for gross emissions reductions. The signatories argue that 'net' targets risk mitigation deterrence and advocate for three independent targets to be integrated into the 2040 climate target and the EU's updated nationally determined contributions.