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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.
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Document type: Case study
Leaning on Uncertainty
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.
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Document type: Case study
Leaning on Uncertainty
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.
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Document type: Case study
Leaning on Uncertainty
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.
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Document type: Case study
Leaning on Uncertainty
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.
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Document type: Report
Kuala Lumpur Declaration on Climate Justice for Southeast Asia and South Asia
The Kuala Lumpur Declaration demands that developed countries fulfill their climate debt through grant-based finance, including an estimated USD 5.1–6.8 trillion by 2030. It advocates for a global Fossil Fuel Treaty, the rejection of 'false solutions' like carbon removal and nuclear power, and the dismantling of restrictive intellectual property regimes to accelerate technology transfer. The declaration further calls for tripling adaptation finance by 2035 and scaling the Fund for Responding to Loss and Damage to hundreds of billions of dollars annually.
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Document type: Statement
Call for evidence on the Governance Regulation
The document argues that EU member states' National Energy and Climate Plans (NECPs) and Long-Term Strategies (LTS) lack transparency and rigorous assessment regarding the deployment of permanent carbon dioxide removals (CDR). Carbon Market Watch warns that relying on unproven CDR volumes risks deterring essential emissions reductions. To remedy this, the author proposes making Multiannual Financial Framework (MFF) funding contingent on reporting quality, introducing dedicated CDR sections in planning templates, and legally defining 'overreliance' on CDR as 'insufficient ambition' within the Governance Regulation.
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Document type: Statement
Legal framework for the possible use of international credits towards the 2040 EU climate target under the European Climate Law
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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Document type: Statement
Strengthening Biomass Carbon Removal and Storage (BiCRS) Protocols
A technical assessment of 25 BiCRS protocols reveals that only 28% are satisfactory, with 72% scoring below satisfactory. The report identifies critical flaws in greenhouse gas accounting, particularly regarding system boundaries, biomass production emissions, and the treatment of uncertainty. It recommends adopting comprehensive system boundaries, standardizing the treatment of biomass baselines, and implementing robust measurement, monitoring, reporting, and verification (MMRV) to protect market and climate integrity.
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Document type: Report
Climate Science in Legal Contexts
The document is a comprehensive glossary designed to bridge the communication gap between the scientific and legal communities in the context of climate litigation. It defines key terms across seven thematic areas: foundational scientific concepts, measurement and data methods, climate and environmental science, risk and impact, public health, Indigenous Knowledge, and socioeconomic policy. The guide emphasizes the distinctions between scientific and legal interpretations of terms like 'bias', 'significance', and 'uncertainty', and explains how attribution science and climate modeling can be used to establish causation and responsibility in court.
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Document type: Guide
The EU’s 2040 climate target: emit now, remove later
The EU's 2040 climate target aims for a 90% net reduction in emissions compared to 1990 levels. However, the author contends that this target is a dilution of ambition because it allows 5% of the reduction to be met through international carbon credits and relies on a 'net' framework rather than separate targets for emissions reductions and carbon removals. This design creates a risk of 'mitigation deterrence,' where the expectation of future carbon dioxide removal (CDR) technologies—such as BECCS and DACCS—justifies slower near-term decarbonization. Despite broad stakeholder support for separate targets, including from some business associations and CDR developers, the European Commission opted for a single net target to simplify governance and maintain industrial competitiveness. The document warns that integrating CDR into the EU Emission Trading Scheme (ETS) could further allow large emitters to avoid direct cuts.
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Document type: Statement
Make Impact Assessments Great Again (MIAGA)
Carbon Market Watch claims the European Commission is routinely ignoring or bypassing required impact assessments and public consultations for major climate policies. The author asserts that this shift toward 'vibe-based' policymaking, driven by deregulation and industry lobbying, undermines transparency and risks significant economic and environmental damage, citing specific examples such as the 2040 climate target and the EU ETS2 Market Stability Reserve.
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Document type: Statement
How California Can Seize Momentum to Advance Carbon Dioxide Removal
Despite the veto of SB 643, California can leverage SB 840 and the Greenhouse Gas Reduction Fund to scale its carbon dioxide removal industry, ensuring it meets its 2030 and 2045 targets while preventing homegrown companies from relocating.
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Document type: Statement
Climate Strategies’ Pathway to Impact 2026-2029
Climate Strategies' 2026-2029 strategy focuses on accelerating the science-policy nexus to deliver inclusive and effective climate action. The organisation operates as a neutral knowledge broker, connecting a network of over 120 members with policymakers to address systemic gaps in climate finance, adaptation, and fossil fuel phase-out. Its strategic framework is built around five impact areas: Prosperity Post Fossil Fuels, Nature and Resilient Food Systems, Global Majority-Powered Change, Equitable Carbon & Climate Innovation, and Building Evidence-Based Climate Narratives. The strategy emphasises the need for Just Transitions, the inclusion of Global Majority perspectives in policy recommendations, and the use of evidence-based narratives to counter climate obstruction and misinformation.
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Document type: Report
TARGETING FAILURE
The report finds that investor climate targets are often opaque, lack ambition, and are poorly linked to real-world emission reductions. Analysis of 83 global investors reveals that many targets rely on volatile financial metrics, exclude scope 3 emissions, and are frequently reported as achieved long before their deadlines. The document recommends that investors adopt science-based sectoral targets, increase transparency in reporting, and align climate solutions investments with established taxonomies.
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Document type: Report
Climate Standards for Private Markets Investors
The Private Equity Stakeholder Project outlines five categories of climate standards for private markets investors: alignment with science-based targets, disclosure of fossil fuel exposure and emissions, the requirement for portfolio-wide energy transition plans, integration of environmental justice and community protections, and transparency regarding political spending and climate lobbying. The framework recommends specific timelines, such as phasing out coal power by 2030 and achieving a 4:1 ratio of low-carbon energy supply investments relative to fossil fuel investments by 2030.
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Document type: Report
Central and Eastern Europe’s energy crossroads: What new public opinion data tells us about the path forward
The document analyzes polling data from Project Tempo's EuroPulse Dashboard, revealing that while 62% of voters in Central and Eastern Europe (CEE) acknowledge human-driven climate change, they prioritize the economy and security over climate action, which ranks 16th out of 18 issues. CEE voters show strong support for wind (62%), solar (65%), and carbon dioxide removal (62%), with higher-than-average support for nuclear power (44%) as a means to ensure self-sufficiency and industrial competitiveness. The Clean Air Task Force (CATF) recommends a diversified approach incorporating 'clean firm power'—including nuclear (SMRs), advanced geothermal, and gas with carbon capture—to maintain 24/7 reliability and reduce dependence on external suppliers, particularly in light of Russia's war in Ukraine. Key barriers identified include a lack of funding consensus, as only 55% of voters support any specific payment option for the transition, and insufficient regional coordination on cross-border infrastructure.
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Document type: Policy brief
Second input SBTi Corporate Net-Zero Standard
The NewClimate Institute provides a critique of the second draft of the SBTi Corporate Net-Zero Standard v2.0, noting improvements in scope 3 emission source identification and reporting granularity while highlighting concerns regarding the 1% threshold for emission responsibility, the use of non-durable removals for fossil emissions, and the frequency of standard renewals.
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Document type: Statement
Mapping opportunities to decarbonize the U.S. pulp and paper industry
The U.S. pulp and paper industry, which accounts for 9% of industrial energy consumption, offers significant potential for net-negative emissions through CCS due to its reliance on waste biomass. A new mapping tool evaluates facilities based on capture costs, capture potential, storage costs, infrastructure clustering, and co-benefits. The analysis identifies the Gulf Coast—specifically Louisiana, Mississippi, and Texas—as having the highest opportunity scores. While private sector interest is growing, the document argues that the 45Q tax credit requires enhancement and regulatory certainty for transport infrastructure is needed to scale these technologies.
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Document type: Briefing
Does the EU need an Emissions Trading System for Agriculture?
The document assesses the potential for an Emissions Trading System for Agriculture (Agri-ETS) in the EU, arguing that such a system would only be effective if it targets large-scale polluters, avoids free allowances and carbon offsets, and is integrated into a wider suite of reforms. It highlights the risks of 'GHG tunnel vision' and the necessity of reforming the Common Agricultural Policy (CAP) to stop subsidising harmful practices. The author advocates for a 'Just Transition Fund for Agri-food' to support small-scale farmers using Agri-ETS revenues.
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Document type: Statement