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The Clean Air Task Force (CATF) recommends a cautious, safeguard-driven integration of permanent carbon removals (specifically DACCS and BioCCS) into the EU ETS to avoid deterring direct emissions reductions. The briefing argues for expanding the ETS scope to include extra-EEA flights, vessels above 400 gross tonnage, and municipal waste incineration and landfills. It specifically highlights the need to address non-CO2 aviation impacts, such as contrails, through financial incentives and robust monitoring. To support the transition, CATF suggests earmarking aviation ETS revenues for sustainable aviation fuels (SAF) and maintaining SAF allowances beyond 2030.

The report analyzes the potential demand response to an EU ETS scope expansion for extra-EEA flights. It finds that demand effects are generally small at current price levels, particularly for high-emitting segments such as long-haul flights, business travel, and private aviation, which exhibit low price elasticity. The study highlights that cost pass-through rates are higher in competitive markets and at uncongested airports. Non-price factors, including value of time, airline loyalty, and airport attractiveness, are identified as primary drivers of the observed differences in price sensitivity across market segments.

Carbon Market Watch asserts that CORSIA is a "phantom scheme" due to patchy enforcement and reliance on low-quality offsets. The author highlights that US airlines, including United, Delta, and American Airlines, are unlikely to pay for their emissions under CORSIA, especially under the Trump administration. Consequently, the document urges the EU to expand the EU ETS to all departing EEA flights to generate revenue for transport decarbonisation and ensure airlines are held accountable for their carbon pollution.

The author contends that CORSIA fails to address aviation's climate impact because it only covers emissions above a high baseline and lacks binding national enforcement mechanisms. Even with penalties, the scheme would only cover 20% of emissions for a Brussels-New York flight by 2030. In contrast, the EU ETS is presented as a superior model due to its 100% coverage of intra-EEA flights and harmonised penalties of €100 per tonne of CO2. The document advocates for the European Commission to extend the EU ETS to all departing flights by mid-2026, which could generate up to €9 billion annually by 2030 to fund zero-emission aircraft and high-speed rail.

Carbon Market Watch asserts that private jet use in Europe is under-regulated despite being the most polluting form of travel. The organization proposes multiplying the carbon price by four for private jets and expanding the scope of the EU Emissions Trading System (EU ETS) to cover the 67% of private jet emissions currently exempt. Such measures could raise between €304 million and €2.2 billion annually by 2030, depending on the scope of coverage and the inclusion of non-CO2 effects. The document also advocates for aviation fuel taxation and the prioritization of low-cost solutions, such as contrail avoidance, over subsidies for unsustainable bio-kerosene.

RMI conducted pilots with BCG, Roland Berger, and Estuaire to compare contrail accounting methods. The results show that a bottom-up, flight-specific approach is significantly more accurate than the standard 1.7x multiplier, revealing that 2% of flights cause 80% of contrail impacts. The report advocates for a phased transition toward high-fidelity accounting to enable targeted corporate travel policies and alignment with emerging EU regulations.

Carbon Market Watch asserts that the EU's Sustainable Transport Investment Plan (STIP) is insufficient without expanding the EU ETS to cover all aviation and shipping emissions. The organization estimates that covering all flights leaving the EEA would generate an additional €9 billion annually, rising to €58 billion if non-CO2 effects and private aviation are included. While the STIP utilizes the EU Innovation Fund and European Hydrogen Bank for cleaner fuels, the author argues that funding should shift away from biofuels toward e-kerosene and railway infrastructure, such as the Trans European Transport Network (TEN-T), to adhere to the 'polluter pays' principle.

The document analyzes the IMO's Net-Zero Framework (NZF), which was delayed by one year in October 2025 due to pressure from the US and oil-producing nations. A study by Cincera Consulting finds the NZF is inadequate, projecting emission reductions of only 8-10% by 2030, far below the 45% required by the Paris Agreement. The brief criticizes the NZF's hybrid approach—combining a GHG fuel standard with limited carbon pricing—noting that the effective carbon price of $14/tCO2eq is too low to drive a transition to green fuels. It recommends that the EU expand its Emissions Trading System (ETS) to cover 100% of emissions for voyages entering or leaving the European Economic Area and urges the IMO to adopt a universal levy to address absolute emissions.

Carbon Market Watch proposes extending the EU ETS to include all departing flights from the European Economic Area (EEA), non-CO2 aviation effects, and private jets. The brief argues that the current limited scope—covering only intra-EEA flights—fails to address the sector's full climate impact and misses significant revenue opportunities. By implementing these extensions and applying carbon price multipliers for private jets, the EU could generate substantial funds to finance e-kerosene development, upgrade railway infrastructure via the Trans-European Transport Core Network (TEN-T), and meet international climate finance targets. The author specifically recommends replacing support for biofuels with a focused e-kerosene scheme extended to 2040.

The report finds that current EU ETS cap trajectories are more ambitious than required by most climate neutrality scenarios, potentially leading to severe allowance shortages and price spikes after 2035. It evaluates several reform options to balance supply and demand, including adjusting the linear reduction factor (LRF), reforming the Market Stability Reserve (MSR), and integrating carbon dioxide removals (CDRs). The authors warn against the inclusion of Article 6 international credits due to risks to environmental integrity and the potential for market collapse. Recommended solutions include a combination of MSR replenishment and technological CDRs or a phased reduction of the LRF post-2035.

The document assesses the effectiveness of the EU ETS and CORSIA in addressing aviation emissions, finding that both schemes fail to cover non-CO2 effects and that CORSIA's reliance on low-quality offsets and a high baseline limits its climate impact. It recommends extending the EU ETS to all flights departing from the European Economic Area (EEA) by 2027.

The report finds a substantial divergence in ambition between the EU ETS and CORSIA. While the EU ETS is moving toward 100% auctioning of allowances by 2026 and high carbon prices, CORSIA relies on offsetting emissions above a baseline, resulting in significantly lower emissions coverage and a much weaker price signal. The EU may expand the EU ETS to extra-EEA flights by 2027 if CORSIA is deemed insufficient to meet climate goals.

The document outlines a detailed schedule of EU ETS and CBAM milestones from 2024 to 2034. Key developments include a shrinking emissions cap, the phase-out of free allowances for aviation, the gradual integration of shipping and municipal waste incineration, and the phased implementation of CBAM. It also details the rollout of the ETS for buildings and road transport (ETS2) and the associated Social Climate Fund, alongside various European Commission reviews of the ETS Directive and Market Stability Reserve.

The EU Industrial Carbon Management Strategy aims to scale up CO2 capture, utilisation, and storage to meet 2040 climate targets, specifically targeting an annual injection capacity of at least 250 million tonnes in the European Economic Area by 2040. To achieve this, the Commission plans to address current imbalances in storage—which is currently concentrated in the North Sea—by establishing transparent permitting processes by 2025 and creating an investment atlas of potential storage sites. The strategy also envisions a vast transport network, potentially reaching 19,000 km by 2040, and proposes a regulatory package for CO2 transport and a demand aggregation platform by 2026. Financial mechanisms discussed include the Innovation Fund, Connecting Europe Facility, and a possible Important Project of Common European Interest for transport and storage. Additionally, the strategy emphasizes industrial carbon removals (such as BECCS and DACCS) to help reach a target of removing 400 million tonnes of CO2 per year by 2040.

The EU ETS for aviation currently covers intra-EEA flights, with a potential expansion to global flights pending a 2026 evaluation of ICAO's CORSIA. A key reform is the gradual phase-out of free allowances, with airlines paying for all emissions by 2026. The system is also introducing monitoring for non-CO2 emissions and providing 20 million free allowances until 2030 to support sustainable aviation fuel (SAF) uptake.

The report asserts that the EU cannot reach net zero by 2050 without large-scale deployment of CCUS, estimating a need to capture and store between 300 and 640 Mt of CO2 annually by 2050. It highlights a significant gap between current project announcements and the necessary infrastructure, particularly in CO2 transport and geological storage. The authors recommend that the European Commission establish clear targets, a regulatory framework for CO2 grids, and financial mechanisms like Carbon Contracts for Difference (CCfD) to de-risk investments. The document specifically identifies 'hard-to-abate' sectors—such as cement, steel, and waste-to-energy—as critical areas where CCUS is either the lowest-cost or only viable decarbonisation pathway. It also emphasizes the necessity of technology-based carbon dioxide removals (CDR) via BECCS and DACS to balance residual emissions.

A study by Öko-Institut for Carbon Market Watch finds that major European airlines rely on low-quality, cheap carbon offsets and lack transparency in reporting, often using misleading claims like 'carbon-neutral flying' to mask a lack of substantive emissions reductions.

Carbon Market Watch argues that including international maritime transport in the EU ETS is essential for sector decarbonisation given the lack of progress at the International Maritime Organisation. The organization recommends covering 100% of international voyages to and from the European Economic Area, starting in 2024, and expanding the scope to include non-CO2 gases and vessels from 400 to 5,000 gross tonnage. It further advocates for the removal of exemptions for outermost regions and specific vessel types, and the creation of an Ocean Fund to receive 75% of generated revenues to support zero-carbon fuels and energy efficiency.

The document outlines enhancements made by the ENVI Committee to the aviation ETS, including accelerating the transition to full auctioning by two years, expanding the scope to all departing flights from the EEA, and introducing monitoring for non-CO2 effects.

The report evaluates the impact of expanding the EU Emissions Trading System (EU ETS) to cover more European aviation flights compared to the European Commission's (EC) proposal, which retains the EU ETS for intra-EEA flights and uses CORSIA for flights between the EEA and other participating states. Using the AERO-MS model, the study finds that expanding the EU ETS to include all outgoing flights (Scenario 1) or all outgoing and incoming flights (Scenario 2) would significantly increase emission reductions and auctioning revenues, though at a higher cost to airlines. Specifically, Scenario 2 would result in a 113% higher emission reduction than the EC proposal. The report also highlights uncertainties in CORSIA's effectiveness, noting that changes in the baseline or non-participation of major aviation countries could reduce its emission reductions by up to 77%.