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The report argues that the proposed Turkish ETS is fundamentally weak due to its reliance on an intensity-based cap, broad unconditional free allocation, and the use of offsets. These design choices are expected to prevent the system from generating a meaningful carbon price signal, thereby failing to drive emissions reductions aligned with the Paris Agreement and leaving Turkish exporters exposed to significant CBAM fees. The authors recommend transitioning to an absolute declining cap, phasing out offsets, and shifting toward auctioning to retain climate revenues domestically.

A joint statement by EEB, Carbon Market Watch, ECOS, and Bellona evaluating proposed carbon farming methodologies. While acknowledging minor improvements regarding risk profiles and operator liability, the group argues that the methodology remains flawed. Key concerns include the failure to mandate pesticide reductions, the lowering of uncertainty deduction factors, the lack of social safeguards against land speculation, and the omission of livestock methane emissions from associated emissions calculations.

The document argues for a coordinated EU-level windfall profit mechanism to address extraordinary profits in the fossil fuel sector caused by geopolitical tensions. It proposes strengthening the previous Council Regulation (EU) 2022/1854 to increase the share of captured profits and expand the scope to include international companies operating in the EU market.

The document argues that traditional carbon offsetting is inherently deceptive because carbon credits cannot reliably counterbalance emissions on climate-relevant timescales. It advocates for the 'beyond value chain mitigation' (BVCM) approach, where credits are treated as contributions to global climate action rather than offsets. The guide outlines principles for credible communication, including the prioritisation of internal decarbonisation and the use of transparent, non-ambiguous language. It also provides case studies of misleading claims from entities like Climate Impact Partners, Audi, and Apple, and offers recommendations for policymakers to ban offsetting claims and for consumers to identify 'red flags' in corporate communications.

Carbon Market Watch opposes the use of international carbon credits to meet the EU's 2040 climate target, arguing that such a strategy would result in higher EU emissions, shift responsibility to the Global South, and undermine industrial competitiveness. The organization asserts that current carbon credit markets lack sufficient quality and transparency. While primarily advocating for a fully domestic approach, the document outlines strict quality criteria and a centralized purchasing mechanism that should be implemented if the EU proceeds with international credits as a last resort.

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 analyzes the first round of Article 6.2 reviews, finding that every reviewed Initial Report contained inconsistencies with reporting requirements. It argues that the Technical Expert Review Team (TERT) lacks the mandate to judge credit quality or enforce compliance, rendering the process a 'box-ticking exercise'. Case studies on Switzerland, Ghana, Guyana, and Vanuatu illustrate how high-risk or non-compliant credits can be traded despite transparency gaps. The author recommends extending the TERT mandate to include quality assessments and prohibiting the trade of credits until reviews are finalized.

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.

A coalition of NGOs argues that the European Commission's plan to modify the EU ETS Market Stability Reserve (MSR) is premature and risks undermining the carbon price signal. They highlight that the MSR has invalidated 3.4 billion allowances since its inception and is essential for managing structural oversupply of allowances, which is expected to persist until 2031. The authors contend that weakening the MSR could increase greenhouse gas emissions after 2030 and hinder the EU's 2040 climate target.

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.

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.

A coalition of organisations calls on the European Council and EU Member States to protect the integrity of the EU ETS against short-term political intervention. The letter argues that stable carbon pricing is essential for low-carbon industrial investment and warns that weakening the system would increase regulatory risks and financing costs. The signatories demand the maintenance of the agreed cap trajectory for 2030 and 2040 targets, the upholding of the polluter pays principle regarding the phase-out of free allocations, and the strategic use of auction revenues and the Innovation Fund to avoid fossil-based lock-in.

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.