Letters to Policy Makers

Dear Member of the European Parliament,

Today you will vote on the so-called “Climate Action Regulation implementing the Paris Agreement” (Effort Sharing Regulation, or ESR). This regulation covers about 60% of the EU’s greenhouse gas emissions. If designed correctly, it can drive innovation in the sectors involved, and lead to great benefits for the society such as cleaner air, reduced energy poverty and more liveable cities.

The effectiveness of the ESR as a climate instrument is however threatened by a too low ambition and the inclusion of several loopholes which, if adopted, will further water down the already weak proposal. The target of -30% compared to 2005 levels proposed by the Commission means the EU aims to reduce its emissions by merely 1% per year over the next 16 years, while in the last five years an annual reduction of almost 2% was achieved. It also means we postpone necessary reductions to much later.

To be in line with the EU’s commitment to the Paris Agreement, a target of at least 47% for the ESR sectors would need to be adopted, alongside a starting point that reflects real emissions levels. On this regard, we call on you to support amendments which strengthen the current proposal, and reject any amendments which suggest to increase or establish new loopholes. 



The starting point should reflect actual emissions and not reward countries for underachieving.  Amendment 59 best reflects where emission levels will be in 2021, which will bring the most benefits in terms of climate action under the regulation.

  • Vote in favour of Amendment 59



To contribute to the efforts of limiting global warming to 1.5C degrees, carbon removals from forests should be promoted in addition to, and not instead of, the efforts to cut emissions. For that reason, the use of LULUCF credits that undermine climate actions in the ESR sectors should be limited.

Amendment 63, 66 rejects the ability to offset emissions under this regulation with the help of land use, which significantly improves the environmental integrity of the system. Amendment 55-57 on the other hand allow for 280 Mt CO2e use of LULUCF credits to offset emissions under this regulation. Given the faulty accounting rules in the LULUCF system this leaves the proposal weak, as there is no guarantee that removals actually take place. This holds true in particular for credits from forest management.

In the Commission proposal, nine countries are also allowed to exploit the ETS surplus to undermine climate action in the non-traded sectors. For that reason the use of ETS credits should be limited. Amendment 62 limits the use of the ETS flexibility to 50 Mt which secures the environmental integrity of the system compared to the Commission’s proposal.

  • Vote in favour of Amendment 62, 63, 66
  • Vote against Amendment 55, 56, 57



The Commission’s proposal suggests a comprehensive review of Member States' GHG emissions reports and the more formal compliance check to only be carried out every five years (in 2027 and 2032). If the first formal compliance check happened only in 2027 it would give countries no time to implement additional policies if they are not on track to meet their targets. Amendment 64 introduces annual compliance checks, which is needed to ensure countries are on track to meet their targets.

  • Vote in favour of Amendment 64



The ENVI report introduced a new ‘early action reserve’. Under this proposal, countries can use ‘hot air’ from the pre-2020 period when many countries were still allowed to increase their emissions. The ENVI report (Amendment 37) suggest the use of this ‘reserve’ to be 70Mt CO2e, while Amendment 58 allow for as much as 90 Mt CO2e of hot air to be carried over from this commitment period to the next. Introducing flexibilities which inflates the carbon budget for the commitment period puts the implementation of the Paris climate goals at risk and both these amendments should therefore be rejected.

  • Vote against Amendment 37 and 58



Article 10 (2) in the Commission’s proposal would allow some countries to have a larger emission budget for the year 2021. Under the current Effort Sharing Directive, these countries are allowed to increase their emissions until 2020. Given almost all these countries have actually reduced rather than increased emissions until now, this is unnecessary under the current proposal. Amendment 65 deletes this provision.

  • Vote in favour of Amendment 65



Caroline Westblom
CAN Europe
EU Climate and Energy Policy Coordinator,
caroline@caneurope.org, +32 2 894 46 74

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