Separate Member State carbon removal targets are essential for a credible EU climate framework after 2030

The European Commission's factual summary of the public consultation on the revision of national targets and flexibilities after 2030 points to a clear conclusion: Europe's next climate framework cannot rely on a single national net target alone.

The consultation received 141 responses, mainly from business associations, NGOs, companies and public authorities. While the summary is not a representative sample of the EU population, it provides important evidence from the stakeholders who will be directly involved in delivering, financing, scrutinising and implementing the EU climate framework after 2030.

Among the options for the design of national climate targets for 2040, the highest level of support was for separate national targets for emissions reductions and removals, supported by 58% of respondents. This was significantly higher than support for a single net national emission reduction target, at 29%, or no national targets, at 21%. For carbon removal targets specifically, the strongest support was for two distinct removal targets: one for the LULUCF sector and one for permanent carbon removals. Limiting removal targets only to the LULUCF sector received the lowest support.

That matters for the Member State targets proposal expected in Q4 2026.

The question is not whether Europe needs both emissions reductions and carbon removals. It does. The question is whether the EU climate framework will make their different roles visible, accountable and investable.

Reductions and removals do different jobs

Emissions reductions stop new greenhouse gases entering the atmosphere. Carbon removals take CO₂ out of the atmosphere and store it. Both are needed for climate neutrality, but they are not interchangeable.

The IPCC defines carbon dioxide removal as a set of approaches that remove CO₂ from the atmosphere and store it durably in geological, terrestrial, ocean or product reservoirs. It also stresses that CDR methods vary significantly in their characteristics, risks, storage duration and governance needs.

This is why a single net target is not enough. A net number can show the balance between emissions and removals, but it does not show how that balance is achieved. It can hide whether a Member State is reducing emissions at the pace required, relying on land sinks, or assuming the future availability of permanent removals.

For a general climate target, this may sound like an accounting issue. It is not. It is a delivery issue.

If reductions and removals are merged into one number, the EU risks weakening accountability for emissions cuts, increasing pressure on land sinks, and failing to create a visible demand signal for permanent carbon removals. Separate targets make the policy task clearer: reduce emissions as far and as fast as possible, protect and restore land-based sinks, and scale permanent removals for the residual emissions that cannot be fully eliminated.

The science supports separate targets

The scientific case for separate targets is well established, and it has only strengthened over the past two years.

McLaren, Tyfield, Willis, Szerszynski and Markusson (2019) argue that targets and accounting for negative emissions should be formally separated from emissions reduction targets to prevent carbon removals from substituting for emissions cuts. Their work highlights a central risk in net-zero policy: if removals are treated as fully interchangeable with reductions, future removal promises can be used to delay near-term mitigation.

This risk is often described as mitigation deterrence. It does not mean carbon removals should be avoided. It means they need to be governed properly. Carbon removals should complement deep emissions reductions, not compensate for a lack of effort.

More recent modelling also supports this approach. A 2025 Nature Communications study by Merfort and colleagues examined the implications of separating emissions and novel CDR targets in global net-zero pathways using an integrated assessment model. The study found that the overall efficiency losses from separating targets were moderate, while separation reduced cumulative emissions, lowered the public financing burden for removals, and limited reliance on geological CO₂ storage.

A 2024 paper in Environmental Research Letters by Koponen and colleagues, produced through the EU-funded NEGEM research consortium, reached a similar conclusion in the specific context of the EU's 2040 target: one way to avoid mitigation deterrence is to create separate targets for emissions reductions, permanent CDR and the LULUCF sector.

In other words: separate targets are not a luxury. They are a practical way to manage risk that shows up consistently across independent modelling exercises.

They also help define what removals are actually for. Buck, Carton, Lund and Markusson (2023) found that residual emissions are often poorly defined in national long-term strategies, even though net-zero targets depend on balancing those residual emissions with carbon removals. Their analysis found that residual emissions in Annex I countries averaged around 18% of current emissions in the most ambitious scenarios, and that many strategies lacked clarity on which sectors would remain residual and how removals would balance them. A related 2024 study in One Earth by Smith, Vaughan and Forster examined long-term national climate strategies more broadly and similarly found that vague treatment of residual emissions and removals tends to mask a lack of real climate ambition.

This matters because residual emissions should not become a political escape hatch. Without separate targets, Member States can avoid difficult decisions about which emissions are genuinely hard to abate and which should be reduced through stronger policy, infrastructure and investment.

The risk of over-relying on the promise of future removals is not abstract. A 2024 Nature study by Schleussner, Ganti, Lejeune and colleagues modelled how much carbon removal capacity the world might need if warming overshoots the Paris Agreement's 1.5°C limit, and found that a reserve of several hundred billion tonnes of removal capacity could be needed just to bring temperatures back down afterwards — capacity that should not be spent offsetting emissions that could have been avoided in the first place. A related 2024 Nature Communications study by Möller, Högner, Schleussner and colleagues found that both the size and the duration of any temperature overshoot increase the risk of triggering irreversible tipping points in the climate system, reinforcing the case for prioritising real emissions cuts and treating removals as a carefully governed complement rather than a substitute.

Political feasibility, not evidence, has been the missing piece

If the evidence for separate targets is this consistent, it is worth asking why the EU's 2040 climate target did not include them.

A 2025 study in Environmental Research Letters by Brad and Schneider examined the EU's 2040 target negotiation in detail, including this same consultation. They confirmed that a majority of responding stakeholders supported separating emissions and removal targets. Yet the European Commission ultimately chose not to include target separation in its 2040 proposal. Looking at the political process behind that decision, the study found that officials were less concerned about the underlying evidence than about practical politics: separate targets were seen internally as adding legal and administrative complexity and reducing flexibility, at a moment when climate policy was already facing pushback over cost and competitiveness concerns, alongside a broader Commission push to simplify and deregulate.

This matters directly for the Q4 2026 proposal. It suggests the scientific and stakeholder case for separate targets has already been made. What has been missing is political will, not evidence. The Member State targets proposal is a chance to close that gap.

Land-based removals and permanent carbon removals also need separate treatment

The consultation result is important not only because respondents supported separate targets for reductions and removals. It is also important because the strongest support for carbon removal targets was for two distinct removal targets: one for LULUCF and one for permanent carbon removals.

That distinction is essential, and it is exactly what the EU's own scientific advisory body has been recommending with increasing specificity.

In its February 2025 report, Scaling up carbon dioxide removals – Recommendations for navigating opportunities and risks in the EU, the European Scientific Advisory Board on Climate Change made separate targets its lead recommendation, ahead of eight others. The Board's advice is that the EU set separate, legally-binding targets for gross emissions reductions, permanent removals and temporary removals, arguing that this structure would make clear to investors and innovators that the EU is serious about both emissions cuts and removals, while stopping progress on one from being used as an excuse for inaction on the other. The Board also proposed setting minimum levels for removals alongside maximum limits on how much removals can contribute to net targets, so that Member States retain flexibility to find cost-effective solutions while the framework still guards against market failure and mitigation deterrence.

The Board's own gap analysis is blunt about the scale of the current shortfall. Beyond 2030, the EU has no targets at all guiding how much removals should contribute to reaching net zero and, eventually, net-negative emissions. There are no medium- or long-term targets for permanent removals, and none for temporary removals beyond the existing LULUCF target either. This gap matters because temporary and permanent removals play different roles on different timescales: temporary removals can support near-term mitigation, while permanent removals are what long-term climate stabilisation ultimately depends on.

Land-based removals are vital for Europe's climate and biodiversity goals. Healthy forests, soils, wetlands and agricultural landscapes are part of the climate solution. But the land sector is also vulnerable to fires, pests, droughts, harvesting pressure and policy choices that can weaken or reverse stored carbon. That vulnerability is not hypothetical: the EU's land carbon sink has already shrunk by around 30% over the past decade, driven by ageing forests, higher harvesting rates and worsening climate impacts. Drawing on research by Pilli and colleagues (2022), the Advisory Board estimates that these risks could limit the future capacity of the EU's land sink to somewhere between 100 and 400 million tonnes of CO₂ by 2050 — a wide range that itself reflects genuine scientific uncertainty about how resilient land-based storage will prove to be. The land sector should be strengthened, not overloaded.

Scientific literature has separately warned against overreliance on land for carbon removal in net-zero pledges. Dooley, Christiansen, Lund, Carton and Self (2024), in a Nature Communications study, quantified just how much land countries' climate pledges collectively assume for carbon removal — around one billion hectares globally — and found that much of this envisages converting existing land uses into forests, at a rate and scale that could put food security and biodiversity goals at risk. Their work reinforces the case for treating land-based removal as a distinct, carefully managed category rather than folding it into a generic removals number.

Permanent carbon removals have a different function, and the difference is not just administrative but physical. A 2024 study in Communications Earth & Environment by Brunner, Hausfather and Knutti modelled what happens when carbon storage of limited duration is used to offset long-lived fossil emissions. They found that storage lasting around a century — typical of many land-based removal methods — leaves measurably more warming on the table by the year 2500 compared with permanent geological storage, and concluded that storage periods of under roughly 1,000 years are insufficient to reliably neutralise fossil CO₂ emissions in a net-zero framework. In practical terms: a tonne of carbon locked away for a century and a tonne locked away for millennia are not climate-equivalent, even though a combined removal target would treat them as if they were.

Permanent removals are needed to durably counterbalance residual fossil and industrial emissions and, eventually, to support net-negative emissions. They also require different infrastructure, investment models, monitoring systems, liability rules and certification pathways than land-based removal. The Advisory Board has also floated the principle of "extended emitter responsibility" — the idea that today's emitters should bear some responsibility for eventually funding the removal of the greenhouse gases they emit. A mechanism like this only makes sense if permanent removal is tracked and targeted separately from land-based removal, since it is specifically designed to counterbalance long-lived fossil emissions with equally durable storage.

Putting LULUCF and permanent removals into one removal target would blur these differences. It would risk treating temporary and permanent storage as equivalent. It would also make it harder to see whether Europe is building the permanent removal capacity needed for the decades ahead.

This is not a new position for the Advisory Board. In its separate advice on amending the European Climate Law, it likewise recommended separate 2040 targets for gross emissions reductions, permanent carbon dioxide removals and temporary carbon dioxide removals, arguing that this structure can help scale removals, avoid mitigation deterrence and provide clearer investment and innovation signals. The February 2025 report builds on that advice with a far more detailed rationale and a concrete set of action points, including setting removal-specific targets for carbon capture and storage across the near, medium and long term, and enshrining a long-term commitment to protect and enhance the EU's land sinks when the LULUCF regulation is next revised.

Separate targets create accountability and demand

The EU's post-2030 climate framework must do more than set ambition on paper. It must create the conditions for delivery.

The consultation shows that stakeholders understand this. A clear majority supported binding national targets adding up to the EU domestic target. Private sector stakeholders also argued in open-text responses that binding national targets are needed not only for accountability, but also to provide predictable investment signals.

This is especially important for permanent carbon removals. The State of Carbon Dioxide Removal report shows that novel CDR remains very small today, at around 0.002 GtCO₂ per year, even though deployment is growing quickly.

Permanent removals cannot scale on vague expectations. Projects need long development timelines, infrastructure, finance, buyers, certification and confidence that policy will create durable demand. The scale of investment involved makes the point starkly: the Advisory Board estimates that meeting the EU's existing goal of 50 million tonnes of CO₂ geological storage capacity per year by 2030 alone will require around €18 billion, with total annual investment needs across all removal methods estimated at between €30 billion and €80 billion by 2050. A separate permanent CDR target would not solve all of this alone, but it would create a foundation for the policies that must follow: public procurement, contracts for difference, infrastructure planning, certification, integration with compliance frameworks and clear rules for corporate use. ‍

The consultation also showed that 67% of respondents agreed that the lack of incentives for industry to invest in permanent carbon removals is a problem negatively affecting the achievement of EU climate objectives.

This is exactly why the Member State targets proposal matters. If permanent removals remain hidden inside a single net target, the demand signal will remain too weak. If they are visible in the target architecture, Member States, investors and project developers can begin planning against a clearer policy horizon.

Flexibility must come with safeguards

The consultation also provides useful guidance on how flexibility should be designed.

Respondents showed the strongest support for making access to flexibility conditional on safeguards that ensure environmental integrity. There was also support for greater transparency in bilateral trading of surplus compliance units or flexibilities between Member States, and for EU facilitation of such trading.

This matters because flexibility can be useful, but only if it does not weaken climate delivery.

Separate targets make flexibility more transparent. They allow policymakers and the public to see whether flexibility is being used to support real emissions reductions, strengthen land sinks, or scale permanent removals. Without that separation, flexibility risks becoming another way to obscure what is happening beneath the net number.

The same principle applies to underperformance. The consultation found that the strongest support for addressing insufficient progress was for Member States to undertake additional measures based on Commission recommendations, followed by financing an EU facility investing in emissions reductions and removals in their national territory. Support was lowest for financing an EU facility investing in emissions reductions or removals outside the EU.

That suggests a practical direction for the post-2030 framework: more accountability, more transparency, and more domestic delivery.

What the Q4 Member State targets proposal should do

The upcoming proposal should reflect both the consultation evidence and the scientific literature — literature that, as shown above, has only grown more consistent on this question over the past two years.

NEP calls for the EU to set separate Member State targets for:

1. Emissions reductions A clear target for reducing gross emissions, so that removals do not substitute for decarbonisation.

2. Land-based removals A distinct target for the LULUCF sector, recognising the importance of forests, soils and land management while accounting for their specific risks and reversibility.

3. Permanent carbon removals A separate target for durable CDR, creating the demand signal needed to scale high-integrity permanent removals for residual emissions and future net-negative emissions.

This structure would not make the framework more complicated for the sake of it. It would make it more honest.

It would show whether Member States are cutting emissions. It would show whether land sinks are being protected and strengthened. It would show whether permanent removals are being built in time, rather than assumed into future climate plans.

The EU's 2040 climate framework should not ask one number to do three different jobs.

Separate targets are the basis for clearer accountability, stronger climate integrity and a real demand signal for permanent carbon removals. The consultation has shown support for this direction. The science explains why it matters. The Q4 Member State targets proposal should now make it part of the EU climate policy framework after 2030.