KOBIZE’s Feedback on the EC proposal for a European Climate Law (ECL) from July 2025

KOBIZE’s Feedback on the EC proposal for a European Climate Law (ECL) from July 2025

KOBIZE’s Feedback on the EC proposal for a European Climate Law (ECL) from July 2025

As part of the public consultations, the National Centre for Emissions Management (KOBiZE, Poland) presented its position on the amendment of the European Climate Law to include the 2040 climate target, which is intended to clearly set the European Union on the path towards achieving climate neutrality by 2050.

KOBiZE’s position refers both to the European Climate Law and to the Impact Assessment presented by the European Commission.

•   The National Centre for Emission Management (KOBiZE), Poland Feedback on the EC proposal for a European Climate Law (ECL) from July 2025 (1.1 MiB, 351 hits)

• Link do the EC’s website: LINK

Acting under Article 4(3) of the European Climate Law, the European Commission presented a proposal to introduce a binding net emission reduction target of 90% by 2040 (compared to 1990 levels). This target is intended as an intermediate step on the road to climate neutrality by 2050 and will form the basis for the EU’s new Nationally Determined Contribution (NDC) at COP30 in 2025.

Achieving a 90% reduction in emissions by 2040 depends on technologies that are currently at the pre-commercial stage, such as e-fuels, direct air capture and storage of CO₂ (DACCS). These technologies are characterised by uncertain costs and deployment timelines, which creates the risk that the target may prove unattainable without their large-scale application.

KOBiZE’s analyses indicate that an approx. 80% reduction by 2040 is achievable using predictable, currently available technologies and costs. This level of reduction constitutes a realistic, yet still ambitious milestone towards the 2050 climate neutrality goal.

In this context, flexibility mechanisms may play a key role, which is why KOBiZE proposes the following measures:

• allowing the use of high-quality international offset units up to the level of 10% of the EU’s 1990 net emissions, which could compensate for residual emissions in both the EU ETS sector and in the sectors covered by the Effort Sharing Regulation (ESR),

• with such units becoming available from 2031 to support the early development of a sustainable offset market.

To ensure transparency and stability, KOBiZE recommends the creation of a European Carbon Central Bank (ECCB), which would: purchase qualified, compliant offset units, store them in reserve, and then gradually release them onto the market. The ECCB could also supervise the inclusion of permanent CO₂ removals into the EU ETS, provided strict quality criteria are met. 

KOBiZE also proposes considering additional instruments to maintain competitiveness and market stability, such as a transparent CO₂ price cap mechanism, linked to marginal abatement costs, in order to ensure market stability.

KOBiZE supports setting post-2030 national targets for non-ETS with the existing EU methodology to ensure fairness and continuity, while also integrating security and resilience considerations to safeguard the EU’s industrial and strategic autonomy.

KOBiZE highlights the need to apply the principle of “energy efficiency first”, as well as support for SMEs, energy-intensive sectors and district heating systems, will be crucial for achieving the EU’s long-term climate goals.