Policy Overview

As part of the Climate Law 2021/1119, the European Commission is required to set an intermediate GHG emissions reductions target for 2040, in alignment with the EU's climate neutrality goal for 2050. A public consultation was launched in March 2023 to gather stakeholders views on the range of emissions reductions and the post-2030 climate policy framework that should accompany the 2040 Climate Target. In February 2024, the Commission proposed a 90% GHG target, with a finalized proposal expected in July 2025, to be followed by a second consultation.

Policy in progress

Despite opposition to a science-based target of 90-95% emissions reductions by 2040 from the heavy industry and fossil fuel sectors, following supportive advocacy from a large coalition of science-aligned actors, the European Commission recommended a 90% reduction in net greenhouse gas emissions by 2040, compared to 1990 levels. However, the Commission is considering to including ‘flexibilities’ to achieve the target, which could impact the ambition for the total domestic emissions reductions.

InfluenceMap Query

GHG emissions regulation

Policy Status

Communication released in February 2024: Commission to present a proposal enshrining the 2040 Target into law on 2nd July 2025

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Policy Engagement Overview

The aggregated evidence of corporate and industry lobbying on the 2040 Climate Target shows a range of actors supporting an ambitious target, especially the utilities and renewables sectors, while heavy industry and fossil fuel sectors advocated for weaker ambition.

Long-term Lobbying Trends

A cross-sector coalition of actors supported a 90–95% 2040 GHG emissions reductions target, including corporations such as Acciona, Danfoss, Schneider Electric, Ørsted, Alphabet, Salesforce, Unilever, Danone, IKEA, H & M and Henkel, and industry associations Corporate Leaders Group (CLG), SolarPower Europe and European Association for Electromobility (AVERE).

A small group of outliers in the heavy industry sector supported a 90% target, including SSAB and Bayer.

The utilities sector was split in its advocacy on the level of ambition for the target. SSE and EDP backed a 2040 Target of ‘at least’ 90%. Industry association Eurelectric and companies such as E.ON, EnBW, and Verbund supported a 80-90% target, above the average trajectory of emissions. Enel, RWE, Engie, and EDF supported an average trajectory target of 75–80%. PGE and CEZ advocated for a 65–75% target.

Several utilities that had previously advocated for an 80–90% target supported a science-aligned target following the release of the Commission’s 90% target proposal in 2024, including Iberdrola, EDF and Fortum.

Heavy industry and fossil fuel sectors did not appear to support a science-based 90–95% target. Industry groups the European Cement Association (CEMBUREAU), and corporations HeidelbergCement, Equinor, OMV, BP, and Shell supported a 75–80% target. Eurometaux, Covestro, Norsk Hydro, and thyssenkrupp advocated for a lower target than the average trajectory of emissions reductions, while BASF opposed setting a target.

Cross-sector and heavy industry associations emphasized the negative impacts resulting from setting a science-aligned 2040 target, such as the effects on companies’ international competitiveness, including the European Chemical Industry Council (Cefic), Federation of German Industries (BDI), German Chemical Industry Association (VCI), the European Steel Association (Eurofer).

InfluenceMap has not detected considerable evidence of European industry advocating for the inclusion of ‘flexibilities’ such as international credits in the 2040 target.

Impacts on Policy Ambition

EU Commission Communication

In February 2024, the Commission released a communication on the 2040 target. The EU Commission proposed a 2040 target which was at the lower end of the ESABCC recommendations, however, it was aligned with the highest ambition option in the EU Commission’s impact assessment, after both supportive and oppositional advocacy from EU industry.

  • 2040 Target: The EU Commission proposed a net target of 90% emissions reductions compared to 1990 levels. The ESABCC had recommended a target in the range of 90 to 95%. The EU Commission highest ambition option in its impact assessment was a target of at least 90%, and up to 95%.

  • Legislative proposal: A full legislative proposal is expected to be presented by the Commission on 2nd July 2025. POLITICO and Reuters have reported that the proposal will include ‘flexibilities,’ such as the ability of countries to use international carbon credits to meet the 2040 Target, which could impact the total domestic emissions reductions. The EU’s 2035 and 2050 targets both cover only domestic emissions.

InfluenceMap Query

GHG emissions regulation

Policy Status

Communication released in February 2024: Commission to present a proposal enshrining the 2040 Target into law on 2nd July 2025

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Live Lobbying Alerts

Federation of German Industries does not fully support EU emissions reduction measures

05/02/2025

Ahead of the German federal election on 23 February, the Federation of German Industries (BDI) released a series of policy recommendations on climate and energy on 3 February. Among other things, the association called on the German government to only support the EU Commission's proposal to reduce GHG emissions by -90% by 2040 on the condition that the implementation of the target does not "overburden industry". The BDI also advocated for reforms of the EU Carbon Border Adjustment Mechanism, emphasizing the need to preserve exports and cautioning against a phase-out of free emissions allowances in the EU Emissions Trading System, positions that are misaligned with the EU Commission's policy ambition. Finally, the association supported 'hydrogen ready' gas infrastructure without stating the need to phase-out fossil gas, and advocated for exemptions of energy-intensive industries from EU environmental law.

Corporate Leaders Group supports EU 2040 GHG emissions reductions target

04/04/2024

In a March joint letter, Corporate Leaders Group Europe advocated for the EU to set a target of at least 90 per cent net reduction in greenhouse gas emissions by 2040 compared to 1990 levels, which is aligned with the European Scientific Advisory Board on Climate Change’s recommendations. In the letter, the industry association also advocated for the removal of fossil fuel subsidies and fully decarbonizing electricity generation, and called for policy measures to transition towards zero-carbon technologies or infrastructure.

Industry associations in Alliance of Energy-Intensive Industries do not clearly support EU 2040 Climate Target

15/02/2024

In a February 7th joint statement, industry associations from the Alliance of Energy-Intensive Industries, including the European Steel Association (Eurofer), the European Cement Association (CEMBUREAU), the European Chemical Industry Council (Cefic), and FuelsEurope, did not take a clear position of support on the EU’s 90% 2040 GHG target, emphasizing the importance of a supportive regulatory framework to achieve the goal but stressing deindustrialization, impacts on international competitiveness and risks of unilateral action. In a separate February 7th press release, Eurometaux’s leadership advocated for “more carrots and fewer sticks” in EU climate policy. Eurofer’s Director General seemed unsupportive the 2040 target of 90% emissions reductions in a press release.

EuroCommerce strongly supports prioritizing GHG emissions reductions above carbon removals in EU

18/01/2024

In a January open letter, EuroCommerce strongly supported the separation of emissions reductions, land sequestration, and carbon removals targets in the EU 2040 Climate Target. The separation of these targets ensures the prioritization of GHG emissions reductions above carbon sequestration and offsetting, avoiding the undermining GHG emissions reduction goals.

Eurofer and Cefic do not fully support 90% EU 2040 Climate Target

18/01/2024

In comments to a Euractiv article on January 3rd, the European Steel Association (Eurofer) and the European Chemical Industry Council (Cefic) did not appear to fully support a 90% 2040 Climate Target in the EU, emphasizing technical feasibility and investment leakage.

Entities Engaged on Policy

Influencemap Performance BandOrganizationPolicy PositionPolicy Engagement Intensity