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Photo: Clean Air Task Force

Under the EU’s revised Climate Law, the bloc can meet up to 5% of its 2040 climate target from 2036 with international carbon credits purchased under Article 6 of the Paris Agreement. A new joint analysis from CONCITO and Clean Air Task Force identifies strategies the European Commission should adopt in its forthcoming legal framework for these purchases to minimise the risks associated with the plan.

The report, More Than a Buyer, identifies a significant risk that the EU may over-rely on international credits that fail to materialise at assumed volumes to meet its climate targets. This risk stems from a range of factors: the strict quality and strategic criteria the credits must meet, Article 6 rules that prevent banking credits across compliance periods, long project lead times, and a growing likelihood that partner countries will want to retain more of their own emissions reductions to meet climate goals.

“The EU has made a bet that international credits will be available at scale in 2036, and right now nothing guarantees that,” said Codie Rossi, Senior Policy Manager for Carbon Management at CATF. “International carbon markets have a track record of underdelivering, and nobody has ever bought quality credits at this volume. No framework can eliminate these risks, but smart policy design can reduce them: one central buyer, and a procurement timeline that starts now, not in 2036.”

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Photo: Clean Air Task Force

To reduce the risks associated with utilising international credits, the report recommends:

  • Using collective buying power to drive real change: By buying credits centrally — through the European Commission, an existing agency, or a dedicated body — rather than leaving it to individual Member States to purchase separately, the EU can tie credit purchases to genuine investment and climate partnerships that could drive lasting transformation in the countries selling them, rather than a race among Member States for the cheapest available compliance option.
  • Planning now for a constrained market: The EU and Member States should begin signalling demand for credits by 2030 at the latest, commit funding for purchases well before 2036, and build in a calibration moment to catch potential shortfalls in supply early, ensuring there is time to intervene or change course.
  • Keeping international credits out of the EU ETS: International credits should be funded nationally as a limited, voluntary flexibility under national climate targets and kept out of the EU Emissions Trading System as a compliance route. Doing so preserves the integrity and predictability of the ETS and lets ETS revenues stay focused on Europe’s domestic clean energy transitions.

Learn more about the Clean Air Task Force here

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