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.”













