The European Climate Law (ECL) is central to shaping EU climate policy up to 2050. Its ongoing revision to set a 2040 target is a crucial opportunity to strengthen ambition and provide clear direction for market actors.
The Nordic Carbon Removal Association (NCRA) supports the proposed 90% emissions reduction target for 2040, as it sets the EU on track towards climate neutrality in 2050 and net negative emissions thereafter. However, the revised Law must also explicitly account for permanent carbon dioxide removal (CDR), which is indispensable to achieving EU and Nordic climate targets.
CDR is now a climate necessity. Both the Commission’s 2040 Communication and the European Scientific Advisory Board on Climate Change make clear that deep emissions cuts alone will not suffice; rapid scaling of CDR is essential.
The Nordics can become Europe’s carbon sink. With strong natural storage capacity, robust regulatory frameworks, and a growing ecosystem of CDR actors, the region is well-positioned to scale permanent removals. A study conducted with Implement Consulting Group shows the Nordics could remove 85–160 MtCO₂ annually by 2050 – up to 60% of Europe’s needs – while creating €9–17 billion in GDP and 148,000 jobs.
The revised European Climate Law must fully integrate carbon removal. Carbon removal is both a climate imperative and an economic opportunity, strengthening EU competitiveness and positioning Europe as a global leader in carbon management.
To make carbon removal count in the 2040 target, the Nordic Carbon Removal Association recommends the following:
- Introduce a dedicated sub-target for permanent carbon removals, alongside the 90% emissions reduction goal. Emissions reductions, land-based removals, and permanent removals must be accounted for separately.
- Focus the sub-target on domestic permanent removals as defined under the CRCF, ensuring regulatory integrity, economic opportunity, and strategic advantage.
- Restrict reliance on international credits. While they may play a limited role, strict quality and certification standards are essential to avoid undermining domestic action.
- Develop dedicated policies to scale permanent removals, such as purchasing programmes, contracts for difference, public procurement, and a dedicated Removal Compliance System (RCS). The EU ETS can help create initial demand but cannot alone build a robust CDR sector.
The NCRA has submitted its position to the Commission’s open public consultation. The full contribution is available here: Feedback of the Nordic Carbon Removal Association on the European Climate Law