Published September 8, 2025

CFE Submission to the European Commission on the 2040 Climate Target

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In September 2025, Carbon-Free Europe submitted input to the European Commission on the proposed amendment to the European Climate Law, which introduces a binding 2040 climate target of a 90% reduction in net greenhouse gas emissions. Our submission underlines that this level of ambition is achievable and cost-effective if pursued through a technology-inclusive approach, paired with early infrastructure investment and a strong industrial strategy.

Read the full submission and supporting materials below.

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Carbon-Free Europe welcomes the Commission’s proposal to set a binding EU target of a 90% reduction in net greenhouse gas emissions by 2040 compared to 1990 levels. This ambition is essential to keep Europe on track for climate neutrality by 2050 and to provide predictability for citizens, industry, and investors.

Our Annual Decarbonisation Perspective (ADP) modelling (2023 & 2024) confirms that a 90% reduction by 2040 is technically and economically feasible, but only through a technology-inclusive approach. All zero- and low-carbon solutions must be available: renewables, nuclear, geothermal, storage, CCS/CCU, hydrogen, and efficiency. Prescriptive frameworks that exclude proven technologies risk undermining delivery and delaying progress. While our modelling does not quantify every exclusion pathway, it clearly shows that only a technology-inclusive approach achieves -90% by 2040 at lowest cost. Excluding options raises costs especially for Member States with limited renewable resources.

Economic feasibility and costs

Our ADP 2024 shows that the -90% by 2040 pathway is more expensive in the short and mid-term than a linear path to 2050 (Core scenario), requiring additional €130 billion per year in the 2030s. Yet delaying action would make the final 10% of reductions prohibitively costly, as these hinge on energy-intensive industries and transport, leading to additional costs of €3.2 trillion by 2050. Early action forces preparation for these hard-to-abate sectors, avoiding a cliff-edge in the 2040s that could jeopardise the 2050 net-zero goal. 

Infrastructure requirements

Achieving -90% emissions by 2040 requires a step-change in infrastructure deployment. Electricity generation capacity must triple from ~1000 GW today to ~3000 GW by 2040, demanding a faster, front-loaded buildout compared to a linear approach.

Compared to the Core scenario, the 2040 pathway requires:

  • Nuclear: +2–3 GW in the 2030s, reaching 6–7 GW/year new capacity.
  • Offshore wind: up to 32 GW/year (+10 GW).
  • Onshore wind: up to 31 GW/year (+6–7 GW).
  • Solar: peaking at 70 GW/year (+20 GW).
  • Utility-scale storage: up to 18 GW/year (+5–7 GW).
  • Hydrogen pipelines: 108 GW by 2050, 30% less than Core (156 GW).
  • CO2 pipelines: 455 Ht/hour by 2050; 20% more than Core (388 Ht/hour).

While hydrogen infrastructure is reduced, CCUS and CO2 infrastructure must expand earlier and faster, adding ~€54 billion industrial costs per year compared to Core. These infrastructures represent not only engineering challenges but also a need for secure access to critical raw materials (CRMs) (see Critical Raw Materials Act).

Competitiveness and industrial strategy

The 2040 target can only be delivered if anchored with the Clean Industrial Deal that ensures affordable energy, secures supply chains, and scales deployment of clean technologies. To decarbonise while remaining competitive, Europe must urgently:

  • Accelerate backbone infrastructure (grids, CO₂ pipelines, hydrogen corridors).
  • Prioritise industry & transport decarbonisation with dedicated, tech-neutral investment.
  • Secure CRMs to avoid deeper dependencies on adversarial suppliers.
  • Support innovation and deployment through ETS revenues and the upcoming Industrial Decarbonisation Bank, the Industrial Decarbonisation Accelerator Act, and targeted state aid.

Conclusion

CFE strongly supports the Commission’s proposal for a -90% by 2040 target and stresses the urgency of meeting the high investment, deployments, and industrial transition needs. This pathway, while more costly in the 2030s, drives critical infrastructure deployment and prepares hard-to-abate sectors for transition. Early action strengthens Europe's competitiveness, secures its leadership in clean technology and energy resilience, and prevents far higher costs in the future.

For further detail, see our Annual Decarbonisation Perspective (2024): https://www.carbonfreeeurope.org/modelling