EU’s 2040 climate goals


The 92 Danish Group has taken the initiative to send a letter to the Minister of Climate, Energy, and Utilities Lars Aagaard regarding the EU’S 2040 climate goals.

Read the English version of the letter below or in Danish here.



To the Minister of Climate, Energy, and Utilities Lars Aagaard

Dear Lars,

We are writing to you regarding the European Commission’s proposal for a new EU climate goal for 2040, and the further process to establish this. Including that, the proposal is on the agenda for the EU Environmental Council meeting on March 25, 2024. We would like to acknowledge your and Denmark’s efforts in this process so far, where we see it positively that you and Denmark early on expressed the desire for a high level of ambition for the new goal, and have taken the initiative to gather countries in the EU for this purpose. We see it as important that you and Denmark continue this effort for a high level of ambition in the coming months until the final 2040 goal is adopted. Below are some inputs in this regard:

90 percent by 2040 is not enough
Although it is positive that the European Commission on February 6 also recommended a 2040 target at the high end of 90%, it is important to note that even such a target will not be sufficient for the EU to meet the 1.5-degree target under the Paris Agreement. The European Commission disregards the higher end of the target at 95% as both the Commission’s own Impact Assessment and the European Climate Council (ESABCC) point out. ESABCC recommended 90-95% (option 3), and regarding this option, the Commission itself writes (s7) that 90-95% is the only one of the three options that is in line with the EU’s climate law to present a carbon budget that does not undermine the EU’s commitments under the Paris Agreement.

We and the Climate Action Network Europe (CAN E) believe that wealthy countries like the EU should achieve net-zero emissions no later than 2040, in order to meet the 1.5-degree target and the current scope of the climate crisis. The arguments for this are thoroughly described in CAN E’s position paper on the EU’s climate goals. The same is advocated by UN Secretary-General António Guterres, who, at the launch of the IPCC synthesis report in March 2023, clearly urged developed countries to commit to reaching as close to net-zero by 2040 as possible. Based on this, there is still a need to work for a higher 2040 target than the 90% that the Commission has now ended up pointing to.

It is important to ensure efforts with goals for individual action areas
One of the positive aspects of the Commission recommending 90% is that it should make it clear to all sectors in the economy that no sector is exempt from contributing to climate action. The EU’s 55% target for 2030 left 45% of emissions continuing, large enough for some sectors to mistakenly continue the notion that their sector could or should be exempted from contributing to climate action. An EU reduction target of 90-100% is high enough to dispel the notion that individual sectors are exempt. However, there is still a risk that the blending of goals from different sectors and between greenhouse gas uptake and reductions will lead to inaction. Therefore, we urge you to work for clear and separate sub-goals for all significant sectors as well as separate goals for both greenhouse gas reductions, land and forest uptake, and industrial uptake (CCS). In addition to working for this at the EU level, we also encourage you to lead Denmark in this area and to use the momentum created by the Commission’s 90% announcement to set indicative 2035 goals for all significant sectors in the Danish economy.

Increased climate ambition will yield economic benefits
As indicated by the Commission’s Impact Assessment (6.3.1) and as emphasized by EU Commissioners Sefcovic, Simpson, and Hoekstra at the presentation, the 90% target will also benefit the EU economically, in terms of health, and by avoiding the costs of climate change. The transition requires significant investments, but as Hoekstra correctly pointed out, inaction will be far more expensive. In line with the analysis from the Commission’s Impact Assessment and the EU Commissioners, CAN Europe recently calculated in a report, Paris Pact Payoff, that if the EU’s climate ambitions are increased to align with achieving the 1.5°C target, the EU can save at least 1 trillion euros by 2030 in the form of, for example, better health, increased employment, and lower living costs. CAN Europe’s report highlights that pursuing a climate ambition level consistent with the goals of the Paris Agreement holds significant potential for unlocking socio-economic benefits towards a climate neutrality goal in 2040.

An ambitious sub-goal for 2035 should be pursued rather than just a linear extrapolation
To adapt to the 5-year common timeframes agreed at the UNFCCC level and in Article 4.7 of the European Climate Law, the upcoming Commission should include both an EU climate target for 2035 and 2040 in its proposal for the European Climate Law. Deriving the 2035 climate target and thus the new NDC from a linear extrapolation without going through a political process, as suggested in the Commission’s communication on the EU 2040 climate target, is not sufficient, as it undermines the significance of the 5-year common timeframes under the UNFCCC. We and CAN Europe believe that an EU 2035 climate target should be between at least -78-82% gross (-90-94% net) emissions reductions compared to 1990 levels.

A targeted effort to phase out fossil energy is crucial
A rapid phase-out of fossil fuels in the EU is crucial and should have particularly high priority after COP28 with concrete and ambitious sub-goals and final phase-out of coal by 2030, fossil gas by 2035, and oil by 2040. As part of this, there must be targeted efforts to phase out all fossil subsidies, put a stop to new fossil extraction projects, and phase out both private and public investments in fossil energy. This must ensure that the G7 decision to end fossil subsidies by 2025 is adhered to and that the COP28 decision on subsidies is followed (including GST para 28h).

EU efforts must not rely excessively on CCS
It is important that the achievement of EU climate goals, including the 2040 target, does not overly rely on the use of uncertain technologies like CCS, as this will delay the sufficient use of known measures and ultimately jeopardize climate goals. A stronger framework for the use of these technologies is therefore necessary, including defining what constitutes unavoidable emissions and in terms of prioritizing alternatives to CCS. At the same time, greater focus and priority must be given to natural CO2 uptake, including restoration and conservation of forests and other natural ecosystems.

For further inputs, see also CAN Europe’s position paper on EU climate goals.


Troels Dam Christensen Secretariat Leader, 92-Group – Forum for Sustainable Development. Letter signed off by:

Care Danmark
Dansk International Bosætningsservice
Danmarks Naturfredningsforening
DOF BirdLife
Global Aktion
Kvindernes U-landsudvalg
Mellemfolkeligt Samvirke
Netværket for økologisk folkeoplysning og praksis/Øko-net
Nyt Europa
Oxfam Danmark
Rådet for Bæredygtig Trafik
Rådet for Grøn Omstilling
Sex & Samfund
Verdens Skove
WWF Verdensnaturfonden

Original Letter in Danish published on 19 March: