Choosing the right climate policies : look before leaping.
Date: 2020-11-05
Institutions: European University Institute
Subjects: adaptation to climate change, climate change policy, emission allowance, environmental tax, greenhouse gas, reduction of gas emissions

CHOOSING THE 
RIGHT CLIMATE 
POLICIES: LOOK 
BEFORE LEAPING

CHAIRMAN’S EXECUTIVE SUMMARY: 

Participants  at  the  High-Level  Policy  Dialogue  debated  3  topical  hy-
potheses that would probably be addressed as part of the forthcoming 
Communication by the European Commission on a “European Green 
Deal”.  These  hypotheses  were:  (1)  the  use  of  carbon  offset  credits  to 
fulfil a higher greenhouse gas reduction in 2030 than previously envis-
aged; (2) introduction of a carbon border tax as a measure to protect 
EU competitiveness; (3) the possible inclusion of transport and housing 
in the EU’s Emissions Trading System. Dialogue participants made ar-
guments for and against each hypothesis. Possible ways of taking each 
issue forward were also identified. 

While there were certain advantages of each hypothesis, overall the feel-
ing of participants was that the drawbacks of each were considerable, 
and that there were risks of adverse consequences. While the issues un-
derlying each of these hypotheses were acknowledged, the existing ap-
proaches in EU policy were on balance thought to be basically sound. 
It emerged clearly from the dialogue that policy strengthening would 
be required at all levels of governance in the case that the EU decides to 
increase its climate ambition in 2030, and reach the objective of carbon 
neutrality by 2050. 

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Issue 2019/08
December 2019

Policy Brief author: Peter Vis
Policy Dialogue convener: Jos Delbeke

The topics discussed at the Dialogue have been summarised for the purpose of this 
paper. The dialogue took place under the Chatham House rule, whereby no attribution 
of opinions expressed can be made.  

The opinions of the authors represent personal opinions and do not represent the posi-
tion or opinion of the European University Institute

 
STG     Policy Brief     Issue 2019/08     December 20192I

N The climate crisis is ever more serious. 
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There is urgent need for policies to be implemented to deliver the Nationally Determined Contributions made under the Par-
is Agreement. Europe has made a useful start in curbing its emissions since 1990 (minus 23.2% to 2018), but is not on track 
to meet its existing target of reducing emission by at least 40% by 2030, and even less a reduction target of 50%, or even 55%, 
by 2030 (yet to be decided)1. 

Several Parties to the Paris Agreement, including the European Union, have decided or are considering setting a goal of 
carbon neutrality, or “net-zero emissions”, around the mid-century. The ambition of such an objective is easily underestimat-
ed, and will require most of the economy to be completely decarbonised. Furthermore, a certain extent of carbon dioxide 
removals will be required to cover unavoidable emissions from certain industrial processes, some sectors of agriculture or 
international aviation.  

Long-term targets are useful as clear indicators of the direction of travel, so as to frame policy development and steer new 
investment. However, it is obviously easier to sign-up to ambitious targets in the longer-term than to implement ambitious 
policies in the near-term. There is a mismatch in timing between the political cycle and the climate crisis. Even if we act now, 
results in terms of emissions reduction are only achieved in the medium- and long-term.  

Fortunately, there are potential short-term benefits from carefully designed policies, in terms of jobs created by investments 
in the transition to a low-emissions economy, such as in renovating homes, in future-orientated industries embracing the 
circular economy, in new infrastructure deployment and in terms of air quality. 

The political capital needed to steer such a transition must not be underestimated. Cost-efficiency and fairness are both cru-
cial requirements of the policy-mix. 

PART 1: TOWARDS A NEW APPROACH ON OFFSETS, IN THE 
WORLD AND IN EUROPE?

Carbon neutrality will require the decarbonisation not just of the 
electricity-generation  sector,  which  itself  will  need  to  produce 
more electricity, but also industry, buildings and most transport 
modes. 

Europe’s existing 40% reduction target for 2030 is a domestic tar-
get, excluding the possibility of using offset credits from outside 
Europe. If Europe’s climate ambition is to be further increased, it 
is likely that consideration of offset credits will be re-opened. The 
arguments in favour of using offsets will centre around cost-ef-
ficiency being an enabler of higher ambition and greater public 
acceptability. Those against will argue in terms of the weak en-
vironmental integrity of many offset credits, of investment flows 
leaving  Europe,  and  also  about  the  inequity  of  “low-hanging” 
abatement possibilities flowing to richer countries, leaving more 
costly abatement options to fulfil commitments made by project 
host countries under the Paris Agreement. 

In the context of the Paris Agreement, under which practically all 
countries have made commitments, the exporting of offset cred-
its must mean that the reductions cannot also count towards the 
emissions performance of the project’s host country. That would 
amount to double-counting. A credit exported must be matched 
by a debit somewhere else in a host country’s inventory. 

The “reduction” achieved in the host country will usually be one 
made  in  comparison  with  a  business-as-usual  scenario  in  the 
host country, and the credit generated will be used to cover high-
er emissions in the purchasing country. While this might be de-
scribed as a “zero-sum game”, where reductions in one country 
merely compensate for extra emissions in another, the reductions 
do lead to lower-emission investments in the host country than 
would have occurred in the absence of the project. 

The desirability of using offset credits in the purchasing jurisdic-
tion is to lower the compliance costs of meeting a given emissions 
target, although the investments are located outside the jurisdic-
tion. While cheaper compliance enables greater ambition for the 
same investment cost on a global level, the downside is an outflow 
of funds that could potentially go towards financing the low-car-
bon transition in the country buying credits. This is not necessar-
ily the best way to create jobs and cleaner investments in the local 
economy. 

In the discussion of this session a recurring theme was the im-
portance of strong governance to ensure environmental integrity. 
Ensuring the absence of double-counting, the additionality of the 
projects, the robustness of methodologies to quantify emissions 
reductions, the traceability of credits and their irrevocable cancel-
lation when used for compliance are all fundamentally important 
criteria. The effective application of these criteria both in the host 
country and the country where the credit is used for compliance 
purposes  pre-supposes  a  robust  and  transnational  governance 
mechanism. Equally important is for there to be an approximate 
balance between the supply and demand for credits. If credits are 
abundant and there is substantial over-supply, the scarcity (and 
hence value) of offset credits will be low. As such, the purchaser 
will  have  little  incentive  to  change  behaviour  and  reduce  emis-
sions. In the contrary case, if credits are very scarce, then the eco-
nomic advantage of lower cost abatement in host countries would 
be  lost.  A  balance  therefore  needs  to  be  struck  between  supply 
and demand.  

The experience of the EU’s Emission Trading System (EU ETS) 
was first to be open towards offset credits. There were so many 
of them available that the price fell, and European emitters act-
ed rationally in trying to maximise the use of credits up to the 

1 All reductions mentioned in this Policy Brief are compared to the level of 
greenhouse gas emissions in 1990. 

STG     Policy Brief     Issue 2019/08     December 20193maximum levels allowed (fortunately there were maximum limits 
set). However, due to serious doubts about the robustness of gov-
ernance of the Clean Development Mechanism (CDM), the EU 
has gradually closed down the scope for using offset credits and 
from 2021 no credits at all can be used for compliance within the 
EU ETS. The EU ETS was undoubtedly put in grave danger by the 
abundance of offset credits that were not always of high environ-
mental quality. 

There was also a high probability that the potential supply of off-
set credits would far exceed demand generated by CORSIA, and 
that the result would be a very low, almost negligible carbon price. 
If this were to prove true, CORSIA would be seen as a very weak 
instrument of questionable environmental added value. In these 
circumstances it could be expected that Governments would be 
pressured to apply more stringent measures to address the rapidly 
growing emissions from international aviation. 

There  was  considerable  discussion  on  the  offsetting  system  to 
be partially introduced in 2021 by the International Civil Avia-
tion Organisation (referred to by its acronym “CORSIA”)2. Views 
within  the  group  varied,  from  CORSIA  being  considered  as  a 
“very  poor  agreement”  to  “an  agreement  with  real  potential  to 
make a difference”. The majority of participants were of the view 
that  CORSIA  was  not  robust  enough  and  suffered  from  weak 
governance. There was particular concern that double-counting 
was not addressed sufficiently. Compliance and control would be 
ensured by the administering country of each airline, potentially 
giving rise to different treatment of operators on the same route. 

Finally, it was discussed how using old offset credits, relating to 
projects established before the Nationally Determined Contribu-
tions  were  made,  could  not  be  additional  reductions  instigated 
as  a  result  of  the  Paris  Agreement.  Investment  in  projects  that 
pre-date the Paris Agreement could not have been motivated by 
any agreement that had not yet been reached. The same argument 
can be used in the context of CORSIA, which was not envisaged 
before 2013. 

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1.  We  need  market-based  solutions  to  reduce  the  cost  of  fulfilling  commitments  made  under  the  Paris 
Agreement.  Offset credits can only be a transitional solution, as ultimately all countries will need an ab-
solute cap on emissions, and to achieve substantial reductions of domestic emissions in absolute terms. 

2.  Good governance is at the heart of implementing the Paris Agreement. The Paris Agreement is a “bot-
tom-up”  agreement,  which  makes  the  question  of  robust  governance  more  complex.  Governance  is 
linked to credibility when it comes to the rules governing offsets. If the EU were to pursue offsets in the 
future, it would have to guarantee strong environmental credibility, if necessary by setting up its own 
governance system. The EU has the hard capacity to regulate governance, and perhaps it could do that 
with like-minded States. The EU is already de facto a robust carbon grouping of countries, and maybe 
that could be extended to wider group of countries. The existing “Florence Process on Carbon Markets” 
is already a precursor network of countries or regions that have established carbon markets within their 
jurisdictions, and could extend its reflections to cover offsets and high standard-setting. 

3.  Companies are global and will be regulated in different ways in different jurisdictions. They might uni-
laterally choose to be covered by a strong governance system that would facilitate credible offsetting that 
optimises cost-efficiency across their worldwide operations. This may be especially true of companies 
that commit to carbon neutrality. 

4.  Offsets are a lower-cost solution, and there is nothing wrong with cost-effectiveness if it ensures environ-
mental integrity. It also means that ambition can be raised. Equity and social fairness must be taken into 
account or grand climate ambitions may backfire. 

5.  The idea of developing possible sectoral orientations for offsets may be an idea worthy of further research 

and reflection.

2 Carbon Offsetting and Reduction System for International Aviation (CORSIA)

STG     Policy Brief     Issue 2019/08     December 20194 
PART 2: CARBON PRICING AND COMPETITIVENESS: A CASE FOR BORDER 
MEASURES?

Climate policies have cost implications, and as climate ambition 
increases,  the  risk  of  adversely  impacting  the  competiveness  of 
European  industries  increases.  Conscious  of  this  fact,  the  Eu-
ropean Union has taken specific measures to address the issue. 
However, if the EU is about to increase its ambition to achieve 
a 50%, or even 55%, reduction of its emissions by 2030, and as-
suming that industry will play a role in achieving this goal, then 
there  is  clearly  a  risk  to  EU  competitiveness.  One  possible  way 
to address this risk, as mentioned on several occasions by Euro-
pean Commission President von der Leyen,  is  a  carbon  border 
tax. Furthermore, the winner of the Noble Prize for Economics in 
2019, William Nordhaus, has advocated the formation of carbon 
“clubs” as a means to protect competiveness.   

So far, the EU has addressed the competitiveness of the industries 
covered by the EU ETS by the maintenance of free allocation to 
exporting industry sectors. This is the compromise reached by all 
the European institutions in the context of the target to reduce 
the EU’s emissions by 40% by 2030. In 2018 the equivalent of ap-
proximately EUR 11.6 billion was allocated to European industry 
for free, which has been criticised by some as a “fossil fuel sub-
sidy”. Generally speaking, economists prefer allocation to be by 
auctioning as opposed to free allocation, but EU legislation fore-
sees partial free allocation to continue through to 2030. 

If going beyond a 40% reduction by 2030 requires an increased 
effort  from  industry  sectors  covered  by  the  EU  ETS,  then  this 
will re-open the question of preserving competitiveness. Industry 
is rightly concerned about maintaining  its  competitiveness,  but 
exporting  industries  are  equally  concerned  about  an  escalation 
of protectionism, and possible retaliatory action. The European 
Commission has framed such a carbon border tax as needing to 
be compatible with World Trade Organisation rules.  

The design of measures to protect competitiveness is not simple. 
It cannot be automatically assumed that the EU has a carbon reg-
ulatory burden and that the rest of the world is doing nothing. 
The extent of climate regulation varies across the world. However, 
there is a striking lack of comparable emissions data relating to 
traded products upon which to base any possible carbon border 
tax. 

Given that free allocation and a carbon border tax are both in-
tended to protect competitiveness, there would be a real risk of 
over-compensation of EU producers if both instruments were to 
be used simultaneously. To prevent undue advantage being gained 
by EU producers, which would more likely be found incompati-
ble with WTO rules, it was widely felt that free allocation should 
be discontinued in the case of a carbon border tax.   

Whether exports from the EU should be relieved of any domes-
tic  carbon  charge  was  also  debated.  Such  an  exemption  would 
be complex to administer and would also reduce the scope and 
environmental effectiveness of the EU ETS. Exporters would no 
longer be incentivised to reduce their emissions within Europe, 
which is a fundamental objective of the system. Furthermore, the 
accounting rules under the UN Framework Convention on Cli-

mate Change and the Paris Agreement would still attribute emis-
sions from production on EU territory to the EU. 

In the absence of detailed data on the carbon content of imported 
products,  WTO  compatibility  could  still  be  possible  if  imports 
were subject to a carbon charge equal to the EU average for the 
same product, and allowing the importer to claim lower liabili-
ty if lower carbon content could be established under equivalent 
Monitoring,  Reporting  and  Verification  rules  as  applied  within 
the EU. Lower liability to the carbon border tax could be won at 
the expense of greater administrative complexity (but not more 
than EU entities are subject to). 

However, there is a general presumption in this debate that im-
ported products are “dirtier” in terms of emissions than equiva-
lent EU production. Such a presumption may be false. European 
production  facilities  are  ageing  while  installations  in  emerging 
economies tend to be more recent, so that the carbon intensity 
per unit of production of non-EU sources products may in some 
cases be lower than equivalent EU production. In the case where 
there is no equivalent EU production, the benchmark for appli-
cation of the carbon border tax might be a world average, against 
which lower emissions intensity might be demonstrated. 

Rather than apply a carbon boarder tax to all imported products, 
the tax might apply rather to limited types of energy or energy-in-
tensive products such as: coal, oil, gas, electricity, iron and steel, 
lime, clinker and cement. Electricity and gas imports to the EU 
were seen as feasible starting points for testing a carbon border 
tax.  

WTO compatibility is nevertheless a high bar to meet for a car-
bon border tax. The minimum needed is for a debate in the WTO 
context  to  begin  in  earnest.  WTO  processes  are  slow,  so  if  EU 
action is conditioned as it has been, there is a need to start the 
process soon. A long discussion in the WTO context should be 
expected. 

The Nordhaus model of carbon clubs is to have political alliances: 
countries would either be “in” or “out”. Such a construction is less 
likely to be compatible with WTO rules. If a club were to take into 
account different degrees of carbon content of imported goods, 
this would de facto create a halfway status that would undermine 
the political nature of the alliance. It must also be borne in mind 
that there are many other factors that impact on competitiveness 
beside carbon regulation, such as the financing of State Owned 
Enterprises. 

The value of a carbon border tax is as much in the threat as in the 
implementation.  However,  the  threat  must  be  credible,  and  the 
EU would ultimately have to be ready to act. Some questioned the 
political resolve of the EU, which did not prove to be sufficient-
ly strong when retaliatory action was threatened in response to 
the inclusion of international aviation (flights to and from third 
countries) into the EU ETS. That carbon border taxes should be 
discussed again has some logic to exert pressure on other coun-
tries, and corresponds with the self-declared “geopolitical” Euro-
pean Commission that has recently been established. It was gen-

STG     Policy Brief     Issue 2019/08     December 20195erally welcomed that the new Commission shows a willingness to 
defend European interests.  

A final phase of discussion returned to the current practices of the 
Commission with regard to trade agreements agreed with envi-
ronmental chapters, introducing conditionality with Paris Agree-
ment implementation. This is clearly another way of incentivising 
third country partners to introduce carbon constraints (that may 
be implemented differently, but which would feed through into 
an economic cost on competitiveness of production by that coun-
try). 

In the context of enhancing competitiveness, the Innovation Fund 
of the EU ETS was widely welcomed, in addition to research fund-
ing under the EU’s research programmes. Suggestions were made 

to  expand  the  Innovation  Fund’s  resources.  Innovation,  and  its 
deployment at scale, by European industry was seen as essential 
to  economic  growth.  An  Industrial  Strategy  was  suggested  that 
would  look  at  what  was  strategically  important  for  Europe,  be 
focused and not constrained by technological neutrality. Europe 
should  not  become  a  gated  economy  that  was  not  competitive, 
unattractive to new investment. It would be in Europe’s interest to 
create a “safe-space” for innovation. Europe already has the dis-
advantage of low economic growth and an ageing population. In 
this context, it was doubtful that a carbon border tax would turn 
this situation around. There was concern that it might, like Brexit, 
rather suck up resources.   

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1.  The discussion was beneficial in having explored the complexities of competiveness and climate pol-

icy, and the carbon border tax instrument in particular.   

2.  The international debate on competitiveness impacts and a carbon border tax will take time and ef-
fort. There are different options, and choices will have to be made. WTO endorsement would be a 
long-haul exercise. This may be more feasible in a limited number of sectors (e.g. electricity imports). 

3.  We must avoid unnecessary complexity. A carbon border tax is an instrument and not a goal. Carbon 

competitiveness impacts could also be addressed in other ways (as has been done to present). 

4.  A quid pro quo of a carbon border tax will be the ending of free allocation. Industry will have to de-
cide which of these two means of addressing competiveness impacts they prefer. To have both would 
amount to a subsidy for EU industry that would never be WTO compatible. 

5.  The creation of a climate club, as advocated by William Nordhaus, would be a blunt, political instru-
ment. The EU would have to be ready for a fight. More realistic would be to strengthen instruments 
to push innovation by industry, harnessing budgetary resources and focusing on technologies critical 
for the climate-transition. This would amount to an enlightened industrial policy. 

PART 3: HOW TO ADDRESS EMISSIONS FROM TRANSPORT/HOUSING

Housing and transport are sectors covered by the Effort Sharing 
Decision  and  Regulation  of  the  European  Union.  They  are  dif-
ficult  to  decarbonise  sectors  for  all  economies,  not  least  due  to 
the number of individual, small emitters and rising standards of 
living that tend to increase energy consumption. 

Germany has recently been going through a robust political de-
bate on carbon pricing and how to address the emissions from 
these two sectors. A national upstream emissions trading system 
has been developed for these sectors. The approach taken builds 
upon existing tax practices and anomalies. The German regula-
tions have been adopted very quickly. Germany would like its na-
tional approach to become the core of cross-border cooperation. 
Revenues raised would go, in part, to fund public transport. 

One main topic of debate was whether road transport should be 
brought into the EU ETS. Views varied: on the one hand, it was 

strongly  felt  that  transport  should  not  be  brought  into  the  EU 
ETS.  CO2  standards  for  vehicles  have  worked,  and  these  stan-
dards need to be further strengthened over time. Taxes on fossil 
fuels also need to be increased through revision of the EU’s ener-
gy taxation Directive. The fear was expressed that including road 
transport and buildings in the EU ETS would weaken the respon-
sibility of Member States for reducing emissions in these sectors, 
although  this  argument  was  contested.  Furthermore,  it  was  felt 
that it was better not to risk adding difficult new sectors to the EU 
ETS, which was possibly too fragile to integrate road transport, 
only recently exiting from a decade of weak carbon prices. 

On the other hand it was also argued that road transport should 
be bought within the EU ETS – so as to be brought under a cap. 
California had done this. This would add additional inelastic de-
mand within the EU ETS. It was pointed out that as road transport 
electrifies, it comes under the EU ETS. It would even be possible 

STG     Policy Brief     Issue 2019/08     December 20196 
 
to develop a “downstream” ETS for road transport, where those 
registered as the vehicle user, would have a liability to pay based 
on annual distances driven multiplied by the CO2 emissions of 
the vehicle. The liability could be settled by payment of a charge 
linked to the price of allowances in a given period, and, so as to 
have a cap on emissions, an equivalent number of ETS allowances 
would be subsequently cancelled. De facto this would have much 
the same effect as an increase in fuel taxes. 

Some  favoured  the  market-based  based  emissions  trading  ap-
proach  and  some  were  strongly  in  favour  of  fuel  taxation,  also 
for housing. It was widely agreed that the energy taxation rules 
needed to be updated. It was understood by all that taxes on fuels 
could be increased in a fiscally neutral way. Care was needed in 
designing the “European Green Deal” to avoid the trap of trigger-
ing a “gilets jaune” reaction. Taxes provided revenues that could 
be recycled for social reasons. Caution was voiced in exacerbat-
ing inequalities of certain groups, such as those living in rural ar-
eas that were more dependent on private transport and less likely 
to be connected to gas grids. The higher taxation of fossil fuels 

could  possibly  slow  fuel  switching,  and  the  air  quality  benefits 
that could be gained, by encouraging the continued use of locally 
supplied wood for burning. Local air quality benefits were both 
tangible and immediate. A strong case was made for deployment 
of a whole range of policies to address transport emissions, and 
not just pricing, such as investments in public transport, cycling 
infrastructure,  parking  policies,  congestion  charging,  and  road 
pricing for freight transport. It was widely supported that avia-
tion and maritime transport should pay taxes on fuel used, like 
other transport modes. 

Due to the inelasticity of transport demand, scepticism was ex-
pressed  that  pricing  mechanisms  would  suffice.  A  high  level  of 
investment  in  new  transport  infrastructure  was  needed,  from 
electric vehicle (EV) charging points, new clean synthetic fuels, 
rail and public transport investment, cycling lanes and pedestri-
anized town centres. High investment costs will be needed to pre-
pare for the energy transition, and have to be paid for somehow. 

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1.  Transport and housing are very sensitive sectors. Everyone has a view on them. These are also socially 
sensitive sectors, impacting people’s lives more directly. The EU ETS is likely to play only a minor part 
in the transport and housing sectors. The EU ETS works through costs and efficiency, whereas the trans-
port sector is more complex. However, there was wide agreement that the aviation and maritime sectors 
could be integrated into the EU ETS. 

2.  Sub-European levels of governance are more important for the transport and housing sectors. A mixture 
of many instruments is needed, and the effort-sharing targets for 2030 will not be met without mean-
ingful new measures. The EU should not hinder such measures. Step-by-step approaches are more judi-
cious. 

3.  Energy taxation urgently needs careful review and reform, removing inconsistencies, such as the exemp-
tions of important modes of transport, such as aviation and maritime. This could potentially be done 
through qualified majority voting 3. Revenues generated can be recycled towards innovation and social 
cohesion. 

4.  We need multiple short-term measures, which also improve air quality, such as parking and congestion 
charges. National Energy and Climate Plans need to be comprehensively scrutinised at EU level so as to 
ensure the adequacy of measures in the transport and housing sectors.  

5.  We need a quantum leap in terms of investment. Capital is available, but we should look at the Stability 

and Growth Pact rules to make investment easier in the necessary low-carbon infrastructure. 

The meeting was closed with the conclusion that while the set of climate policies deployed in Europe was more complete, 
and generally functioning better than ever (with a carbon price under the ETS of EUR 25 a tonne, and revenues accruing 
as a result generally being used for good purpose), there was absolutely no room for complacency in view of attaining cli-
mate-neutrality in Europe by 2050. More and strengthened policy initiatives at all levels of governance would urgently have 
to be developed in the coming months and years. The forthcoming “European Green Deal” was an opportunity to be seized. 

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3 Subject to agreement by the European Council.

STG     Policy Brief     Issue 2019/08     December 20197 
School of Transnational Governance
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© European University Institute, 2019

doi:10.2870/160852
ISBN:978-92-9084-774-8
ISSN:2599-5928
QM-AY-19-008-EN-N

STG     Policy Brief     Issue 2019/08     December 20198