In-depth report on the results of the public consultation on the EU climate target for 2040 : final report.
Date: 2024-01-31
Institutions: Directorate-General for Climate Action
Subjects: EU environmental policy, climate change policy, public consultation, report, sample survey

In-depth Report on the Results of the 
Public Consultation on the EU Climate 
Target for 2040 

Final Report 

Work carried out by Technopolis Group in association with COWI A/S and Eunomia. 

December 2023 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Climate Action 
Directorate A – Strategy, Analysis and Planning 
Unit A.2 – Foresight, Economic Analysis & Modelling 

Contact: Johannes SCHULER 

E-mail: Johannes.SCHULER@ec.europa.eu 
            CLIMA-2040-TARGET@ec.europa.eu  

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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Luxembourg: Publications Office of the European Union, 2024 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Contract details 

European Commission – DG Climate Action, A.1 

Service contract to “Support for the public consultation for setting the EU greenhouse gas 
emission reduction target for 2040”. 

Service request: 090203/2022/882654/SER/CLIMA.A.2 

Framework contract: ENV.F.1. /FRA/2019/0001 

Contractors 

Work carried out by Technopolis Group: 

In association with COWI A/S and Eunomia: 

Authors 

Jan  Stede,  Marc  Blauert,  Gaëtan  Coatanroch,  Hywel  Jones,  Ruslan  Zhechov,  Luigi  Lo 
Piparo,  Helen  Garber,  Margrethe  Steinert,  Ieva  Stanilovaityte,  Love  Edander  Arvefjord, 
Nils Karlsson, Götz Franz Geilhardt, Barbara Hansen-Duncan (Technopolis Group) 

Michael Munk Sørensen, Gabriel Franca, Beatrice Horvath (COWI A/S) 

Tanzir Chowdhury, Celia Somlai (Eunomia) 

Disclaimer 

This  document  should  be  regarded  solely  as  a  summary  of  the  contributions  made  by 
stakeholders in the public consultation on the EU climate target for 2040. It cannot in any 
circumstances be regarded as the official position of the Commission or its services.  

Responses to the consultation activities cannot be considered as a representative sample 
of the views of the EU population. 

The  abstracts  of  the  position  papers  submitted  by  the  stakeholders  (Appendix  C)  are 
prepared by the contractors and cannot in any circumstances be regarded as the official 
position of the Commission or its services to these position papers. 

  
 
 
 
 
 
 
 
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Table of Contents 

1. 

Introduction ................................................................................................... 3 

2.  Background on the public consultation and methods ............................... 4 

2.1.  Methodological approach for survey analysis (public consultation 
questionnaire) .......................................................................................................... 5 

2.1.1. 
2.1.2. 
2.1.3. 
2.1.4. 

Stakeholder groups ......................................................................................... 5 
Analysis of closed questions ........................................................................... 7 
Analysis of open questions ............................................................................. 7 
Strategies for campaign identification ............................................................. 7 

2.2.  Methodological approach for the analysis of position papers ........................ 8 

3.  Analysis of the responses to the public consultation questionnaire ....... 9 

3.1.  Overview of responses .................................................................................. 9 

3.2.  General section ........................................................................................... 11 

Overall opinion on the EU’s climate ambition for 2040 .................................. 11 
3.2.1. 
3.2.2. 
Contribution of individual sectors to the EU’s climate ambition ...................... 26 
3.2.3.  My personal contribution to protect the climate ............................................. 30 
The impacts of the climate crisis ................................................................... 39 
3.2.4. 

3.3.  Expert section ............................................................................................. 47 

General policy framework ............................................................................. 47 
3.3.1. 
3.3.2.  Mitigation of GHG emissions from the land sector and policy options ........... 53 
The role of carbon removals ......................................................................... 56 
3.3.3. 
Technologies ................................................................................................ 60 
3.3.4. 
Engagement and social impacts ................................................................... 71 
3.3.5. 
Adapting to climate change ........................................................................... 75 
3.3.6. 

3.4.  Results of the identified campaign .............................................................. 76 

4.  Analysis of the public consultation position papers ............................... 78 

4.1.  Overview of position papers selected and status of analysis ...................... 79 

4.2.  General stakeholder opinion on the 2040 target and associated 
opportunities, challenges and enabling factors ...................................................... 79 

4.2.1. 
4.2.2. 
4.2.3. 
4.2.4. 

Level of ambition for 2040 target ................................................................... 79 
Opportunities related to a higher climate ambition ........................................ 80 
Challenges and enabling factors related to the climate target for 2040 ......... 81 
Linkage of an ambitious climate target to climate change adaptation ............ 83 

4.3.  General stakeholder opinion on the contribution of Individual sectors to the 
EU's climate ambition ............................................................................................ 84 

4.4.  General stakeholder opinion on the role of policy instruments .................... 85 

4.4.1. 
4.4.2. 

Role of EU ETS post-2030 ............................................................................ 85 
Role of CBAM ............................................................................................... 86 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

4.4.3. 

Role of ESR .................................................................................................. 86 

4.5.  General stakeholder opinion on the land sector .......................................... 87 

4.5.1. 
4.5.2. 

Options to tackle agricultural emissions ........................................................ 87 
Stakeholders targeted by a carbon price on agricultural emissions ............... 87 

4.6.  General stakeholder opinion on the role of carbon removals ...................... 87 

4.7.  General stakeholder opinion on carbon capture and storage/use ............... 88 

4.7.1. 
4.7.2. 

Role of different carbon capture and storage technologies ........................... 88 
Challenges associated to CCUS ................................................................... 89 

4.8.  General stakeholder opinion on energy technologies ................................. 90 

4.8.1.  Most relevant solutions for the energy transition ........................................... 90 
Opportunities associated with energy technologies ....................................... 90 
4.8.2. 
Challenges associated with energy technologies .......................................... 91 
4.8.3. 

4.9.  General stakeholder opinion on other options to be considered ................. 91 

4.9.1. 
Carbon sequestration ................................................................................... 92 
4.9.2.  Waste-to-Energy ........................................................................................... 92 

4.10.  General stakeholder opinion on engagement and social impacts ........... 92 

4.10.1. 
Just transition ............................................................................................... 92 
Impacts on citizens ....................................................................................... 93 
4.10.2. 
4.10.3.  Upskilling ...................................................................................................... 93 

5.  Analysis of the call for evidence section .................................................. 95 

5.1.  Background and methods ........................................................................... 95 

5.2.  Overview of responses ................................................................................ 95 

5.3.  Key themes by stakeholder group ............................................................... 95 

6.  Key insights from the targeted stakeholder event ................................... 99 

Appendix ........................................................................................................... 101 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

1.  Introduction 

In the context of the requirement to propose an intermediate EU climate target for 2040, the 
European  Commission  (EC)  conducted  consultation  activities  aimed  at  supporting  the 
corresponding 
impact  assessment.  These  consultation  activities  are  summarised 
comprehensively in this in-depth report. 

The  consultation  activities  for  the  intermediate  EU  climate  target  for  2040  included  the 
following elements: 

•  Public  consultation  (questionnaire  and  position  papers):  A  public  consultation 
was  conducted  over  a  12-week  period  from  the  31/03/2023  until  the  23/06/2023.  It 
included a questionnaire and the option to submit position papers. The questionnaire 
comprised of a general section (17 questions) and an expert section (18 questions). 
The  general  section  was  targeted  at  a  wider  group  of  stakeholders  while  the  expert 
section  was  more  technical  and  involved  questions  about  specific  policy  domains 
relevant for the target setting. The consultation incorporated mainly closed questions 
(32) but also few open questions. 

•  Call  for  evidence:  In  addition  to  the  public  consultation,  stakeholders  had  the 
opportunity to share general remarks and feedback on the policy initiative through a 
call  for  evidence.  They  had  the  opportunity  to  upload  position  papers  which  were 
analysed together with the position papers received in the public consultation. 

•  Targeted stakeholder event: A targeted hybrid stakeholder event was hosted by the 
EC  in  Brussels.  Participants  were  informed  about  the  policy  initiative  for  setting  the 
EU climate target for 2040 and invited to share their views. 

Covering the different consultation activities, the in-depth report is structured as follows: 

Chapter 1: Introduction 

Chapter 2: Background on the public consultation and methods 

Chapter 3: Analysis of the responses to the public consultation questionnaire 

Chapter 4: Analysis of the public consultation position papers 

Chapter 5: Analysis of the call for evidence section 

Chapter 6: Key insights from the targeted stakeholder event 

Additionally, the report provides the following three appendixes as background materials: 

Appendix A: Public consultation questionnaire (English version) 

Appendix B: Overview of the main characteristics of the selected position papers 

Appendix C: Abstracts of selected position papers 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

2.  Background on the public consultation and methods 

The public consultation was launched on the 31/03/2023 and ran until the 23/06/2023 (twelve 
weeks).  With  the  public  consultation,  the  EC  offered  all  citizens  and  stakeholders  the 
opportunity to express their views on the initiative to set an intermediate EU climate target for 
2040.  Setting  an  intermediate target  is  required  by  the  provisions  of  Art  4.  of the  European 
Climate Law. 

The  public  consultation  was  launched  in  the  EU  survey  portal.  It  included  the  following 
elements: 

•  Public  consultation  questionnaire:  The  questionnaire  involved  two  sections:  A 
general  section  and  an  expert  section.  The  general  section  consisted  of  questions 
that are of relevance for a wide range of stakeholder groups. It included questions on 
the EU’s overall climate ambition for 2040, associated opportunities and challenges, 
and  related  policy  needs.  The  expert  section  consisted  of  questions  that  are  more 
technical.  It  involved  questions  related  to  the  role  of  specific  policy  instruments,  the 
role of carbon removals, and technological options (see Table 1). 

•  Public  consultation  position  papers:  Respondents  were  given  the  opportunity  to 
hand-in  position  papers  as  part  of  their  response  to  the  public  consultation 
questionnaire as well as in their reply in the call for evidence section. 

Public consultation questionnaire 

The structure of the public consultation, as depicted in Table 1, incorporated a combination 
of  closed  and  open  questions.  Most  questions  were  closed  questions  presented  in  either 
multiple-choice,  multiple-response,  or  Likert-scale  (5-point)  answer  formats.  In  addition,  the 
questionnaire  included  some  open-ended  questions.  These  open-ended  questions  were 
designed in some cases as stand-alone questions and in other cases as follow-up questions 
to get additional feedback on the topic of a previous closed question. 

The  general  section  included  four  sub-sections  with  17  questions  (+4  follow-up  open 
questions).  The  expert  section  contained  six  sub-sections  with  18  questions  (+2  follow-up 
open  questions).  Overall,  the  questionnaire  included  35  questions  (+6  follow-up  open 
questions). 

At  the  end  of  the  questionnaire,  respondents  were  given  the  opportunity  to  upload  position 
papers which were then considered for analysis (see Chapter 4). 

To ensure accessibility and inclusivity, respondents were able to provide their input in any of 
the 24 official languages of the EU. 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Table 1  

Structure of the public consultation questionnaire 

General section 

Participants were asked to provide feedback on the following sub-sections: 

•  Overall opinion on the EU’s climate ambition for 2040 (Q1-6) 
•  Contribution of individual sectors to the EU’s climate ambition (Q7-9) 
•  My personal contribution to protect the climate (Q10-13) 
•  The impacts of the climate crisis (Q14-17) 

Expert section 

Participants were asked to provide feedback on the following sub-sections: 

•  General policy framework (Q18-20) 
•  Mitigation of GHG emissions from the land sector (agriculture, forestry, and other land use) 

and policy options (Q21-22) 

•  The role of carbon removals (Q23-24) 
•  Technologies (Q25-30) 
•  Engagement and social impacts (Q31-34) 
•  Adapting to climate change (Q35) 

Public consultation position papers 

Both  the  position  papers  collected  through  the  public  consultation  questionnaire  and  in  the 
call for evidence section were included in the analysis of public consultation position papers 
(see Chapter 4). 

2.1.  Methodological  approach 
consultation questionnaire) 

for  survey  analysis  (public 

2.1.1. Stakeholder groups 

To improve the accuracy and relevance of the stakeholder groups, a two-step process was 
undertaken, as described below. 

Step  1:  Manual  review  and  recoding.  The  first  step  involved  two  types  of  manual 
verification  and  recoding.  First,  the  respondents'  self-identification  under  the  stakeholder 
groups was checked to ensure the accuracy of their selection. Whenever respondents clearly 
chose an incorrect option, the respective observations were corrected. This step also applied 
to  the  "Others"  stakeholder  group,  where  responses  were  assigned  to  more  specific 
stakeholder  groups  whenever  possible.  In  the  second  part  of  this  manual  verification 
process,  the  focus  was  put  on  the  size  category  of  the  business  associations  stakeholder 
group. This was necessary to be able to differentiate economic stakeholders into those that 
are/represent  (i)  small  and  medium-sized  enterprises  (SMEs)  and  those  that  are/represent 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

(ii)  large  companies  (see  Step  2  below).  Business  associations  typically  choose  the  size 
category based on their own number of employees. In the manual recoding the size category 
of the business associations was adjusted to reflect whether they represented SMEs or large 
companies mainly. The recoding is based on expert judgment regarding the economic sector 
a business association represents and using lists of their members available online. 

Step 2: Re-assignment to adjusted stakeholder groups. In the second step, the manually 
checked and recoded stakeholder groups from the questionnaire were re-assigned to better 
suit  the  reporting  needs  of  DG  CLIMA  for  their  impact  assessment  (e.g.,  need  to  focus 
specifically on SMEs). Table 2 below summarises this re-assignment of stakeholder groups. 
The main adjustments to the questionnaire categories are that the responses from economic 
actors  (business  associations,  business/companies)  have  been  organised  into  Business 
associations/companies (large companies) and Business associations/companies (SMEs). In 
addition,  the  responses  from  NGOs,  environmental  organisations,  trade  unions,  and 
consumer  organisations have  been  clustered  as responses from  civil  society  organisations, 
due to the limited number of responses form e.g. trade unions and consumer organisations. 

Table 2 

Re-assignment of stakeholder groups 

Stakeholder group from 
questionnaire 

Size category 

Stakeholder group for 
survey analysis 

•  Academic/research institution 

• 

- 

•  Academic/research 
institutions 

•  Business 

companies (SMEs) 

associations/ 

•  Business 

associations/companies 
(Large) 

•  Civil society organizations 

•  EU citizens 

•  Public authorities 

•  Others 

•  Business association 
•  Company/business 

•  Business association 
•  Company/business 

•  Consumer organisation  
•  Environmental organisation  
•  Non-governmental 
organisation (NGO)  

•  Trade union 

•  EU citizen 

•  Public authority  

•  Non-EU citizen 
•  Other 

•  Micro (1 to 9 employees) 
•  Small (10 to 49 employees) 
•  Medium (50 to 249 employees) 

• 

Large (250 employees or more) 

• 

- 

• 

• 

• 

- 

- 

- 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

2.1.2. Analysis of closed questions 

The  data  from  closed  questions  underwent  thorough  processing  and  cleaning  to  facilitate 
descriptive analysis and representation of the consultation data. The results are consistently 
presented  as  percentage  values,  indicating  the  proportion  of  responses  within  each 
respective  stakeholder  group.  Additionally, 
for  multiple-choice  or  multiple-response 
questions,  the  absolute  number  of  responses  is  included  in  the  graphs  to  provide  further 
information. To simplify the graphical representation of results, the observations categorized 
as "I don't know" and "No response" are joined into a single response category. For Likert-
scale questions, the relative distribution of responses is complemented by an item average. 
This  average  is  calculated  based  on  the  Likert-scale  responses,  excluding  the  "I  don't 
know/No  response"  category.  This  methodological  approach  is  reasonable  since  in  the 
questionnaire  only  the  endpoints  of  the  Likert-scale  items  are  labelled,  maintaining  the 
interval scale of the response items. 

2.1.3. Analysis of open questions 

The  methodology  used  for  analysing  open-text  questions  involves  several  steps.  After 
translating  all  responses  to  English,  eliminating  invalid  ones,  and  identifying  coordinated 
responses,  a semi-automated  thematic  analysis  was  conducted.  The  initial  responses  were 
closely  examined  for  each  individual  question  to  identify  common  themes,  employing  an 
inductive  approach  that  allows  the  data  to  determine  the  emerging  themes  without 
preconceived notions.  

In  the  survey  analysis,  certain  responses  are  encountered  that  are  deemed  invalid  and 
therefore excluded from the final data set. Invalid responses include those such as ".", "n/a", 
"na", "yes", "I do not know.", "None", "", " ", "-", "hm". 

Additionally,  the  analysis  of  open  question  also touches  on the  identification  of  coordinated 
responses (see next paragraph for more details).  

Overall, the views from the public consultation are not statistically representative. 

2.1.4. Strategies for campaign identification 

For  the  identification  of  campaigns,  different  strategies  were  used  on  the  subset  of  closed 
and  open  questions  in  the  questionnaire.  On  the  closed  questions,  a  K-means  clustering 
approach  was  used  to  identify  responses  with  a  high  degree  of  similarity.  Since  a  smaller 
subset of  respondents  answered the  expert  section  compared  to  the  general  section  of the 
questionnaire, the data on the closed questions were first split into the two sections and then 
analysed for very similar answers to the closed questions. 

Additionally,  for  the  open  questions,  the  similarity  of  strings  was  compared  based  on  the 
Optimal  String  Alignment  (restricted  Damerau-Levenshtein  distance)  algorithm.  The 
approach performs a pairwise comparison of strings and measures the minimum number of 
operations required to transform one string into another. Strings that show a high degree of 
similarity are isolated based on the algorithm and then compared manually. 

The chosen strategy for the identification of coordinated responses led to the discovery of a 
distinct group consisting of 23 EU citizens from Slovakia within the questionnaire responses. 
This group provided coherent open-text narrative responses, emphasizing the importance of 
politicians avoiding CO2-emitting means of transportation. Notably, all these responses were 
submitted  during  the  final  days  of  the  consultation  period.  Considering  the  number  of 
responses, their origin from EU citizens within one country, and the high level of agreement 
observed  in  the  closed questions,  this  group  was  classified  as  a  campaign  and  segregated 
and analysed separately from the non-campaign responses, in line with the requirements of 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

the Better Regulation Toolbox #54. The analysis of the campaign responses is presented in 
a separate summary analysis (see Chapter 3.4). 

In  addition,  the  strategy  also  led  to  the  identification  of  highly  similar  open-text  responses 
from  approximately  nine  environmental  organizations  (number  slightly  varying  by  open-text 
question).  However,  the  closed  question  responses  from  these  organizations  exhibit 
divergent viewpoints. Considering the small number of responses and the shared knowledge 
among  environmental  organisations,  it  was  decided  not  to  treat  these  answers  as  a 
campaign.  In  the  analysis  of  the  open  questions,  the  topics  to  which  the  answers  of  the 
environmental  organisations  were  counted  are mentioned  in  a footnote to  acknowledge  the 
similarities found. 

2.2.  Methodological  approach  for  the  analysis  of  position 

papers 

An  analysis  of  the  main  views  expressed  in  a  selection  of  position  papers  was  conducted. 
Three  main  sources  were  used  to  identify  120  relevant  papers:  the  public  consultation,  the 
call  for  evidence  and  desk  research.  Papers  were  selected  in  agreement  with  DG  CLIMA. 
The  objective  of  this  analysis  was  to  identify  the  main  views  expressed  during  the  public 
consultation.  A  preliminary  screening  of  all  papers  was  conducted,  to  identify  the  main 
characteristics and core idea of the papers. After selection, an in-depth review of all papers 
was conducted in an internal Excel file to identify the statements relevant for the analysis and 
the topics to which they belong. The team then associated them with a unique identifier and 
basic  information  on  the  respondents  which  was  subsequently  used  as  variables  for  the 
analysis:  stakeholder  groups,  country,  sector  etc.  The  main  trends  are  explained  and 
described, observed through this thematic analysis. In addtion, some assumptions are drawn 
respective to their rationale. 

To  provide  insights  into  potential  differences  in  opinions  between  different  groups  of 
respondents,  the  assessment  of  the  respondents’  position  included  an  analysis  on  the 
composition  of  stakeholder’s  groups,  e.g.  by  type  of  respondent,  country,  economic  sector, 
based on the information made available by respondents through the consultation survey. 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

3.  Analysis  of  the  responses  to  the  public  consultation 

questionnaire 

3.1.  Overview of responses 

In  total,  903  stakeholders  responded  to  the  public  consultation.  Among  these,  one  genuine 
duplicate was identified.1 Additionally, 23 (3%) responses were classified as part of a single 
campaign,  segregated  and  analysed  separately  (see  Chapter  3.4).  Therefore,  the  main 
analysis focussed on the remaining 879 responses. 

The  public  consultation  questionnaire  was  structured  in  two  sections:  a  general  and  an 
expert section. Out of the 879 analysed responses, 819 (93%) respondents opted to reply to 
the general section and 580 (66%) to the expert section. A subset of 19 respondents did not 
provide a response to either of them. 

Geographical distribution of responses from EU Member States 

The geographical distribution of EU responses is depicted in Figure 1. 811 responses coming 
from  respondents  who  self-identified  as  located  in  the  EU  were  received.  The  frequency  of 
responses varied greatly across Member States. Most responses came from Germany (235, 
27%),  followed  by  Belgium  (129,  15%)  and  Italy/Spain  (both  54,  6%).  Relatively  high 
response rates were received from the Netherlands (47, 5%), Slovakia (44, 5%), France (39, 
4%), Sweden (36, 4%), Finland (35, 4%), and Austria (35, 4%). In contrast, fewer responses 
were received from some Central and Eastern European countries. 

1 Response from BDEW Bundesverband der Energie- und Wasserwirtschaft e.V. recorded twice. 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

I n = 811 (Number of responses from EU27 Member States. The campaign responses are not included here. An additional 68 
responses were received from non-EU countries.) 

Figure 1  Geographical distribution of responses by EU Member States 

Stakeholder groups 

Among the 879 responses  included  in the  analysis  of  non-campaign  responses,  480 (55%) 
were  provided  by  private  individuals  (EU  citizen:  468;  Non-EU  citizen:  12),  and  399  (45%) 
were received from organisations. 

As Figure 2 illustrates, out of the 399 responses received from organisations, 244 responses, 
and  thus  the  largest  number,  were  submitted  by  companies/businesses  (121,  14%)  and 
business  associations  (123,  14%).  For  analysis,  these  responses  were  further  categorised 
into  two  groups:  companies  and  business  associations  that  are  SMEs  or  predominantly 
represent  SMEs  (108,  12%)  and  companies  and  business  associations  that  are  large 
companies (+250 employees) or predominantly represent large companies (136, 16%). The 
third  largest  group  of  organisational  responses  was  from  civil  society  organisations  (98, 
11%).  This  category  includes  responses  from  NGOs  (68,  8%),  environmental  organisations 
(20,  2%),  trade  unions  (9,  1%)  and  consumer  organisations  (1,  0.1%).  In  addition,  23  (3%) 
responses were received from academic/research institutions and a matching number of 23 
(3%) responses were provided by public authorities. Also, 23 (3%) responses were classified 
as “Other”.2 

2 Includes the responses from non-EU citizens (12). 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

I n = 879 (Number of responses to the public consultation questionnaire. The responses from Slovakia which are classified 
as a campaign are not included here.) 

Figure 2  Correspondence between stakeholder groups responding to the public consultation questionnaire and groups used 
for the analysis 

3.2.  General section 

3.2.1. Overall opinion on the EU’s climate ambition for 2040 

The first section of the general part of the survey engaged with respondents’ overall opinion 
on the EU’s climate ambition for 2040. 

In particular, this section included questions on the general emission reduction ambition, as 
well  as  concrete  proposals  for  a  specific  level  of  ambition  Furthermore,  respondents 
were asked how carbon removals should be integrated into the target architecture of EU 
climate  policy  i.e.  whether  there  should  be  a  single  “net”  target  or  separate  targets  for 
emission  abatement  and  carbon  removals  (nature-based  removals/technology-based 
removals).  Stakeholders’  views  on  challenges  and  opportunities  associated  with  an 
increased climate ambition and gender aspects of climate policies are also covered in this 
section. 

3.2.1.1. Q1: Emissions reduction ambition for 2030–2040 

In  Q1,  stakeholders  were  asked  to  indicate  how  the  EU  should  pursue  the  climate 
transition  up  to  2040,  when  considering  the  EU’s  objective  of  achieving  climate 

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neutrality by 2050 and the current energy crisis. Four options were available for selection. 
Three response options represented a sequence in terms of the level of ambition (accelerate 
the  pace  of  transition,  maintain  the  current  pace  of  transition,  decrease  the  pace  of 
transition).  Additionally,  a  fourth  response  option  was  that  the  level  of  ambition  should  be 
made dependent on the climate ambition in other countries. 

I n = 819 (Responses to the general section of the questionnaire) 

Figure 3  Responses to Q1 of the questionnaire 

General findings 

As  depicted  in  Figure  3,  the  large  majority  of  respondents  want  the  EU  to  accelerate  the 
transition to climate neutrality in the 2030-2040 period (Individuals: 369, 80%; Organisations: 
229,  64%;  Total:  598,  73%).  By  a  wide  margin  from  the  first  option,  the  second  most 
frequently  chosen  option  is  that  the  EU’s  climate  transition  should  continue  at  the  current 
pace  (Individuals:  14,  3%;  Organisations:  66,  18%;  Total:  80,  10%).  Few  respondents 
advocate for a slower transition (Individuals: 38, 8%; Organisations: 12, 3%; Total: 50, 6%) or 
suggest  that  the  pace  should  depend  on  the  level  of  climate  ambition  in  other  countries 
(Individuals: 34, 7%; Organisations: 15, 4%; Total: 49, 6%).  

Overall, the responses to Q1 strongly endorse setting an ambitious EU climate target 
for  2040.  This  endorsement  is  particularly  pronounced  among  individuals,  where  a  robust 
majority  expresses  support  for  accelerating  the  climate  transition.  Notably,  a  substantial 
portion of organizations also backs an acceleration of the transition.  

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However,  it  is  worth  noting  that,  when  comparing  organizations  and  individuals,  there  is  a 
relatively higher percentage of support for maintaining the current pace among organizations 
(18%) compared to individuals (3%). 

Differences between stakeholder groups 

Civil  society  organisations  (84,  91%)  together  with  academic  and  research  institutions  (17, 
85%) are the organisational stakeholders with the highest level of support to accelerate the 
transition to climate neutrality in the 2030-2040 period. 

Businesses  and  business  associations  have  a  relatively  greater 
toward 
maintaining  the  current  pace  of  the  transition.  This  applies  both  for  SMEs  (25,  26%)  and 
large  companies  or  business  associations  representing  large  companies  (31,  25%).  Thus, 
the difference between individuals and organisations in the response option to maintain the 
current  pace  of  the  transition  can  be  attributed  to  the  contributions  of  businesses  and 
business  associations  mainly.  However,  also  within  the  group  of  businesses  and  business 
associations,  most  responses  want  the  EU  to  accelerate  the  transition  (SMEs:  51,  53%; 
Large: 60, 48%). Only a few businesses and business associations argue for a slower pace 
of the transition (SMEs: 7, 7%; Large: 5, 4%). 

inclination 

Differences between Member States 

In  addition,  Table  3  below  breaks  down  the  responses  to  Q1  by  EU  Member  State.  The 
responses from non-EU countries are aggregated into one row. The percentages represent 
the shares of chosen answers to Q1 by Member State. 

In nearly all Member States there is strong support to accelerate the climate transition. 

Notable dissent is observed only among respondents from Czechia and Slovakia, where only 
22% (Czechia) and 7% (Slovakia) express a preference for accelerating the current pace of 
the transition. Among Slovak respondents, who are also relatively larger in number (n = 43), 
about half of the respondents prefers the option of a pace dependent on other countries' level 
of  ambition  (20,  47%),  followed  by  a  slower  pace  compared  to  the  current  trajectory  until 
2030 (15, 35%). 

Table 3  

Responses to Q1 divided by stakeholders’ country of origin. 

Member State 

Emissions reduction ambition for 2030 – 2040 

Accelerate 
the 
transition 

Continue 
at the 
current 
pace 

Slower than 
the current 
pace 

Depend on other 
countries’ climate 
ambition 

I don’t know./ 
No response. 

Austria (n = 34) 

Belgium (n = 122) 

Bulgaria (n = 4) 

Croatia (n = 6) 

Cyprus (n = 1) 

Czechia (n = 9) 

Denmark (n = 13) 

Estonia (n = 3) 

Finland (n = 28) 

France (n = 35) 

Germany (n = 223) 

Greece (n = 4) 

Hungary (n = 5) 

73,5% 

57,4% 

75,0% 

83,3% 

100,0% 

22,2% 

100,0% 

66,7% 

82,1% 

85,7% 

88,8% 

100,0% 

60,0% 

2,9% 

7,4% 

0,0% 

0,0% 

0,0% 

11,1% 

0,0% 

0,0% 

3,6% 

0,0% 

1,8% 

0,0% 

20,0% 

17,6% 

14,8% 

0,0% 

16,7% 

0,0% 

44,4% 

0,0% 

0,0% 

3,6% 

14,3% 

4,5% 

0,0% 

0,0% 

13 

2,9% 

6,6% 

25,0% 

0,0% 

0,0% 

22,2% 

0,0% 

0,0% 

0,0% 

0,0% 

1,8% 

0,0% 

0,0% 

2,9% 

13,9% 

0,0% 

0,0% 

0,0% 

0,0% 

0,0% 

33,3% 

10,7% 

0,0% 

3,1% 

0,0% 

20,0% 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Ireland (n = 7) 

Italy (n = 49) 

Latvia (n = 1) 

Lithuania (n = 1) 

Luxembourg (n = 1) 

Malta (n = 2) 

Netherlands (n = 45) 

Poland (n = 13) 

Portugal (n = 9) 

Romania (n = 15) 

Slovakia (n = 43) 

Slovenia (n = 2) 

Spain (n = 49) 

Sweden (n = 34) 

Non-EU countries (n = 
61)  

100,0% 

81,6% 

100,0% 

100,0% 

100,0% 

100,0% 

82,2% 

61,5% 

44,4% 

40,0% 

7,0% 

50,0% 

67,3% 

85,3% 

75,4% 

0,0% 

6,1% 

0,0% 

0,0% 

0,0% 

0,0% 

4,4% 

7,7% 

44,4% 

20,0% 

4,7% 

50,0% 

20,4% 

11,8% 

8,2% 

0,0% 

6,1% 

0,0% 

0,0% 

0,0% 

0,0% 

6,7% 

7,7% 

11,1% 

26,7% 

34,9% 

0,0% 

10,2% 

0,0% 

1,6% 

0,0% 

4,1% 

0,0% 

0,0% 

0,0% 

0,0% 

2,2% 

23,1% 

0,0% 

6,7% 

46,5% 

0,0% 

2,0% 

2,9% 

6,6% 

0,0% 

2,0% 

0,0% 

0,0% 

0,0% 

0,0% 

4,4% 

0,0% 

0,0% 

6,7% 

7,0% 

0,0% 

0,0% 

0,0% 

8,2% 

3.2.1.2. Q2: EU emission reduction target for 2040 

For  Question  Q2,  participants  are  requested  to  provide  their  opinion  on  the  net  emission 
reduction target for 2040: “The EU has committed to reduce its net GHG emissions by 55% 
compared to 1990 levels by 2030 and aims to achieve climate neutrality by 2050 (-100%). In 
your  opinion,  what  should  be  the  net  emission  reduction  target  for  2040  to  put  the  EU  on 
track  to  meeting  the  2050  climate  neutrality  target?”.  There  are  five  available  options  to 
choose  from,  ranking  from  a  low  level  of  ambition  of  “up  to  -65%  emission  reduction”  to  a 
high ambition of “more than -90% emission reduction”. 

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I n = 819 (Responses to the general section of the questionnaire) 

Figure 4  Responses to Q2 of the questionnaire 

General findings 

Figure  4  reports  the  results  for  Q2.  It  illustrates  that  the  responses  to  Q2  align  with  the 
findings  observed  in  Q1,  wherein  a  substantial  majority  of  respondents  advocate  for  an 
acceleration of the pace of the climate transition during the 2030-2040 period. 

The  largest  number  of  responses  (Individuals:  210,  46%;  Organisations:  107,  30%;  Total: 
317, 39%) report that the net emission reduction target for 2040 should be “more than -90%”. 
This means that among the group of private individuals responding to the public consultation, 
almost half favour a net emission reduction target for 2040 of “more than -90%”. 

The second most frequently chosen response is that the net emission reduction target should 
be  “between  -80%  and  -90%”  (Individuals:  112,  24%;  Organisations:  75,  21%;  Total:  187, 
23%) followed by the net emission reduction target “between “-75% and -80%” (Individuals: 
50, 11%; Organisations: 85, 24%; Total 135, 17%). 

Only  a  relatively  smaller  percentage  of  responses  call  for  a  less  ambitious  net  emission 
reduction target “between -65% and -75%” (Individuals: 9, 2%; Organisations: 20, 6%; Total: 
29, 4%) or “up to -65%” (Individuals: 38, 8%; Organisations: 8, 2%; Total: 46, 6%).  

Differences between stakeholder groups 

There are differences in the level of ambition called for between different stakeholder groups. 
The results are shown in Figure 5. The groups most in favour of a highly ambitious target of 
“more  than  -90%”  are  civil  society  organisations  (58,  63%)  together  with  EU  citizens  (202, 
45%). Also, academic and research institutions exhibit a strong preference for an ambitious 
target  with  35%  (7)  of  the  respondents  choosing  “more  than  -90%”  and  another  35%  (7) 
choosing “between -80% and -90%”. 

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For business associations and companies, the response pattern is more diverse. The highest 
level of approval is evident for a moderate target range of “between -75% and -80%” (Large 
companies: 29.4%, 37; SMEs: 28.9%, 28). However, in both groups, there is also support for 
a highly ambitious target. This is especially notable among SMEs, where approximately 20% 
advocate for a target of “more than -90%” and another 20% for a target “between -80% and -
90%.” Additionally, only a few business associations and companies call for an ambition level 
below -75%. 

For public authorities as well, the largest share of approval can be observed for a moderate 
target range of “between -75% and -80%” (37.5%, 6). 

I n = 799 (Responses to the general section of the questionnaire) 

Figure 5  Responses to Q2 of the questionnaire by stakeholder group 

3.2.1.3. Q3: Role of carbon removals in the 2040 climate target 

The  third  question  Q3,  looks  more  closely  at  the  consideration  of  carbon  removals  in  the 
architecture  of  EU  climate  targets.  The  participants  are  asked  to  indicate  how  they  believe 
carbon  removals  should  be  considered,  so  that  the  EU  achieves  its  2040  climate  target. 
Specifically,  it  is  asked  if  there  should  be  a  single  “net”  emission  target,  which  considers 
carbon removals together with actual GHG emissions, if carbon removals and GHG emission 
reduction  should  be  separate  targets  or  if  it  is  better  to  have  three  targets,  one  target  for 
reducing  GHG  emissions,  one  target  for  nature-based  carbon  removals  and  another  target 
for industrial removals with permanent storage. 

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I n = 819 (Responses to the general section of the questionnaire) 

General findings 

Figure 6  Responses to Q3 of the questionnaire 

Analysing  Figure  6,  it  can  be  observed  that  most  respondents  (Individuals  272,  59%; 
Organisations 171, 48%; Total 443, 54%) believe that it is better to have separate targets for 
GHG  emission  reductions,  nature-based  carbon  removals  and  industrial  removals  with 
permanent  storage.  Only  126  respondents  (Individuals:  63,  14%;  Organisations:  63,  18%; 
Total: 126, 15%) favour the option of considering both types of carbon removals together, but 
separately  from  emission  reduction  targets.  Finally,  only  a  small  proportion  of  respondents 
(Individuals:  63,  14%;  Organisations:  84,  23%;  Total:  147,  18%)  prefer  a  single  “net” 
emissions target (reduction and removal). 

Thus, it can be observed that most respondents call for a different approach in deriving the 
climate  target  architecture  for  2040  compared  to  the  current  approach  for  2030,  where 
carbon removals play a lesser role compared to expectations for the 2030-2040 period. 

On  this  question,  individuals  and  organisations  generally  show  a  similar  response  pattern. 
However, with 59% (272) in comparison to 48% (171), a larger proportion of individuals than 
organisations favoured separate targets for GHG emission reductions, nature-based carbon 
removals and industrial removals with permanent storage. Meanwhile, a larger proportion of 
organisations  (84,  23%)  than  individuals  (63,  14%)  chose  the  option  of  a  single  “net” 
emissions target. 

Differences between stakeholder groups 

When comparing the different organisational stakeholder groups, it is particularly noticeable 
that the majority of civil society organisations and academic/research institutions believe that 
three  separate  targets  are  the  best  solution  (civil  society  organisations:  64,  70%; 

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Academic/research  institutions:  14,  70%).  Only  few  (civil  society  organisations:  9,  10%; 
Academic/research institutions: 1, 5%) institutions favour the single target. 

In  contrast,  large  and  SME  business  associations/companies  as  well  as  public  authorities 
seem  to  disagree  more  on  this  question.  This  is  reflected  by  the  fact  that  they  are  more 
evenly divided between the group in favour of three separate targets (Large: 46, 37%; SMEs: 
34,  35%;  Public  authorities:  7,  44%)  and  the  group  in  favour  of  a  single  target  (Large:  42, 
33%; SMEs: 26, 27%; Public authorities: 3, 19%). The stronger call for a single “net” target 
from  the  organisational  stakeholders  is  mainly  due  to  the  positions  expressed  by  business 
associations/companies  (SMEs  and  large).  Together  they  account  for  68  (SME:  26;  Large: 
42) of the 84 organisations that call for a single “net” target. 

3.2.1.4. Q4: Opportunities associated with higher climate ambition 

The fourth question Q4 gauges what opportunities and benefits the respondents expect from 
an  ambitious  climate  target  by  2040.  The  participants  are  able  to  choose  multiple  answers 
from  a  range  of  opportunities,  describing  the  impact  of  an  ambitious  climate  target  on 
mitigating  the  climate  crisis,  avoiding  societal,  business-related  and  individual  costs, 
improving  personal  well-being,  increasing  energy  security,  establishing  a  circular  economy, 
reinforcing EU’s leading role in climate diplomacy, creating green jobs, improving European 
economic  competitiveness  as  well  as  living  up  to  our  responsibility  towards  future 
generations and non-EU states and societies. The results are depicted in Figure 7.  

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I n = 819 (Responses to the general section of the questionnaire) 

Figure 7  Responses to Q4 of the questionnaire 

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General findings 

As  demonstrated  in  Figure  7,  from  the  selection,  the  top  three  benefits  associated  with  a 
more  ambitious  climate  goal  are  “It  will  ensure  that  we  do  our  part  in  protecting  the  planet 
and fulfilling our duty towards future generations.” (Individuals 334, 73%; Organisations 237, 
66%; Total, 571, 70%), “It will improve our well-being (by lowering pollution, improving health 
and creating more liveable cities) and help protect the planet’s ecosystems.” (Individuals 340, 
74%, Organisations 215, 60%; Total 555, 68%) and “It will improve energy security, reduce 
the EU’s dependency on imported fossil fuels and reduce exposure to volatility in fossil fuel 
prices.” (Individuals 309, 67%; Organisations 233, 65%; Total 542, 66%).  

Overall,  at  least  50%  of  the  total  819  respondents  choose  almost  all  selectable  possible 
benefits. The only two options that are selected by fewer than 50% of the respondents are “It 
will  improve  the  competitiveness  of  the  European  economy  and  give  EU  industry  a  first-
mover advantage on global markets.” (Individuals 195, 43%; Organisations 189, 53%; Total 
384,  47%)  and  “It  will  help  individuals  and  business  lower  their  energy  and  climate  bills.” 
(Individuals 157, 34%; Organisations 148, 41%; Total 305, 37%). 

When  comparing  individuals  and  organisations,  individuals  seem  more  focused  on  the 
positive  potentials  of  higher  climate  ambitions  regarding  positive  environmental  and  health 
effects. This is reflected in their most selected option being “It will improve our well-being (by 
lowering  pollution,  improving  health  and  creating  more  liveable  cities)  and  help  protect  the 
planet’s ecosystems.” (340, 74%). Conversely, organisations associate an ambitious climate 
goal  most  closely  with  a  change  towards  more  sustainable  economic  production  patterns 
reflected in their most common selection “It will give a clear signal that the EU economy will 
embrace sustainable production and consumption models (e.g. circular and sharing economy 
approach).”  (251,  70%).  Both  Individuals’  (157,  34%)  and  Organisations’  (148,  41%)  least 
common  selection  is  “It  will  help  individuals  and  businesses  lower  their  energy  and  climate 
bills.” 

Differences between stakeholder groups 

For  SMEs  associations/companies,  large  business  associations/companies  and  for  public 
authorities the  most  promising  potentials  are  all related  to  economic  factors,  such  as  green 
jobs  (59%,  57%  and  75%),  economic  signals  (58%,  73%  and  75%)  and  energy  security 
(56%, 59% and 81%). Additionally, these actors interpret the transition also as a potential to 
ensure that the EU can fulfil its duty towards future generations (53%, 61%, and 50%).  

Conversely,  civil  society  organisations  focus  on  social  aspects  as  the  benefits  of  an 
ambitious  climate  target,  such  as  the  mitigation  of  social  damages  to  societies  (89%),  the 
improvement  of  our  well-being  (89%)  and  the  fulfilment  of  our  duty  towards  future 
generations (87%).  

Academic/research  institutions  focus  most  on  the  EU’s  energy  security  (80%)  and  the 
reinforcement of EU leadership to combat climate change globally (80%). 

3.2.1.5. Q5:  Challenges  and  enabling  actions  for  the  EU  climate  ambition  to  2040 
and beyond 

For  question  Q5  the  respondents  are  asked  how  important,  from  a  scale  from  1  (very 
unimportant)  to  5  (very  important),  they  consider  different  challenges  and  associated 
enabling  factors  to  be  for  the  EU  to  reach  its  climate  ambition.  The  list  of  addressed 
challenges  and  factors  contains  a  faster  expansion  of  renewables  accompanied  by 
supporting  legislation,  ensuring  public  support  for  climate  ambition  supported  by  EU  policy, 
improvements  in  energy  efficiency  promoted  by  the  EU,  a  change  in  investment  flows  by 
aiding  green  financing,  avoiding  an  increase  in  energy  prices  for  vulnerable  households 
through  a  societal  just  transition,  supporting  small  and  medium  enterprises  through  the 

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transition, avoiding new resource dependencies by securing the supply, supporting research 
and innovation, monitoring the evolution of GHG emissions and climate impacts through EU 
space data, financing the capturing and storing of CO2 and overcoming lock-in effects due to 
old infrastructure by employing digital solutions on a large scale that reduce GHG emissions 
(for full description of challenges compare Figure 8).  

General findings 

Overall,  we  can  see  in  Figure  8  that  the  responses  indicate  that  all  challenges  and  related 
enabling  factors  are  relevant  to  the  stakeholders.  Among  these  the  most  prioritised 
challenges  and  associated  enabling  factors  for  the  EU  climate  ambition  are  avoiding  an 
increase  in  energy  prices  for  vulnerable  households  through  a  societal  just  transition 
(Average = 4.34, 52% rating 5), ensuring public support for climate ambition supported by EU 
policy (Average = 4.29, 56% rating 5) and improving energy efficiency (Average = 4.27, 56% 
rating 5).  

While  still  considered  important,  the  least  prioritised  challenges  and  associated  enabling 
factors for the EU climate ambition are financing the capturing and storing of CO2 (Average = 
3.52,  31%  rating  5),  by  employing  digital  solutions  to  reduce  GHG  emissions  (Average  = 
3.57, 23% rating 5) and furthering research and innovation (Average = 3.76, 37% rating 5). 

A  general  trend  which  can  be  observed  from  these  answers,  is  that  respondents  seem  to 
prioritize social challenges over more technical or industrial challenges, possibly due to these 
being  less  salient  to  the  public  than  others.  Furthermore,  broad  challenges  to  which  all 
respondents have a direct link to, like improving overall energy efficiency are more agreeable 
than more “narrow” factors like overcoming old infrastructure through digital solutions. 

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I n = 819 (Responses to the general section of the questionnaire) 

Figure 8  Responses to Q5 of the questionnaire 

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Differences between stakeholder groups 

Generally, EU citizens and organisations agree on the most and least important challenges 
to  the  EU  climate  ambition.  For  both  stakeholder  groups  the  most  prioritised  options  are 
aiding  vulnerable  households  with  energy  prices  and  boasting  public  support  for  climate 
action  through  adequate  policy  for  societal  change.  The  least  important  for  both  groups  is 
capturing CO2 from the atmosphere. 

In  contrast,  organisational  stakeholders  among  themselves  differ  in  their  opinions.  For  civil 
society  organisations,  the  most  prominent  challenges  are  further  improvements  in  energy 
efficiency  (Average  =  4.75,  74%  rating  5)  and  a  faster  expansion  of  renewable  energies 
(Average  =  4.72,  72%  rating  5).  The  least  prioritised  aspects  are  the  deployment  of  new 
technologies (Average = 3.16, 28% rating 5) and the role of carbon capture (Average = 3.53, 
28% rating 5). Academic/research institutions rate further improvements in energy efficiency 
(Average = 4.50, 55% rating 5) and a socially just transition (Average = 4.46, 45% rating 5) 
as the most important challenges. Support for SMEs (Average = 3.32, 15% rating 5) and the 
promotion and deployment of digital solutions (Average = 3.40, 10% rating 5) are rated the 
least important challenges. SMEs rate the deployment of new technologies (Average = 4.40, 
54% rating 5) and the risk of new dependencies (Average = 4.32, 46% rating 5) as the most 
prominent  challenges.  The  least  prominent  challenges  for  this  stakeholder  group  are  the 
deployment  of  digital  solutions  (Average  =  3.89,  30%  rating  5)  as  well  as  the  support  for 
SMEs (Average  =  3.89, 30% rating  5).  These  answers  suggest  that  SMEs  feel  prepared to 
reach EU’s climate ambition as they see governmental support as one of the least prominent 
aspects  in  this  context.  Large  business  associations/companies  depict  a  similar  response 
pattern  compared  to  the  SMEs.  The  two  most  important  challenges  are  public  support 
(Average  =  4.49,  48%  rating  5)  and  the  risk  of  new  dependencies  (Average  =  4.48,  57% 
rating 5). In contrast to other organisational stakeholder groups, large companies furthermore 
stress  the  importance  of  new  technologies  and  R&I  (Average  =  4.47).  In  contrast  to  other 
organisational  stakeholder  groups,  large  companies  furthermore  stress  the  importance  of 
new  technologies  and  R&I  (Average  =  4.47,  56%  rating  5).  The  least  important  challenges 
are  the  support  of  SMEs  (Average  =  3.79,  20%  rating  5)  and  Capturing  CO2  (Average  = 
3.92,  40%  rating  5).  For  public  authorities,  the  most  prominent  challenges  are  the  required 
shift of investment flows (Average = 4.47, 69% rating 5) and further improvement in energy 
efficiency  (Average  =  4.40,  63%  rating  5).  The  least  prominent  challenges  for  this 
stakeholder  group  are  the  support  of  SMEs  (Average  =  3.80,  31%  rating  5)  and  the 
deployment of digital solutions (Average = 3.87, 19% rating 5). 

3.2.1.6. Q6a: Gender aspects of climate policy (closed question) 

For question Q6 the respondents are asked how much they agree, from a scale from 1 (No, I 
totally disagree) to 5 (Yes, I totally agree) with the statement that gender aspects should be 
considered more in the transition to climate neutrality and in climate and related policies. 

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I n = 819 (Responses to the general section of the questionnaire) 

General findings 

Figure 9  Responses to Q6a of the questionnaire 

As  Figure  9  illustrates,  varying  perspectives  on  the  more  comprehensive  consideration  of 
gender aspects in the transition to climate neutrality can be observed. Individuals agree less 
that the inclusion of the gender perspectives in climate policy is important than organisations. 

While all response options get a relevant number of replies, the most common answers are 
polarised on the extremes of the scale. 22% (181) of all respondents indicate that they totally 
agree  with  a  greater  inclusion  of  gender  aspects  concerning  the  climate  transition  while  a 
similar  share  (19%,  162)  indicate  that  they  totally  disagree  with  the  EU  considering  gender 
aspects more. This illustrates a possible divide in the response to this question. This gulf is 
also represented in the comparison of the response patterns of individuals and organisations. 
While  individual’s  most  common  answer  is  that  they  totally  disagree  (129,  28%),  the  most 
common response by organisation is that they totally agree (102, 28%).  

Differences between stakeholder groups 

Looking at the mean scores of the 5-point scale for different stakeholders, EU citizens exhibit 
the lowest average with 2.78. Contrarily, civil society organisation have the highest average 
with  4.26.  Notably,  a  high  share  of  the  no  responses  was  provided  by  business 
associations/companies  (SMEs  and  large),  indicating  that  few  corporate  stakeholders  are 
willing to share their views on the role of gender aspects for climate policy. 

3.2.1.7. Q6b: Gender aspects of climate policy (open question) 

In  total,  237  valid  open-text  responses  were  submitted  to  Q6b.  Please  note  that  one 
response  can  be  included  in  multiple  themes.  Based  on  a  thematic  analysis  of  the  survey 

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responses  to Q6b  questions, the  most  preferred themes regarding  how  climate  and  related 
policies should better address gender aspects are:  

•  Gender  inequality  and  vulnerability  theme  was  mentioned  in  82  out  of  237 
responses,  35%*,  highlighting  the  importance  of  gender  equality  in  decision-making 
processes, promoting women's participation and representation in policy-making, and 
addressing gender-specific vulnerabilities to climate change.  

•  Gender impact assessments and policy integration theme appeared in 68 out of 
237  responses,  29%*,  suggesting  the  incorporation  of  gender  impact  assessments 
into  climate  policies  and  the  integration  of  gender  objectives  throughout  the  policy 
cycle, including governance, analysis, impact assessments, and monitoring.  

•  Education  and  training  theme  was  present  in  41  out  of  237  responses,  17%, 
emphasizing  the  significance  of  providing  education,  training,  and  empowerment 
opportunities for women, particularly in STEM fields and green jobs, to enhance their 
involvement in climate action.   

• 

Intersectionality  and  inequalities  theme  appeared  in  26  out  of  237  responses*, 
11%,  emphasizing  the  need  to  consider  the  intersectional  nature  of  climate  and 
gender issues, and address multiple forms of discrimination and inequalities such as 
race, disability, and socioeconomic factors in climate policies. 

I *Nine responses were identical or semi-identical. It was decided not to declare these responses as campaign due to the small 
number and they were included into the analyses. These responses are marked in the result. 

As  the  other  end  of  the  spectrum,  scepticism  and  disbelief  was  present  in  35  out  of  237 
responses,  representing  responses  that  express  scepticism  disbelief,  or  dismissal  of  the 
relevance of gender in climate policy and question the need for addressing gender aspects. 

Figure  10  illustrates  the  survey  responses  to  the  Q6b  question,  displaying  the  total 
stakeholder  responses  (237)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

Figure 10 Number of responses to Q6b grouped by identified themes and stakeholder groups 

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3.2.2. Contribution of individual sectors to the EU’s climate ambition 

After  exploring  the  respondents’  overall  opinion  on  the  EU’s  climate  ambition  for  2040,  this 
section  investigates  stakeholders’  views  on  the  contribution  of  specific  sectors  to  the 
EU’s  climate  ambition.  First,  it  is  analysed  which  sector  should  do  more  to  reduce  GHG 
emissions. Subsequently, participants are requested to rank different sectors in terms of their 
expectations for achieving climate neutrality first. Lastly, the different stakeholders are asked 
to evaluate their capacity to innovate and access financing of the sector or company they are 
working in.  

3.2.2.1. Q7: Which sector should do more to reduce GHG emissions? 

In question Q7 the respondents are asked which economic sector should do more to reduce 
GHG emissions. The participants give a response on a scale from 1 (can reduce little more) 
to 5 (can reduce a lot more) regarding the extent to which the six sectors have the potential 
to reduce their GHG emissions.  

I n = 819 (Responses to the general section of the questionnaire) 

General findings 

Figure 11 Responses to Q7 of the questionnaire 

Looking at Figure 11, the responses regarding the level of ambition in specific sectors of the 
economy are in line with the call for an overall more ambitious 2040 climate target (see Q1). 
Across all sectors, at least 40% of the respondents give a rating of 5, meaning that a sector 
“can reduce a lot more". 

Of the six sectors, the three that respondents deemed should do much more, were “Aviation 
& maritime transport” (Average = 4.42, 57% rating 5), “Road transport (passenger and freight 

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transport)”  (Average  =  4.39,  59%  rating  5)  and  “Industrial  processes  &  waste”  (Average  = 
4.25,  48%  rating  5).  The  lower  half  of  the  list  includes  “Agriculture,  forestry  and  other  land 
use” (Average = 3.96, 40% rating 5), “Buildings (residential and services)” (Average = 4.14, 
45% rating 5) and “Production of electricity and district heating” (Average = 4.18, 51% rating 
5). 

Differences between stakeholder groups 

For EU citizens the most prioritised sector is “Aviation & maritime transport” (Average = 4.40, 
65%  rating  5)  while  the  least  prioritised  sector  is  “Agriculture,  forestry  and  other  land  use” 
(Average  =  3.81,  41%  rating  5;  civil  society  organisations:  Average  =  4.59,  68%  rating  5). 
Conversely,  civil  society  organisations  deem  the  sector  “Road  transport  (passenger  and 
freight  transport)“  to  be  the  most  important  for  reductions  (Average  =  4.75,  70%  rating  5), 
while also seeing “Agriculture, forestry and other land use” to be the least prioritised among 
the  economic  sectors  (Average  =  4.59,  68%  rating  5).  Hereby,  civil  society  organisations 
seem  to  conclude  that  all  sectors  can  significantly  reduce  GHG  emissions,  reflected  in  all 
average  ratings  being  higher than  4.  The  same accounts  for  academic/research  institutions 
which also indicate high average values for all sectors, from “Road transport (passenger and 
freight  transport)”  (Average  =  4.78,  75%  rating  5)  to  “Buildings  (residential  and  services)” 
(Average = 4.28, 50% rating 5).  

The  group  of  SMEs  selects  “Road  transport  (passenger  and  freight  transport)”  (Average  = 
4.47, 48% rating 5) as the sector that should do the most and the sector “Agriculture, forestry 
and  other  land  use”  (Average  =  3.72,  23%  rating  5)  that  should  do  the  least  to  cut  GHG 
emissions.  Large  business  associations/companies  indicate  that  the  sector  “Road  transport 
(passenger and freight transport)” should do the most to reduce emissions (Average = 4.55, 
48% rating 5) and that the sector “Industrial processes & waste” (Average = 3.92, 29% rating 
5)  should  do  the  least.  Lastly,  public  authorities  believe  that  the  sector  “Production  of 
electricity  and  district  heating”  (Average  =  4.87,  81%  rating  5)  should  mostly  enhance  their 
efforts  to  cut  GHG  emission,  whereas  the  sector  “Agriculture,  forestry  and  other  land  use” 
(Average = 3.53, 31% rating 5) should do this the least.  

According  to  these  responses  there  exists  an  overall  agreement  that  all  sectors  should 
accelerate  their  transition  towards  climate  neutrality.  Nevertheless,  there  are  stakeholder-
specific differences concerning the prioritisation of sectors. 

3.2.2.2. Q8: Sectors expected to reach climate neutrality first 

In  Q8  the  respondents  are  asked  what  economic  sectors  they  expect  to  reach  climate 
neutrality first in the coming decades. They rank the different sectors in the order they expect 
them to achieve climate neutrality from 1 (first to reach climate neutrality) to 6 (last to reach 
climate  neutrality).  Unlike  the  other  questions,  the  analysis  of  Q8  is  distinct  because  the 
ranking of one sector influences the ranking of other sectors. This is because only one sector 
can  be  chosen  for  each  rank,  resulting  in  sector-rank  combinations  being  displayed  in  the 
analysis. 

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I n = 678 (Responses that provided a ranking. Observations that did not provide a ranking are not included here.) 

Figure 12 Responses to Q8 of the questionnaire 

As  can  be  seen  in  Figure  12,  respondents  most  frequently  choose  the  "Production  of 
electricity and district heating" sector as the first to achieve climate neutrality, with 54% of the 
respondents (9% of sector-rank combinations) ranking it as their first choice. Conversely, the 
"Aviation & maritime transport" sector is most selected as the last to attain climate neutrality, 
with 48% of the respondents (8% of sector-rank combinations) ranking it sixth. Additionally, 
there  is  a  descending  (ascending)  pattern  for  the  remaining  Ranks  assigned  to  the  sector 
"Production of electricity and district heating" ("Aviation & maritime transport"), which further 
supports the ranking of the sector. 

A more balanced pattern can be observed for the other four sectors. Interestingly, by giving 
the  two  decentralised  sectors  "Road  transport  (passenger  and  freight  transport)"  and 
"Buildings (residential and services)" a lower ranking than to the sector "Industrial processes 
&  waste",  the  respondents  indicate  that  they  expect  these  sectors  to  achieve  climate 
neutrality sooner. 

For the sector "Agriculture, forestry, and other land use", 16% of the respondents (3% of the 
sector-rank combinations), believe that it is the first sector to achieve climate neutrality. But 
for  the  other  ranks  an  ascending  pattern  is  observed  with  23%  (4%  of  the  sector-rank 
combinations) believing that this sector will achieve climate neutrality last. This divergence in 
the responses may be due to differing expectations about the extent of nature-based carbon 
removal and/or the ability to reduce agricultural emissions in the coming decades. 

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3.2.2.3. Q9: Capacity to innovate 

For  this  question  Q9,  respondents  assess  the  existing  capacity  to  innovate  and  access 
financing of the sector or company they are working in. They gauge whether they agree with 
these  three  statements,  from  a  scale  from  1  (very  unimportant)  to  5  (very  important):  that 
their  sector  or  company  has  the  capacity  to  carry  out  the  necessary  innovation  for  the 
transition  to  a  net-zero  emission  economy,  that  their  sector  or  company  has  access  to  risk 
capital and financing and that their sector or company has access to EU dedicated facilities 
for the green transition. 

I n = 819 (Responses to the general section of the questionnaire) 

General findings 

Figure 13 Responses to Q9 of the questionnaire 

First,  it  should  be  noted  that  Question  9  can  be  interpreted  differently  by  the  varying 
stakeholder  groups.  While  the  question  is  most  directly  relatable  for  the  two  stakeholder 
groups  business  associations/companies  (SMEs)  and  business  associations/companies 
(large),  other  stakeholder  groups,  such  as  EU  citizens,  may  relate  this  question  to  their 
individual  working  environment.  For  other  stakeholder  groups,  such  as  civil  society 
organizations,  the  link  to  their  sectoral  work  environment  may  be  less  clear.  This  divergent 
understanding  is  presumably  responsible  for  the  relatively  high  shares  of  “I  don't  know/No 
response” answers observable in Figure 13. 

However, when excluding the “I don't know/No response” answers, most respondents believe 
that  their  sector  or  company  has  the  capacity  to  carry  out  the  necessary  innovations  to 
manage  the  transition  to  a  net-zero  economy  (Average  =  3.71,  26%  rating  5).  Far  fewer 
respondents  consider  their  sector  or  company  to  have  access  to  risk  capital  and  financing 
(Average = 2.76, 11% rating 5) and that their sector or company has access to EU facilities 
(Average = 2.58, 7% rating 5). 

Differences between stakeholder groups 

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The stakeholder groups for which the question is most salient and therefore whose answers 
are  the  most  meaningful  are  business  associations/companies  from  both  SMEs  and  large 
companies.  Such  types  of  respondents  are  both  highly  optimistic  about  their  sectoral  and 
company  capacity  to  carry  out  the  innovation  needed  for  a  transition  to  net  zero  (SMEs: 
Average  of  4.2,  37%  rating  5;  Large:  Average  of  4.14,  35%  rating  5).  For  the  other  two 
question 
the  group  of 
companies/business  associations  (large)  show  a  slightly  higher  level  of  agreeing  than  their 
counterparts from the group of SMEs. 

the  access 

respondents 

items  on 

financing, 

from 

to 

For  the  question  item  on  access  to  risk  capital  and  financing,  large  firms  respond  with  an 
average  of  3.11,  with  the  largest  proportion  of  respondents  answering  with  the  neutral 
response option in the middle of the 5-point scale (45, 36%). Among SMEs, the average is 
2.9,  with the  majority  of responses  again  coming  from  the midpoint  of  the  scale  (33,  34%). 
Among  SMEs,  the  number  of  those  who  choose  the  answer  option  "I  don't  know/No 
response" is significantly higher (SMEs: 30, 31% vs. Large: 20, 16%). 

When  asked  about  access  to  EU-specific  financial  facilities,  the  average  is  2.63  for  large 
companies and business associations, which primarily represent large companies, and only 
2.49  for  their  SME  counterparts. Given  the  need  for  private  investment to  facilitate  the  net-
zero  transition,  the  results  for  business/industry  stakeholders  may  suggest  that  sufficient 
access  to  private  risk  finance  and  public  support  facilities  remains  a  challenge  for  some 
sectors. 

3.2.3. My personal contribution to protect the climate 

This  sub-section  of  the  general  section  aims  to  explore  the  individual  willingness  of 
respondents  to  contribute  to  climate  protection.  First,  the  respondents  are  asked  how 
aware  they  and  society  are  to  the  impacts  of  climate  change.  Then,  the  next  question 
investigates what people expect as being the most relevant changes to peoples’ daily lives. 
The other two questions ask for the willingness to act on a personal level and what incentives 
would most benefit climate action. 

3.2.3.1. Q10: Awareness of climate change impact and climate 

For Q10, respondents were asked how aware they were with regards to the effects of climate 
change,  and  their  views  on  society’s  awareness  of  the  realities  of  climate  change  and  its 
impact. They were asked to indicate whether they agreed on a scale from 1 (totally disagree) 
to  5  (totally  agree)  with  different  statements  referring  to  awareness  and  actions  at  an 
individual  level,  as  well  as  individuals’  views  on  society’s  awareness  and  readiness  in 
meeting challenges of climate change. Given that responses to this question relate to actions 
and  opinions  at  the  individual  level,  and  therefore  only  general  comments  can  be  made 
regarding the views and opinions of organisations. This is reflected in Figure 14, at least half 
of  responses  from  Organisations  were  “I  don’t  know/No  response”  across  the  statement 
categories. 

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I n = 819 (Responses to the general section of the questionnaire) 

* Some question items were shortened for better readability. This applies in particular to the examples given in a question item. 
See Appendix A for the full text of the question items. 

Figure 14 Responses to Q10 of the questionnaire 

As depicted in Figure 14, the majority of responses indicate that they are aware of the reality 
of climate change and its expected impacts (363 individuals, 79% rating 5) (Avg. = 4.66 of all 
respondents).  The  second  most  preferred  option  for  Individuals  is  being  ready  to  change 
their behaviour to reduce their carbon footprint (e.g., by using sustainable transport; using or 
producing  renewable  energy;  reducing  consumption,  reusing,  and  recycling  products; 
consuming  foods  with  a  lower  climate  impact;  etc.)  (312  individuals,  68%  rating  5)  (Avg.  = 
4.36  of  all  respondents).  Contrarily,  only  a  low  number  of  individuals  assumed  that  these 
actions  also  apply  on  the  societal  scale:  Society  feels  the  need  to  manage  and  adapt  to 
climate change (38 individuals, 8% rating 5) (Avg. = 2.83 of all respondents), society is aware 
of the reality of climate change (36 individuals, 8% rating 5) (Avg. = 2.70 of all respondents), 

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and  society  is  ready  to  implement  actions  (18  individuals,  4%  rating  5)  (Avg.  =  2.50  of  all 
respondents). 

Even though respondents that represent an organisation do not offer a clear perspective on 
whether  their  answers  reflect  their  personal  views  or  those  of  their  organisations,  most  of 
them chose preferred to say they are aware of the reality of climate change and its expected 
impacts (159, 44% rating 5). 

3.2.3.2. Q11a:  Most  important  changes  expected  for  peoples’  daily  lives  (closed 
question) 

Question  11a  gathers  individual  responses  on  where  they  expect  to  see  the  greatest 
changes happening in their daily life. Respondents were able to pick from multiple answers 
across seven categories including, “My current job”, “Transport used for long-distance trips”, 
“Food  (including  food  waste)”,  “Education  and  skills  needed  for  future  jobs”,  “Housing  (e.g. 
energy  consumption  in  buildings,  living  space)”,  “Consumer  goods  and  services  (including 
reduce, reuse, repair & recycle), “Transport used for short-distance trips”. The responses to 
this  question  relate  to  actions  and  opinions  at  the  individual  level,  hence  the  focus  on 
individuals over organisations. 

I n = 819 (Responses to the general section of the questionnaire) 

Figure 15 Responses to Q11a of the questionnaire 

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Most respondents (315; 69%) indicated that they expected the greatest changes to happen 
in how they consumed goods and services (e.g., reduce, reuse and recycle).  

Housing (e.g., energy consumption in buildings, living space) was the second most selected 
option  by  individuals  (209;63%)  for  greatest  change  in  daily  life.  Considerably  fewer 
responses  (52;  11%)  referred  to  challenges  associated  with  changes  that  would  reflect  in 
their  current  jobs.  Even  though  respondents  that  represent  an  organisation  do  not  offer  a 
clear  perspective  on  whether  their  answers  reflect  their  personal  views  or  those  of  their 
organisations,  most  of  them  chose  housing  (e.g.,  energy  consumption  in  buildings)  (133; 
37%) to be the area of potential greatest change.  

3.2.3.3. Q11b:  Most  important  changes  expected  for  peoples’  daily  lives  (open 
question) 

In  total,  212  valid  open-text  responses  were  submitted  to  Q11b,  23  responses  were 
segregated  from  the  analysis  as  they  were  identified  as  a  campaign.  193  responses  were 
included in the analysis. Please note that one response can be included in multiple themes. 
Based  on  a  thematic  analysis  of  the  survey  responses  to  Q11b  questions,  the  themes 
identified most often by respondents regarding what changes expected in their daily life due 
to the efforts to reach climate neutrality are:  

•  Changes  in  consumption  and  lifestyle  theme  was  present  in  41  out  of  193 
responses*,  21%.  This  theme  includes  reducing  energy  and  demand,  controlling 
unsustainable  products,  and  promoting  reduction 
to 
deforestation.  It  also  involves  promoting  sustainable  diets,  car-sharing,  and  remote 
work. Waste reduction, reuse, and repair were also mentioned.  

in  consumption 

linked 

•  Transitioning from fossil fuels theme was mentioned in 20 out of 193 responses*, 
10%. This theme encompasses the challenge of transitioning regions that heavily rely 
on  fossil  fuels  to  more  sustainable  and  renewable  energy  sources.  Respondents 
mentioned issues with energy shortages and potential failure of renewables such as 
wind and solar energy.  

•  Land  use  changes  and  water  management  theme  appeared  in  18  out  of  193 
responses*,  9%.  Responses  mentioned  land  use  changes  such  as  rewetting 
landscapes and the management of water resources. These changes are expected to 
contribute to carbon sequestration and enhance resilience to climate change impacts.  

•  Social  and  economic  impacts  theme  was  mentioned  in  14  out  of  193  responses, 
7%.  This  theme  encompasses  various  aspects  such  as  social  tensions,  wealth 
disparity,  poverty,  loss  of  purchasing  power,  social  unrest,  and  economic  impacts 
resulting from climate change mitigation and adaptation measures. 

I *Five responses were identical or semi-identical. It was decided not to declare these responses as campaign due to the small 
number and they were included into the analyses. These responses are marked in the result. 

Figure  16  illustrates  the  survey  responses  to  the  Q11b  question,  displaying  the  total 
stakeholder  responses  (193)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

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Figure 16 Number of responses to Q11b grouped by identified themes and stakeholder groups 

3.2.3.4. Q12: Willingness for action at individual level 

For question Q12, respondents were asked which personal actions they would be willing to 
take to fight climate change. Answers ranged from 1 (No, I would not be willing to do this), 2 
(I am not sure whether I would do it or not), and 3 (Yes, I would be willing to do this).  The list 
of  actions ranged  from  reducing  wasteful  consumption,  have  goods  repaired  or  reuse them 
rather than buying new ones, eat food with a lower climate impact, such as plant based, local 
or sustainably produced food, to compensating some of their emissions through reliable and 
certified carbon-offsetting programmes.  

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I n = 819 (Responses to the general section of the questionnaire) 

Figure 17 Responses to Q12 of the questionnaire 

Overall,  the  responses  to  Q12  relate  to  actions  and  opinions  at  the  individual  level,  hence 
focusing on individual respondents is of high importance. 

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Most  individual  respondents  indicated that  they are  willing  to  reduce  wasteful  consumption, 
through  buying  and  using  long-lasting  appliances,  clothes,  and  other  products  (Individuals: 
409, 89%; Total: 540, 66). Closely behind the first option, individuals report a willingness to 
have  goods  repaired  or  reuse  them,  rather  than  buying  new  ones  (Individuals:  404,  88%; 
Total:  536,  65%).  Considerably  fewer  Individuals  are  willing  to  compensate  some  of  their 
emissions via reliable and certified carbon-offsetting programmes. Fewer individuals reported 
that  investing  in  energy  measures  for  my  building  that  reduce  its  emissions  (solar  panels, 
thermal  insulation,  heat  pumps),  and  improving  the  energy  performance  of  my  building 
(insulation,  triple  glazing,  more  efficient  heating,  etc.)  was  not  applicable  to  their  case 
(Individuals: 184, 40%; Total: 238, 29%).  

Even though respondents that represent an organisation do not offer a clear perspective on 
whether their answers reflect their personal views or those of their organisations, the majority 
of  them  chose  that  they  would  be  willing  (133,  37%)  to  use  alternatives  to  the  car  for 
everyday  journeys  (e.g.  walking,  cycling,  public  transport),  or  reduce  trips  (e.g.  by  working 
from home), to have goods repaired or reuse them, rather than buying new ones (132, 37%) 
and to reduce wasteful consumption (131, 36%).  

3.2.3.5. Q13a: How to improve incentives for climate action (closed question) 

For  Q13a  respondents  were  asked  which  proposals  would  help  to  reduce  their  personal 
climate  footprint.  They  rank  the  different  proposals  from  1  (not  helpful)  to  5  (very  helpful). 
Respondents could also rank the proposals by answering “I don’t know” and “No response”.  

The  list  of  proposals  ranged  from  ensuring  the  price  of  goods  and  services  reflects  their 
impact on climate-change making climate-friendly products with a lower climate impact more 
attractive,  to  providing  better  information  on  how  to  invest  in  solutions  that  will  help  people 
reduce  their  GHG  emissions  or  increase  carbon  removals  notably  from  buildings,  food 
consumption  or  transport.  Similarly  to  Q10,  as  depicted  in  Figure  18  at  least  half  of  the 
organisations did not provide a response across the statement categories, or they indicated 
that  they  did  not  know  which  proposal  would  help  them  reduce  their  personal  climate 
footprint.  

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I n = 819 (Responses to the general section of the questionnaire) 

* Some question items were shortened for better readability. This applies in particular to the examples given in a question item. 
See Appendix A for the full text of the question items. 

Figure 18 Responses to Q13a of the questionnaire 

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Most  individual  respondents  believe  that  ensuring  that  the  price  of  goods  and  services 
reflects their impact on climate change thus making climate-friendly products more attractive 
would be very helpful (342 individuals, 75% rating 5) (Avg. = 4.45 of all respondents). Other 
items that are rated as helpful included easing the financing of investments in solutions that 
lead to reductions in personal GHG emissions (279 individuals 61% rating 5) (Avg. = 4.35 of 
all  respondents)  and  creating  access  for  the  most  vulnerable  in  society  to  have  access  to 
sustainable  and  climate-friendly  goods  and services (273  individuals,  59% rating  5) (Avg. = 
4.25  of  all  respondents).  Aspects that  were  perceived  as  less,  but  still,  helpful  included  the 
proposals  to  provide  better  information  on  how  to  invest  in  solutions  that  will  help  people 
reduce  their  GHG  emissions  or  increase  carbon  removals,  notably  from  buildings,  food 
consumption or transport (187 individuals, 40% rating 5) (Avg. = 3.91 of all respondents) and 
to support sharing and leasing services to facilitate the access to technologies that reduce an  
individual’s  net  GHG  emissions  (e.g.  heat  pump,  photovoltaic  panels  or  electric  vehicles) 
(207 individuals, 45% rating 5) (Avg. = 3.93).  

Even though respondents that represent an organisation do not offer a clear perspective on 
whether  their  answers  reflect  their  personal  views  or  those  of  their  organisations,  most  of 
them  choose  that  proposals  that  ease  finance  of  investment  in  solutions  that  would  lead  to 
personal GHG reductions in homes, were very helpful (123, 34%).  

3.2.3.6. Q13b: How to improve incentives for climate action (open question) 

In  total,  157  valid  open-text  responses  were  submitted  to  Q13b.  Please  note  that  one 
response  can  be  included  in  multiple  themes.  Based  on  a  thematic  analysis  of  the  survey 
responses  to  Q13b  questions,  the  top  4  identified  themes  regarding  what  proposals  would 
help to reduce personal climate footprint are:  

•  Fossil fuel subsidies and consumption reduction theme was mentioned in 36 out 
of  157  responses*,  23%.  This  theme  focuses  on  the  need  to  eliminate  fossil  fuel 
subsidies  and  adopt  measures  to  support  the  reduction  of  consumption.  It 
emphasizes  the  importance  of  phasing  out  environmentally  harmful  subsidies  and 
decreasing reliance on fossil fuels.  

•  Public transportation and mobility theme was present in 25 out of 157 responses, 
16%.  This  theme  focuses  on  improving  public  transport  provision  and  expanding 
public transportation networks. It emphasizes the promotion of climate-friendly public 
transport options and the reduction of reliance on cars through the encouragement of 
active  mobility,  aiming 
in 
to  enhance  accessibility  and 
transportation.  

reduce  emissions 

•  Carbon pricing and taxes theme was mentioned in 25 out of 157 responses, 16%. 
This theme emphasizes the need for implementation of carbon pricing mechanisms, 
such as carbon taxes, to incentivize emission reductions. It also suggests the levying 
of  taxes  on  various  environmentally  harmful  products  and  the  use  of  economic 
incentives  and  regulation  to  drive  behaviour  change  towards  more  sustainable 
practices.  

•  Sustainable  agriculture  and  dietary  choices  theme  appeared  in  12  out  of  157 
responses,  8%.  This  theme  highlights  the  importance  of  promoting  sustainable 
agricultural  practices  and  supporting  plant-based  diets.  It  emphasizes  the  need  to 
make  vegan  and  plant-based  foods  more  affordable,  reduce  the  carbon  footprint  of 
agricultural products, and conserve biodiversity in agriculture. 

I  * Nine responses were identical or semi-identical. It was decided not to declare these responses as campaign due to the small 
number and they were included into the analyses. These responses are marked in the result. 

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Figure  19  illustrates  the  survey  responses  to  the  Q13b  question,  displaying  the  total 
stakeholder  responses  (157)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

Figure 19 Number of responses to Q13b grouped by identified themes and stakeholder groups 

3.2.4. The impacts of the climate crisis 

This sub-section of the general section of the public consultation explores the expectations 
of  the  respondents  regarding  the  impacts  of  the  climate  crisis.  First,  focus  is  on  the 
possible effects of climate change for individuals. Consequently, people are asked about the 
possible  effects  of  climate  change  at the  place they  live  and  for society as  a  whole.  Lastly, 
the respondents are asked about their level of agreement on statements regarding the need 
to adapt to climate change. 

3.2.4.1. Q14a: Possible effects of climate change for individuals (closed question) 

“Loss of biodiversity and natural habitats” is of the biggest concern for 506 answers (62% of 
all). This is the case both to individuals (355; 77%) and organisations as a whole (151; 42%). 
It is also of very high concern to academics (13; 65%) and CSO (65; 71%) and not so high to 
business associations of large companies (26; 21%) and business associations of SMEs (31; 
32%). 

It  is  closely  followed  by  “Damage  from  natural  hazards”  which  is  of  high  concern  both  to 
individuals  (327;  71%)  and  organisations  (151;  42%).  It  is  also  of  very  high  concern  to 
academics (11; 55%) and CSO (65; 71%) and not so high to business associations of large 
companies (26; 21%) and business associations of SMEs (32; 33%). 

“Loss of job or income due to changes in the sector where I work” is of little concern both to 
individuals  (52;  11%)  and  to  organisations  as  a  whole  (45;  13%).  A  higher  share  of  CSOs 
(24; 26%) single this out as a concern.  

“Increasing material losses to my property” is of little concern too: individuals (63; 14%) and 
organisations (50; 14%). A higher share of CSOs (30; 33%) single this out as a concern.  

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I n = 819 (Responses to the general section of the questionnaire) 

Figure 20 Responses to Q14a of the questionnaire 

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3.2.4.2. Q14b: Possible effects of climate change for individuals (open question) 

In  total,  152  valid  open-text  responses  were  submitted  to  Q14b.  Please  note  that  one 
response  can  be  included  in  multiple  themes.  Based  on  a  thematic  analysis  of  the  survey 
responses  to  Q14b  questions,  the  top  4  identified  themes  regarding  what  effect  of  climate 
change people most concerned about:  

•  Climate  refugees  and  migration  theme  was  present  in  28  out  of  152  responses, 
18%.  Many  respondents  expressed  concerns  about  migration  and  the  displacement 
of people due to climate change. They highlighted the potential for forced migration, 
large-scale  population movements,  and  the  emergence  of  climate  refugees  who  are 
forced  to  leave  regions  made  uninhabitable  by  climate  change  impacts.  The  fear  of 
migration  waves,  conflicts  over  resources,  and  the  limited  capacity  of  countries  to 
accommodate refugees were common themes.  

•  Social  and  political  conflicts  theme  was  mentioned  in  24  out  of  152  responses, 
16%.  Social  and  political  conflicts  arising  from  climate  change  were  major  concerns 
among respondents. They mentioned the possibility of social unrest, polarization, and 
division  within  societies.  The  fear  of  social  tipping  points,  conflicts,  and  wars  over 
resources  such  as  water  was  prevalent.  Many  respondents  also  highlighted  the 
potential  destabilization  of  democracies  and 
the  rise  of  non-democratic  or 
authoritarian regimes.  

•  Health  impact  theme  appeared  in  22  out  of  152  responses*,  15%.  The  impact  of 
climate  change  on  health  was  a  significant  concern  for  respondents.  They 
emphasized  the  sub-lethal  effects  of  heat,  humidity,  air  pollution,  and  other  climate-
related  factors  on  human  health.  Mental  health  issues,  such  as  climate  anxiety  and 
depression,  were  frequently  mentioned.  Concerns  about  respiratory  and  heart 
diseases,  as  well  as  health  inequalities  resulting  from  climate  change,  were  also 
expressed.  

•  Economic impact theme was mentioned in 10 out of 152 responses, 7%. Economic 
consequences resulting from climate change were a concern for many respondents. 
They mentioned  the  potential  for financial  disasters,  increased  living  costs,  and  loss 
of  livelihoods.  Economic  slowdowns  and  higher  prices  were  also  mentioned. 
Inequality,  both  within  and  between  countries,  was  a  common  theme,  with 
respondents  expressing  worries  about  the  unequal  distribution  of  climate  change 
impacts and the exacerbation of economic inequalities. 

I  *Five responses were identical or semi-identical. It was decided not to declare these responses as campaign due to the small 
number and they were included into the analyses. These responses are marked in the result. 

Figure  21  illustrates  the  survey  responses  to  the  Q14b  question,  displaying  the  total 
stakeholder  responses  (152)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

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 Figure 21 

Number of responses to Q14b grouped by identified themes and stakeholder groups 

3.2.4.3. Q15: Possible natural hazards caused by climate change at the place where 
you live  

Individuals indicate the highest level of fear regarding heatwaves (322; 70%), droughts (310; 
68%) and lack of water (306; 67%). This group is followed by floods and intense rain (223; 
49%); and wildfires (191; 42%). 

As an average, organisations fear the same hazards - heatwaves (142; 39%), droughts (139; 
39%) and lack of water (127; 35%), as well as floods and intense rain (141; 39%). 

From the point of view of public authorities, floods and intense rain is the most feared hazard 
(11;  69%)  followed  by  droughts  (9;  56%),  heatwaves  (8;  50%),  lack  of  water  (8;  50%)  and 
wildfires  (56;  38%).  Rising  sea  levels  and  windstorms  are  the  lowest  concern  to  public 
authorities (2; 13%). 

Academics fear droughts and heatwaves the most (12; 60%) followed by floods and intense 
rain (10; 50%) and lack of water (9; 45%). Rising sea levels (3; 15%), windstorms (5; 25%) 
and wildfires (6; 30%) are feared the least by academics. 

Business  associations  of  SMEs  rank  floods  and  intense  rain  first  (31;  32%);  followed  by 
droughts and heatwaves (27; 28%). Windstorms are of the least concern for SMEs (11; 11%) 
together with rising sea levels (16; 17%). Business associations of large companies prioritise 
lack of water (29; 23%) in addition to floods and intense rain (31; 25%), droughts (25; 20%) 
and heatwaves (28; 22%). 

Civil society organisations (CSO) are concerned to a high extent by most hazards whereby 
heatwaves (62;  67%),  droughts (59;  64%),  lack of  water (55;  60%);  floods  and  intense rain 
(54; 59%), and wildfires (52; 57%)are ranked closely. 

Rising sea levels and windstorms are feared the least both by individuals (97; 21% and 78; 
34%) and organisations (78; 22% and 79; 22%). 

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 I n = 819 (Responses to the general section of the questionnaire) 

3.2.4.4. Q16: Possible effects of climate change for society 

Figure 22 Responses to Q15 of the questionnaire 

Individuals  identify  three  main  impacts  for  their  countries:  natural  disasters  (338;  74%), 
negative impacts on food production (315; 69%) and migration or refugee movements (307; 
67%)  while  three  others  are  of  similar,  slightly  lower  importance:  negative  impact  through 
increasing water availability (280; 61%); increasing inequalities due to climate hazards (275; 
60%) and negative impacts on health (275; 60%). 

Negative impacts on energy supply (127; 28%) and negative impacts on critical infrastructure 
(146; 32%) are of lowest importance to individuals as potential impacts of climate change. 

On average, organisations single out natural disasters as the main impact (167; 46%) while 
all others have been selected by between 27% and 37% of the responding organisations.  

According  to  public  authorities,  natural  disasters  (11;  69%)  and  negative  impact  on  health 
(11;  69%)  have  the  highest  negative  impacts  followed  by  negative  impacts  through 
decreasing  water  availability  (9;  56%)  and  negative  impacts  on  food  production  (8;  50%). 
Loss of lives (25%), negative impacts on the economy and employment (4; 25%) and more 
conflicts between countries due to declining water cycles and less resources (4; 25%). 

Business associations of SMEs single out negative impact on energy supply as the highest 
impact (34; 35%) followed by natural disasters (31; 32%). Loss of lives is of the least concern 
(13, 13%). Business associations of large companies identify natural disasters as the highest 
concern  (38;  30%)  while  loss  of  lives  (14;  11%),  negative  impact  on  the  economy  and 

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employment (14; 11%) and migration or refugee movement due to climate change (15; 12%) 
are of the least concern. 

Almost  all  of  the  negative  impacts  are  of  high  concern  to  CSOs  (between  50;  50%  and  68; 
74%).  

I n = 819 (Responses to the general section of the questionnaire) 

Figure 23 Responses to Q16 of the questionnaire 

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3.2.4.5. Q17: Adapting to climate change where you live 

It has to be noted that on average more than half of the organisations either do not know or 
have  not  responded  to  all  statements  (at  least  203  respondents  per  item  in  the  group  of 
organisations) hence the opinions of those who responded are skewed. The share of these 
organisations  is  the  highest  for  associations  of  large  companies  (around  80%,  100 
respondents  in  the  group  of  large  business  associations/companies)  and  the  lowest  –  for 
public authorities (20-30%, 4 to 5 respondents in the group of public authorities). 

79% of the individuals (strongly) agree (4 and 5) that local or national authorities should do 
more  to  prepare  the  city  and  region  to  climate  change  (363  individuals,  Avg.  =  4.33  of  all 
respondents). 36% of organisations (strongly) agree with that statement (129 respondents), 
but the percentage is relatively high for academics (10, 50%) and CSOs (60, 65%).  

64% of the individuals (strongly) agree (4 and 5) that they would be ready to invest to make 
their  building  more  resilient  to  climate  change  (294  individuals,  Avg.  =  3.98  of  all 
respondents).  Only  28%  of  organisations  (strongly)  agree  with  that  (102  respondents), 
although the percentage is relatively high for academics (9, 45%) and CSOs (46, 50%). 

43%  of  the  individuals  (strongly)  agree  (4  and  5)  that  we  need  more  climate  adaptation 
policies  that  take  gender  differentiated  needs  and  the  needs  of  disadvantages  age  groups 
into  consideration  (199  individuals,  Avg.  =  3.39  of  all  respondents).  Only  26%  of 
organisations  (strongly)  agree  with  that  (91  respondents),  but  the  percentage  is  relatively 
high for CSOs (49, 54%).  

75%  of  individuals  (strongly)  disagree  (1  and  2)  that  plans  to  prepare  for  inevitable  climate 
change  events  have  been  sufficiently  prepared  (346  individuals,  Avg.  =  1.71  of  all 
respondents).  At  the  same  time,  38%  of  public  authorities  agree  with  the  statement  (6 
respondents). The share of those who agree is very low for other types of organisations. 

69%  of  individuals  (strongly)  disagree  (1  and  2)  that  concrete  actions  to  improve  climate 
resilience  in  their  place  of  residence  have  been  carried  out  and  judge  them  sufficient  (316 
individuals,  Avg.  =  1.80  of  all  respondents).  At  the  same  time,  19%  of  public  authorities 
agree  with  the  statement  (3  respondents).  The  share  of  those  who  agree  with  this  view  is 
very low for other types of organisations. 

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I n = 819 (Responses to the general section of the questionnaire) 

Figure 24 Responses to Q17 of the questionnaire 

46 

  
 
 
 
 
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3.3.  Expert section 

3.3.1. General policy framework 

The first part of the expert section is focused on aspects regarding the EU’s general policy 
framework,  including  the  scope  and  role  of  the  carbon  pricing  instruments,  the  Carbon 
Border Adjustment Mechanism (CBAM) and the Effort Sharing Regulation (ESR) as well 
as  its  links  with  the  ETS.  In  addition  to  the  European  Climate  Law,  the  public  consultation 
highlights  the  EU’s  current  policy  instruments, the  EU  Emission  Trading System  (ETS),  the 
Effort  Sharing  Regulation  (ESR)  and  the  LULUCF  Regulation  (land  use,  land  use  change 
and forestry), before providing the questions. 

3.3.1.1. Q18: Scope and role of EU-wide carbon pricing instruments 

For  Question  Q18,  stakeholders  are  asked  to  state  their  opinion  on  how  the  emissions 
trading in the EU could evolve in a post-2030 policy framework in terms of GHG coverage, 
sectoral coverage, and relations with non-EU emissions trading schemes. Stakeholders can 
indicate  their  agreement  for  each  of  the  five  statements  on  scale,  ranging  from  1  (totally 
disagree) to  5 (totally  agree). More  precisely, stakeholders  can  indicate  their  agreement  on 
the  EU  emissions  trading  covering  all  fossil  fuel  uses,  all  non-CO2  GHG  emissions  and  all 
GHG  emissions  also  from  other  sectors.  The  other  two  statements  relate  to  potential  links 
with other markets and the role of Carbon Capture and Utilization (CCU): “Options to link the 
EU  ETS  with  other  compliance  carbon  markets  should  be  pursued,  provided  that  the 
environmental  integrity,  potential  cost-efficiency  gains  and  more  options  for  emissions 
abatement  are  carefully  assessed.”  and  “The  EU  emissions  trading  should  maintain  the 
obligation to surrender allowances for CCU for sectors with hard to abate, residual emissions 
and for sectors that require a carbon feedstock to promote carbon circularity.” 

General findings   

As depicted in Figure 25 among the response items for the evolution of EU emissions trading 
post-2030, respondents most strongly advocate that all fossil fuel uses should be covered by 
emissions trading, including those that are so far not or not entirely covered (Average = 4.27, 
48% rating 5).  

The  second  most  prioritised  response  with  an  equally  strong  level  of  agreement  among 
respondents    is  that  the  EU  emission  trading  should  also  cover  non-CO2  GHG  emissions 
(Average  =  4.09,  46%  rating  5).  The  third  most  prioritised  item  is  the  extension  of  EU 
emissions trading to other sectors not yet subject to emissions trading (Average = 3.80, 36% 
rating  5).  In  contrast  to  the  first  item,  this  option  rather  concerns  non-fossil-fuel  related 
emissions from e.g., extractive industries or the land sector.  

A relatively smaller percentage of the responses argues for a link between EU ETS and other 
compliance carbon markets (Average = 3.79, 29% rating 5). The item on which there is the 
most disagreement is on whether or not to adjust the obligation to surrender allowances for 
hard-to-abate  sectors  and  those  which  require  a  carbon  feedstock.  (Average  =  3.48,  21% 
rating  5).  Regarding  this  response  item,  a  relatively  higher  share  of  37%  of  respondents 
answer "I don't know/No response". 

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I n = 580 (Responses to the expert section of the questionnaire) 

The bottom two statements have been shortened for clearer graphical representation. However, the full text can be found above 
in the description of question Q18. 

Differences between stakeholder groups 

Figure 25 Responses to Q18 of the questionnaire 

For Q18, the following deviations between the stakeholder groups are observed: civil society 
organisations are in very strong agreement that EU emissions trading should cover all fossil 
fuel uses (Average: 4.69) and that EU emissions trading should also cover all non-CO2 GHG 
emissions  (Average:  4.66).  Additionally,  civil  society  organisations  appear  to  be  more 
sceptical about the abolishment of the obligation to surrender allowances for CCU (Average: 
2.82) and the linking with other ETS systems (Average: 2.97). 

For  business  associations/companies,  linking  the  EU  ETS  with  other  compliance  markets 
(Large,  average:  4.19;  SME,  average:  3.96)  and full  coverage  of  all  fossil  fuel  uses  (Large, 
average:  4.10;  SME,  average:  3.94)  are  the  response  items  that  are  associated  with  the 
highest  level  of  agreement.  The  preference  for  a  linking  may  be  explained  by  the 
competitiveness  dimension  and  the  hope  for  a  prolonged  availability  of  allowances.  In 
contrast  to  the  other  stakeholder  groups  business  associations/companies  more  strongly 

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advocate  for  a  reform  on  the  treatment  of  CCU  under  the  EU  ETS  (Large,  average:  3.63; 
SME, average: 3.90).  

EU citizens display a relatively strong agreement across all items. Particularly regarding the 
coverage  of  non-CO2  emissions  (Average:  4.43),  coverage  of  all  fossil  fuel  emissions 
(Average: 4.31), and the coverage of other sectors (Average: 4.27). 

3.3.1.2. Q19a:  Future  role  of  the  carbon  border  adjustment  mechanism  (CBAM) 
(closed question)  

In question Q19 the respondents express their opinion regarding the future role of the CBAM. 
They  do  so  by  indicating  whether  they  agree  from  a  scale  from  1  (totally  disagree)  to  5 
(totally  agree)  with  the  following  statements:  “Priority  should  be  given  to  sectors  where  the 
emission  reduction  efforts  are  the  lowest”,  “Any  extension  of  CBAM  to  all  ETS  products, 
which  will  replace  free  allocation,  should  be  done  progressively  and  prioritise  certain 
sectors.” and “Priority should be given to sectors where absolute emissions are the highest.”. 

I n = 580 (Responses to the expert section of the questionnaire) 

General findings 

Figure 26 Responses to Q19a of the questionnaire 

The  first  thing  that  becomes  apparent  when  analysing  Figure  26  is  that  across  all  three 
question  items  about  40%  of  the  respondents  did  not  provide  an  answer.  This  is  probably 
due to the novelty of the envisaged CBAM regulation and its specificities. 

Among  the  evaluable  answers,  most  responses  seem  to  agree  that  the  sectors  where 
absolute  emissions  are  the  highest  should  be  prioritised  (Average  =  3.90,  28%  rating  5). 
Then, the second most prioritised response is that an extension of CBAM to all ETS products 

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should  be  done  progressively  and  prioritise  certain  sectors  (Average  = 3.76,  24% rating  5). 
The  least  favoured  answer  concerns  the  prioritisation  of  sectors  where  the  emission 
reduction efforts are the lowest (Average = 2.97, 13% rating 5). 

Differences between stakeholder groups 

For  all  stakeholder  groups,  the  question  on  prioritising  the  sectors  with  the  least  effort  to 
reduce emissions is the one with the lowest level of agreement. 

Respondents  from  civil  society  organisations,  and  from  the  group  of  EU  citizens  most 
frequently  selected  the  option  regarding  the  prioritisation  of  sectors  where  absolute 
emissions  are  the  highest  (Averages:  civil  society  organisation,  4.45;  EU  citizens,  4.01), 
resembling the overall trend. 

In contrast, respondents from SMEs and large businesses as well as public authorities most 
frequently  select  the  answer  that  the  CBAM  extension  should  be  done  progressively  and 
prioritise certain sectors (Averages, SMEs, 3.80; Large businesses, 3.95; Public authorities, 
4.27). 

3.3.1.3. Q19b:  Future  role  of  the  carbon  border  adjustment  mechanism  (CBAM) 
(open question)  

In  total,  151  valid  open-text  responses  were  submitted  to  Q19b.  Please  note  that  one 
response  can  be  included  in  multiple  themes.  Based  on  a  thematic  analysis  of  the  survey 
responses to Q19b questions, the top 3 identified sectors where CBAM could extend are:  

•  Transportation  sector  appeared 

in  29  out  of  151  responses*,  19%.  The 
transportation  sector  received  attention  in  the  survey  responses,  with  respondents 
emphasizing  the  need  to  address  emissions  from  various  modes  of  transportation. 
Aviation,  maritime  transport,  freight,  and  passenger  transport  were  specifically 
mentioned.  Respondents  called  for  measures  to  reduce  emissions  from  vehicles, 
improve  efficiency,  and  potentially  ban  emission-intensive  luxury  goods.  The 
importance  of  considering  carbon 
international 
agreements in the transportation sector was also highlighted.  

leakage  risk  and  observing 

•  Chemicals and polymers sector was mentioned in 24 out of 151 responses*, 16%. 
The  chemicals  and  polymers  industry  are  another  sector  that  was  frequently 
mentioned  as  a  priority  for  CBAM  extension.  There  is  a  call  to  phase  out  free 
allowances for the sector and focus on sustainable production practices. The carbon 
footprint of chemicals and polymers, as well as the potential impact of CBAM on the 
sector,  are  areas  of  concern.  It  is  evident  that  stakeholders  want  to  address 
emissions  in  the  industry  and  ensure  a  smooth  transition  towards  more  sustainable 
chemical and polymer production.  

•  Agriculture  sector  was  present  in  20  out  of  151  responses,  13%.  The  agriculture 
sector emerged as one of the top priorities for the extension of the CBAM based on 
the  survey  responses.  Respondents  emphasized  the  importance  of  including 
agriculture in the scope of CBAM, particularly in addressing emissions from livestock 
production,  farming  practices,  and  food  production.  Additionally,  the  inclusion  of 
livestock production and the promotion of regenerative agriculture are highlighted as 
important  focus  areas.  The  impact  of  deforestation  on  the  agriculture  sector  is  also 
mentioned,  suggesting  the  need  to  consider  its  effects  when  implementing  CBAM. 
There were no explicit mentions of arguing for CBAM coverage specifically in case a 
carbon price is set for agricultural emissions. 

I *Nine responses were identical or semi-identical. It was decided not to declare these responses as campaign due to the small 
number and they were included into the analyses. These responses are marked in the result. 

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Note  that  the  Energy  sector  was  mentioned  in  the  responses  frequently.  However,  as 
electricity  is  already  included  in  the  CBAM,  these  were  excluded  from  the  analysis.  The 
energy  and  power  sector  were  mentioned  in  the  responses,  highlighting  its  relevance  to 
CBAM.  Respondents  emphasized  the  inclusion  of  energy-related  sectors  such  as  solar, 
wind,  hydrogen,  and  refineries.  The  focus  was  on  addressing  emissions  associated  with 
energy production, ensuring a full value chain approach, and replacing free allowances. The 
importance  of  renewable  energy  sources  and  their  role  in  reducing  carbon  emissions  was 
also highlighted by some respondents.  

As  the  other  end  of  the  spectrum,  12  out  of  the  151  respondents  (8%)  provided  sceptical 
responses towards CBAM. 

Figure  27  illustrates  the  survey  responses  to  the  Q19b  question,  displaying  the  total 
stakeholder  responses  (151)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

 Figure 27 

Number of responses to Q19b grouped by identified themes and stakeholder groups 

3.3.1.4. Q20:  Future  role  of  the  Effort  Sharing  Regulation  (ESR)  and  links  with  the 
ETS 

In  Question  Q20  the  respondents  express  how  the  scope  of  emissions  under  the  Effort 
Sharing Regulation and the associated national targets should evolve in the EU’s post-2030 
climate  policies.  They do  so  by  indicating  whether they  agree  with  the following  statements 
from a scale from 1 (totally disagree) to 5 (totally agree): “The ESR and associated national 
targets    should  cover  only  GHG  emissions  that  are  not  subject  to  the  EU  ETS”,  “National 
targets  should  be  replaced  by  EU-wide  sectoral  legislation.“,  “The  ESR  and  associated 
national targets should keep the same GHG scope as currently, covering both emissions that 
are not under  the EU ETS and emissions from fuels used  in road transport and buildings.” 
and “There should be national targets covering all GHG emissions from all sectors (including 
those covered by the EU ETS).”. 

General findings 

Similar to the responses to Q19a about the CBAM, it should be noted that across all question 
items,  around  40%  of  the  respondents  did  not  provide  an  answer,  hinting  at  a  potential 
unfamiliarity with the ESR. 

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The first three response options can be seen as a sequence of a varying scope of the ESR 
targets  (1-  only  cover  emissions  not  subject  to  emissions  trading,  2-  keep  scope  of  current 
ESR  and  thereby  have  dual  targets  for  the  emissions  covered  by  ETS2,  3-  extend  ESR 
targets  to  all  emissions  including  those  covered  by  ETS1/ETS2).  The  fourth  option 
represents an alternative where targets are set based on sectoral legislation. 

I n = 580 (Responses to the expert section of the questionnaire) 

Figure 28 Responses to Q20 of the questionnaire 

As  illustrated  by  the  homogeneous  appearance  of  Figure  28  there  are  no  clear  response 
patterns across the different statements. However, one aspect that can be observed is that 
the two options, to extend the scope of the national targets in the ESR to all GHG emissions 
from  all  sectors (Average  =  3.36,  29%  rating  5) and  to  keep  the  current scope,  (Average = 
3.35, 20% rating 5) receive more agreement than the other two options. 

Differences between stakeholder groups  

For  civil  society  organisations,  a  favourable  attitude  towards  extending  the  scope  of  the 
national  targets  in  the  ESR  to  all  GHG  emissions  from  all  sectors  (Average  =  4.38,  55% 
rating  5)  or to  keep the current  scope (Average =  4.34,  49%  rating  5)  is  most  pronounced. 
Conversely,  their  view  of  the  narrower  scope  of  the  ESR,  which  only  covers  emissions  not 
covered  by  EU  emissions  trading  or  the  introduction  of  EU-wide  sectoral  legislation,  is  not 
positive. 

Especially  large  companies  or  business  associations  representing  large  companies  favour 
the idea that national targets should only cover emissions not covered by an ETS (Average = 
4.11, 37% rating 5), whereas they strongly disagree with the idea that national targets should 
cover all GHG emissions from all sectors (Average = 1.85, 7% rating 5). 

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The emerging pattern of differing opinions between economic stakeholders and stakeholders 
from civil society is consistent with the results of Q18 and Q19. 

3.3.2. Mitigation  of  GHG  emissions  from  the  land  sector  and  policy 

Regarding the mitigation of GHG emissions, the land sector is of particular importance with 
agriculture contributing to 12% of EU emissions. Therefore, this section of the survey delves 
deeper into the evaluation of potential solutions for mitigating GHG emissions in this sector. It 
particularly focuses on the role of carbon pricing and non-carbon pricing instruments as 
well as on different actors, for which setting a carbon price would be most effective. 

3.3.2.1. Q21:  The  role  of  carbon  pricing  and  non-carbon  pricing  instruments  for 
agricultural emissions and land-based removals 

Question  Q21  deals  with  different  instruments  for  handling  agricultural  emissions  and  land-
based removals. Four statements are presented, focusing either on climate policies to set a 
carbon price on agricultural emissions or on other options, such as national targets, sectoral 
standards,  or  better  information  and  support.  Stakeholders  can  indicate  their  agreement 
regarding these statements on a scale from 1 (totally disagree) to 5 (totally agree).  

General findings 

First,  Figure  29  shows  that  a  higher  share  of  “I  don’t  know/No  response”  options  can  be 
observed  among  the  organizations  (about  50%  per  response  item)  as  compared  to  the 
individuals (between 16-27% per response item). The higher share of non-responses among 
organizations  is  primarily  due  to  business  associations  and  companies  providing  no 
response to the question. The reason likely being that their economic activities are unrelated 
to the agricultural sector. 

Among  the  items,  respondents  indicate  that  they  mostly  agree  with  the  option  that 
unsustainable  farming  practices  should  be  ruled  out  through  ambitious  sectoral  standards 
(Total: Average = 4.23, 37% rating 5; Individuals: 52% rating 5; Organisations: 27% rating 5). 
The second most prioritised response is that emission reductions and carbon removals in the 
agricultural sector should be covered by national targets and achieved through, inter alia, the 
EU Common Agricultural Policy (CAP) (Total: Average = 4.01, 27% rating 5; Individuals: 31% 
rating 5; Organisations: 25% rating 5). Taken together, the two items in combination may be 
interpreted as a preference by respondents to maintain the current national targets supported 
by the  CAP  and  underpin them  by  ambitious  sectoral  standards that rule out  unsustainable 
farming practices. 

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I n = 580 (Responses to the expert section of the questionnaire) 

* Some question items were shortened for better readability. This applies in particular to the examples given in a question item. 
See Appendix A for the full text of the question items. 

Figure 29 Responses to Q21 of the questionnaire 

Carbon pricing of agricultural emissions, coupled with payments for carbon removals, gets an 
average  level  of  support  among  the  respondents  (Total:  Average  =  3.65,  22%  rating  5; 
Individuals: 31% rating 5; Organisations: 17% rating 5).  

The  response  item  that  non-regulatory  approaches  (better  information,  innovation  funding, 
consumer demand for climate action in farming) would be enough to drive the transformation 
of  the  agricultural  sector  is  strongly  disagreed  with  (Total:  Average  =  1.75,  5%  rating  5; 
Individuals: 7% rating 5; Organisations: 3% rating 5). 

Differences between stakeholder groups 

The  stakeholder  groups  that  show  the  same  response  pattern  as  the  overall  trend  are  civil 
society  organisations  and  EU  citizens.  EU  citizens  are  relatively  more  supportive  of  carbon 
pricing  of  agricultural  emissions  than  civil  society  organisations.  (EU  citizens:  Average  = 
3.73, 30% ranking 5; civil society organisations: Average = 2.83, 14% ranking 5).  

Large  business  associations/companies  (subset of  approximately  30% that responded)  and 
academic  research  institutions  are  in  strong  support  of  all  options  (all  averages  above  4), 
with  the  exception  that  non-regulatory  approaches  will  be  sufficient  to  reduce  agricultural 
emissions  (Large  business  associations/companies:  Average  =  1.56,  0%  ranking  5; 
academic research institution: Average = 1.27, 0% ranking 5). The respondents from SMEs 
(subset  of  approximately  45%  that  responded)  indicate  an  overall  agreement  on  the 
statements  (all  averages  above  3.4),  except  for  the fact that  a  non-regulatory  approach  will 
be insufficient (Average = 2.30, 6% ranking 5).  

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For  public  authorities  the  most  favoured  option  is  that  emission  reductions  and  carbon 
removals  in  the  agricultural  sector  should  be  covered  by  national  targets  and  achieved 
through  the  EU  common  agricultural  policy  (CAP)  and  thereby  maintaining  national 
responsibility (Average = 4.25, 22% ranking 5).  

Despite  the  nuanced  differences  between  the  stakeholder  groups  regarding  the  best 
strategies for the agricultural sector, all stakeholders agreed that a non-regulatory approach 
will be insufficient to drive the transformation of the agricultural sector. 

3.3.2.2. Q22: Agricultural emissions and climate policies  

In Q22 stakeholders are asked to indicate for which actors a carbon price should be set. Four 
options are presented, and on each one can be (dis)agreed on, on a scale, ranging from 1 
(totally  disagree)  to  5  (totally  agree).  Four  different  actors  are  available  for  selection:  Food 
companies, producers of fertilisers, consumers, and farmers.  

I n = 580 (Responses to the expert section of the questionnaire) 

General findings 

Figure 30 Responses to Q22 of the questionnaire 

Figure  30  highlights  that,  overall,  respondents  agree  the  most  on  a  carbon  price  on 
agricultural emissions set at the level of food companies (Average = 4.26, 37% rating 5). The 
second  most  prioritised  response  is  that  there  should  be  a  carbon  price  on  producers  of 
fertilisers (Average = 4.07, 32% rating 5). Thus, the two most agreed on options are the ones 
where the carbon price would be set for industry actors and then passed-on along the value 
chain.  The  other  two  options,  where  consumers  (Average  =  3.49,  21%  rating  5)  or  farmers 
are  subject  to  a  carbon  price  (Average  =  3.18,  15%  rating  5)  are  less  favoured  by  the 

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respondents. High “I don’t know/No response” shares of about 40% are observed. They are 
especially high among business associations and companies. 

Differences between stakeholder groups 

Regarding  variations  among  different  stakeholder  groups,  the  following  results  can  be 
observed: The stakeholders from the group of civil society organisations, EU citizens as well 
as  from  SMEs  and  large  business  associations/companies  depict  the  same  preferences  as 
the overall trend. For civil society organisations the agreement to place the carbon price on 
food companies or producers of fertilizers is most pronounced (for food companies: Average 
= 4.62, 58% ranking 5; for producers of fertilizers: Average = 4.30, 49% ranking 5). 

For  public  authorities,  food  companies  are  the  most  preferred  actor  for  a  carbon  price 
(Average:  4.08,  28%  ranking  5),  followed  by  consumers  (Average:  3.62,  17%  ranking  5), 
producers  of  fertilisers  (Average:  3.54,  17%  ranking  5)  and  the  least  preferred  actor  for  a 
carbon price are farmers (Average: 3.23, 22% ranking 5).  

Academic/research  institutions  have  an  overall  high  level  of  agreement  with  all  response 
items  but  also  exhibit  a  preference  for  putting  a  carbon  price  on  producers  of  fertilisers 
(Average: 4.50, 37% ranking 5) or food companies (Average: 4.46, 42% ranking 5). 

In  comparison  with  Q21,  which  asks  whether  a  carbon  price  would  be  a  suitable  means  of 
reducing  emissions  in  the  agricultural  sector,  there  is  greater  agreement  among  the 
stakeholder  groups  on the  subordinate  question  of  where  in  the  value  chain  such  a  carbon 
price  signal  could  be  introduced.  This  is  particularly  true  of  civil  society  stakeholders  and 
stakeholders from the economic sector. 

3.3.3. The role of carbon removals 

This  part  of  the  expert  section  investigates  stakeholders’  opinion  on  the  role  of  carbon 
removals  to  limit  the  temperature  increase  to  1.5°C.  After  a  short  introduction  on  nature-
based solutions as well as on industrial ones that capture atmospheric carbon, two questions 
are presented. The first question deals with the general role of carbon removals whereas 
the second one looks more closely on the relative contribution of nature-based removals 
and industrial removals as potential parts of the solution to achieve EU’s climate target.  

3.3.3.1. Q23: General role of carbon removals 

For  Q23,  participants  are  requested  to  select  one  out  of  two  options.  They  can  either 
advocate that carbon removals should play a very limited role as all GHG emissions can be 
brought close to zero by 2050, including in sectors that are currently considered as difficult to 
fully  abate  (like  agriculture,  aviation  or  some  industrial  processes).  Or  respondents  can 
advocate for  an  important  role  of  carbon  removals  because  this  approach  can  compensate 
remaining  unabated  GHG  emissions  in  different  sectors,  including  agriculture,  industrial 
processes,  while  driving  the  growth  of  the  EU  clean  industry  and  providing  co-benefits  for 
other environmental objectives.  

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I n = 580 (Responses to the expert section of the questionnaire) 

General findings 

Figure 31 Responses to Q23 of the questionnaire 

As  depicted  in  Figure  31,  there  is  no  clear  opinion  on  the  role  of  carbon  removals.  On  the 
one  side,  almost  half  of  the  respondents  indicate  that  carbon  removals  should  play  an 
important role to meet climate neutrality by 2050 (Individuals: 73, 32%; Organisations: 201, 
57%;  Total:  274,  47%).  On  the  other  side,  36%  of  respondents  (211  participants  in  total) 
argue  for  a  very  limited  role  of  carbon  removals  to  meet  climate  neutrality  by  2050 
(Individuals:  111,  49%;  Organisations:  100,  28%).  16%  of  respondents  (95  participants  in 
total) indicate to have no opinion on this topic or did not provide a response (Individuals: 42, 
19%; Organisations: 53, 15%).  

Hence, there seems to exist a general disagreement among the respondents when it comes 
to  the  role  of  carbon  removals  with  a  slight  preference  for  a  more  important  role  to  meet 
climate  neutrality  by  2050.  In  this  context,  respondents  representing  organisations  seem  to 
favour  the  important  role  of  carbon  removals  whereas  respondents  in  the  group  of  private 
individuals seem to favour the limited role. 

Differences between stakeholder groups  

Analysing  the  responses  from  different  stakeholder  groups,  the  following  distinctions  are 
observed: civil society organisations (52, 62%) together with EU citizens (110, 50%), are the 
stakeholders  who  prefer  to  limit  the  role  of  carbon  removals  to  meet  the  climate  neutrality 
target by 2050.  

In contrast, academic/research institutions (10, 53%), public authorities (11, 61%) and SMEs 
(60,63%) as well as large business associations/companies (94, 73%) have a higher share of 
responses in favour of an important role of carbon removals. The percentage of respondents 
who did not provide an opinion or response is around 13% to 20% for all stakeholder groups.  

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Thus, the observed disagreement between the respondents seems to arise particularly due 
to the different opinions from the groups of EU citizens and the organised civil society on the 
one hand, and other stakeholder groups from the academic, economic, and public sector on 
the other hand.  

3.3.3.2. Q24: Relative contribution of nature-based removals and industrial removals 

After  exploring  stakeholders’  attitude  on  the  general  role  of  carbon  removals,  in  question 
Q24, respondents indicate their attitude regarding the relative role of nature-based compared 
to  industrial  removals.  Three  statements  are  provided,  ranking  from  a  stronger  reliance  on 
nature-based  removals  via  a  balanced  approach  between  nature-based  and  industrial 
removals through to a stronger reliance on industrial removals. 

General findings 

Figure 32 shows that, overall, 31% of the respondents (180 participants in total) believe that 
there should be a stronger reliance on the LULUCF sink, since they are convinced that the 
large-scale  deployment  of 
is  uncertain  (Individuals:  106,  47%; 
Organisations: 74, 21%). 

industrial  removals 

Closely followed, 27% of the respondents (156 participants in total) indicate that there should 
be  a  balance  between  the  LULUCF  sink  and  industrial  removals  (Individuals:  47,  21%; 
Organisations: 109, 31%).  

Fewer respondents argue for a stronger reliance on industrial removals, since the evolution 
of  the  LULUCF  sink  is  uncertain  (Individuals:  21,  9%;  Organisations:  87,  25%,  Total:  108, 
19%).  At  the  same  time,  23%  of  the  respondents  (136  participants  in  total)  refrain  from 
indicating an opinion or response (Individuals: 52, 23%; Organisations: 84, 24%).  

Thus, it seems that a slight preference for the reliance on the LULUCF sink and a balanced 
approach exists, rather than a primary focus on industrial removals. 

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I n = 580 (Responses to the expert section of the questionnaire) 

Differences between stakeholder groups   

Figure 32 Responses to Q24 of the questionnaire 

When  exploring  the  answers  of  the  different  stakeholder  groups,  the  following  differences 
occur:  Both,  civil  society  organisations  (50,  60%)  and  EU  citizens  (105,  48%)  are  the 
stakeholders with the highest share on support for a stronger reliance on the LULUCF sink. 
This  pattern  aligns  with  question  Q23,  where  these  two  groups  also  scored  highest  for  a 
limited role of carbon removals.  

In contrast, academic/research institutions (9, 47%), large business associations/companies 
(53,  41%)  as  well  as  public  authorities  (6,  33%)  show  the  highest  support  for  a  balanced 
approach between the LULUCF sink and industrial removals. Only the respondents from the 
group of SMEs display a preference for a stronger reliance on industrial removals, since the 
evolution of the LULUCF sink is seen as uncertain (32, 33%).  

Overall,  the  share  of  participants  with  no  opinion  or  no response  is  particularly  pronounced 
for  respondents  from  SMEs  (29,  30%),  public  authorities  (6,  33%),  large  business 
associations/companies (31, 24%) and EU citizens (51, 23%). This may assign a unique role 
to SMEs, implying that this group may potentially benefit the most from industrial removals at 
the economic level, considering that SMEs are especially suited to offer such solutions.  

Thus,  there  seems  to  exist  a  pronounced  difference  between  EU  citizens  and  civil  society 
organisations on the one hand and SMEs on the other hand. Half of the stakeholder groups 
(academic/research  institutions,  large  business  associations/companies,  public  authorities) 
agree on a more balanced approach when it comes to the role of nature-based and industrial 
carbon removals. 

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3.3.4. Technologies  

This  part  of  the  expert  section  evolves  around technologies  and  their  roe  in  EU’s  transition 
towards  climate  neutrality.  On  the  on  de  hand,  this  section  investigates  the  barriers  to 
carbon capture and storage technologies and the prioritisation of several deployment 
options. On the other hand, the most relevant energy technologies are evaluated as well 
as the opportunities and challenges regarding these technologies and their deployment.  

3.3.4.1. Q25: Barriers to carbon capture and storage technologies 

On the barriers to the use of CCS, its cost is overall ranked as the main one. The next most 
important  barriers  are  economic  signals  and  availability  of  storage  capacity,  but  not  much 
different  to  the  assessment  of  technological  maturity  and  regulatory  framework.    Public 
acceptance  is  rated  as  the  least  important  barrier.  The  average  share  on  “I  don’t  know/No 
response” is 25%.  

  storage  availability  and  iv)  the 
The  four  barriers  i)  costs  of  CCS,  ii)  price  signals,  iii)  CO
maturity  of  the  technology  are  all  related  to  each  other  and  all  are  ranked  as  important 
indicating that the economic case for using the technology is not considering to be strong. 

₂

There  are  significant  differences  across  the  stakeholder  groups  on  what  they  rank  as  the 
most important barriers as depicted in Figure 33. 

•  Academic/research  institutions  rank  economic  signals  as  the  most  important  barrier 
followed  by  the  regulatory  framework  and  the  technology  cost.  They  score 
technological  maturity,  public  acceptance  and  CO
  storage  capacity  as  the  least 
important barriers (all three have similar scoring of importance).  

•  Business  associations  and  companies representing  SMEs rank  cost  of  CCS  highest 
followed  by  economic  signals  and  regulatory  framework.  They  score  public 
acceptance as the least important barrier.  

₂

•  Business  associations  and  companies  representing  large  companies  rank  cost  of 
CCS highest followed by the regulatory framework. They score technological maturity 
as the least important barrier.  

•  Civil society organisations rank economic signals, technological maturity and cost of 
CCS has almost equally high in importance. They score regulatory framework as the 
least important barrier. 

•  EU  citizens  rank  cost  of  CCS  and  technological  maturity  as  the  most  important 

barriers. They rank public acceptance as the least important barrier.  

•  Public  authorities  rank  cost  of  CCS  as  the  highest  and  then  economic  signals, 
technological  maturity  and  storage  available  as  second  (similar  scoring  of 
importance). They score public acceptances as the least important barrier. 

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I n = 580 (Responses to the expert section of the questionnaire) 

3.3.4.2. Q26: Carbon capture and use or storage 

Figure 33 Responses to Q25 of the questionnaire 

  from  non-energy  related  industrial  process  is  scored  as  the  most  favoured 
Capture  of  CO
  from  combustion  of  biomass  is  second  most  favoured 
deployment  of  CCS.  Capture  of  CO
followed by the coproduction of clean gas and biochar and followed by capture of CO
 from 
combustion  of  fossil  fuels.  In  relation  to  the  storage  technologies,  permanent  storage  is 
slightly favoured compared to uses of the captured CO
 in fuels and products. On average, 
32% of the respondents have not scored the listed technological options.  

₂

₂

₂

Figure 34 shows that there is some difference between the stakeholder groups: 

₂

•  Academic/research  institutions  score  capture  from  non-energy  industrial  process 
 from combustion of fossil 

highest and they favour permanent storage. Capture of CO
fuels is favoured the least.  

•  Business  association  and  companies  (SMEs)  consider  capture  of  CO

  from  the 
combustion  of  biomass,  together  with  capture  from  non-energy  related  industrial 
process  as  the  CCS  deployment  options  that  should  have  the  highest  priority. 
Permanent storage is favoured more than use of captured CO

.  

₂

₂

•  Business  associations  and  large  companies  consider  the  capture  of  CO

  from 
energy-related  industrial  processes  as  the  CCS  deployment  option  to  be  prioritised. 
This stakeholder group have a slightly higher preference towards permanent storage 
over  the  use  of  captured  CO
in  fuels  and  products  to  replace  virgin  fossil  carbon. 
This  stakeholder  group (both  SMEs  and  large companies  included)  generally  give  a 
higher priority to all technologies compared to the average answers.  

₂ 

₂

₂

•  Civil  society  organizations  give  the  highest  priority  to  the  capture  of  CO

energy  industrial  process.  Then  they  have  capture  of  CO

  from  non-
  from  the  air  as  the 
₂

₂

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technology  with  second  highest  priority.  No  other  stakeholder  group  score  this 
technology so high. In general, they have lower scoring of all technologies compared 
to the average answers. 

•  EU  citizens  also  have  given  the  highest  priority  to  capture  of  CO

  from  non-energy 
related  industrial  processes.  Then,  they  give  almost  equal  scoring  of  all  the  other 
technologies.  

₂

•  Public  authorities  have given  the  highest  priority  to  capture  of  CO

 from non-energy 
.  Then 
related  industrial  processes  and  to  permanent  storage  of  the  captured  CO
high priorities are given to use of the captured CO
 and to coproduction of clean gas 
and biochar. Overall, this stakeholder group has given similar levels of priority to the 
different deployment technologies. 

₂

₂

₂

I n = 580 (Responses to the expert section of the questionnaire) 

3.3.4.3. Q27a: Energy technologies (closed question) 

Figure 34 Responses to Q26 of the questionnaire 

As depicted in Figure 35, the respondents consider that the most relevant technologies are 
wind,  solar  and  hydropower.  Then  highly  relevant  are  also  energy  efficiency,  storage 
technologies, demand management and other forms of renewable energy. Less relevant are 
nuclear power, and the various forms of biofuels. Finally, fossil fuel with CCS is considered 
the least relevant technology.  

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Most of the stakeholder groups have answered like the average answers presented above.  

Business  and  companies  (including  both  SMEs  and  large  companies)  have  scored  the 
relevance  differently.  They  also  have  the  renewable  energy  wind,  solar  and  hydro  as  the 
technologies with highest relevance, but then all other technologies are considered more or 
less  equally  relevant.  Only  fossil  fuel  with  CCS  is  considered  less  relevant.  Furthermore, 
large companies have also given the highest score to hydrogen ant its derivatives among the 
stakeholders, having it as the third most relevant technology. 

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I n = 580 (Responses to the expert section of the questionnaire) 

Figure 35 Responses to Q27a of the questionnaire 

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3.3.4.4. Q 27b: Energy technologies (open question) 

In total, 156 valid open-text responses were submitted to Q27b. Most of the responses were 
mentioning  technologies  (e.g.,  Renewable,  Hydrogen  and  Nuclear)  that  were  already 
included in Q27a.  

•  Renewable  energy  (48  out  of  156  responses,  31%)  sources  such  as  wind,  solar, 
biomass,  geothermal,  and  hydropower  were  frequently  cited  as  key  solutions  for 
achieving  carbon  neutrality.  These  sources  were  recognized  for  their  potential  to 
generate clean energy and contribute to reducing greenhouse gas emissions.  

•  Hydrogen  (19  out  of  156  responses,  12%)  produced  from  renewable  sources 
emerged as an important solution. Respondents highlighted the importance of basing 
hydrogen production on renewable energy, emphasizing its potential as a clean and 
sustainable energy carrier.  

•  Nuclear  power  (15  out  of  156  responses,  10%)  including  both  fusion  and  fission 
technologies,  emerged  as  a  prominent  solution.  There  were  mentions  of  fourth-
generation  nuclear  fission  and  small  modular  reactors  (SMRs)  as  potential  avenues 
for transitioning to carbon neutrality.  

Figure 36 Number of responses to Q27b grouped by identified themes and stakeholder groups 

Other specific technology mentioned in the responses was Bioenergy with Carbon Capture 
and Storage (BECCS) (4 responses).  

Even  though,  not  technology  solutions,  the  concept  of  a  market  economy  and  the  law  of 
supply  and  demand  were  frequently  mentioned  in  the  responses.  As  well  as  energy 
efficiency  and  consumption  reduction  were  emphasized  as  crucial  strategies  for  the 
energy  transition.  Suggestions  included  promoting  a  culture  of  energy  and  product 
consumption  reduction,  as  well  as  focusing  on  insulation,  reuse,  and  recycling  to  minimize 
energy demand. 

Figure  36  illustrates  the  survey  responses  to  the  Q27b  question,  displaying  the  total 
stakeholder  responses  (156)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

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3.3.4.5. Q28:  Opportunities  and  challenges  with  regard  to  energy  technologies  and 
their development 

Full  question:  What  are the  biggest  opportunities  in the  energy  sector  and  in the sectors  of 
the  economy  consuming  energy  (residential,  industry,  transport),  including  for  the  wider 
economy  and  security  of  supply?  What  are  the  biggest  challenges  related  to  the  future 
development of a low-carbon energy sector, including as regards to public acceptance or the 
availability of land and natural resources?  

In total, 269 valid open-text responses were submitted to Q28. This question can be divided 
into  two  parts,  responses  addressing  the  opportunities  and  responses  addressing  the 
challenges. Please note that one response can be included in multiple themes.  

Opportunities  

Based on a thematic analysis of the survey responses to Q22 questions, the top 5 identified 
opportunities regarding energy technologies and their development are:  

•  Renewable  energy  deployment  as  opportunity  was  mentioned  in  112  out  of  269 
responses,  42%.  The  opportunity  lies  in  accelerating  the  deployment  of  renewable 
energy sources such as solar and wind power. This can lead to a significant reduction 
in  greenhouse  gas  emissions,  enhanced  energy  efficiency,  and  the  creation  of  a 
sustainable and clean energy system.  

•  Energy  efficiency  and  energy  savings  as  opportunity  appeared  in  59  out  of  269 
responses,  22%.  Emphasizing  energy  efficiency  and  implementing  energy-saving 
measures  can  result  in  reduced  energy  consumption  and  lower  energy  bills.  By 
optimizing  energy  use  in  buildings,  transportation,  and  industrial  processes,  we  can 
achieve more sustainable and cost-effective energy systems.  

•  Technological advancements and innovation as opportunity was mentioned in 39 
out  of  269  responses,  15%.  The  opportunity  lies  in  fostering  technological 
advancements  and  promoting  innovation  in  the  energy  sector.  This  includes  the 
development  of  new  renewable  energy  technologies,  energy  storage  solutions,  grid 
optimization systems, and digitalization, which can drive the transformation towards a 
low-carbon energy future. 

•  Clean air and reduced dependence on fossil fuels as opportunity was mentioned 
in 33 out of 269 responses, 12%. Transitioning to clean energy sources presents an 
opportunity  to  improve  air  quality  by  reducing  pollutants  emitted  from  fossil  fuel 
combustion.  It  also  offers  the  chance  to  decrease  reliance  on  finite  fossil  fuel 
resources and enhance energy security.  

•  Job  creation  and  economic  growth  as  opportunity  was  present  in  21  out  of  269 
responses,  8%.  Investing  in  clean  energy  technologies  and  industries  can  generate 
new employment opportunities and stimulate economic growth. This includes jobs in 
renewable energy installation, manufacturing, research and development, and related 
sectors, contributing to a green and resilient economy.  

Challenges  

Based  on  a  thematic  analysis  of  the  survey  responses  to  Q22  questions,  the  top  five 
identified challenges regarding energy technologies and their development are:  

•  Lack  of  policy  implementation  and  ambition as  challenge  was  mentioned  in  107 
out  of  266  responses,  40%:  A  key  challenge  is  the  inadequate  implementation  and 
lack  of  ambition  in  policies  related  to  the  energy  transition.  Without  robust  policy 

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frameworks and ambitious targets, it becomes difficult to drive the necessary changes 
and achieve the desired outcomes.  

•  Cost  and  affordability  of  clean  energy  as  challenge  appeared  in  51  out  of  266 
responses, 19%. The challenge lies in making clean energy sources more affordable 
and  cost-competitive  compared  to  traditional  fossil  fuel-based  alternatives.  High 
upfront  costs  limited  financial  incentives,  and  market  dynamics  can  hinder  the 
widespread adoption of clean energy technologies.  

•  Access  to  financing  and  investments  as  challenge  appeared  in  31  out  of  266 
responses,  12%.  Securing  sufficient  financing  and  investments  for  clean  energy 
projects is a critical challenge. The availability of affordable capital, access to funding 
mechanisms,  and  mitigating  investment  risks  are  crucial  factors  in  scaling  up  clean 
energy deployment and achieving a sustainable energy transition.  

• 

Infrastructure  requirements  as  challenge  was  mentioned  in  27  out  of  266 
responses, 10%: The transition to a low-carbon energy sector necessitates significant 
infrastructure  development,  including  renewable  energy  generation  facilities,  grid 
expansion,  and  energy  storage  systems.  Addressing  the  infrastructure  requirements 
poses challenges in terms of planning, financing, and timely implementation.  

•  Public  acceptance  and  engagement  as  challenge  appeared  in  18  out  of  266 
responses,  7%.  The  challenge  involves  gaining  public  acceptance  and  engagement 
in the energy transition. This includes addressing concerns, fostering awareness, and 
involving  communities  in  decision-making  processes  to  ensure  a  smooth  and 
inclusive transition. 

Figure  37  illustrates  the  survey  responses  to  the  Q28b  question,  displaying  the  total 
stakeholder  responses  (266)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes for opportunities and challenges grouped by stakeholder categories. 

 Figure 37 

Number of responses to Q28 grouped by opportunities, challenges, identified themes and stakeholder 

groups 

3.3.4.6. Q29: Other options to fight climate change to be considered 

The  respondents  overall  rate  nature-based  options  the  highest.  It  means  afforestation, 
peatland restoration and agroforestry are the highest rated options. Then, other nature-based 

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options such as coastal blue carbon and soil carbon sequestration are rated high followed by 
innovative  solutions  through  digitalisation  and  innovative  mobility  technologies.  The  least 
rated  option  is  solar  radiation  modification.  Respondents  that  have  not  replied  or  replied  I 
don’t know are around 39%.  

The is some difference across stakeholder groups:   

•  Academia/research  institutions  consider  all  options  more  or  less  equally  relevant 

except solar radiation modification and nuclear fusion energy.  

•  Business  associations  and  companies  also  rate  most  of  the  options  as  relevant. 
Again,  solar  radiation  is  considered  less  relevant  compared  to  the  other  options 
followed  by  option  on  plant-based  meat  substitutes.  This  stakeholder  group  have  a 
high  share  of  no  reply  or  I  don’t  know  replies  (for  most  options  above  50%  of  the 
respondents in this category.) 

•  Civil  society  organisations  rate 

the  nature-based  options  such  as  peatland 
restauration,  afforestation,  agroforestry  and  coastal  blue  carbon  as  most  relevant 
options.  The  least  relevant  include  solar  radiation  modification,  ocean-based  carbon 
storage and nuclear fusion. The are rated as irrelevant or very irrelevant. 

•  EU citizens also rate the nature-based options as the most relevant options followed 
by the innovative techniques (digitalisation in certain sectors and mobility). They also 
rate solar radiation modification as irrelevant. The other options are scored between 
irrelevant and relevant. 

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I n = 580 (Responses to the expert section of the questionnaire) 

Figure 38 Responses to Q29 of the questionnaire 

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3.3.4.7. Q30: Open question on the future role of other innovative options 

Full  question:  Which  other  innovative  technologies  could  be  used  to  reduce  emissions,  in 
particular in hard-to-abate industrial sectors or to compensate for hard-to-capture emissions?  

In  total,  167  valid  open-text  responses  were  submitted  to  Q30.  Please  note  that  one 
response  can  be  included  in  multiple  themes.  Based  on  a  thematic  analysis  of  the  survey 
responses  to  Q30  questions,  the  top  three  identified  themes  regarding  future  role  of  other 
innovative options:  

•  Ecodesign of products and processes (18 out of 167 responses, 11%) involves the 
integration of sustainability principles into the design, manufacturing, and life cycle of 
products.  The  responses  emphasized  the  significance  of  considering  environmental 
impacts 
including  material  sourcing, 
production  methods,  and  end-of-life  considerations.  Ecodesign  was  proposed  as  an 
innovative  approach 
to  reduce  emissions  by  optimizing  resource  efficiency, 
minimizing waste, and promoting sustainable manufacturing practices.  

the  entire  product 

throughout 

lifecycle, 

•  Nature-based  solutions  (11  out  of  167  responses,  7%)  refer  to  approaches  that 
utilize and restore natural ecosystems to address climate change and environmental 
challenges.  The  responses  highlighted  the  importance  of  nature-based  solutions  in 
tackling  emissions 
reduction,  emphasizing  concepts  such  as  biodiversity 
conservation,  ecosystem  restoration,  and  green  infrastructure.  These  solutions 
leverage  the  power  of  ecosystems  to  sequester  carbon,  enhance  resilience,  and 
provide co-benefits such as improved biodiversity and water management.  

•  Carbon  capture  and  utilization  (CCU)  technologies  (9  out  of  167  responses,  5%) 
aim to capture CO2 emissions from industrial processes and utilize them for various 
purposes,  such  as  producing  valuable  products  or  storing  the  captured  carbon.  The 
responses  emphasized  the  importance  of  CCU  in  offsetting  hard-to-capture/abate 
emissions and reducing the overall carbon footprint. The potential of CCU in sectors 
like maritime and cement production was highlighted, indicating its relevance in hard-
to-abate industrial sectors.  

Note that most of the question were not directly addressing innovation options. 

Figure  39  illustrates  the  survey  responses  to  the  Q30  question,  displaying  the  total 
stakeholder  responses  (167)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

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Figure 39 Number of responses to Q30 grouped by identified themes and stakeholder groups 

3.3.5. Engagement and social impacts 

This  part  of  the  expert  section  approaches  several  aspects  concerning  the  involvement  of 
different actors as well as the social and sectorial impacts of climate change. Specifically, the 
survey asks about the local and regional implementation of the European Green Deal as 
well as about the social impacts of climate change policies and sectoral impacts of the 
transition. 

3.3.5.1. Q31: Local and regional implementation of the European Green Deal 

Figure  40  depicts  stakeholders’  opinion  on  the  involvement  of  local,  regional  and  private 
actors  in  the  green transition: One  third  of  the  individuals  that  have  replied,  states that  it  is 
absolutely not the case and one third that it is not the case, that they are sufficiently involved 
in  the  support  of the  green  transition.  Only  around  10%  of the  individuals  that  have  replied 
find it to be the case. For organisations, there is slightly more positive opinion. Still one third 
find it not to be the case and only 10% that it is the case. 

There are some differences between the different stakeholder groups. Among organisations, 
academia/research  institution  and  civil  society  organisations  are  most  critical  and  here 
around 40% says that local, regional and private actors have absolutely not been sufficiently 
involved  and  around  28%  that  it  is  not  the  case.  In  total,  these  stakeholders  plus  the  EU 
citizens, vary between 62-68% in believing that local, regional and private sector actors have 
not  been  sufficiently  involved.  The  opposite  opinion,  in  that  these  groups  have  been 
sufficiently involved, vary between 0% and 10% between academic institutions, civil society 
and  EU  citizens.  Among  Business  associations  and  company  respondents,  circa  25%  that 
finds the involvement to have been not sufficient, while 13% find it to be sufficient. Here 36% 
has not provided an opinion. Public authority respondents are the most positive. Here 50% of 
the  respondents  have  the  neutral  opinion,  while  around  17%  of  the  respondents  find  that 
involvement has not been sufficient and the same share that it has been sufficient.  

Opinion on national energy and climate plans (NECPs): One third of the individuals have not 
replied or replied I don’t know. This may reflect less knowledge about the plans, though this 
cannot be concluded based on the answers. There is about 26% of respondents that find the 
NECPs not a good source to inform the 2040 policy framework, while about 23% consider it 

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to be good source. For organisations, the opinion is more positive. 27% finds the NECPs a 
good source, 20% are more neutral on 22% do not find the NECPs a good source. There is 
also for this category about one third with no opinion.  

The  pattern  of  differences  among  the  organisations  that  have  replied  is  similar  to  the  sub-
question on involvement. 

 I n = 580 (Responses to the expert section of the questionnaire) 

3.3.5.2. Q32: Social impacts of climate change policies 

Figure 40 Responses to Q31 of the questionnaire 

This question lists four statements about requirements for a just transition to green economy. 
Overall,  all  stakeholder  groups  agree  with  the  five  statements  and  there  are  only  minor 
differences  in  how  they  rate  or  score  each  statement.  On  the  statement  on  ensuring  inter-
generational  fairness  55%  of  all  respondents  that  said  that  they  totally  agree.  On  the 
statement about the need for supporting low- and middle-income households financially, 50% 
totally  agree.  Then,  41%  totally  agree  with  the  last  two  statements  on  the  need  to  support 
vulnerable individuals and more generally that strengthening of carbon pricing may lead to a 
need for mitigation the impacts on the citizens.  

There are limited differences across the stakeholder groups.  The main difference is that for 
business  associations  and  companies,  about  half  of  the  respondents  in  these  categories 
have either not provided a response or replied I don’t know. 

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I n = 580 (Responses to the expert section of the questionnaire) 

3.3.5.3. Q33: Sectoral impacts of the transition 

Figure 41 Responses to Q32 of the questionnaire 

The question includes six statements on sectoral impacts of the green transition. As depicted 
in  Figure  42  round  27%  of  all  respondents  totally  agrees  with  all  statements,  while  almost 
40%  of the respondents  have  not  provided  a  scoring  of  their  agreement.  The  statement  on 
the  need  for  EU  action  to  reskill  and  upskill  the  workforce  is  totally  agreed  by  46%  of  all 
respondents.  The  statement  on  a  larger  impact  on  micro-companies  is  the  stamen  where 
less totally agree – here it is around 15%.  

There are no major differences across stakeholder groups. 

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I n = 580 (Responses to the expert section of the questionnaire) 

3.3.5.4. Q34: Open Question on affected sectors after 2030 

Figure 42 Responses to Q33 of the questionnaire 

Full  question:  If  you  believe  the  sectors  affected  by  the  green  transition  will  change  after 
2030, which sectors do you believe will be affected by then and how?  

In  total,  151  valid  open-text  responses  were  submitted  to  Q34.  Please  note  that  one 
response  can  be  included  in  multiple  themes.  Based  on  a  thematic  analysis  of  the  survey 
responses  to  Q34  questions,  the  top  3  identified  sectors  that  will  be  affected  by  2030  and 
how:  

•  The  energy  sector  (58  out  of  151  responses,  38%)  is  expected  to  undergo 
significant changes as part of the green transition. Respondents widely acknowledge 
the  need  to  phase  out  fossil  fuels,  particularly  coal  and  gas,  and  transition  towards 
renewable  energy  sources.  This  shift  will  require  substantial  investment  in  clean 
energy technologies and infrastructure. The sector will face challenges in adapting to 
these new technologies and ensuring a reliable and sustainable energy supply. Rapid 
decarbonization  is  seen  as  crucial  for  mitigating  climate  change  and  achieving  a 
greener energy system. 

•  The agriculture and food sector (28 out of 151 responses, 19%) is expected to be 
significantly  impacted  by  the  green  transition.  Respondents  stress  the  need  for 
sustainable  farming  practices  and  a  shift  towards  plant-based  agriculture.  This 
includes  reducing  the  intensity  of  animal  farming  and  promoting  agroecology  to 

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minimize  environmental  impacts.  Climate  resilience,  biodiversity  conservation,  and 
food  security  are  also  crucial  considerations  for  the  sector.  Transitioning  to  more 
sustainable  and  resilient  food  systems  will  require  changes  in  production  methods, 
land management practices, and consumer behaviours. 

•  The  transport  sector  (11  out  of  151  responses,  7%)  is  expected  to  experience 
transformative effects from the green transition. Respondents recognize the urgency 
of  reducing  emissions  and  promoting  sustainable  mobility.  The  transition  to  electric 
vehicles  (EVs)  and  alternative  fuels  is  seen  as  essential  for  reducing  reliance  on 
internal  combustion  engine  vehicles.  Furthermore,  improving  public  transportation, 
expanding rail systems, and encouraging car-sharing initiatives are highlighted as key 
strategies.  To  achieve  greener  transportation,  there  is  an  emphasis  on  reducing 
private car usage and promoting active transportation modes like walking and cycling. 

Figure  43  illustrates  the  survey  responses  to  the  Q34b  question,  displaying  the  total 
stakeholder  responses  (151)  in  the  first  column.  The  subsequent  columns  present  the 
identified themes grouped by stakeholder categories. 

Figure 43 Number of responses to Q34 grouped by identified themes and stakeholder groups 

3.3.6. Adapting to climate change 

The last part of the expert section involved one question on the right scope of regulation of 
EU’s  adaptation  needs,  especially  to  safeguard  and  ensure  resilience  of  the  economic 
sectors that are of high relevance for mitigation efforts. 

3.3.6.1. Q35: EU policy ambition on climate resilience of mitigation efforts 

As  Figure  44  shows,  on  average,  29%  of  all  respondents  believe  the  EU  should  draft  new 
legislation.  Around  18%  support  that  EU  should  do  more  to  promote  climate  resilience 
through  soft  measures  and  circa  20%  responded  that  EU  should  make  specific  provisions 
within exiting legislation. Only 5% believe that current EU legislation is sufficient. Finally, 28% 
has either replied I don’t know or not replied to this question.  

There are several differences across stakeholder groups. Academia/research institutions and 
EU citizens have replied that they think the EU should draft new legislation – here the share 
is around 40-50% of the respondents. For business associations and companies only a little 
more  than  10%  favour  new  legislation  while  25%  answers  that  EU  should  promote  climate 

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resilience  of  the  mitigation  effort  through  soft  measures.  For  public  authorities  the  share  in 
favour of soft measures is 28%, while only 11% reply that EU should draft new legislation.   

I n = 580 (Responses to the expert section of the questionnaire) 

3.4.  Results of the identified campaign 

Figure 44 Responses to Q35 of the questionnaire 

Among  the  responses  to  the  public  consultation,  one  campaign  is  identified.  In  total,  23 
responses  of  private  individuals  from  Slovakia  are  classified  as  part  of  a  campaign.  The 
identification  of  the  campaign  is  mainly  based  on  the  answers  provided  in  the  open-text 
question  Q11b,  where  respondents  are  given  the  opportunity  to  provide  an  open-text 
response  to  the  question  which  other  important  changes  the  expect  for  peoples’  daily  lives 
(see Section 3.2.3.3) The 23 responses provided coherent open-text narratives, emphasizing 
the  importance  of  politicians  avoiding  CO2-emitting  means  of  transportation.  Additional 
supporting  reasons  to  classify  the  responses  as  a  campaign  include  a  high  level  of 
agreement observed in the closed questions, that the responses were submitted during the 
final  days  of  the  consultation  period,  and  that  all  originated  from  the  specific  group  of  EU 
citizen from Slovakia.  

All  campaign  responses  only  submit  replies  to  the  general  section  of  the  questionnaire. 
Therefore,  the  expert  section  is  not  affected  by  the  identified  campaign.  To  avoid  possible 
bias  in  the  results,  the  campaign  responses  are  isolated  and  presented  separately.  This 
approach is in line with the requirements of the Better Regulation Toolbox #54. 

An insight into the consolidated views of the campaign is given in the following: 

• 

(Q1) Regarding the overall opinion on the EU’s climate ambition for 2040, most of the 
campaign  response  (19,  83%)  emphasize  that  the  EU  should  make  its  ambition 

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• 

• 

• 

• 

depend  on  other  countries’  climate  ambition.  Few  individuals  in  this  campaign  (4, 
17%) advocates for a slower transition than the current pace. 

(Q2) Almost all respondents did not provide a preferred net emission reduction target 
for 2040 (22, 96%). 

(Q3) Almost all replies indicated that it is better to have one target for reducing GHG 
emissions,  a  target  for  nature-based  carbon  removals  and  a  target  for  industrial 
removals with permanent storage (21, 91%). 

(Q6)  The  respondents  in  the  campaign  unanimously  disagreed  with  the  idea  that 
gender  aspects  should  be  considered  in  the  transition  to  climate  neutrality  (23, 
100%). 

(Q11b) In response to the open question about what other important changes can be 
expected for people's daily lives, respondents give coherent narratives and stressed 
the  importance  of  politicians  avoiding  CO2-emitting  modes  of  transport  (identifying 
attribute for the campaign). 

Overall, the  answers  in the  campaign  can  be  characterised  as  expressing  climate-sceptical 
beliefs and attitudes. In the other questions in the general section, for example, they show a 
significantly lower willingness to act on an individual level (e.g. to accept renewable energy 
infrastructure  or  to  buy  climate-friendly  products).  In  addition,  respondents  expressed  the 
expectation that climate change would have minimal impact on their daily lives, as they did 
not expect any dangerous effects from more frequent climate-related hazards. Nevertheless, 
they strongly agreed with aspects of a socially just transition by supporting the vulnerable in 
society to have access to sustainable and climate-friendly products and services. 

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4.  Analysis of the public consultation position papers 

Key messages of the public consultation position paper analysis: 
•  Overall, a strong support to the EC was expressed regarding the principle of setting 
the GHG target for 2040. There were however fewer responses regarding the overall 
level  of  ambition  to  be  set,  with  a  large  majority  of  opinions  advocating  for  an 
acceleration  (between  -80%  target  and  net  zero).  No  paper  called  for  a  slower 
transition, but some called for a careful feasibility analysis.  

•  A higher climate ambition would bring economic, environmental and social benefits. It 

would strengthen the EU leadership at the global scale, and foster innovation.  

•  To achieve the 2040 target, the EU will face multiple challenges, from a broad range 
of  perspectives:  technological,  financial,  social,  political  or  regulatory.  If  properly 
addressed,  these  challenges  could  however  become  enabling  factors  for  the 
transition.   

•  Among  the  sectors  that  should  further  reduce  their  GHG  emissions,  transport, 

agriculture and forestry, buildings and industry were particularly highlighted.  

•  The  ETS  plays  a  key role  for mitigating  EU  emissions,  and  will  continue to  do  so  in 
the  future.  It  however  needs  to  evolve  to  effectively  support  the  2040  target. 
Challenges  to  be  addressed  include,  among  others,  the  extension  of  the  sectoral 
coverage, the articulation with carbon removals, and the international articulation.    

•  Opposing  views  exist  on  the  role  of  CBAM,  with  stakeholders  considering  it  will 
become a key instrument and others that its efficiency is still unsure. Consequently, 
extension of CBAM is also a controversial issue.  

•  Views  on  the  ESR  are  scarcer,  but  opinions  expressed  indicated  a  potential  for 

adjustment, notably in articulation with ETS.  

•  To  tackle  agricultural  emissions,  several  options  were  underlined,  ranging  from 
sustainable farming to dietary changes or the role of agriculture as a carbon removal.  

•  Carbon removals are considered instrumental to reach climate neutrality, but should 

not deter GHG emission reduction at source. 

•  Some  support  exists  for  the  uptake  of  carbon  capture  and  storage  technologies. 
Views are mixed regarding the type of technologies. Concerns are expressed on the 
economic viability, the scale-up potential or the energy consumption.  

•  Among the barriers associated to CCUS, regulation, economic and technical barriers 

are the most commonly identified.  

• 

In  terms  of  technologies,  an  increased  share  of  renewable  energies,  better  energy 
efficiency  and  CCUS  are  identified  as  the  most relevant  solutions.  A  combination  of 
these technologies will be needed to achieve the target. The development of energy 
technologies  was  most  closely  associated  with 
for 
sustainability,  economic  development  and  innovation.  Economic,  infrastructure  and 
regulatory aspects are the most significant barriers.  

increased  opportunities 

•  The importance of a fair transition was clearly underlined.  

NB. Position papers are less consistent or comprehensive than surveys and by their nature 
focus on what the submitter believed to be a priority. In addition, respondent formulations to 

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to 

be 

need 

extent 

some 
and 
supporting/opposing/neutral  views.  Therefore,  counts  of  respondents  in  this  section  should 
be  treated  with  caution.  The  survey  provides  a  more  systematic  reflection  of  views.  These 
results  cannot  be  considered  statistically  significant  given  the  limited  number  of  papers 
providing opinions of each topic. However, with regard to the organisation’s influence, these 
opinions should nevertheless be considered. 

terminology 

interpreted 

common 

into 

4.1.  Overview  of  position  papers  selected  and  status  of 

analysis  

A  total  of  237  position  papers  were  received  from  the  public  consultation,  and  146  through 
the call for evidence (63 were submitted to both). In addition, a couple of additional papers 
were identified through desk-research. Based on a preliminary review and a selection agreed 
with DG CLIMA (removal of duplicates, relevance, type of stakeholder, previous contribution 
to IIA), 120 papers were thoroughly analysed. 

42  papers,  representing  more  than  a  third  of  the  papers  originated  from  business 
associations, 17 papers were analysed from public authorities (14%),16 papers (13%) came 
from  NGOs,  and  13  papers  from  private  enterprises  from  various  sectors  (11%,  notably 
companies from the transport and energy sectors as well as the manufacturing industry). The 
remaining papers included positions from Academia (12, 10%), Environmental Organisations 
(8, 7%), Trade Unions (2, 2%), Consumer organisation (1, 1%) and others (9, 8%).   

In terms of geographical distribution, a vast majority of the paper originated from EU Member 
States.  In  terms  of  Members,  Belgium,  with  53  papers  (44%),  Germany,  with  19  papers 
(16%) and Finland and the Netherlands, with 7 each (6%) represent the major contributors. 7 
papers (6%) originate from non-EU countries.  

The  sectoral  coverage  of  the  analysed  papers  is  broad,  with  44  papers  originating  from 
organisations  working  in  all  sectors  and  24  organisations  focusing  on  various  sectors.  For 
stakeholders  involved  in  a  single  sector,  the  most  frequently  represented  sector  was  the 
energy sector with 21 papers, followed by the manufacturing industry (12) and the transport 
sector (7). In addition, 7 positions from the sectors of land-use, land-use change and forestry 
were  analysed,  together  with  3  positions  from  the  finance  sector,  and  2  from  the  building 
sector.   

In  the  following  section,  identified  views  from  all  stakeholder  groups  concerning  multiple 
aspects  related  to  the  EU  2040  climate  targets  are  presented.  In  general,  because  of  the 
open nature of the position papers and the diversity of views presented it is difficult to draw 
any strong conclusions about responses from any stakeholder groups or a particular sector. 

4.2.  General  stakeholder  opinion  on  the  2040  target  and 
associated opportunities, challenges and enabling factors  

4.2.1. Level of ambition for 2040 target 

Of the position papers, 103 (86%) touched on the general topic of target setting for 2040 and 
the associated impact assessment. Almost all contributions mentioned that they support the 
Commission's  target  setting  process  in  principle.  Notably  2  position  papers  submitted  by 
public authorities say that in their view the target setting for 2040 should be postponed as it is 
still  too  uncertain  to  predict  the  impact  of  a  2040  target  and  that  the  implementation  of 
measures to achieve the 2030 climate targets should remain the primary objective. 

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Regarding  the  level  of  ambition  associated  with  the  2040  climate  target,  relatively  fewer 
contributions  provided  specific  statements.  A  total  of  41  papers (34%  of  the  total) analysed 
contained a specific statement on the level of ambition for the net emission reduction target 
for  2040.  Most  of  the  papers  that  included  a  specific  statement  (32)  advocated  for  an 
acceleration  of  the  transition  (more  than  -80%  target),  four  papers  argued  for  an  ambitious 
target without further specifying if this would involve an acceleration of the transition, and five 
argued for maintaining the current speed of the transition (75-80% target). 

In  the  group  arguing  for  an  acceleration  of  the  transition,  7  position  papers,  all  from  the 
stakeholder groups of environmental organisations and NGOs, called for a net zero target for 
2040.  Another  8  position  papers  argued  for  a  target  of  -90%  or  more  and  7  papers  for  a 
target  of  -80%  or  more.  The  remaining  10  position  papers  were  not  as  specific,  but  some 
referred  to  the  1.5°C  degrees  target  and/or  the  Paris  Agreement,  implying  an  ambitious 
interim target for 2040. 

There are no position papers that explicitly called for a slower transition. However, many of 
the  contributions  contained  statements  calling  on  the  Commission  to  undertake  a  critical 
review  of  the  practical  feasibility  of  an  ambitious  2040  target.  Aspects  mentioned  more 
frequently  included  an  analysis  of  the  enabling  environment  (e.g.,  financing,  availability  of 
renewable  energy,  development  of  energy  infrastructure),  impacts  on  competitiveness 
(carbon  leakage),  the  impact  on  energy  prices  and  the  cost-effectiveness  of  a  more 
ambitious target. Overall, these aspects can be summarised as deriving the 2040 target from 
the perspective of a realistic transition pathway for industry. 

Other  aspects  mentioned  about  the  target  setting  included  that  the  reliance  on  a  science-
based  approach  and  that  not  only  the  intermediate  target  but  also  the  carbon  budget 
approaches  are  of  high  relevance.  Additionally,  1  public  authority  advocated  for  setting  an 
additional  interim  target  for  2035,  which  would  be  aligned  with  the  five-year  timeframe  for 
Nationally Determined Contributions (NDCs). 

4.2.2. Opportunities related to a higher climate ambition 

57  papers  (48%  of  the  papers  analysed)  specifically  expressed  an  opinion  about  the 
opportunities related to higher climate ambition.  

22 of these submissions emphasized that a higher ambition towards climate neutrality would 
benefit  EU’s  economic  competitiveness  and  would  give  economic  actors  first-mover 
advantages  on  the  global  market.  In  this  context,  stakeholder  generally  stressed  the 
economic benefits of an ambitious transition. 

14  responses  indicated  that  a  higher  climate  ambition  would  help  to  create  new  jobs, 
particularly  in  the  green sector.  The  same  number  of  submissions  emphasised  that  a  more 
ambitious  transition  would  improve  EU’s  energy  security  and  decrease  the  current 
dependency on imported energy.  

Additionally, 8 stakeholders particularly felt that a higher climate ambition would reinforce EU 
leadership by delivering effective climate action as a role model on the global level. Another 
aspect  that  was  specifically  mentioned  by  7  responses  is  that  a  higher  ambition  towards 
climate  neutrality  would  enhance  the  development  and  deployment  of  innovations  and 
technologies (including, for example, circular solutions). 

Furthermore, 6 papers stressed that a higher climate ambition would give a clear signal that 
the EU economy embraces sustainable production and consumption models, including smart 
incentives and a higher degree of predictability for economic actors. 6 papers also mentioned 
that a higher climate ambition would help individuals and businesses lower their energy and 
climate bills.  

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3 submissions stressed that a higher ambition would improve our well-being. Moreover, the 
following  economic,  energy-related  and  social  aspects  were  explicitly  highlighted  as 
opportunities  by  two  responses  each:  help  to  decrease  economic  resource  dependencies, 
enhance  global  cooperation,  foster  a  fair  and  just  global  trade,  support  a  faster  energy 
transition,  mitigate  costs  to  societies  who  are  likely  to  suffer  from  climate  change,  to 
significantly  support  countries  of  the  Global  South  to  enable  mitigation,  and  simultaneously 
address the climate and the biodiversity crises.  

On  top  of  this,  the  following  economic  opportunities  were  mentioned  by  one  stakeholder 
each:  avoidance  of  high  costs  and/or  high-risk  technologies  in  pursuit  of  decarbonization, 
financial  stability,  enhancement  of  the  EU’s  location  advantage,  kick-start  of  the  hydrogen 
economy,  and  fostering  of  local  food  production  and  woodworking  industry.  Additional 
energy-related  and  social  aspects  also  highlighted  in  one  paper  each  included:  support  to 
decentralized renewable  energy  production,  acceleration  of  coal  phase out  or  the  transition 
of  the  transport  sector,  support  to  local  governments  to  achieve  climate  neutrality, 
implementation of long-term measures and improvement of the discussion on climate risks.  

4.2.3. Challenges  and  enabling  factors  related  to  the  climate  target  for 

A  total  of  89  submission  (74%  of  the  papers  analysed)  expressed  an  opinion  about  the 
challenges  and  associated  enabling  factors regarding  the  EU  climate  ambition  to  2040  and 
beyond.  Overall,  the  submissions  showed  that  the  EU  is  facing  multiple,  technological, 
financial, social, and political challenges.  

18  of  these  responses  explicitly  highlighted  political  and  administrative  challenges,  such  as 
regulative and administrative barriers, bureaucratic hurdles or unstable political commitment 
and  leadership.  Additionally,  this  challenge  encompassed  complex  requirements,  including 
the  need  for  appropriate  legal  frameworks  and  adequate  definitions  regarding  climate 
policies.  Sufficient  and  effective  (administrative)  coordination  and  cooperation  on  different 
political  and  stakeholder  levels,  including  the  prevention  of  overburdened  and  understaffed 
political  institutions,  were  also  rated  as  a  major  challenge.  Related  to  these  political  and 
administrative challenges, 4 responses anticipated that additional challenges may arise due 
to different interest on the national and EU level. Two stakeholders also explicitly mentioned 
the  competitive  geopolitical  context  as  a  crucial  barrier  for  the  EU  to  achieve  the  climate 
target for 2040. 

13  submissions  indicated  that  the  climate  transition  will  require  a  shift  in  investment  flows, 
ensuring that resources are appropriately allocated to climate-friendly economic activities. In 
this regard, respondents considered that this required shift was critical for EU to maintain its 
economic  competitiveness.  In  general,  financial  aspects  were  perceived  as  a  crucial 
challenge: seven respondents felt particularly concerned about increasing costs and prices, 
evoked by the green transition; six responses emphasised that a lack of financial resources 
represented  a  significant  hurdle,  and  five  submissions  specifically  stressed  that  avoiding 
financial burdens on citizens, workers and industries depicted a great challenge.   

Besides, regarding the role of technologies and energy supply, 13 responses indicated that 
the  development  and  deployments  of  new  technologies  and  solutions  represent  a  crucial 
challenge in order to reach the 2040 climate targets. In this context, hydrogen power seems 
to  be  of  high  importance  for  the  stakeholders.  Furthermore,  9  submissions  believed  that  a 
faster  expansion  of  renewable  energies  is  needed  to  reach  EU’s  climate  ambitions.  four 
responses  considered  that  an  improvement  in  energy  efficacy  is  necessary.  At  the  same 
time,  7  opinions  doubted  on  the  role  of  new  technologies  and  the  possible  acceleration  of 
energy  efficiency,  e.  g.  the  limitations  of  the  deployment  of  carbon  removals.  The  same 
scepticism  was  expressed  regarding  the  allocation  and  availability  of  affordable  green 

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electricity.  A  further  3  submissions  perceived  energy  security  as  a  major  challenge.  Hence, 
the  technology  and  energy  sectors  were  generally  evaluated  as  challenging  factors  in  the 
climate transition. 

Moreover,  11  stakeholders  emphasised  that  ensuring  a  fair  transition  poses  a  significant 
challenge  that  the  EU  must  consider  while  striving  for  climate  neutrality.  In  particular,  the 
responses  demanded  that  climate  policies  consider  the  needs  of  younger  and  following 
generations  as  well  as  countries  of  the  Global  South  to  achieve  a  fair  and  equitable 
distribution  of  global  mitigation  efforts  (regarding  the  social  costs  of  delayed  or  a  lack  of 
action).  On  top  of  this,  the  rights  of  workers  were  also  stressed  because  a  fair  transition  is 
only possible if workers are not subjected to exploitation.  

8  stakeholders  explicitly expressed  concerns regarding  the  limited  time  horizon to  keep the 
global  temperature  below  1.5ºC,  especially  when  considering  the  technical  time  frame  of 
measures that go beyond 2030 or 2040.  

When it comes to the role of the general public, 6 submissions found that public support is a 
critical challenge for climate ambition, particularly concerning behavioural and social change. 
On a related note, three stakeholders considered more awareness and education for citizens 
as crucial.  

On  the  economic  level,  3  submissions  stressed  that  balancing  between  a  free  and  a 
regulated market may be challenging in the context of the climate transition. Two responses 
considered the requirements of new economic models as a major hurdle, including the shift 
away  from  constant  growth.  Creating  adequate  incentives  for  business  to  become  climate 
friendly was rated as a further challenge by two stakeholders.  

An  additional  aspect  that  was  mentioned  by  4  stakeholders  represented  the  challenge  for 
hard-to-decarbonise sectors to reach climate neutrality, e. g. transport sector.  

Monitoring  and  reporting  on  the  evolution  of  GHG  emissions  and  supporting  small  and 
medium  enterprises  are  challenges  that  were  highlighted  by  three  stakeholder  each. 
Furthermore,  two  submissions  each  stressed  challenges  related  to  the  need  for  more 
research in the climate field as well as the establishment of a sustainable infrastructure in the 
transport sector as a requirement for a sustainable transition.  

Challenges  that  are  brought  up  by  single  submissions  included:  green  washing,  ocean 
protection, lack of level playing field, policies to scale up CCS, reducing energy demand, the 
skill  gap,  and  the  risk  of  new  dependencies  on  resources  and  raw  material  as  well  as  the 
support of vulnerable households who may struggle during the climate transition.  

Next to these major challenges, 80 stakeholders explicitly emphasise enabling factors related 
to the climate target for 2040. In general, the submissions centred around political, financial, 
and  technological  aspects  that,  if  approached  adequately,  can  operate  as  enablers.  There 
are significant overlaps between the identified challenges and enabling factors, suggesting a 
fine line between what withholds and what accelerates the EU’s climate transition.  

52  responses stress  that  political  and  administrative measures  are  powerful to  promote  the 
climate  transitions.  These  submissions  particularly  highlight  the  positive  effect  of  robust, 
holistic,  and  inclusive  frameworks  that  support  and  incentivise  sustainable  decisions.  Such 
frameworks  and  binding  legislations  will  ensure  long  term  predictability,  stability,  and 
transparency,  which,  in  turn,  are  perceived  as  meaningful  conditions  that  can  operate  as 
enabling  factors.  In  this  regard,  stakeholders  emphasize  that  such  frameworks  should  also 
encourage  the  development  of  technologies  and  innovations,  facilitating  a  streamlined 
process  with  less  bureaucracy  and  faster  deployment.  The  potential  of  collaborations  at 
different  political  levels  represents  another  political  and  administrative  aspect  that  the 
responses explicitly name as critical enabling factor. In this context, some submissions argue 

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for  EU-wide  legislations  and  regulations  whereas  other  responses  demand  more  room  for 
local  decision-making.  A  strong  political  will  and  staple  commitment  are  deemed  essential 
driving  forces  to  achieve  the  2040  climate  target.  Furthermore,  stakeholders  acknowledge 
the  importance  of  enhancing  existing  regulations  like  the  EU  ETS  and  CBAM  for  their  full 
transformative potential. 

Apart  from  the  role  of  political  and  administrative  action,  15  submissions  point  out  to 
sophisticated investments and financial fundings as enabling factors in the climate transition. 
These  factors  contribute,  again,  to  economic  predictability  and  facilitate  the  deployment  of 
necessary  technologies,  innovations,  and  transformations.  The  enabling  dimension  of  new 
technologies  and  solutions  is  stressed  in  further  12  responses,  including  the  role  of 
digitalisation, hydrogen power, energy supply in general and research. The positive potential 
of innovations is explicitly highlighted in a further 7 submissions.  

Regarding the energy sector, 5 stakeholders perceive the expansion of renewable energies a 
meaningful  catalyst  of  the  climate  transition  and  4  respondents  believe  that  a  further 
improvement in energy efficiency will help to reach the 2040 climate target.  

Additionally,  3  submissions  explicitly  mention  that  monitoring  and  reporting  of  EU  and 
national  emissions  are  enabling  factors  related  to  the  2040  climate  target.  2  responses 
highlight the potential of sufficient and skilled workforces as another crucial enabling factor.  

The  woodworking  industry  as  well  as  forests  and  forest-based  sectors  are  also  seen  as 
potential enabling forces by 3 stakeholders. 2 submissions also point out to carbon capture 
and storage as an enabling factor.  

On  top  of  this,  the  following  enabling  factors  are  highlighted  by  1  submission  each: 
establishing free markets where effective, focusing on effective carbon management (e. g. in 
the  agriculture  sector),  combining  behavioural  and  technological  changes  and  promoting 
public support as well as targeting companies responsible for the climate crisis.  

4.2.4. Linkage  of  an  ambitious  climate 

target 

to  climate  change 

When  it  comes  to  the  connection  between  climate  change  mitigation  and  climate  change 
adaptation,  and  particularly  how  to  regulate  sectors  essential  for  mitigation  efforts  but 
impacted  by 
transport 
infrastructure,  or  land-use),  only  a  small  number  of  position  papers,  6  out  of  120,  offer 
specific feedback. 

the  effects  of  climate  change  (e.g.,  energy 

infrastructure, 

Among these, one position paper advocates for the implementation of a Climate Adaptation 
Law  that  should  be  guided  by  nature-positive  principles,  prioritizing  people  and  equity,  and 
guided by investing in future capacity to enhance climate resilience within the EU. 

Additionally,  2  other  papers  emphasize  the  significance  of  joint  planning  for  both  climate 
change  mitigation  and  adaptation  to  identify  co-benefits  and  trade-offs  between  these 
measures. Another paper suggests implementing provisions within the existing framework to 
better support the development of a resilient industry. 

One position paper highlights the necessity for society to adapt to reduced water availability 
as another key impact in addition to the escalating occurrences of extreme weather events. 
Lastly,  one  paper  points  out  the  potential  of  sustainable  finance  in  driving  climate  change 
adaptation. 

Impact of climate policies on SMES  

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17 position papers (14% of the total) provided opinions on the impact of climate policies on 
SMEs.  These  notably  included  12  companies  and  business  associations,  one  organisation 
from research and academia and one NGO.   

Overall,  the  respondents  do  not  expect  negative  impacts  on  SMEs  provided  that  the 
administrative  burden  does  not  increase,  and  that  support  and  resources  are  provided  to 
cope  with  the  needed  transition,  with  the  principle  of  fair  transition  underlined  in  many 
instances. On the contrary, climate policies could be a trigger for innovation, growth and for 
job-creation at SME level.  

4.3.  General  stakeholder  opinion  on 

the  contribution  of 

Individual sectors to the EU's climate ambition 

Position  papers  have  been  analysed  with  regards  to  priority  sectors  that  should  further 
reduce their GHG emissions, to sectors expected to reach climate neutrality first. 

Around  70  position  papers  (58%  of  all  answers)  provided  opinions  on  the  prioritisation  of 
sectors and the following sectors were singled out: transport; industrial processes and waste; 
production  of  electricity  and  district  heating;  buildings  (residential  and  services);  LULUCF; 
energy  intensive  industries;  fertilisers;  ETS  sectors;  oil  and  mining;  food;  pharmaceuticals; 
and HORECA. 

4.3.1. Priority sectors that should further reduce their GHG emissions 

A  number  of  policy  papers  identified  the  following  sectors  as  priority  for  GHG  emission 
reduction:   

•  Transport. 24 position papers identified the sector as priority to further reduce GHG 
emissions,  originating  from  the  following  stakeholder  groups:  companies  and 
business associations (10, out of these 4 are related to emission trading and different 
modes of transport), NGOs (3), Public Authorities (3) and academia (2) and Other (4). 

•  Agriculture and forestry. 14 position papers identified the sector as priority to further 
reduce  GHG  emissions,  originating  from  the  following  stakeholder  groups:  Public 
Authorities 
(2)  and 
Environmental  organisations  (2),  academia  (1);  Other  (3).  One  of  the  business 
associations prioritising this sector comes from the forestry sector.  

(4),  companies  and  business  associations 

(2),  NGOs 

•  Buildings. 11 position papers identified the sector as priority to further reduce GHG 
emissions,  from  various  stakeholder  groups:  companies  and  business  associations, 
academia,  consumer  organisation.  It  is  worth  noting  that  the  business  associations 
prioritising  buildings  represent  producers  of  materials  (glass,  wood)  used  in  building 
renovations.  

• 

Industry.  10  position  papers  identified  the  sector  as  priority  to  further  reduce  GHG 
following  stakeholder  groups:  Academia  (3); 
emissions,  originating 
companies and business associations (2); NGOs (2) and Environmental organisations 
(2) and Other (1). One of the business associations prioritising this sector is of SMEs.  

from 

the 

4.3.2. Sectors expected to reach climate neutrality first 

14 position papers (12% of all answers) dwell on the issue of which sectors are or should be 
expected  to  reach  climate  neutrality  first,  from  all  stakeholder  groups,  with  business 
associations representing half the opinion expressed. Buildings have been identified 4 times 

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as the sector expected to reach climate neutrality first. 2 of the businesses associations have 
identified buildings are of industries relevant to building renovation and decarbonisation.  

The  number  is  very  low  to  draw  any  meaningful  conclusions.  However,  there  are  some 
indirect  opinions  on  the  topic  which  are  worth  mentioning.  Transport,  AFOLU  and  energy 
have been identified once each. 

Despite  the  low  number  of  answers  some  noteworthy  insights  were  communicated. 
According to several organisations (industry and consumer associations), scientific evidence 
and  cost-benefit  analysis  is  needed  to  accurately  rank  sectors  based  on  their  expected 
timeline for reaching climate neutrality. Several stakeholders identified transport as the sector 
with  the  most  potential  for  further  GHG  emission  reductions  in  the  coming  years,  including 
through  modal  shift  (e.g.,  rail).  Two  papers  indicated  the  building  sector.  The  key  role  of 
policy  and  enabling  factors  to  drive  cost-effective  abatement,  and  notably  the  ETS  for  the 
energy sector, were underlined.  

4.4.  General  stakeholder  opinion  on 

the  role  of  policy 

instruments 

4.4.1. Role of EU ETS post-2030 

63  papers  (53%)  commented  specifically  on  the  role  of  the  ETS  post-2030.  25  business 
associations,  representing  a  wide  range  of  sectors  (including  energy,  manufacturing 
industries,  transport,  LULUCF,  finance  or  buildings),  10  public  authorities,  8  companies,  8 
NGOs, 4 environmental organisations notably expressed an opinion.  

An overwhelming majority considered the EU ETS as an instrument playing a key role in the 
mitigation of EU emissions and that will continue to do so in the future. It contributed to set a 
price  on  carbon  for  European  stakeholders,  and  in  articulation  with  other  policies,  having  a 
positive impact on the continuous decrease of European emissions. Nonetheless, a majority 
of  stakeholders  considered  that  an  evolution  of  the  tool  in  relation  to  the  2040  target  is 
needed.  

The most widely discussed topic was the sectoral coverage. Extension to all or to a restricted 
number of additional (economic) sectors was suggested in more than one third of the papers 
analysed, from  all  stakeholder  groups.  A  better coverage  of  transport,  including  for  aviation 
and  maritime  activities  not  covered  in  the  current  system  was  notably  mentioned  several 
times. Only one paper, from a business association, advised not to extend to other sectors. 
The  integration  of  all  activities  in  a  single  system  was  also  discussed,  with  some 
stakeholders  advising  for  keeping  separate  systems  as  this  is  currently  the  case  (or  even 
creating  new  systems  for  agriculture)  and  others  suggesting  merging  the  systems  in  a 
medium  to  long-term  perspective.  The  articulation  with  other  policies  and  instruments  (e.g. 
ESR, LULUCF, CBAM) was also discussed in about 10 papers, with opinions expressed by 
business  associations,  public  authorities  and  companies.  Concerns  were  expressed  about 
the  risk  of  double-coverage,  translatability  of  ETS-prices  to  CBAM-prices  and  scope 
coverage.       

A second topic that was discussed in about a third of the papers was the articulation of the 
ETS  with  carbon  removals,  to  ensure  operability.  Most  stakeholders  but  two  supported  an 
integration  of  carbon  removal  in  the  ETS  (a  business  association  and  an  environmental 
organisation).     

A  third  topic  indicated  in  a  significant  number  of  papers  concerned  the  international 
articulation  of the  ETS, and  linkages  to  be  established  with systems  in  third  countries/other 
regions. For aviation, the compatibility with CORSIA was notably underlined.     

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Other topics discussed in the papers concerned the importance of predictability and stability 
of the ETS, the overall cap (with several stakeholders calling for a more stringent cap), the 
issue of hard-to-abate sectors, the extension to non-CO2 GHG (with an issue of accounting), 
the  relationship  between  the  ETS  and  the  fair  transition,  the  use  of  the  innovation  fund  to 
support  industrial  projects,  the  extension  to  all  fossils-fuels  or  the  avoidance  of  the 
application of the cross-sectoral-correction factor.  

Finally,  two  papers  called  for  the  abolishment  of  the  mechanism,  and  expressed  doubts 
about  the  usefulness  of  market-based  solutions  to  steer  greenhouse  gases  emissions 
decrease  compared  to  binding  sectoral  targets  and  ban  of  the  most-emissive  activities  per 
capita  (e.g.  private  jets).  One  also  emphasized  on  transfer  effects  and  the  potential 
detrimental impacts on most vulnerable people.   

4.4.2. Role of CBAM 

39  papers  (33%)  provided  elements  on  the  role  of  CBAM.  20  business  associations, 
(covering  either  several sectors,  manufacturing  industries  or  energy),  5 public  authorities, 5 
companies,  4  NGOs,  1  environmental  organisation,  1  consumer  organisation  and  1 
academic/research institution notably expressed an opinion.  

The  most  discussed  topic  was  the  role  of  CBAM,  with  28  papers  commenting  the  matter, 
from  all  stakeholder  groups.  Most  of  the  papers  supported  the  view  that  CBAM  plays  an 
essential  role  to  avoid  carbon  leakage  and  to  support  carbon  market  internationalisation. 
However,  more  than  a  third  were  doubtful  and  considered  that  CBAM  efficiency  should  be 
demonstrated,  in  light  notably  of  its  effects  along  the  whole  value  or  potential  trade  policy 
countermeasures. One  stakeholder  considered that  CBAM  is  ineffective. It  should  be  noted 
that  opinions  differed  among  stakeholder  groups:  for  instance,  4  business  associations 
considered  that  CBAM  was  essential,  while  8  considered  that  its  efficiency  should  be 
demonstrated.  

The  second  most  discussed  topic  concerned  CBAM  extension.  Views  expressed  in  22 
papers,  from  all  stakeholder  groups,  were  also  differing.  Almost  two  thirds  of  the  papers 
considered that CBAM should be extended: to sector at most risk of carbon leakage, to cover 
the  export  part  of  the  EU  production,  to  integrate  downstream  sectors  or  cover  all  sectors 
covered by free allowances under the ETS. The last third considered that a CBAM extension 
should  be  carefully  considered.  It  was  not  possible  to  draw  conclusions  at  the  stakeholder 
group level, as views differed among the same type of stakeholders.  

The last topic discussed in the papers concerned the allocations, with 7 opinions stemming 
mostly  from  business  associations  and  NGOs.  Opinions  are  mixed,  with  about  half 
considering  that  sectoral  free  allocations  are  needed,  while  the  other  half  considering  free 
allocations  should  be  stopped.  One  stakeholder  advocated  for  a  reduction  feeding  the 
Innovation Fund.  

4.4.3. Role of ESR 

23 papers (19%) expressed an opinion on the role of ESR. 8 business associations covering 
various  sectors,  5  public  authorities,  4  companies,  3  NGOs,  2  environmental  organisations 
and 1 academic/research institution notably expressed an opinion.  

A bit less than half the papers, from all stakeholder groups, expressed the need to adjust the 
ESR,  notably  given  the  broadening  scope  of  the  ETS.  Another  suggestion  expressed  by  2 
stakeholders is a target break down at sectoral level or per type of carbon removal. One fifth 
of the papers consider that ESR plays an important role, and that it should be strengthened, 
with  national  targets  kept.  One  business  association  considers  the  ESR  as  currently 
ineffective. One public authority considered that the ESR should keep the same scope.    

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4.5.  General stakeholder opinion on the land sector 

4.5.1. Options to tackle agricultural emissions 

Approximately 44 of the analysed papers (37% of the total) commented on options to tackle 
agricultural  emissions.  Out  of  these,  business  associations,  public  authorities  and  NGOs 
were the most common stakeholder groups. The most frequently mentioned options to tackle 
agricultural  emissions  were  sustainable  farming/carbon  farming  (9)  followed  by  a  focus  on 
dietary  changes  (7)  and  the  role  of  agriculture  as  a  carbon  removal  (7).  Other  frequent 
options  mentioned  were  some  form  of  market  incentives  and  to  not  include  the  agricultural 
sector in LULUCF.  

However,  there  were  different  views  on  the  options  to  tackle  agricultural  emissions 
depending on the kind of organisation. While a focus on carbon farming/sustainable farming 
was the most common option on an aggregated level for all organisations, this was only the 
case  for  the  stakeholder  groups  “public  authority”  and  “other”.  For  academia/research 
institutions,  the  most  common  option  mentioned  was  a  change  in  diet.  This  was  also  the 
case  for  environmental  organisations.  For  business  associations  this  was  market-based 
solutions  such  as market  incentives  and the  EU ETS.  For  NGOs,  the most  common  option 
mentioned was the role of agriculture as a carbon removal.  

4.5.2. Stakeholders targeted by a carbon price on agricultural emissions 

Only  seven  of  the  analysed  papers  (6%  of  the  total)  commented  specifically  on  which 
stakeholders  should  be  targeted  by  a  price  on  agricultural  emissions.  Opinions  originated 
from NGOs and environmental organisations (notably focusing on agricultural issues), other 
stakeholders and academic research institutions.  

Out  of  these  papers,  all  referred  to  companies  as  the  main  stakeholders  to  targeted  by  a 
carbon price, and 5 of them specifically mentioned large companies. Two papers additionally 
mentioned individual consumers and farmers. Several papers expressed concerns on carbon 
pricing about the unnecessary burden on (small) farmers, potential lock-in effects in intensive 
farming  practices  and  impacts  due  to  transfer-effects  on  low-income  households.  A  more 
specific action mentioned against companies included the obligation to pay a CO2-equivalent 
tax  for  food  sold.  One  paper  stated  that  while  a  carbon  price  at  the  farm  level  may  seem 
desirable, it raised concerns such as administrative burden and disproportionate impacts on 
small farms that are financially more vulnerable. The paper instead argued that the focus of a 
carbon price should be on large agricultural food actors.  

4.6.  General  stakeholder  opinion  on 

the  role  of  carbon 

removals 

Approximately  73  papers  (61%  of  the  analysed  papers)  commented  on  the  role  of  carbon 
removals  to  reach  2040  climate  neutrality  goals.  Among  those,  the  different  stakeholder 
groups  were  represented  in  the  following  way:  companies  and  business  associations  (34); 
public  authorities  (11);  academia  (10);  NGOs  (10);  environmental  organisations  (7);  others 
(5). Papers covered various aspects of the issue.  

4.6.1. Nature-based vs technological removals 

Most  papers  acknowledged  carbon  removals  as  an  important  means  to  reach  climate 
neutrality goals, yet reservations and concerns were shared in 15 position papers, in several 
contexts.  While  most  papers  acknowledge  the  importance  of  carbon  removals,  they 

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emphasised  they  should  not  be  a  substitute  and  offset  for  GHG  emission  reduction  and 
should only be considered as a second best option. Further, several stakeholders underlined 
that  current  assumptions  about  future  GHG  removals  are  overall  too  optimistic,  and  the 
potential  for  technological  removals  to  be  economically  scaled  up  still  needs  to  be 
demonstrated.  The  papers  originating  from  stakeholders  with  strong  environmental  focus 
have  a  strong  preference  for  nature-based  removals  over  technological  ones,  but  2  papers 
warn that nature-based removals are unstable and could not be relied upon in the long run. 
Inversely,  a  EU  carbon  technology  platform  points  out that  a  stronger reliance  on  industrial 
removals is needed as the Land use, land-use change, and forestry (LULUCF) sink does not 
allow to achieve permanent removals. 

4.6.2. Targets for carbon removals 

5  papers,  from  various  stakeholder  groups,  shared  an  opinion  on  the  types  of  carbon 
removal  targets  to  be  introduced.  Several  papers  point  out  that  legally  binding  EU-wide 
targets should be set for increasing the EU’s net sink. Papers disagree on the need to set up 
a  common  or  separate  target  for  nature-based  and  technological  removals.  A  big  industrial 
association believes that setting separate targets may provide further incentives to scale-up 
carbon removal technologies. 

4.6.3. Role of different types of removals 

Approximately 40 papers commented on the role of carbon removals to reach 2040 climate 
neutrality  goals.  Among  those  the  different  stakeholder  groups  were  represented  in  the 
following  way:  14  companies  and  business  associations;  7  public  authorities;  7  NGOs;  5 
environmental organisations; 4 others; 3 academia. 

Several  forestry  associations  and  a  business  association  emphasised  the  importance  of 
forests  as  a  carbon sink,  and that  active  forest management  is  important  to  achieve this.  3 
stakeholders  (a  think-tank,  an  environmental  industry  of  a  coal  producing  country  and  a 
company)  argued  that  carbon  capture  would  play  an  important  role,  for  energy-intensive 
industries  to  reduce  hard-to-abate  emissions  or  for  achieving  a  net-zero  aviation  industry. 
Another think-thank considered that oceans play a major role in regulating the global climate 
by absorbing a large proportion (25–30%) of anthropogenic CO2 emissions. According to an 
industrial  association  of  wood  industries,  agricultural  removals  should  not  be  treated  the 
same  as  other  nature-based  removals  as  this  could  lead  to  a  situation  where  the  forest 
sector  offsetting  emissions  from  other  sectors.  Finally,  according  to  a  bioenergy  industry 
association,  large-scale  applications  of  bioenergy  solutions  in  district  heating,  biofuels 
production,  and  industry  are  necessary  for  cost-effective  carbon  dioxide  removals  through 
Bioenergy with Carbon Capture and Storage (BECCS). 

4.7.  General  stakeholder  opinion  on  carbon  capture  and 

storage/use 

4.7.1. Role of different carbon capture and storage technologies 

Out  of  the  120  papers  reviewed,  34  papers  (28%)  commented  specifically  on  the  role  of 
different  carbon  capture  and  storage  technologies.  Business  associations  (14),  public 
authorities  (4)  and  others  (4)  were  the  most  common  stakeholder  group  to  comment.  All 
other  groups  come  right  after,  with  very  few  papers  mentioning  CCUS,  except  for  trade 
unions, which has no paper mentioning it. 

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15  papers,  from  business  associations,  academic  institutions  and  public  authorities  encouraged  the 
uptake  of  carbon  capture  and  storage  technologies,  without  assigning  priority  to  one  specific 
technology type.  

 emissions to 
Looking  at specific technologies, 9 papers referred to CCS as  a  priority to reduce CO
low  levels,  with  4  discussing  the  role  of  BECCS  in  extending  carbon  storage  facilities.  4  papers 
including  a  different  range  of  stakeholders:  (NGOs,  Aviation  associations  and  energy  business) 
commented  on  CDR,  and  most  specifically  DAC,  as  having  a  high  potential  for  reaching  net-zero 
emissions, especially in the aviation sector.  

₂

In  general,  non-governmental  institutions  and  other  actors  did  not  support  carbon  capture 
technologies, issuing concerns over its viability as a solution for achieving climate change targets and 
the  potential  for  detracting  from  emission  reduction  efforts.  One  non-profit  organisation  argued  for 
caution  when  relying  on  carbon  offsets,  as  the  approach  provides  no  guarantees  on  “locking-in” 
carbon for the future. Three stakeholders considered carbon capture technologies would have limited 
effects on GHG emission reduction targets due to their large costs and energy requirements.  

4.7.2. Challenges associated to CCUS 

41  papers  commented  on  specific  barriers  (34%  of  the  total),  with  many  among  these 
mentioning  multiple  challenges.  Business  associations  (13),  NGOs  (8),  companies  (7),  and 
academia  (4)  are  the  stakeholder  groups  with  most  papers  commenting  on  the  topic.  The 
most  encountered  barriers  associated  with  the  deployment  of  CCUS  are  economic, 
regulatory, technical and infrastructure.  

Regulatory  and  legal  barriers  emerged  as  one  of  the  main  barriers  encountered,  with  16 
papers referring to these challenges. Business, academic actors and NGOs argued the legal 
framework in place for carbon capture and storage technologies should be revised. A robust 
certification framework is required to establish high quality standards and ensure the integrity 
of carbon removal technologies. For the aviation sector, the integration with frameworks such 
as  ICAO  CORSIA  or  EU  ETS  would  support  the  emergence  of  a  carbon  removal  market. 
Moreover, regulatory gaps were mentioned in national frameworks, where the absence of a 
national  legal  basis  to  use  CCUS  or  provisions  supporting  Net  Zero  Industry  Act  increased 
uptake barriers. Complex permitting procedures (e.g. CCUS on industrial scale is banned or 
limited  in  certain  Member-States)  and  unclear  rules  applying  to  the  accounting  of  captured 
emissions were additional hurdles highlighted by industry actors.  

15 stakeholders commented on the economic barriers which prevent the large deployment of 
CCUS. A few papers mentioned that CCUS did not have an economic rationale now due to 
the  large  investments  required  and  the  restrictive  price  of  the  technologies.  Moreover,  the 
energy  intensiveness  rendered  CCUS  reasonable  only  for  large  scale  application  without 
more efficient alternatives (e.g. in the cement sector). Capture, transport, and storage costs 
were also mentioned as significant financial barriers.  

12  papers  mentioned  concerns  over  the  technical  and  infrastructure  reliability  of  the 
technologies,  as  well  as  the  varying  degrees  of  efficiency.  The  progress  for  large  scale 
application of CCUS has been slow. Papers mentioned there were controversies surrounding 
the  capacity  to  transport  and  store  gases  underground  without  leakages,  as  well  as  the 
availability  of  resources,  locations,  and  potential  for  long-term  geological  storage  of  CCUS. 
Focusing  on  sustainability,  environmental  organizations  and  business  actors  mentioned  a 
large-scale  deployment  of  CCUS  technologies  would  require  a  significant  number  of 
resources (e.g. availability of affordable electricity) which may impact negatively the sectors 
producing them or relying on these resources.  

Three  papers  dismissed  CCUS  as  a  relevant  solution  for  meeting  climate  targets  or 
considered  moral  issues  surrounding  the  technology:  framing  carbon  dioxide  removals  in  a 
same  manner  as  emission  reduction  detracted  from  achievement  of  global  climate 

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objectives.  Challenges  remained  also  due  to  public  acceptance  and the  scalability  potential 
of CCUS. 

4.8.  General stakeholder opinion on energy technologies 

4.8.1. Most relevant solutions for the energy transition  

72  papers  (60%)  discussed  the  most  relevant  technologies  for  supporting  the  energy 
transition, as well as opportunities and barriers of their uptake. More than one fourth of the 
papers  give  an  idea  of  the  importance  of  renewable  energy,  energy  efficiency  and  carbon 
capture technologies as the most viable solutions for the energy transition.  

33 position papers argued for enhancing the utilization of renewable energies and increasing 
their  share  in  energy  consumption.  Moreover,  15  papers  supported  applying  energy 
efficiency  principles  and  taking  into  consideration  the  beneficial  interaction  between 
renewables, increased energy efficiency and GHG targets. The expansion of electricity grid 
systems  and  electricity-related  technologies,  as  well  as  the  smart  electrification  of 
renewables, were suggested as the most viable solutions for the energy transition. Business 
stakeholders,  one  trade  union  and  two  NGOs  supported  carbon  capture  and  storage  as  a 
measure to reduce hard to abate emissions.  

22  papers  did  not  assign  a  specific  priority  to  the  technologies  mentioned  or  referred  to 
several  types  of  technologies,  arguing  for  technology  neutrality,  as  the  choice  between 
different  technologies  should  remain  market  driven.  For  energy  technologies,  stakeholders 
identified  renewable  energy  sources,  energy  efficiency  and  CCUS  as  the  most  relevant 
solutions for the energy transition. 

Among  all  the  stakeholder  groups,  business  associations  and  public  authorities  were  most 
receptive  to  a  diversified  mix  of  energy  technologies  solutions.  Academic  institutions  were 
more inclined towards energy efficiency and renewable energy or preferring to not prioritize. 

4.8.2. Opportunities associated with energy technologies 

Out of the 120 position papers reviewed, 68 (57%) mentioned opportunities associated with 
energy  technologies.  Overall,  the  development  of  energy  technology  was  most  closely 
associated  with  increased  opportunities  for  sustainability,  economic  development  and 
innovation in the position papers reviewed.   

32  stakeholders,  among  which  business  associations,  companies,  academia  and  NGOs 
were  the  most  likely  to  mention  sustainability  opportunities.  Breakthroughs  in  energy 
technologies  could  indeed  allow  energy-intensive  industries  to  reduce  hard  to  abate 
emissions. For instance, several technologies could play an important role in decarbonizing 
the  aviation  sector,  from  carbon  removal  to  fossil  free  technologies.  Similarly,  hydrogen-
based  steel  making,  power  to  heat,  chemical  recycling  and  CCUS  could  facilitate  the 
transition in the cement sector. 

19 papers highlighted economic gains. The papers emphasized that investing in new energy 
technologies  would  create  enhanced  financial  gains,  lower  costs  for  consumers  and 
strengthen  competitiveness  for  European  businesses.  New  innovative  energy  solutions  are 
essential for a steady European energy supply and to increase the emergence of competitive 
industrial  start-ups.  For  instance,  a  national  Energy  Ministry  expected  investments  in  new 
energy technologies would result in the creation of 300,000 jobs in high potential industries, 
such  as  nuclear  power,  electromobility,  grid  infrastructure,  digitalization,  and  thermal 
modernization of buildings. 

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11  stakeholders  highlighted  that  the  development  of  energy  technologies  would  bring 
additional incentives for innovation and research, with positive spill overs in many industries. 
For  instance,  one  paper  mentioned  the  development  of  bioenergy  would  play  an  important 
role in decarbonizing several sectors, including transport, electricity, and heating and cooling.  

Three  business  associations  and  one  public  authority  argued  for  technology  neutrality, 
mentioning  all  options  including  nuclear  energy  should  be  considered  for  a  technology 
neutral  approach  to  meet  climate  targets  in  a  cost-efficient  way.  Other  actors  such  as  a 
national government mentioned social benefits related to the implementation of a plan meant 
to  decarbonize  the  country’s  public  transport  sector,  which  would  lead  to  frequent  and 
broader transport coverage, as well as easing pressure of the housing market.  

4.8.3. Challenges associated with energy technologies  

52  papers  (43%)  discussed  the  different  challenges  in  the  development  of  energy 
technologies,  with  economic,  infrastructure  and  regulatory  as  the  most  significant  barriers. 
Companies,  business  associations  and  non-governmental  associations  were  the  most 
common stakeholder group to comment.  

Economic  barriers  were  mentioned  by  almost  all  stakeholders,  highlighting  several 
dimensions.  The  introduction  of  innovative  technologies  at  an  industrial  scale  would 
increases  challenges  for  regional  energy  intensive  industries,  such  as  the  metals  industry 
facing competition from countries not applying a carbon price. Moreover, the development of 
new technologies requires large upfront costs and long investment cycles. 

Infrastructure  reliability  (wind  and  solar  power  demand  additional  space)  and  compatibility 
with renewable energy (adaptation of power and gas grids, hydrogen and CO
 transport and 
storage, expansion of grid sources, adapting multimodal interchange hubs) were among the 
key  concerns  of  the  position  papers.  Challenges  remain  for  solar  PVs  and  electric  grid 
systems, including rigidity and lack of available grid connections. 

₂

Businesses associations, companies and NGOs were the most common stakeholder to face 
regulatory  and  legal  barriers  in  the  development  of  energy  technologies.  New  legislative 
frameworks  and  regulatory  predictability  are  needed  to  facilitate  the  development  of  new 
energy technologies and incentivize consumers and operators to invest in such technologies. 
Moreover, long and complex permitting procedures and public opposition are barriers to the 
accelerated development of Renewable Energy Storage (RES) projects.  

In addition, companies and business associations raised concerns over limited availability of 
rare resources  needed for  energy  technology  development.  A  small  number  of  papers  also 
raised concerns on data privacy. Public authorities and non-governmental institutions, as well 
as one business association, highlighted that the deployment of new technologies should be 
implemented in sustainable way, accounting for environmental and social welfare. 

4.9.  General  stakeholder  opinion  on  other  options  to  be 

considered 

36  of  the  analysed  position  papers  (30%)  discussed  alternative  options  to  limit  climate 
change. Among these, business associations (8) followed by individual companies (7) were 
the  most  common  stakeholder  groups  to  comment.  The  analysed  papers  argue  for  various 
alternative solutions, which are presented below.  

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4.9.1. Carbon sequestration  

9 stakeholders brought up carbon sequestration as a feasible option. All stakeholder groups 
were  represented  among  these  organisations  in  an  even  way.  The  majority  of  the 
organisations  discussed  the  possibilities  of  carbon  storage  through  soil  sequestration  and 
forestry. One illustrative example is a business association arguing that the EU, to a higher 
degree, should promote wood-based carbon storage together with creating better conditions 
for  sustainable  forest  management  as  means  for  limiting  climate  change.  In  addition,  one 
company  emphasised  the  role  of  carbon removal  technologies  for  hard-to-abate  emissions. 
Two significant technologies discussed in this regard are biochar carbon removal (BCR) and 
enhanced  weathering  (EW),  which  were  stated  to  offer  promising  solutions  for  long-term 
carbon sequestration and sustainable climate mitigation. 

Additionally, 2 papers emphasised the possibilities of ocean-based carbon sequestration. For 
instance,  one  research  institution  argued  that  future  climate  policy  frameworks  should 
incorporate  and  create  better  conditions  for  solutions  such  as  the  expansion  of  seagrass 
beds to capture carbon.   

4.9.2. Waste-to-Energy  

3 stakeholders (2 business associations and an organisation representing local governments 
in a Member State) argued that the concept of waste-to-energy should be incorporated into 
future policy frameworks.   

One  business  associations  emphasised  the  possibilities  of  leveraging  the  full  potential  of 
concrete  recycling  and  using  waste  streams  to  lower  the  concrete  sector’s  emissions. 
Another  organisation  stated  that  the  Commission  has  a  very  negative  view  of  waste-to-
energy  (WtE)  even  though  there  is  currently  an  under-capacity  in  the  EU,  with  waste  still 
being landfilled or incinerated without energy recovery. The organisation furthermore argued 
that the Commission should create better conditions for more efficient WtE in the foreseeable 
future.  

4.10. General  stakeholder  opinion  on  engagement  and  social 

impacts 

57 analysed position papers (48% of the total) discussed the social impact of future climate 
change  policies.  Among  these  organisations,  the  most  common  stakeholder  groups  were 
business associations (10), individual companies (8) and research institutions (7).  

The  analysed  papers  discussed  multiple  aspects  in  relation  to  social  impacts  of  climate 
change  policies.  However,  several  reoccurring  themes  among  the  comments  could  be 
identified.  

4.10.1. 

Just transition  

The  most  common  comment related to  the  social  impacts  of  future  climate  change  policies 
was  that  coming  policy  frameworks  need  to  ensure  a  just  transition,  where  vulnerable 
groups, communities and Member States are protected from climate risks and poverty. 28 of 
the  analysed  papers  made  a  comment  on  the  need  for  a  socially  or  economically  just 
transition.  The  stakeholder  groups  that  most  often  discussed  the  importance  of  a  just 
transition were NGOs (6) and public authorities (6).  

In general, the view from a majority of the NGOs (4) can be illustrated by one of the position 
papers  stating  that  future  legislative  frameworks  need  to  advance  a  green  transition  that  is 

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socially  and  economically  just,  and  that  the  EU  needs  to  strengthen  the  protection  of 
vulnerable groups and middle and low-income households against climate risks and poverty. 
Another NGO concludes that for a smooth transition to be realised and to achieve an efficient 
fight  against  climate  change,  social  acceptability  is  key.  It  is,  therefore,  stated  to  be  a 
necessity  to  ensure  that  local  communities  –  particularly  vulnerable  communities  –  benefit 
equitably from the transition and the development of renewable energy technologies. Hence, 
the  organisation  calls  for  social  policies,  in  addition  to  fiscal  policies,  to  favour  social 
inclusion.      

Similar comments are made by public authorities. For example, a Member State emphasised 
that  future  policies  need  to  ensure  that  the  energy  transition  is  conducted  socially  just  and 
not  leave  any  communities  or  individuals  behind.  It  furthermore  noted  that  regions  most 
negatively affected by the transition, including coal-dependent regions, need to be provided 
with new development opportunities.  

In addition, a representative paper from a research institute recommended the integration of 
marginalised  groups  in  policy-making.  Due  to  their  knowledge  and  experiences  to  address 
issues  of  social  justice  in  climate  policies,  the  youth,  the  elderly,  immigrants  and  the 
economically  disadvantaged  should  be  included  in  the  process  of  formulating  future  EU 
climate policies.  

Lastly,  one  trade  union  criticised  previous  EU  climate  policies  for  not  having  European 
workers in mind. The union, therefore, argued that austerity and deregulation create a risk of 
lowering labour standards and employment conditions, especially in Member States that rely 
on low labour costs to attract foreign investments. Future climate policies would thus need to 
consider all potential effects on European workers.   

4.10.2. 

Impacts on citizens  

Another common point brought up in the analysed papers is the various effects future climate 
policies  will  have  on  EU  citizens.  14  papers  discussed  potential  positive  and  negative 
impacts  future  climate  policies  could  have  on  individual  citizens.  Organisations  from  all 
stakeholder  groups  discussed  these  issues,  with  individual  companies  (4)  being  the  most 
common group.  

In general, the companies argued that ambitious climate policies would have positive social 
and economic impacts on individual citizens in the EU. However, the EU should ensure that 
no  citizens  are  left  behind  in  the  transition.  Several  companies  argued  that  higher  climate 
ambitions  would  help  individuals  to  lower  their  energy  and  climate  bills,  and  this  would 
consequently  reduce  energy  poverty  and  social  inequalities  and  improve  social  cohesion. 
However, in relation to the transport sector, if GHG emissions from road transport were to be 
significantly  and  quickly  reduced,  it  would  affect  the  employment  and  income  of  workers  in 
the transport and energy sectors.  

Another  positive  effect  of  setting  more  ambitious  climate  targets  and  decreased  emissions 
brought  up  in  2  papers  is  improved  air  quality,  leading  to  better  health  for  EU  citizens, 
especially  in  more  polluted  areas  of  Europe.  Lastly,  several  organisations  underlined  the 
importance  of  safeguarding  individual  freedom  of  citizens  when  new  policies  and  future 
technologies are being implemented. 

4.10.3. 

Upskilling  

Finally, a few business associations discussed the need for upskilling and reskilling workers 
to reduce negative effects on certain groups. One organisation stated that the EU needs to 
invest in up-skilling and reskilling to support employment, income and social inclusion in the 
EU and help address current and future labour market needs in relation to a green transition 

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in  Europe.  Another  business  association  emphasised  that  there  is  a  need  to  reskill  and 
upskill  the  workforce  in  the  EU  to  meet  the  demands  of  a  green  and  circular  economy. 
However, the organisation argued that this is a matter of national competence and that it thus 
should be addressed by Member States.  

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5.  Analysis of the call for evidence section 

5.1.  Background and methods 

In  addition  to  the  public  consultation,  respondents  were  able  to  share  feedback  on  the 
initiative  to  setting  the  EU  climate  target  for  2040  through  a  call  for  evidence.  The  call  for 
evidence  was  integrated  as  a  separate section  into  the  webpage  of  the public  consultation. 
As  part  of  the  call  for  evidence,  stakeholders  were  also  given  the  opportunity  to  upload 
position papers. A total of 146 position papers were collected in the call for evidence which 
were  considered  together  with  the  position  papers  received  in  the  public  consultation  (see 
Chapter 4). 

The responses in the call for evidence section varied more widely as they are not as directed 
to specific aspects of the target setting process. The open text comments were analysed to 
identify key themes by stakeholder group. 

5.2.  Overview of responses  

In  total,  579  submissions  were  received  in  the  call  for  evidence  section.  Among  the 
submissions, some duplicates could be identified. After the removal of 13 duplicate answers, 
566 unique feedbacks remained. 

The  countries  where  most  submissions  in  the  call  for  evidence  originated  from  include 
Slovakia  (126,  22%),  Germany  (100,  18%),  Belgium  (60,  11%),  and  Finland  (50,  9%).  In 
addition,  some  other  central  and  eastern  European  Member  States  were  also  well 
represented, such as Croatia (29, 5%) and Poland (28, 5%). 

Of  the  126  responses  received  from  Slovakia,  122  were  from  private  individuals.  The  vast 
majority of which expressed a critical attitude towards an ambitious EU climate policy. Unlike 
the  campaign  identified  in  the  responses  to  the  public  consultation  questionnaire,  the  text 
responses  differed  so  much  that  it  was  not  considered  a  campaign  in  the  call  for  evidence 
section. 

5.3.  Key themes by stakeholder group 

Out  of  the  566  unique  feedbacks,  356  (63%)  were  received  from  EU  citizen.  Overall, 
opinions are divided in two clear groups. The majority of the opinions support stringent GHG 
emission reduction targets by 2040 acknowledging that climate change is a serious threat to 
the  EU.  More  radical  opinions  insist  on  reaching  climate  neutrality  by  2040.  The  second 
group  of  opinions  come  from  climate  sceptics  insisting  the  climate  change  is  not 
anthropogenic,  that  no  action  should  be  taken,  and  that  climate  action  is  a  waste  of 
resources.  A  majority  of  these  opinions  come  from  the  group  of  Slovakian  responses  from 
private individuals. 

A  number  of  opinions  insists  that  there  should  be  stronger  pressure  to  companies  and 
citizens  to  reduce  all  GHG  emissions  which  could  be  reduced  through  technical  and 
behavioural  means.  Moreover,  as  a  global  trading  partner, the  EU  has  an  important role  to 
play in bringing all G20 countries and other trading partners on the same trajectory. 

EU  citizens  in  support  of  stringent  targets  and  action  suggest  several  concrete  solutions 
including  reduced  use  of  plastics;  improved  circular  economy;  reduced  meat  consumption; 
car-free  city  centres;  increased  share  of  renewable  energy;  reduced  chemical  use; 
afforestation;  increased  recycling;  enforcement  of  polluter  pays  principle;  etc.  EU  and 

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national  governments  are  expected  to  use  fiscal  and  economic  incentives  to  drive 
sustainable  solutions  within  companies.  Further  efforts  should  be  made  to  increase  the 
lifetime  of  products.  The  need  to  stop  biodiversity  loss,  depletion  of  resources  and  soil 
sealing  has  also  been  mentioned.  Individual  opinions  single  out  nuclear  as  a  wasted 
opportunity while other EU citizens are against the reliance on carbon removals. 

It  is  noteworthy  to  mention  that  among  the  group  of  EU  citizens  who  support  ambitious 
targets  and  stronger measures,  there  exists  a  division.  Some  advocate for these  actions to 
be taken without significant economic sacrifices, while others believe that society should be 
prepared to bear the associated costs. 

Several opinions emphasise that setting ambitious targets is not enough, there is also a need 
to  ensure  adequate  resources  to  achieve  the  objectives,  e.g.  by  establishing  an  European 
Climate Fund. Moreover, climate targets and the need for decisive actions need to be clearly 
communicated to different stakeholder groups. 

98  (17%)  submissions  were  made  by  business  associations  (55,  10%)  and  companies 
(43, 8%). Overall, companies and business associations are in favour of setting ambitious yet 
realistic  2040  GHG  emission  reduction  targets  based  on  the  best  available  science.  Some 
opinions,  that  can  be  attributed  to  a  sub-group  of  replies  that  argues  for  very  ambitious 
targets, provide concrete figures and insist that the 2040 emission reduction target should be 
set at a minimum of 90% to 95%, compared to 1990 levels. Some opinions state that there 
should be no more than 8-10% of carbon removals in this target. By setting a high bar, the 
EU will inspire other regions and nations to follow suit. 

While  some  opinions  are  in  favour  of  a technology-neutral  transition,  business  associations 
of different industries and technological sectors emphasise their importance for achieving the 
ambitious targets. For example, according to a renewable energy federation, targets can be 
achieved  mainly  through  significantly  higher  shares  of  renewable  energies  and  exploiting 
untapped  potentials  of  energy  efficiency  improvements.  It  suggests  a  cautious  approach  to 
Carbon  Dioxide  Removal  (CDR)  technologies  and  a  priority  to  nature-based  solutions. 
According  to  a  gas  network  in  a  MS,  a  rapid  deployment  of  renewable  gases,  including 
biomethane  and  green  hydrogen  must  take  place  in  addition  to,  not  instead  of,  increased 
renewable generation capacity and the associated continued electrification of large sections 
of  the  economy.  An  association  of  public  and  railway  transport  insists  that  public  transport 
should  be  prioritised,  and  that  the  Connecting  Europe  Facility  (CEF)  envelope  should  be 
increased, and greater consideration should be given to urban nodes, and the increase in the 
Structural Funds’ envelope by prioritising urban and rail public transport issues.  

According  to  a  chemical  industry  association,  it  is  imperative  that  the  ambitious  climate 
targets  are  accompanied  by  measures  to  ensure  that  the  wide  range  of  chemical  products 
can  continue  to  be  competitive  in  Europe,  based  on  a  high-quality  and  reliable  basic  raw 
material  supply  that  ensures  strategic  autonomy.  According  to  a  bioenergy  association, 
bioenergy must continue  to  play  an  important role  in the  transport  sector  and  the  electricity 
market.  According  to  a  coalition  of  European  airlines  and  unions  representing  airline 
employees,  the  EU's  environmental  aspirations  must  consider  the  international  and 
intercontinental nature of the industry. According to an association representing the interests 
of the  European  electricity  industry,  looking towards  2030,  2040  and  2050,  decarbonisation 
speedways  confirm  the  key  role  of  clean  electrification  in  accelerating  European  path  to 
climate neutrality and underlines its potential in lowering households’ energy bills. According 
to  an  ESCO  associations,  when  working  on  a  new  2040  climate  target,  the  key  guiding 
Energy  Efficiency  First  principle  should  not  be  overlooked,  as  energy  efficiency  measures 
and renewables uptake go hand in hand.  

Additional  suggested  measures  include  phasing  out  of  fossil  fuels  and  the  reduction  of 
emissions from the agricultural sector. 

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According  to  a  biofuel  organisation,  sustainable  advanced  biofuels  are  a  fast-track  solution 
and they bring multiple benefits in terms of CO2 reduction, investments, increased revenues 
for  farmers  and  forestry,  and  an  increase  in  energy  security.  According  to  a  hydrogen 
association, it is necessary to define a clear GHG reduction path beyond 2030 towards the 
2050 climate neutrality objective. The energy sector will play a central role in this process as 
it represents more than 75% of total emissions, with clean hydrogen playing a major role in 
driving  the  decarbonisation  of  the  European  economy.  According  to  a  heating  industry 
association, any proposal for a 2040 climate target, and any potential pathways to achieve it, 
should therefore take into due account the key contribution of efficient heating technologies 
for  decarbonisation,  and  effectively  promote  their  deployment  across  different  sectors  and 
applications, particularly in buildings.  

According to a car industry association, there is a risk that wrong targets may overwhelm the 
performance of the EU’s or individual Member States’ economies. Only a transition towards 
climate neutrality, which preserves the industrial base and thus the prosperity of citizens, is a 
successful transition and has the chance to find counterfeiters around the world.  

Overall,  companies  share  the  opinion  that  the  private  sector  who  will  be  key  in  making  the 
huge  investments  in  the  green  transition  needs  clear  targets  and  public  commitment  to  be 
able to decide the needed investments.  

55 (10%) submissions were made by civil society organizations, including NGOs (43, 8%), 
environmental organizations (9, 2%), trade unions (2, 0.4%), and one consumer organization 
(0.2%).  The  key  messages  from this  stakeholder  group  underscore  the  importance  to  meet 
the  requirements  set  by  the  Paris  Agreement,  generally,  advocating  for  a  more  ambitious 
“net zero” transition. The submissions stress that the target setting should be based on up-to-
date scientific evidence provided by actors such as the European Scientific Advisory Board 
on  Climate  Change  or  the  Intergovernmental  Panel  on  Climate  Change.  In  this  context, 
special attention was given to the agricultural and land sector, highlighting the significance of 
preserving  land  and forests.  Additionally,  a commonly mentioned  demand  concerns  a rapid 
and  controlled  phase-out  of  fossil  energy,  coupled  with  a  stronger  expansion  of  renewable 
energy  sources.  Overall,  the  messages  from  civil  society  organisations  emphasize  the 
necessity of taking a holistic approach towards achieving an ambitious transformation. 

14  (3%)  submissions  were  made  by  academic  and  research  institutions.  The  key 
messages from these responses relate to the prevalent demand that the EU should integrate 
latest  scientific  evidence  when  formulating  the  emission  targets  for  the  2030-2040  period. 
The  submissions  of  academic/research  institutions  interconnect  the  EU's  climate  transition 
with  multiple  other  research  fields  such  as  the  impact  on  global  health,  the  role  of  carbon 
removals, forest and wood products as well as the importance of independent research and 
high-quality education. Another important aspect for academic and research institutes seems 
to  be  the  EU's  historical  responsibility  when  it  comes  to  carbon  emissions.  Within  this 
context, the EU is urged to allocate carbon space to countries in the global south to ensure a 
fair and equitable transition. 

to  need 

7  (1%)  submissions  were  made  by  public  authorities.  The  key  messages  from  these 
responses  related 
transition  which 
encompasses  aspects  such  as  green  technologies  and  interventions  to  re-skill.  In  this 
context, the submissions of public authorities highlight EU’s crucial role as a supporting force 
that can facilitate the transition of other countries such as Turkey and thereby contribute to its 
global responsibility. Public authorities note that actions should be implemented now, without 
any delay of an ambitious transition.  

investments  concerning 

the  green 

for 

A further 36 (6%) responses came from non-EU citizens (4, 0.7%) or from stakeholders who 
classified themselves as “Other” (32, 6%). The topics of these responses largely mirrored the 

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topics of the other stakeholder groups. Especially those stakeholder types that relate strongly 
to their respective type. 

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6.  Key insights from the targeted stakeholder event 

On 9 June 2023, an all-day targeted stakeholder event was held to gather further feedback 
and  insights  on the  view  of  the  EU’s  2040  climate  targets. It  was  attended  in  person  by  34 
stakeholder representatives, including ten from the energy sector, six from industry, six from 
think tanks, and six from NGOs, as well as representatives from transport, agriculture, SMEs, 
trade unions, and cities. In addition, a further 48 participants followed the meeting online. 

The contents of the event are summarised in the following: 

Climate  impacts  and  cost  of inaction:  Stakeholders  were  convinced that  natural  hazards 
and  biotic  risks  will  impact  the  forestry,  agriculture,  and  other  land-use  sectors,  as  well  as 
renewables  and  waste  management/recycling.  They  emphasised  that  cities  and  industries 
will be affected by employment and work-related risks. In this context, the communication of 
mitigation  and  adaptation  measures  should  be  linked  with  other  environmental  benefits  to 
give a positive narrative, as well as to stress the costs of inaction. 

Fair  transition,  employment  and  social  aspects:  Stakeholders  highlighted  the  skills  gap 
regarding  the  required  technologies  and  demographic  factors  as  aspects  that  should  be 
considered.  It  was  stressed  that  financial  support  will  be  needed  for  green  infrastructure 
(especially for smaller cities), as well as targeted support for lower/middle income groups for 
the switch of technologies (e.g., upfront costs of heat pumps and electric vehicles).  

Energy  –  including  storage,  grids,  and  renewables:  Stakeholders  believed  that  aspects 
such  as  energy  efficiency  and  contributions  to  energy  security  are  key  in  the  energy 
transition. There was disagreement on the role of hydrogen and e-fuels. 

Carbon removals/storage: Participants demanded a clear differentiation between emission 
reductions  and  carbon  removals,  suggesting  separate  targets.  The  focus  should  be  on 
emission  reductions,  with  carbon  removals  reserved  only  for  residual  hard-to-abate 
emissions.  In  addition,  two  targets  are  also  needed  within  the  context  of  carbon  removals: 
one for nature-based removals, and one for technological removal/storage.  

Economic  effects,  competitiveness,  industry,  and  SMEs:  Most  stakeholders  approved 
the positive effects of having long-term targets and a more stable and predictable legal and 
regulatory  framework  is  required  for  investments.  CBAM  should  not  only  protect  domestic 
production from imports that are subject to less stringent climate regulations, but also support 
the export share so that the EU market does not become smaller. More support for industry, 
such as Carbon Contracts for Differences (CCfD) will be needed for the transition. Additional 
claims  included  that  the  EU  industry  needs  capital  investment  and  reliable/available 
renewables  as  well  as  breakthrough  technologies  for  key  industries  and  lead  markets  for 
green technologies. 

Agriculture,  food  security  and  land  sectors  (LULUCF,  forests,  biodiversity,  and 
biomass):  Agriculture  stakeholders  called  for  intensified  food  production  within  GHG 
boundaries.  Forestry  stakeholders  emphasised  the  important  role  of  wood-based  raw 
materials  and  products,  whereas  civil  society  organizations  called  for  agriculture  to  avoid 
energy crops and questioned the role of wood-based products. 

International aspects, and non-EU climate action: Stakeholders emphasised that the EU 
should align with the UNFCCC 5-year policy cycles, such as setting a 2035 target. Additional 
claims included: assessing the EU’s carbon footprint and the global contribution of EU-based 
companies  in  terms  of  behaviour  and  policies  outside  of  Europe,  as  well  as  embedding 
carbon in trade flows.  

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Behavioural change and lifestyles: Stakeholders proposed to frame the green transition as 
“our well-being and lifestyles will be damaged if we fail to limit global warming to 1.5ºC”. The 
focus  should  be  on  sufficiency  principles,  active  mobility,  new  production  models,  and 
consumption-related  emissions,  as  well  as  the  green  infrastructure  and  support  for  upfront 
costs that are needed to enable individual climate-friendly choices. 

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Appendix 

Appendix A: Public consultation questionnaire (English version) 

Public consultation on the EU climate target for 2040 

Introduction 

I.I Background 

Climate change remains the defining challenge of the coming decades. As an essential part 
of the European Green Deal, the European Climate Law enshrines the EU’s commitment to 
becoming the first climate neutral continent by 2050 and its 2030 climate target of cutting net 
greenhouse gas (GHG) emissions by at least 55% compared to 1990 levels. It is now more 
important  than  ever  for  the  EU  to  get  and  stay  on  track  to  climate  neutrality  and  greater 
climate resilience. This will lead to long-term economic, societal, and environmental benefits 
for  the  people  of  Europe  that  leave  no  one  behind  while  providing  a  positive  example  to 
galvanise global action.  

The  detrimental  effects  of  global  warming  are  becoming  more  frequent  and  evident,  with 
devastating impacts all around the world. The urgent need for strong global action to tackle 
climate  change  comes  at  a  time  of  high  energy  prices,  a  global  food  supply  crisis,  and 
geopolitical  tensions,  triggered  by  Russia’s  invasion  of  Ukraine.  The  energy  crisis  brought 
about by the war has reminded us of the risks of EU energy dependence and has made very 
clear the need to step up the transition to climate neutrality in the EU and globally, both for 
energy security and economic stability and to reduce climate-related disruptions and impacts. 

The  EU  has  developed  a  comprehensive  set  of  climate,  energy,  environmental  and  related 
legislation and enabling policies that have allowed it to reduce GHG emissions and exceed 
its  climate  commitments.  These  policies  and  measures  have  led  to  a  clear  decoupling 
between economic activity and GHG emissions and have spurred the development of clean 
energy. 

The  EU’s  legally  binding  objective  of  climate  neutrality  by  2050  sets  the  direction  of  travel. 
The comprehensive policy framework to deliver on the increased climate target for 2030, the 
“Fit for 55” legislative package, was proposed by the Commission in 2021. Once it has been 
politically agreed by the European Parliament and the Council, Fit for 55 will accelerate the 
modernisation  of  our  economy,  the  roll-out  of  renewable  energy,  the  deployment  of  new 
technologies and will ensure a more efficient use of our natural resources. Improved low- and 
zero-carbon technologies and experience in implementing climate policies further expand the 
opportunities for transforming the EU economy and society beyond 2030. 

Given the depth of the economic and societal transformations required, the short timeframe 
and  the  extent  of  policy  and  economic  decisions  as  well  as  the  importance  of  incentivising 
the right kind of investments and avoiding carbon lock-in effects, the EU needs a clear GHG 
reduction path beyond 2030 towards the 2050 climate neutrality objective. This will create a 
better  understanding  of  the  urgent  need  for  transformation  in  the  different  sectors  of  the 
economy  and  inform  the  future  preparation  of  a  post-2030  climate  and  energy  policy 
framework. 

The  European  Climate  Law  calls  on the  Commission  to  propose  an  EU-wide  climate target 
for  2040,  taking  into  account  an  indicative  GHG  budget  (defined  as  the  cumulative  net 
emissions over the period) for 2030 – 2050. The Commission’s initiative for a climate target 
for 2040 will be accompanied by an impact assessment that will address the different types 
of impacts related to the target.  

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The  replies  to  this  questionnaire  will  contribute  to  the  impact  assessment  and  shape  the 
upcoming initiative. This public consultation focuses on the overall level of ambition for 2040 
and  looks  at  the  possible  evolution  and  role  of  EU  climate  policy  instruments  in  order  to 
prepare the ground for future analysis of the policies the EU must implement after 2030.  

I.II Guidance on the questionnaire 

This  public  consultation  consists  of  a  set  of  introductory  questions  related  to  your  profile, 
followed  by  a  questionnaire  split  into  two  sections:  a  general  section  and  a  section  for 
experts.  Please  note  that  you  are  not  obliged  to  respond  to  both  parts,  and  you  can 
choose  to  fill  in  only  one  of  the  two  (either  the  general  section  or  the  section  for 
experts). In addition, not all questions in the questionnaire have to be answered. 

•  About  you:  Since  the  public  consultation  is  open  both  to  organisations  and 

individuals, the first block consists of questions related to your profile.  

•  General  section:  The  second  block  consists  of  questions  related  to  your  opinion 
on  the  EU’s  overall  climate  ambition  for  2040,  associated  opportunities  and 
challenges, and related policy needs. 

•  Expert section: The third block is more technical, and consists of questions related to 
the role of policy instruments, carbon removals, technological options and adaptation 
to climate change.  

At the end of the questionnaire you are invited to provide additional comments and to upload 
additional  information,  position  papers  or  policy  briefs  that  express  in  more  detail  your 
position or views or those of your organisation.  

The results of the questionnaire will be published online, along with uploaded position papers 
and policy briefs.  

Please  read  the  specific  privacy  statement  attached  to  this  consultation with  information  on 
how personal data and contributions will be processed. 

In  the  interest  of  transparency,  if  you  are  replying  on  behalf  of  an  organisation,  please 
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received from individuals. 

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box] 

Which sections do you want to respond to? (multiple answers possible) 

  General section (section 1) 
  Expert section (section 2) 

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General section 

This  section  addresses  individuals  and  organisations  alike.  The  questions  aim  to  find  out 
more about opinions on the EU’s overall climate ambition for 2040, associated opportunities 
and challenges, and related policy needs. 

Overall opinion on the EU’s climate ambition for 2040 

The  European  Climate  Law  requires  the  EU  to  achieve  climate  neutrality  by  2050.  This  is 
defined  as  a  balance  between  any  remaining  emissions  of  the  main  greenhouse  gases 
(carbon dioxide, nitrous oxide, methane and the fluorinated greenhouse gases) and removals 
of  CO2  from  the  atmosphere.  It  further  sets  a  target  for  the  EU  to  reduce  net  GHG  gas 
emissions  by  at  least  55%  by  2030,  compared  to  1990  levels.  The  EU  seeks  to  lead  by 
example to promote ambitious climate action across the world. 

In  response  to  the  energy  crisis  due  to  Russia’s  invasion  of  Ukraine    the  European 
Commission also proposed the REPower EU plan, to rapidly reduce dependence on Russian 
fossil fuels and fast-forward the green transition. 

Emissions 

Q1: 
2040  
Considering  the  objective  of  achieving  climate  neutrality  by  2050  and  the  current  energy 
crisis, how should the EU pursue the climate transition up to 2040?   

reduction 

ambition 

2030 

for 

– 

  The EU should accelerate the transition to climate neutrality.  
  The transition to climate neutrality should continue at the current pace. 
  The transition should be slower than the current pace.    
  The EU’s ambition should depend on other countries’ climate ambition. 
  I do not know. 

Q2: EU emission reduction target for 2040 

The EU has committed to reduce its net GHG emissions by 55% compared to 1990 levels by 
2030  and  aims to  achieve  climate  neutrality  by 2050  (-100%).  In  your  opinion,  what  should 
be  the  net  emission  reduction  target  for  2040  to  put  the  EU  on  track  to  meeting  the  2050 
climate neutrality target? 

  up to -65% emission reduction (a very low ambition, barely increased compared 

to the target for 2030). 

  between -65% and -75% emission reduction.   
  between -75% and -80% emission reduction (following the average trajectory 

between 2030 and climate neutrality in 2050). 
  between -80% and -90% emission reduction.   
  more than -90% emission reduction (a very high ambition, close to reaching 

climate neutrality already in 2040). 

  I do not know. 

You can also indicate a specific value here: 

Q3: Role of carbon removals in the 2040 climate target  

The  opposite  of  CO2  emissions  are  CO2  removals,  also  called  ‘carbon  removals’.  Carbon 
removals are processes in which carbon dioxide is removed from the atmosphere and stored 

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in a durable way in geological, terrestrial or ocean reservoirs or in products. Carbon removal 
solutions can be nature-based, for example through improving soil, forest management, or by 
restoring  ecosystems,  or  they  can  be  industrial  through the  development  of  technologies  to 
capture  and  store  carbon  from  the  atmosphere.  Carbon  removals  are  indispensable  for 
achieving EU climate neutrality because it may not be possible (or would be very expensive) 
to  mitigate  all  emissions.  As  a  first,  important  step,  the  Commission  has  proposed  a 
regulation  establishing  a 
to  guarantee 
transparency, reliability, and environmental integrity. 

for  certifying  carbon 

framework 

removals, 

The  EU’s  2030  climate  target  is  expressed  in  ‘net’  emissions,  which  is  the  sum  of  GHG 
emissions and carbon removals. In your opinion, how should carbon removals be considered 
so that the EU achieves its 2040 climate target?  

  Carbon removals should be considered together with actual GHG emissions. 

Hence, it is enough to have only a single ‘net’ emissions target for 2040 to set the 
GHG trajectory towards climate neutrality by 2050 in a cost-effective way. 

  It is better to set a separate target for reducing GHG emissions and another target 

for carbon removals.  

  It is better to have one target for reducing GHG emissions, a target for nature-
based carbon removals and a target for industrial removals with permanent 
storage. 

  No opinion / I do not have enough information to make a judgment. 

Q4: Opportunities associated with higher climate ambition  

What are the benefits of an ambitious climate target by 2040? Which opportunities would you 
consider as most relevant when implementing an ambitious climate target by 2040? (Multiple 
answers  possible;  if  no  opinion  just  skip  this  item.)  (response  options  will  be  provided  in 
random order) 

  It will improve our well-being (by lowering pollution, improving health and 
creating more liveable cities) and help protect the planet’s ecosystems. 
  It will ensure that we do our part in protecting the planet and fulfilling our duty 

towards future generations. 

  It will reinforce EU leadership and inspire action to combat climate change 

globally. 

  It will help individuals and businesses lower their energy and climate bills. 
  It will help mitigate costs to societies who are likely to suffer from climate 

change (e.g. from extreme weather events, droughts or loss of ecosystems). 
  It will improve energy security, reduce the EU’s dependency on imported fossil 

fuels and reduce exposure to volatility in fossil fuel prices. 

  It will simultaneously address the climate and the biodiversity crises. 
  It will give a clear signal that the EU economy will embrace sustainable 
production and consumption models (e.g. circular and sharing economy 
approach).  

  It will improve the competitiveness of the European economy and give EU 

industry a first-mover advantage on global markets. 

  It will create green and high added-value jobs, including those that are difficult 

to outsource outside the EU (e.g. maintenance of renewable energy 
installations, construction and renovation, bioeconomy). 

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Q5: Challenges and enabling actions for the EU climate ambition to 2040 and beyond 

There will be challenges on the path to climate neutrality by 2050. There will also be ways to 
overcome these challenges, while at the same time modernising our economy and ensuring 
a socially just transition.  

How  important  do  you  consider  the  different  challenges  and  associated  enabling  factors 
listed  below  for  the  EU  to  reach  its  climate  ambition?  Please  rate  them  from  1  =  very 
unimportant to 5 = very important. (response options will be provided in random order) 

1 = Very unimportant;  
5 = very important 

I  don’t 
know 

New  technologies  and  solutions  need  to  emerge  and  be 
deployed  (e.g.  clean  fuels),  which  will  require  more 
research, development and innovation. 

1 

2 

3 

4 

5 

Public  support  is  critical  for  climate  ambition,  which  will 
require  behavioural  and  societal  changes.  This  needs  to 
be  reflected  in  policies,  for  instance  on  reusing  and 
recycling and a fair transition. 

1 

2 

3 

4 

5 

Small  and  medium  enterprises  will  need  support  to 
develop and adapt as part of the transition. 

1 

2 

3 

4 

5 

A faster expansion of renewable energies is needed. This 
will  be  supported  by  more  ambitious  EU  and  Member 
State legislation to further cut GHG emissions.   

1 

2 

3 

4 

5 

Further improvements in energy efficiency are necessary. 
The  EU  should  promote  the  smarter  and  more  efficient 
use of energy and resources. 

1 

2 

3 

4 

5 

Capturing  CO2  from  the  atmosphere  and  storing  through 
nature-based and industry-based solutions is vital for the 
EU's climate neutrality. It should be financially supported. 

1 

2 

3 

4 

5 

The  climate  transition  will  require  a  shift  in  investment 
flows.  It  is  very  important  to  promote  green  financing  to 
ensure  that  resources  are  appropriately  allocated  to 
climate-friendly economic activities. 

Vulnerable  households  (such  as  single  parents)  may 
struggle  with  increasing  energy  prices  and  face  an 
just 
unequal  burden  of  climate  change.  A  socially 
through 
transition 
mechanisms 
lower-income 
households financially.  

is  key  and  should  be  ensured 
to  support  middle-  and 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

There  is  a  risk  of  new  dependencies  on  resources  and 
raw  materials.  Action  should  be  taken  to  secure  supply 
and ensure sustainable use of these resources. 

1 

2 

3 

4 

5 

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Older infrastructure may lock people into carbon-intensive 
consumption  patterns.  Promoting  and  deploying  digital 
solutions such as smart meters or digital-enabled mobility 
solutions  on  a  large  scale  can  help  reduce  GHG 
emissions. 

1 

2 

3 

4 

5 

Monitoring  and  reporting  on  the  evolution  of  GHG 
emissions  and  climate  impacts  is  crucial.  EU  space  data 
and services should be further used to do this. 

1 

2 

3 

4 

5 

Q6: Gender aspects of climate policy 

Climate  policy  and  climate  action  can  be  seen  from  many  different  perspectives.  In  your 
view,  should  more  consideration  be  given  to  gender  aspects  in  the  transition  to  climate 
neutrality and in climate and related policies? 

No, I totally disagree (1) 

1         2         3         4           5 

Yes, I totally agree (5) 

If you believe this is an important topic, how should climate and related policies better 
address gender aspects? 

Contribution of individual sectors to the EU’s climate ambition 

Q7: Which sector should do more to reduce GHG emissions? 

The potential of different sectors to further reduce GHG emissions may vary. In your opinion, 
to which extent can the different sectors further reduce their GHG emissions?  

1 = can reduce little more;  

5 = can reduce a lot more  

I don’t know 

Production  of  electricity  and  district 
heating 

1         2         3         4           5 

Industrial processes & waste  

1         2         3         4           5 

Buildings (residential and services)  

1         2         3         4           5 

Road  transport  (passenger  and  freight 
transport) 

1         2         3         4           5 

Aviation & maritime transport 

1         2         3         4           5 

Agriculture, forestry and other land use  

1         2         3         4           5 

Q8: Sectors expected to reach climate neutrality first 

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It  will  be  easier  for  some  sectors  to  reach  climate  neutrality  than  for  others.  For  example, 
different  sectors  could  face  different  investment  needs,  conditions  of  technical  feasibility  or 
may require changes by consumers. 

Please rank the following sectors in the order in which you expect them to reach 
climate neutrality in the coming three decades, where (1) is the first to become climate 
neutral and (6) is the last to reach climate neutrality If you do not know or you do not 
feel able to provide a ranking, please simply skip that question. (response options will 
be provided in random order)   

Sector 

Ranking (1 to 6) 

Production of electricity and district 
heating  

Industrial processes & waste  

Buildings (residential and services)  

Road transport (passenger and 
freight transport) 

Aviation & maritime transport 

Agriculture, forestry, and other land 
use  

Q9: Capacity to innovate 

How do you assess the capacity to innovate and access financing of the sector or company 
you are working in?   

Please rate them from 1 = totally disagree to 5 = totally agree. 

1 = totally disagree; 5 = 
totally agree 

I don’t 
know 

My  sector  or  company  has  the  capacity  to  carry  out 
the  necessary  innovation  (e.g.  product  innovation, 
technologies,  technical  skills,  etc)  to  manage  the 
transition to a net-zero emission economy. 

1 

2 

3 

4 

5 

My sector or company has access to risk capital and 
financing. 

1 

2 

3 

4 

5 

My  sector  or  company  has  access  to  EU  dedicated 
facilities  for  the  green  transition  (e.g.  InvestEU,  Just 
Transition Fund, Modernisation Fund, etc.). 

1 

2 

3 

4 

5 

My personal contribution to protect the climate  

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Q10: Awareness of climate change impact and climate action 

The  effects  of  climate  change  have  been  regularly  described  in  the  reports  by  scientists  of 
the Inter-governmental Panel on Climate Change (IPCC). Their analyses are covered by the 
media.  

How  aware  are  you  and  how  aware  do you think  society  is  of  the  reality  of  climate  change 
and  its  impacts?  Please  indicate  the  extent  to  which  you  agree  with  the  statements  below, 
from totally disagree (1) to totally agree (5). 

1 = totally disagree; 5 = 
totally agree 

I do 
not 
know 

I  am  aware  of  the  reality  of  climate  change  and  its 
expected impacts. 

1 

2 

3 

4 

5 

I  am  ready  to  change  my  behaviour  to  reduce  my 
carbon  footprint  (e.g.  by  using  sustainable  transport; 
using  or  producing  renewable  energy;  reducing 
recycling  products; 
consumption, 
consuming 
impact; 
reducing 
fashion  consumption;  or  by  choosing 
climate-friendly investment plans). 

foods  with  a 

lower  climate 

reusing  and 

1 

2 

3 

4 

5 

I have felt or experienced the present-day impacts of 
climate change (e.g. hotter summers, dryer land, less 
snow) and I feel a need to adapt to these impacts. 

1 

2 

3 

4 

5 

There  are  many  factors  preventing  me  from  taking 
further  action,  for  example  insufficient  information  on 
products or services, lack of sustainable choices and 
infrastructure, or solutions that are too complicated. 

1 

2 

3 

4 

5 

Society  is  aware  of the reality  of  climate  change and 
its expected future impacts. 

1 

2 

3 

4 

5 

Society is ready to implement actions to reduce GHG 
emissions  (e.g.  by  using  sustainable  transport;  using 
or  producing  renewable  energy;  reducing,  reusing 
and recycling products; consuming foods with a lower 
climate  impact;  reducing  fashion  consumption;  or  by 
choosing climate-friendly investment plans). 

Society  feels  the  need  to  manage  and  adapt  to 
climate  change  (e.g.  different  infrastructure  in  cities; 
preparedness  for  floods,  droughts  and  heatwaves; 
greening spaces; improving health conditions). 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

Q11: Most important changes expected for peoples’ daily lives 

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The  effort  to  reduce  GHG  emissions  in  the  EU  will  progress  further  in  the  coming  years  in 
order  to  reach  climate  neutrality  by  2050.  Where  do  you  expect  the  greatest  changes  to 
happen in your daily life? (Multiple answers possible.) (response options will be provided in 
random order) 

  Housing (e.g. energy consumption in buildings, living space)  
  Transport used for short-distance trips 
  Transport used for long-distance trips    
  Food (including food waste) 
  Consumer goods and services (including reduce, reuse, repair & recycle) 
  My current job 
  Education and skills needed for future jobs 

Please specify any other expected changes: 

Q12: Willingness for action at individual level 

Consumer  choices  and  behavioural  change  can  considerably  impact  our  GHG  emissions. 
Which of the following personal actions would you be willing to take to fight climate change? 
Please indicate your personal choice from (1) ‘No, I would not be willing to implement this’ to 
(3) ‘Yes, I would be willing to implement this’. 

Actions 

(1)  No, I would not be willing to 

do this  

(2)  I am not sure whether I 

would do it or not 

(3)  Yes, I would be willing to do 

Not 
applicable 
in my case 

Eat  food  with  a  lower  climate  impact,  such 
as  plant-based, 
local  or  sustainably 
produced food. 

Improve  the  energy  performance  of  my 
building  (insulation,  triple  glazing,  more 
efficient heating, etc.).  

Invest  in  energy  measures  for  my  building 
that  reduce  its  emissions  (solar  panels, 
thermal insulation, heat pumps). 

Accept  infrastructure  for  renewable  energy 
such as wind turbines, above-ground power 
lines or solar panels in your municipality.  

Buy  products  and  services  that  are  more 
climate-friendly (according to a trusted label 
or  certificate),  even  if  they  come  at  a 
somewhat higher price. 

Consider  how  climate-friendly  a  product  is 
when the information of its climate impact is 

this 
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provided (e.g. through a label).  

Have goods repaired or reuse them, rather 
than buying new ones.  

Reduce wasteful consumption, for instance 
buying  and  using  long-lasting  appliances, 
clothing, and other products. 

Use  alternatives  to  the  car  for  everyday 
journeys 
(e.g.  walking,  cycling,  public 
transport),  or  reduce  trips  (e.g.  by  working 
from home).  

For  long  journeys,  fly  less  and  travel  more 
by  alternative  modes 
trains)  or 
(e.g. 
consider shorter distance trips. 

Switch  to  sharing-based  business  models 
to  rent  products  rather  than  owning  them, 
such as car-sharing.  

Compensate  some  of  my  emissions  via 
reliable  and  certified  carbon-offsetting 
programmes.  

in  active  political  support 

for 
Engage 
increased  climate  ambition,  regardless  of 
political affiliation. 

1 

1 

1 

1 

1 

1 

1 

2 

2 

2 

2 

2 

2 

2 

3 

3 

3 

3 

3 

3 

3 

Q13: How to improve incentives for climate action 

Climate policies and the trajectory to climate neutrality by 2050 will require us to change our 
consumption  patterns,  both  for  products  and  services.  Which  of  the  following  proposals 
would help you to reduce your personal climate footprint? (response options will be provided 
in random order) 

1 = not helpful;  
5 = very helpful 

I don’t 
know 

Raise awareness of the climate impact of goods and 
services. 
Label  the  climate  impact  of  goods  and  services  so 
that  consumers  can  better  choose  more  climate-
friendly options. 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

Ensure the price of goods and services reflects their 
impact on climate change, making climate-friendly 
products with a lower climate impact more attractive. 
Ensure the price of goods and services reflects their 
impact on climate change, but treat first 
necessity/regular/ -luxury goods and services 
differently. 
Provide better information on how to invest in 
solutions that will help people reduce their GHG 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

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emissions or increase carbon removals, notably from 
buildings, food consumption or transport. 
Ease financing of investments in solutions that will 
lead to reductions in personal GHG emissions, 
notably from a person’s house (e.g. installing heat 
pumps), transport means (e.g. electric cars or 
affordable public transport) or food consumption. 
Support sharing and leasing services to facilitate the 
access to technologies that reduce an individual’s net 
GHG emissions (e.g. heat pump, photovoltaic panels 
or electric vehicles).  
Put in place measures to make sure that the most 
vulnerable in society have access to sustainable and 
climate-friendly products and services.  

If other, please specify: 

1  

2 

3 

4 

5 

1  

2 

3 

4 

5 

1  

2 

3 

4 

5 

The impacts of the climate crisis 

Setting  a  2040  climate  target  will  confirm  the  importance  for  the  EU  of  tackling  climate 
change,  which  is  already  having  an  impact  on  our  society  and  economy.  Scientists  have 
emphasised that, without a significant reduction of GHG emissions, climate change and the 
impacts it brings will accelerate in the coming years and decades, with possible tipping points 
reached  and  large-scale  irreversible  outcomes.  The  impacts  from  the  changing  climate  are 
also  likely  to  hamper  efforts  to  reduce  GHG  emissions  needed  to  reach  a  2040  target  and 
climate neutrality. 

The  following  questions assess  perceptions  of  risks  and  impacts,  which will  increase  in  the 
absence of ambitious global climate action.   

Q14: Possible effects of climate change for individuals 

Which effects of climate change are of most concern for you? (Multiple answers possible; if 
no opinion, skip this item.) (response options will be provided in random order) 

  Loss of life due to natural hazards such as heatwaves, floods, droughts or 

wildfires. 

  A change of landscape and forests in areas I relate to or that I live in. 
  Loss of job or income due to changes in the sector in which I work. 
  Having to face changes in my private life or activities, e.g. facing water-scarcity; 
not being able to do outdoor activities in summer; less opportunity for winter-
related activities; paying more for energy, food and transport; fewer transport 
services that address my specific needs as a woman, person with disabilities or 
as a young or older person). 

  Spread of new diseases (e.g. malaria) and pandemics. 
  Damage from natural hazards (floods, wildfires, droughts, etc.) and rising sea 

levels. 

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  Loss of biodiversity and natural habitats. 
  Increasing material losses to my property. 
  Varying capacity of different social groups to adapt (e.g. older people, persons 

with disabilities, displaced persons, low income households, and other 
vulnerable groups).  

Please specify any other effects below: 

Q15: Possible natural hazards caused by climate change at the place where you live  

As an individual, what possible hazards induced by climate change do you fear most? 
(Multiple answers possible; if no opinion, skip this item.) (response options will be 
provided in random order) 

  Wildfires 
  Droughts 
  Floods and intense rain 
  Rising sea levels 
  Heatwaves 
  Windstorms 
  Lack of water 

Q16: Possible effects of climate change for society 

What will be the main climate change-related impacts for society in your country in the next 
20 years? (Multiple answers possible; if no opinion, skip this item.) (response options will be 
provided in random order) 

  Natural disasters (e.g. fires, droughts or floods). 
  Loss of lives. 
  Negative impacts on the economy and employment. 
  Negative impacts on health. 
  Negative impacts on energy supply. 
  Negative impacts on critical infrastructure. 
  Negative impacts on food production. 
  Negative impacts through decreasing water availability for example  municipal 

water-saving measures. 

  More conflicts between countries or regions and their inhabitants e.g. due to 

declining water cycles and land resources. 

  Migration or refugee movements due to climate change and environmental 

crises. 

  Increasing inequalities due to climate hazards and different socio-economic 

vulnerabilities in society. 

Q17: Adapting to climate change where you live 

The  Intergovernmental  Panel  on  Climate  Change  (IPCC),  the  intergovernmental  scientific 
body of the United Nations responsible for advancing knowledge on human-induced climate 
change,  warns  in  its  latest  report  that  the  world  is  set  to  reach  the  1.5ºC  temperature 

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increase level within the next two decades. While stressing that preventing mounting loss of 
life,  biodiversity  and  infrastructure  requires  the most  significant  cuts  in GHG  emissions,  the 
IPCC also calls for more action to adapt to climate change. 

Buildings  can  be  adapted  to  increase  their  resilience  to  climate  change,  for  example  by 
improving thermal insulation, using highly durable materials, retrofitting or by greening urban 
areas to fight the urban heat.   

Considering your place of residence, your community, and the city or region you live in, how 
much  do  you  agree  with  the  following  statements  from  totally  disagree  (1)  to  totally  agree 
(5)? (response options will be provided in random order) 

Statements 

1 = totally disagree; 5 = 
totally agree 

I don’t 
know 

The risks associated with climate change for my place 
of  residence  have  been  assessed  and  I  can  access 
this information. 

1 

2 

3 

4 

5 

Plans to prepare for inevitable climate change events 
have  been  sufficiently  developed  and  I  am  informed 
of them. 

1 

2 

3 

4 

5 

Concrete  actions  to  improve  climate  resilience  in  my 
place of residence have been carried out and I judge 
them sufficient. 

1 

2 

3 

4 

5 

The  local  or  national  authorities  should  do  more  to 
prepare my city or region for climate change. 

1 

2 

3 

4 

5 

I am aware which climate impacts are threatening the 
building I live in. 

1 

2 

3 

4 

5 

Some  physical  measures  have  already  been 
implemented  to  prepare  my  building  for  climate 
change impacts.  

1 

2 

3 

4 

5 

I would be ready to invest to make my building more 
resilient to climate change. 

1 

2 

3 

4 

5 

We  need  more  adaptation  policies  that  take  gender-
differentiated  needs  and  the  needs  of  disadvantaged 
groups into account. 

1 

2 

3 

4 

5 

Expert section 

Appears  only  when  expert  section  (section  2)  was  selected  previously  in  the  About 
you section 

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This  section  complements  questions  on  the  2040  climate  target  by  exploring  how  the  EU’s 
climate  policies  could  evolve  after  2030  to  set  the  EU  on  track  to  meeting  its  climate 
neutrality  target  by  2050.  It  includes  questions  on  the  role  of  the  EU  Emissions  Trading 
System  (ETS),  the  Effort  Sharing  Regulation  and  sectoral  targets,  questions  on  GHG 
mitigation  in  the  land  sector,  the  role  of  carbon  removals,  technologies,  and  the  role  of  EU 
policy on adaptation to climate change for buildings and energy infrastructure. 

The  section  is  addressed  predominantly  to  people  with  expert  knowledge.  As  an  individual, 
you may also respond to it, but it is not mandatory.  

General policy framework 

In addition to the European Climate Law, GHG emissions from the EU are currently covered 
by three policy instruments: 

• 

• 

• 

the EU Emission Trading System (ETS) Directive, an EU-wide market-based instrument 
to reduce GHG emissions from specific sectors through a declining cap on emissions, a 
carbon price signal and trading of emission allowances; 
the Effort Sharing Regulation, which sets EU-wide and national targets on GHG 
emissions reduction from the other sectors (excluding land use, land use change and 
forestry (LULUCF)); 
the LULUCF Regulation, which defines an EU-wide target of delivering 310 million tonnes 
of CO2 equivalent (MtCO2e) removals from the LULUCF sector by 2030. 

Q18: Scope and role of EU-wide carbon pricing instruments 

In the context of the Fit-for-55 package, the scope of the EU ETS is being extended to cover 
most of the CO2 emissions from the use of fossil fuels and industrial processes.  

How  could  emissions  trading  in  the  EU  evolve  in  a  post-2030  policy  framework  in  terms  of 
GHG  coverage,  sectoral  coverage,  and  relations  with  non-EU  emissions  trading  schemes? 
(response options will be provided in random order) 

Options 

1 = totally disagree; 5 = 
totally agree 

I 
don’t 
kno
w 

EU  emissions  trading  should  cover  all  fossil  fuel 
uses,  including  those  that  are  so  far  not  or  not 
entirely  covered,  e.g.  in  the  non-road  transport 
sector. 
EU emissions trading should also cover all non-CO2 
GHG  emissions  from  the  use  of  fossil  fuels  and 
industrial processes, not only CO2 emissions. 
EU  emissions  trading  should  also  cover  GHG 
emissions 
(e.g.  extractive 
industries or the land sector). 
EU  emissions  trading  maintains  the  obligation  to 
surrender  allowances 
that  are 
captured  and  utilised  (Carbon  Capture  Utilisation, 
‘CCU’)  in  non-permanent  products.  This  aspect  of 
emissions  trading  should  be  adapted  for  sectors 

from  other  sectors 

for  emissions 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

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that  require  a  carbon 

with  hard  to  abate,  residual  emissions  and  for 
sectors 
feedstock  (e.g. 
chemicals,  pulp  and  paper)  in  order  to  promote 
carbon circularity. 
Options  to  link  the  EU  ETS  with  other  compliance 
carbon  markets  should  be  pursued,  provided  that 
the  environmental  integrity,  potential  cost-efficiency 
gains  and  more  options  for  emissions  abatement 
are carefully assessed. 

1 

2 

3 

4 

5 

Q19: Future role of the carbon border adjustment mechanism (CBAM) 

In  October  2023,  the  European  Commission  will  introduce  the  carbon  border  adjustment 
mechanism,  which,  for  the  goods  and  sectors  under  its  scope,  will  replace  the  existing 
mechanisms to prevent the risk of carbon leakage under the EU ETS. Instead, the CBAM will 
ensure equivalent carbon pricing for imports and domestic products. Under the (provisional) 
CBAM  agreement,  the  Commission  is  mandated  to  assess  the  possibility  of  including  all 
sectors identified as at risk of carbon leakage in the ETS Directive (Directive 2003/87/EC) at 
the latest by 2030.  

1 = totally disagree; 5 = 
totally agree 

I 
don’t 
know 

Any extension of CBAM to all ETS products, which will 
replace  free  allocation,  should  be  done  progressively 
and prioritise certain sectors. 

1 

2 

3 

4 

5 

Priority  should  be  given  to  sectors  where  absolute 
emissions are the highest. 

1 

2 

3 

4 

5 

Priority should be given to sectors where the emission 
reduction efforts are the lowest. 

1 

2 

3 

4 

5 

If  the  scope  of  CBAM  were  extended  to  additional  sectors,  which  sectors  would  be 
the priority? 

Q20: Future role of the Effort Sharing Regulation (ESR) and links with the ETS 

With  the  ‘Fit  for  55’  package,  some  emissions  currently  falling  under  the  ESR  (and  the 
associated national targets) will also be covered under an EU ETS (notably CO2 emissions 
from road transport and buildings).  

How  should  the  scope  of  emissions  under  the  ESR  and  the  associated  national  targets 
evolve in the EU’s post-2030 climate policies?  

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1 = totally disagree; 5 = 
totally agree 

I 
don’t 
know 

The ESR and associated national targets should cover 
only  GHG  emissions  that  are  not  subject  to  the  EU 
ETS. 

1 

2 

3 

4 

5 

The ESR and associated national targets should keep 
the  same  GHG  scope  as  currently,  covering  both 
emissions  that  are  not  under  the  EU  ETS  (e.g. 
agriculture methane  and  nitrous  oxide  emissions)  and 
emissions  from  fuels  used  in  road  transport  and 
buildings (subject to the new ETS).  

1 

2 

3 

4 

5 

There  should  be  national  targets  covering  all  GHG 
emissions from all sectors (including those covered by 
the EU ETS). 

1 

2 

3 

4 

5 

National  targets  should  be  replaced  by  EU-wide 
sectoral legislation. 

1 

2 

3 

4 

5 

Mitigation of GHG emissions from the land sector (agriculture, forestry and other land 
use) and policy options 

Q21:  The  role  of  carbon  pricing  and  non-carbon  pricing  instruments  for  agricultural 
emissions and land-based removals  

Agriculture  is  responsible  for  almost  12%  of  EU  emissions.  One  possible  way  for  climate 
policies to tackle this problem is to set a carbon price on agricultural emissions. But there are 
also  other  options,  such  as  national  targets,  sectoral  standards,  or  better  information  and 
support.  

Please indicate your preference for the different options by rating the statements from totally 
disagree (1) to totally agree (5). (response options will be provided in random order) 

1 = totally disagree;  
5 = totally agree 

I don’t 
know 

A carbon price on agricultural emissions, coupled with 
payments for carbon removals, will provide farm-level 
incentives to move to sustainable farming practices. 

1 

2 

3 

4 

5 

Emission  reductions  and  carbon  removals  in  the 
agricultural  sector  should  be  covered  by  national 
targets  and  achieved  through,  inter  alia,  the  EU 
common agricultural policy (CAP). 

1 

2 

3 

4 

5 

Unsustainable  farming  practices  should  be  ruled  out 
that  make 
by  ambitious 
sustainable farming practices the new standard.  

standards 

sectoral 

1 

2 

3 

4 

5 

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the  climate 

Non-regulatory approaches such as better information 
on 
to 
innovation, combined with consumers’ higher demand 
for  climate  action,  will  be  enough  to  drive  the 
transformation of the farming sector. 

food  and  support 

impact  of 

1 

2 

3 

4 

5 

Q22: Agricultural emissions and climate policies 

If a carbon price was set on agricultural emissions, for which actor should it be set? Please 
rate the following options from totally disagree (1) to totally agree (5).  

1 = totally disagree;  
5 = totally agree 

I don’t 
know 

Farmers:  A  carbon  price  or  stricter  standards  at  the 
farm level would steer the decisions of the actors who 
are more directly in control of agricultural emissions. 

1 

2 

3 

4 

5 

Food  companies:  Making  food  producers  liable  for 
the  climate  footprint  of  a  product  along  the  entire 
value  chain  would  drive  the  transition  towards  more 
sustainable food systems. 

fertilisers:  Fertilisers  generate 
Producers  of 
greenhouse  gases  when  applied  on  the  land.  Asking 
producers  to  pay  the  corresponding  carbon  price 
would  promote  the  most  sustainable  and  efficient 
fertilising solutions. 

the  most  GHG-intensive 

Consumers:  A  carbon  price  linked  to  the  emissions 
of 
food  products  (e.g. 
animal-based) would incentivise a shift towards more 
climate-friendly diets. 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

The role of carbon removals 

The objectives of the Paris Agreement are challenging, and scientific evidence presented by 
the IPCC indicates that it will be necessary at a certain point to remove a significant amount 
of CO2 from the atmosphere in order to stay below 2°C, and even more so in order to limit 
the temperature increase to 1.5°C. Carbon removals are processes in which carbon dioxide 
gas  is  removed  from  the  atmosphere  and  durably  stored  in  geological,  terrestrial  or  ocean 
reservoirs or in products. While some nature-based solutions like growing forests and storing 
carbon  in  biomass  have  already  existed  for  a  long  time,  industrial  solutions  that  capture 
atmospheric  carbon  and  then  store  it  underground  (directly  with  direct  air  capture  and 
indirectly through carbon capture associated with bioenergy) are so far only used on a small 
scale or are still being developed.  

Q23: General role of carbon removals  

Carbon  removals  can  decrease  the  overall  level  of  CO2  in  the  atmosphere  or  cover  for 
remaining GHG emissions from the economy.  

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What  should  be  the  role  of  carbon  removals  to  meet  the  EU  climate  neutrality  target  by 
2050?  

  A very limited role. All GHG emissions can be brought down close to zero by 

2050, including in sectors that are currently considered as difficult to fully abate 
(like agriculture, aviation or some industrial processes). 

  An important role. Carbon removals compensate remaining unabated GHG 

emissions in different sectors, including agriculture, industrial processes, while 
driving the growth of the EU clean industry and providing co-benefits for other 
environmental objectives. 

  No opinion. 

Q24: Relative contribution of nature-based removals and industrial removals 

If the EU were to rely to a certain extent on carbon removals to meet its targets in 2040, what 
should  be  the  relative  contribution  of  nature-based  removals  in  the  land  sector  (“LULUCF”) 
and  industrial  removals  (direct  air  capture  or  carbon  capture  and  storage  associated  with 
bioenergy)?  

  A stronger reliance on the LULUCF sink, since the large-scale deployment of 

industrial removals is uncertain. 

  A balance between the LULUCF sink and industrial removals. 

  A stronger reliance on industrial removals, since the evolution of the LULUCF sink 

is uncertain. 

  No opinion. 

Technologies 

Q25: Barriers to carbon capture and storage technologies 

What are the main hurdles to deploying carbon capture and storage technologies? 

1 = minor; 5 = major 

I don’t know 

Public acceptance 

Regulatory framework 

Technology maturity 

Cost of CO2 capture technology  

CO2 storage availability 

Economic  signals  (e.g. 
carbon) 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

the  price  of 

1         2         3         4           5 

Q26: Carbon capture and use or storage  

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Which  deployment  of  carbon  capture  and  storage  and  carbon  capture  and  use  should  be 
prioritised? 

1 = lower priority; 5 = higher 
priority 

I don’t know 

Capture  of  CO2  from  the  combustion  of 
fossil-fuel. 
Capture  of  CO2  from  non-energy  related 
industrial processes CO2 emissions. 
Capture  of  CO2  from  the  combustion  of 
biomass. 
Capture  of  CO2  directly  from  the  air 
(direct air capture). 
Permanent  storage  of  captured  CO2  in 
underground  geological 
to 
avoid emissions (fossil CCS) or generate 
negative emissions (BECCS/DACCS). 
The  use  of  captured  CO2  in  fuels  and 
products to replace virgin fossil carbon. 
The  co-production  of  clean  gas  and 
biochar through the treatment of biomass 
in  an  approach  combining  the  use  and 
storage of biogenic carbon. 

formations 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

1         2         3         4           5 

Q27: Energy technologies 

The energy system today is responsible for around 75% of the EU's GHG emissions and is 
currently undergoing a rapid transformation. Accelerating this change will play a central role 
in the transition towards a carbon-neutral economy. 

The following table lists different energy technologies. Which are the most relevant solutions 
for  the  energy  transition  towards  carbon  neutrality?  Please  rate  the  options  from  not 
important (1) to very important (5).  (response options will be provided in random order) 

Energy  efficiency 
reducing the need to produce and consume energy. 

first  principle:  prioritise 

further 

1 = very irrelevant; 5 = 
very relevant 

I don’t 
know 

1 

2 

3 

4 

5 

Renewable  energy  from  wind  (onshore,  offshore  and 
floating),  solar  (including  rooftop  and  decentralised 
installations) or hydro. 

1 

2 

3 

4 

5 

Bioenergy from advanced biofuels or solid biomass. 

1 

2 

3 

4 

5 

Other  forms  of  renewable  energy,  like  geothermal 
(including heat pumps), wave or tidal. 

1 

2 

3 

4 

5 

Nuclear energy (existing nuclear fission). 

1 

2 

3 

4 

5 

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Fossil fuels with carbon capture and storage. 

Solid biomass for heat and electricity production. 

Advanced liquid biofuels. 

Biogas from agricultural and domestic waste. 

1 

1 

1 

1 

2 

2 

2 

2 

3 

3 

3 

3 

4 

4 

4 

4 

5 

5 

5 

5 

Electricity  storage,  long  duration  storage  and  heat 
storage (electricity system integration). 

1 

2 

3 

4 

5 

Hydrogen  and  its  derivatives  (produced  in  a  carbon-
neutral manner).  

1 

2 

3 

4 

5 

Demand  management,  demand  response  and  greater 
digitisation of energy systems. 

1 

2 

3 

4 

5 

Please specify any different options below: 

Q28:  Opportunities  and  challenges  with  regard  to  energy  technologies  and  their 
development 

What  are  the  biggest  opportunities  in  the  energy  sector  and  in  the  sectors  of  the  economy 
consuming  energy  (residential,  industry,  transport),  including  for  the  wider  economy  and 
security  of  supply?  What  are  the  biggest  challenges  related  to  the  future  development  of  a 
low-carbon energy sector, including as regards to public acceptance or the availability of land 
and natural resources?  

Q29: Other options to fight climate change to be considered 

Please  rate  the  options  below  to  indicate  the  most  relevant  solutions  for  limiting  climate 
change: (response options will be provided in random order) 

1 = very irrelevant; 5 = 
very relevant 

I don’t 
know 

Afforestation, reforestation and forest restoration. 

Peatland  restoration  (rewetting,  revegetating,  and 
paludiculture on peatlands). 

1 

1 

2 

2 

3 

3 

4 

4 

5 

5 

Agroforestry  and  other  agricultural  soil  management 
practices. 

1 

2 

3 

4 

5 

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Soil carbon sequestration. 

Bio-energy carbon capture & storage (BECCS). 

Direct air carbon capture and storage (DACCS). 

Innovative  mobility  technologies  (wireless  charging, 
multimodal  urban  platforms,  autonomous  shared 
vehicles). 

1 

1 

1 

2 

2 

2 

3 

3 

3 

4 

4 

4 

5 

5 

5 

1 

2 

3 

4 

5 

Biochar (carbon sequestration by heating biomass in 
low oxygen environment). 

1 

2 

3 

4 

5 

Enhanced  weathering  (that  allows  CO2 
to  be 
removed  from  the  atmosphere  through  storing  into 
silicate rocks spread onto surfaces). 

1 

2 

3 

4 

5 

Coastal  blue  carbon 
restoring  and  managing  coastal  wetlands 
mangroves, saltmarshes, sea grasses). 

(carbon  sequestration  by 
like 

1 

2 

3 

4 

5 

Ocean-based  carbon  storage  (ocean  fertilisation, 
ocean alkalinity enhancement, artificial upwelling). 

1 

2 

3 

4 

5 

Nuclear fusion (energy generation through the fusion 
of atoms). 

1 

2 

3 

4 

5 

Solar  radiation  modification  (temporary  measure  to 
limit  climate  change  through  aerosol  injection  to 
reflect more sunlight into outer space). 

1 

2 

3 

4 

5 

Production  of  plant-based  meat  substitutes  or  ‘in 
vitro’ meat. 

1 

2 

3 

4 

5 

Innovative  technologies  improving  digitalisation  in 
different  sectors  (digital  energy  systems,  precision 
farming,  connected  mobility,  etc.)  that  reduce  GHG 
emissions. 

1 

2 

3 

4 

5 

Q30: Open question on the future role of other innovative options 

Which other innovative technologies could be used to reduce emissions, in particular in hard-
to-abate industrial sectors or to compensate for hard-to-capture emissions?  

Engagement and social impacts 

Q31: Local and regional implementation of the European Green Deal  

Local and regional authorities such as cities, regions and local communities, as well 
as other actors such as civil society and the private sector, can play an important role 

124 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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in  achieving  the  energy  transformation,  reducing  GHG  emissions  and  adapting  to 
climate  change.  Many  regions,  cities,  companies  and  citizens'  organisations  are 
implementing projects covering energy, transport, food and waste management, and 
thereby helping to foster the green transition. Importantly, they often achieve local co-
benefits  related  to  economic  and  social  development,  health  and  well-being,  while 
contributing to a low carbon economy and the energy transition.  
In your view… 

…are  local,  regional,  and  private  sector  actors 
sufficiently 
the  green 
transition? 

in  supporting 

involved 

1 = No, absolutely not;  
5 = Yes, absolutely 

I don’t 
know 

1 

2 

3 

4 

5 

 …are  national  energy  and  climate  plans  (NECP)  a 
good source to inform the 2040 policy framework? 

1 

2 

3 

4 

5 

Q32: Social impacts of climate change policies  

While  achieving  climate  neutrality  will 
long-term  economic,  societal  and 
lead 
environmental benefits for the people of Europe, the increase in the price for fossil fuels will 
have  significant  social  and  distributional  impacts  that  can  disproportionally  affect  regions, 
sectors and vulnerable people in our society.  

to 

In view of ensuring a just transition, please rate the following statements from totally disagree 
(1) to totally agree (5). 

1 = Totally disagree;  
5 = Totally agree 

I don’t 
know 

After  2030,  there  will  be  a  greater  need  to  support 
vulnerable individuals who must cope with the costs 
associated with the green transition. 

Strengthening carbon pricing to spur climate-friendly 
activities, services and goods may affect the cost of 
living.  It  should  be  accompanied  by  adapted  fiscal 
policies to mitigate the impacts on citizens.  

Vulnerable  households  (such  as  single  parents) 
may struggle with increasing energy prices and face 
an unequal burden of climate change. A socially just 
transition  is  key  and  should  be  ensured  through 
mechanisms  to  support  middle-  and  lower-income 
households financially.  

It  is  important  to  ensure  inter-generational  fairness: 
ambitious  action  is  needed  now  to  limit  future 
adverse impacts of climate change on young people 
and future generations. 

1  

2 

3 

4 

5 

1  

2 

3 

4 

5 

1  

2 

3 

4 

5 

1  

2 

3 

4 

5 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Q33: Sectoral impacts of the transition 

The green transition will create new opportunities but also lead to a decline in employment in 
certain  sectors  (such  as  coal,  peat,  oil  shale,  petroleum)  and  increase  the  need  for 
transformation  in  others  (GHG  intensive  industry  such  as  non-metallic  minerals,  basic 
metals, chemicals, cement, fertilisers, and oil refining). In addition, some small and medium 
sized enterprises may be impacted by changes necessary for decarbonising operations and 
manufacturing less energy-intensive products. 

Please rate the following statements from totally disagree (1) to totally agree (5). 

1 = Totally disagree;  
5 = Totally agree 

I don’t 
know 

The  green  transition  represents  an  opportunity  for 
small and medium sized enterprises (SMEs). 

1 

2 

3 

4 

5 

After  2030,  there  will  be  a  greater  need  to  support 
SMEs  to  cope  with  the  adaptation  and  costs 
associated with the green transition. 

The impact on competitiveness of micro-companies 
is  likely  to  differ  from  the  impact  on  small  and 
medium-sized ones. 

The  EU  transition  to  a  net-zero  economy  impacts 
differently  on  the  competitiveness  of  SMEs  from 
those of large companies. 

1  

2 

3 

4 

5 

1 

2 

3 

4 

5 

1 

2 

3 

4 

5 

The  most  affected  sectors  by  the  green  transition 
will significantly change after 2030. 

1 

2 

3 

4 

5 

The 
likely  structural  shift  and  changing  skill 
requirements  in  the  economy  towards  a  green  and 
circular economy will require EU action to reskill and 
upskill the workforce. 

1 

2 

3 

4 

5 

Q34: Open Question on affected sectors after 2030 

If  you  believe  the  sectors  affected  by  the  green  transition  will  change  after  2030,  which 
sectors do you believe will be affected by then and how? Please describe briefly in the text 
field.  

Adapting to climate change 

Climate change is already causing observable effects on the environment. Towards 2040 it 
will  increasingly  impact the  achievement  of  our climate targets through  its  effect  on  sectors 
such  as  energy,  transport  and  land-use.  Some  of  these  observable  effects  include  more 

126 

  
 
 
 
 
 
 
 
 
 
 
 
 
 
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extreme  temperatures,  higher  wind  speeds,  heavier  rainfall,  droughts  and  wildfires  all  of 
which negatively impact climate mitigation efforts. 

Q35: EU policy ambition on climate resilience of mitigation efforts  

Assets instrumental in delivering our climate mitigation targets will be exposed to the effects 
of  a  growing  number  of  extreme  weather  events.  This  includes  energy  infrastructure,  (from 
generation  and  transmission  to  distribution  and  the  final  customer),  transport  infrastructure 
(from bicycle roads to the high-speed train network) and land use (both in terms of sectoral 
carbon emissions and carbon removal).  

What do you believe would be the right scope for regulating these sectors from the point of 
view of climate adaptation and resilience? (One option possible.) 

  Current EU regulations and policy are sufficient to guarantee the security of the 

mitigation efforts in face of climate impacts. 

  The EU should do more to promote the climate resilience of mitigation efforts 

using soft measures (guidance, training, etc.) 

  The EU should provide specific provisions related to climate risks in the existing 

EU legislative framework  

  The EU should draft new legislation to improve the climate resilience of mitigation 

efforts. 

  I do not know. 

[Option to submit position papers] 

127 

  
 
 
 
 
 
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Appendix B: Overview of the main characteristics of the selected position papers 

Table 4  

Stakeholder groups distribution for the selection position papers 

Stakeholder group 

Academic/research institution 

Business association 

Company/business 

Consumer organisation 

Environmental organisation 

Non-governmental organisation (NGO) 

Other 

Public authority 

Trade union 

Total 

Count 

12 

42 

13 

1 

8 

16 

9 

17 

2 

120 

Table 5 

Distribution of geographical origin of selection position papers 

Country 

Austria 

Belgium 

Denmark 

Estonia 

Finland 

France 

Germany 

Ireland 

Italy 

Netherlands 

Poland 

Romania 

Slovenia 

Spain 

Sweden 

Switzerland 

128 

Count 

4 

53 

4 

1 

7 

4 

19 

1 

2 

7 

2 

2 

1 

2 

4 

3 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Table 6 

Length of the selected position papers 

Table 7 

Language of the selected position papers 

United Kingdom 

United States 

Total 

Paper length 

1-5 

6-10 

11-20 

20-50 

>50 

Total 

Paper language 

DE 

EN 

ES 

IT 

PL 

SE 

Total 

2 

2 

120 

Count 

61 

23 

10 

13 

13 

120 

Count 

4 

112 

1 

1 

1 

1 

120 

129 

  
 
 
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Appendix C: Abstracts of the selected position papers  

120 position papers submitted by stakeholders have been analysed to carry out the thematic analysis presented in this report. An abstract 
of those position papers is available in the table below. 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Academic/research 
institution 

Centre for European Policy 
Studies (CEPS) 

Belgium 

All sectors 

Academic/research 
institution 

COP21 Ripples 

Spain 

Various sectors 

Academic/research 
institution 

Wood Circus 

Finland 

Buildings 

Academic/research 
institution 

INHERIT 

Germany 

Various sectors 

130 

covered: 

Climate, 
Economic, Policy, 
Crisis, European, 
Emissions, 
Recovery 

EU, Climate, 
Policy, Energy, 
European, 
Emissions 

Woodworking, 
European, 
Industries, 
Circular, 
Sustainable 

Income, Scenario, 
Participants, 
Energy 

Policy briefing by CEPS on aligning the EU post-pandemic 
economic recovery and the Paris decarbonization objectives. The 
policy briefing contains recommendations for the short and long 
term. In relation to the covid crisis and climate change, the paper 
mentions that the crisis will require the EU to think big and that 
this provides an opportunity to go beyond the incrementalism that 
has characterised climate policy to date. Possible areas for 
transformational approaches are the creation of low-carbon lead 
markets (as for example outlined in the European Commission’s 
New Industrial Strategy for Europe), the kick-start of the 
hydrogen economy or a focus on the basic material value chain, 
which is responsible for half of global GHG emissions. CEPS also 
state that it may be wise to postpone an increase in the 
emissions reductions target for 2030 to 50-55% as the 
implications of the pandemic are yet uncertain. However the 
paper was written in 2020. 

The EU 2040 emissions reduction ambition is not the specific 
focus of the paper. The paper makes the case for an adequacy 
assessment framework and its application within the EU with the 
aim to assess the implementation of the Paris Agreement at the 
national level and how to reach the set target of 1.5C, as well as 
GHG emission reduction by 2030 and 2050 respectively.  COP21 
Ripples project makes the case that the focus for change should 
not be solely on emissions, but also on other dimensions such as 
international economic and social governance, and 
interrelationships of global markets. 

The paper analyses the importance of the wood industry for the 
green transition. For example, woodworking industries provide 
options for more sustainable buildings, link to renovation wave 
and new Bauhaus. The paper states that wood and wood-base 
products will help achieving the carbon neutrality goals set by the 
European Green Deal. This is due to high production efficiency, 
and high potential of recovery, reusing and recycling, creating a 
more sustainable economy. 

The paper brings insights into citizen’s perceptions of four future 
scenarios for healthier, more equitable and sustainable European 
societies in 2040. The scenarios are based on perceptions from 
citizens of five European Countries.  Participants in the study 
were especially positive towards development of new smart 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Academic/research 
institution 

Potsdam Institute for 
Climate Impact Research 

Germany 

All sectors 

Academic/research 
institution 

European Scientific 
Advisory Board on Climate 
Change 

Denmark 

All sectors 

covered: 

Scenario, Energy, 
Emissions, Life, 
Change, Behaviour 

Climate, EU, 
Emissions, Global, 
Scenarios 

Academic/research 
institution 

German Institute for 
International and Security 
Affairs 

Germany 

Various sectors 

Ocean, Carbon, 
Climate, Marine, 
Storage, Policy 

Academic/research 
institution 

Agora Energiewende 

Germany 

Energy 

Climate neutrality, 
Emissions, 
Climate, 
Transition.   

131 

homes to increase levels of energy-efficient housing. For 
example, discussions in the UK highlighted that smart meters 
could increase personal capabilities to understand specific 
devices' energy consumption. 

The paper evaluates how behavioural and technological changes’ 
have contributed to decarbonisation. It concludes that changes in 
lifestyles are crucial and could contribute to achieving climate 
targets before 2050 and that the combination of both behavioural 
and technology changes can lead the EU to reach net zero 
emissions by 2040. 

In this position paper, the European Scientific Advisory Board on 
Climate Change gives input to the determination of an EU-wide 
2040 climate target and projected indicative greenhouse gas 
budget for 2030-2050. Their key recommendation is that the 
European Commission should follow an approach that is 
systematic, transparent and guided by EU values. This will help 
to demonstrate that the proposal incorporates the full range of 
scientific, legal, technical and ethical issues that it is required to 
consider under the European Climate Law. Moreover, providing 
integrated scenarios will guide the setting of scientifically sound 
intermediate 2040 targets and a 2030–2050 greenhouse gas 
budget for the EU, which is the main focus and argument of this 
position paper.  

The paper looks into the role of the ocean in carbon removal and 
EU climate policy. It mentions that the oceans may become the 
new “blue” frontier for carbon removal as the challenges of land-
based removal approaches are increasingly recognised. As there 
is a tension between the rights of states to use ocean resources 
within their exclusive economic zones and the international 
obligation to protect the ocean as a global common, the paper 
state that the EU need to clarify the balance between the 
protection and use paradigms in ocean governance when 
considering using the ocean as an enhanced carbon sink or 
storage site. 

The report presents a structural transition pathway away from 
fossil gas use by 2050 based on detailed sectoral modelling of 
the energy, buildings, and industry sectors. It concludes that by 
2040, EU greenhouse gas emissions could decline by 89% 
relative to 1990 levels, with a 

projected remaining Union greenhouse gas budget for the 2030–
2050 period of 14.3 Gt. 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Academic/research 
institution 

Eurac Research - Institute 
for Comparative 
Federalism 

Italy 

Various sectors 

Academic/research 
institution 

NAVIGATE consortium 

Germany 

All sectors 

covered: 

Local policies, Best 
practices, 
Transport, Energy, 
Water, Spatial 
planning. 

Targets, 
Emissions, 
Navigate, 
Decarbonisation 

Academic/research 
institution 

CDRterra 

Germany 

Various sectors 

Climate, carbon  

Academic/research 
institution 

European Roundtable on 
Climate Change and 
Sustainable Transition 
(ERCST) 

Belgium 

All sectors 

Climate, target, 
carbon    

Business association  Glass Alliance Europe 

Belgium 

Manufacturing 
industry 

Glass, EU, ETS, 
industry, 
Emissions 

The document presents a collection of best practices, i.e., a non-
exhaustive list of examples concerning how the subnational 
governments analysed, the two Autonomous Provinces of Trento 
and Bolzano and the two Austrian 
Länder of Vorarlberg and Tyrol, have successfully managed to 
mainstream climate change considerations in subnational and 
local policies, plans, and initiatives. 

The document discusses the EU 2040 target in relation to 
insights from the NAVIGATE project. More specifically, it 
discusses this in the areas of industry, buildings and transport, 
but also the EU’s efforts to achieve the global methane pledge. It 
also discusses economic and fairness implications of the 
transition to net zero. The paper mentions that the 2040 target 
should be chosen in a manner that allows the completion of the 
final act of replacing or compensating the residual emissions in 
hard to abate sectors e.g., heavy industry, and aviation in the 
remaining 10 years after 2040 

In the paper, CDRterra emphasises that the EU needs to 
strengthen the emission reduction targets, to focus on the 
integration of carbon removals and strengthen EU ambitions and 
international collaborations. That implementing an ambitious 
climate target by 2040 brings multiple opportunities, including 
mitigating climate change impacts, driving clean energy transition 
and innovation, improving public health, enhancing economic 
resilience, conserving the environment, and promoting social 
justice. 

The document is ERCST's rationale accompanying the answers 
for the 2040 targets questionnaire. Among other statements, the 
organisation argues that the transition to climate neutrality should 
continue at the current pace and that the EU's ambition should 
depend on other countries' climate ambition. 

In the paper the Glass Alliance Europe state that they fully 
supports the decarbonisation objectives set out in the Climate 
Law to address climate change and its harmful consequences on 
our planet, and in the paper share their view on the ongoing 
reform of the EU ETS. The glass industry recommend that the 
EU should maintain the ETS cap decrease as proposed by the 
Commission and without rebasing to avoid further increasing the 
pressure on European industry with no effect on the overall 
reduction target. The alliance also recommends the EU to 
introduce measures to avoid the application of the cross-sectoral-
correction factor (CSCF) and more. 

132 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Business association 

International Emissions 
Trading Organisation 
(IETA) 

Switzerland 

Various sectors 

Business association  European Community 

Belgium 

Transport 

Shipowners Associations 
(ECSA) 

Business association  EUROPEAN HYDROGEN 

Netherlands 

Energy 

BACKBONE 

Business association  European Banking 

Germany 

Finance 

Federation (EBF) 

Business association  European Automobile 

Belgium 

Transport 

Manufacturers Association 
(ACEA), Potsdam Institute 
for Climate Impact 
Research (PIK) 

133 

covered: 

EU, ETS, 
Emissions, 
Carbon, Climate, 
IETA, International 

Shipping, Industry, 
IMO, EU, Maritime, 
Fuels 

Hydrogen, 
Infrastructure, 
Energy, European, 
Network 

EU, Taxonomy, 
Banks, Transition, 
Activities, Green, 
Companies, 
Finance 

Transport, 
Vehicles, Truck, 
Zero emissions, 
Road, Policy 

Position paper on the development of the EU ETS to 2050, 
highlighting the importance of a strong cap and extension to other 
sectors. IETA for example suggest providing stand-alone ETS 
systems for sectors already covered by the EU ETS (e.g., Road 
Transport and Buildings) to provide a strong price signal for 
sectors that would otherwise not receive one through EU ETS 
inclusion. IETA also support placing the intra-EU maritime sector 
in the EU ETS as long as the rigorous MRV requirements are 
met.  

The ECSA position paper centres around the implications of the 
target of carbon neutrality in the shipping industry and discusses 
the options on how the EU can support the green transition in the 
shipping industry. However, the ECSA also state that as a global 
industry, regulations to address GHG from shipping must be set 
at the global level via the UN IMO. Regional regulation carries the 
risk of being suboptimal, resulting in carbon leakage and the 
distortion of the level playing field, as well as undermining the 
good progress made by the IMO. 

Proposal of a European Hydrogen Backbone for 2040 which 
offers cost-effective, long-distance hydrogen transport. Based on 
the increased hydrogen targets set by the REPowerEU of a 20.6 
Mt renewable and low carbon hydrogen market in Europe by 
2030, the EHB proposes a plan for rapid increase in the 
hydrogen infrastructure network, establishing, deploying key 
transport corridors by 2030, and expanding it to a backbone for a 
pan-European network by 2040, which will comprise of 53,000 
kilometers consisting 60% of repurposed infrastructure, and 40% 
of new infrastructure 

The European Banking Federation (EBF) addresses in this 
position paper the role of the financial sector in encouraging the 
green transition in line with the EU Commission's Action Plan on 
Sustainable Finance. The EBF believes that the EU Taxonomy 
should be enhanced by the creation of mechanisms that will 
incentivize investors and companies in the transition to a 
sustainable and low-carbon economy. Mechanisms must 
acknowledge the transition needs, capacity, and willingness of 
companies at different stages across sectors/geographies as well 
as support gradual improvements in companies climate metrics.  

The position paper centres around the transition to zero 
emissions in the road freight transport. The paper emphasizes 
that to achieve the carbon-neturality goal in 2050, all new 
commercial vehicles sold must be fossil-free by 2040. 
Furthermore, the paper reiterates that it is not enough to set 
goals, but there must also be set a path to achieve those goals. 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Business association  Concawe 

Belgium 

Energy 

covered: 

Carbon, Fuels, 
Energy  

Business association  Eurometaux 

Belgium 

Manufacturing 
industry 

Energy, Supply, 
Recycling  

Business association  European cement 

Belgium 

association 

Manufacturing 
industry 

Storage, 
Transport, CCUS 

Company/business 

European Energy 
Exchange AG 

Germany 

Energy 

Climate, 
emissions, energy   

Business association  The Austrian Forest 

Austria 

Owners´ Cooperative 
(“Waldverband Österreich”) 

Land-Use, Land-
Use Change and 
Forestry 

Forestry, carbon, 
carbon credits   

134 

The paper argues that a sound CO2 emission pricing will be the 
single most effective policy to push the transition towards a 
carbon-neutral transport sector. 

The report is a theoretical assessment of different potential 
trajectories for the EU refining industry to contribute to EU climate 
targets for 2050. With a wide focus on road, aviation and 
maritime sectors, three potential demand scenarios show the 
total volume of low carbon fuels that could be required to 
contribute to climate neutrality in EU transport by 2050 as well as 
the number of plants and level of investment required (Volumes 
ranging from ~70 up to ~160 Mtoe/y with a cumulative ~190-660 
B€/y investment at the end of the period). 

The document discusses metals and clean energy. More 
specifically, how Europe can fulfil its goal of “achieving resource 
security” and “reducing strategic dependencies” for its energy 
transition metals, through a demand, supply, and sustainability 
assessment of the EU Green Deal and its resource needs. The 
demand pull for global metals is expected to soften beyond 2030 
and then again after 2040 as the deployment of clean energy 
technologies slows down, and more metals become available 
from secondary supply. Europe will be impacted by global supply 
constraints due to its import reliance for several ores and metals. 
Europe has the potential to change this picture through recycling, 
but only after 2040. 

The position paper discusses a framework for carbon capture 
investments. The European Cement Association more 
specifically discuss CCUS deployment in the cement sector, and 
that EU and national regulatory frameworks should be 
strengthened with regards to innovation funding, clear regulations 
for CO2 infrastructure, both storage and transportation networks 
and more. Regarding EU 2040 targets the Association express 
the need for industrial CO2 VS alternatives (BECCS, Direct Air 
Capture) and that these should be clearly assessed and 
documented as part of the EU 2040 target plan. 

In the paper, EEX emphasises that a clear 2040 climate target 
will be key not only for European climate efforts but also for 
further global cooperation to reduce emissions. EEX furthermore 
state that energy markets will remain a key instrument in 
delivering these ambitions.   

This position paper discusses carbon management in the forest. 
More specifically principles for selling carbon credits. According 
to the Austrian Forest Owners´ Cooperative, the main 
opportunities lie in holding the agriculture and forestry sector 
accountable for their emissions as a whole. The organisation 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

Business association  Finnish Forest Industries 

Finland 

Federation 
(Metsäteollisuus ry) 

Land-Use, Land-
Use Change and 
Forestry 

Climate, forest, 
carbon  

Business association  SMEunited 

Belgium 

All sectors 

Business association  ENTSO-E, European 

Belgium 

Energy 

Network of Transmission 
System Operators for 
electricity 

Business association  SGI Europe 

Belgium 

Various sectors 

Climate, energy, 
transition 

Climate, energy, 
transition 

Climate, 
emissions, 
decarbonisation   

Business association  Eurometaux (European 

Belgium 

non-ferrous metals 
association) 

Manufacturing 
industry 

Climate, transition 

Business association  EuroACE - Energy Efficient 

Belgium 

Buildings 

Climate, buildings 

Buildings 

135 

state that carbon management in agriculture will increasingly 
remove CO2 from the atmosphere and will have to store it in the 
biomass over the long term. The Cooperative further argues that 
the EU needs to foster stronger market incentives for companies 
to become climate neutral. 

In the position paper, the Finnish Forest Industries present the 
climate solutions provided by the sector. The organisation argue 
that the 2040 climate policies need to promote active geopolitics, 
strategic autonomy, green growth and future green transition.  

In the position paper, SME United argue that the climate and 
energy goals for 2040 must be feasible, clear transition pathways 
must be established, and guidance and support for SMEs in the 
energy transition must be in place. SME United underline the 
importance of future European climate targets being feasible and 
realistic that form clear transition pathways for SMEs towards net 
zero emissions. 

ENTSO-E shares and supports the European Commission’s 
commitment to accelerate the green energy transition to achieve 
climate neutrality by 2050. ENTSO-E state that the sustainable 
transition will require a massive deployment of large-scale 
renewable sources, innovative low-carbon technologies, deeper 
electrification, digitalisation and smart system integration. 
ENTSO-E state that the power system of the future will be based 
on three key elements, all essential for a sustainable, resilient 
and affordable power system: carbon neutral energy sources, 
system flexibility resources and an adequate development of the 
power grid. 

In its position paper, SGI Europe calls for a climate 2040 target of 
a minimum of 80% of emissions reduction and that the EU should 
accelerate its decarbonisation efforts in each sector where 
economically and socially feasible. SGI Europe also underlines 
the importance that European legislations should be technology 
neutral to enable more industries to contribute to the climate 
objective. 

In this position paper, Eurometeaux recommend that the 2040 
climate targets should enable conditions for the European 
industry, be based on science-based impact assessments, create 
a business case for decarbonisation and ensure global 
competitiveness of European Industry.   

EuroACE recommend the Commission to adopt a 2040 target in 
line with its 2050 objectives and frontload action in the buildings 
sector. EuroACE furthermore considers the 90% GHG scenario 
as feasible although it will require the EU to slightly increase the 
pace of decarbonisation after 2030 compared to the trajectory 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Business association  EHI - European Heating 

Belgium 

Energy 

Industry 

covered: 

Decarbonisation, 
buildings 

Business association  Eurochambres 

Belgium 

All sectors 

Climate, business 

Business association  Euromines 

Belgium 

Various sectors 

Climate, mining, 
emissions   

Business association  SolarPower Europe 

Belgium 

Energy 

Solar, renewables 

136 

target, allowing time and resources to address the emissions of 
hard-to-abate sectors post-2040. 

This report by EHI describe the decarbonisation pathways for the 
European building sector. The report looks at the targets until 
2030 and 2050, especially comparing it to REPowerEU and Fit 
for 55 packages. The report compared two pathways for the 
decarbonisation of the building sector. Pathway A focusses on 
very high electrification with little space for other technologies or 
energy carriers. Pathway B considers a high electrification which 
relies on an optimisation through more available solutions. The 
report concludes that Pathway B is the most cost-efficient choice.  

In the paper, Eurochambres emphasises the need for pioneering 
energy technologies to unlock new business opportunities; key 
innovations, like CCS/CCU for achieving climate goals and 
streamlining permitting procedures and to foster knowledge 
transfer between businesses and academia. Streamlining 
permitting procedures and fostering knowledge transfer between 
businesses and academia are therefore essential. Eurochambres 
mentions that concerns arise regarding the CBAM's impact on 
international competition and carbon leakage protection. The 
chamber network also warns about financial challenges faced by 
SMEs in securing sustainability financing due to overburdening 
regulations. However, despite the challenges, increased climate 
protection can offer business opportunities under favourable 
conditions. 

In their position paper, Euromines argue that a new target should 
be implemented with appropriate enabling framework conditions 
for a competitive and decarbonized industry; that there is a need 
for a business case for decarbonisation and that targets and 
policies require a sound scientific base. Euromines further urges 
the EU not to increase the number of sectors covered by the ETS 
as this will drive costs up higher without bringing about better 
technology and to not include further greenhouse gas emissions 
within the ETS as this will lead to an unsustainable race for 
remaining certificates. 

In the position paper, Solar Power Europe state that the 
technologies that we need to reach a fossil-free climate neutrality 
are already in our hands. That solar PV is, among all 
decarbonisation technologies, the most efficient and the most 
affordable to decarbonise our energy system and that it should 
be prioritsed in coming policy frameworks. 

  
 
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

Business association 

eFuel Alliance e.V. 

Germany 

Various sectors 

Fuel, climate 

Business association  Community of European 

Belgium 

Transport 

Climate, emissions  

Railway and Infrastructure 
Companies (CER) 

I the paper, the eFuel Alliance state that they strongly support the 
coming EU climate targets. The organisation  present five key 
recommendations in their position paper: 1. We need ambitious 
action across sectors and the promotion of all relevant climate-
friendly solutions to accelerate the transition towards carbon 
neutrality. 2. A targeted import strategy for eFuels will support 
emerging economies and developing countries in their transition 
to a more sustainable, low-carbon future, while at the same time 
ensuring that the volumes of CO2-neutral fuels needed for 
Europe's decarbonisation and energy security strategy are made 
available. 3. Pre qualifications schemes for eFuels production 
facilities and a clear planning horizon until 2050 in the Renewable 
Energy Directive and other relevant legislation must be set to 
provide the investment security needed for the industrial scale-up 
of eFuels. 4. Regulatory support for the deployment of Direct Air 
Capture technology is required to achieve negative emissions 
and create closed carbon cycles. 5. We need to establish a 
legislative framework that enables climate-friendly technologies 
to be deployed at a large scale. 

In their position paper, CER underlines that European railways 
are a key to tackle EU decarbonisation challenge in the next two 
decades. CER are calling the EU policy makers to facilitate a 
regulatory framework by cost-effectively reducing emissions in 
transport. The paper states that CER and member companies 
are ready to support the Commission impact assessment with 
technical inputs and further expertise. 

Business association  Confederation for Danish 

Denmark 

All sectors 

Climate, transition   DI supports an 80 – 90% 2040 EU climate target and thus also a 

Industry 

Business association  Association of Big 
Industrial Energy 
Consumers Romania 

Romania 

Energy 

Industry, climate 

Business association  European Chemical 

Belgium 

Industry Council (Cefic) 

Manufacturing 
industry 

Climate, 
regulations 

137 

further acceleration of EU’s effort to become climate neutral. 
Noting the EU’s Climate Advisory Board recommendation of a 
90-95% ambition,  they urge the EU-Commission to include the 
international perspective – and possibilities to ensure 
international cooperation in the assessments to come. DI also 
call for a well-balanced regulation to meet EU’s objectives, and 
state that  regulation must assist  the EU to also meet energy 
security objectives and competitive objectives. 

In this position paper, among other points, ABIEC highlight the 
importance of ensuring enabling conditions for European 
industries, a proper business case for decarbonisation and to 
ensure global competitiveness of European industries, when 
formulating the 2040 climate targets.  

In the position paper, Cefic highlights the chemical sector's long 
investments cycles and the need for a supporting and coherent 
regulatory framework to secure necessary investments to deploy 
and scale up disruptive technologies.  

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

Business association  Svenskt Näringsliv/Con-

Sweden 

All sectors 

Climate, emissions   The document consists of additional comments to the public 

federation of Swedish 
Enterprise  

Business association  Confederation of European 

Belgium 

Paper Industries 

Manufacturing 
industry 

Climate, industry 

Business association  Eurelectric 

Belgium 

Energy 

Climate, emissions 

consultation questionnaire from The Confederation of Swedish 
Enterprise. The Confederation of Swedish Enterprise state their 
main principles to take into consideration when realizing the 2040 
climate target. These include an energy and climate framework 
2040 and supplementary measures to reach its objective to be 
technology neutral, cost-effective and market based. They also 
emphasise that it is essential to promote competitiveness of 
European businesses and continuously assess the established 
policies to that end. 

In this position paper CEPI makes several recommendations. 
Among other things that we should prioritise the reduction of 
fossil emissions without resorting to compensation, that we 
should recognise and favour biogenic carbon and distinguish it 
from recycled fossil carbon and that we should secure the EU 
strategic autonomy by facilitating access to fossil-free energy for 
the industrial users and efficient use of forest biomass.  

In their position paper Eurelectric state that they fully support the 
efforts to meet the objectives of the European Climate Law, in 
line with the 1.5 °C ambition set by the Paris Agreement. They 
also state that electrification is the most direct, efficient, and 
effective way to achieve the  decarbonisation goal, as it reduces 
emissions in three ways: switching to carbon-neutral power 
generation, reducing total energy demand, and replacing fossil-
based inputs to industrial processes. If properly implemented, a 
forward-looking energy transition based on ambitious 
intermediary targets on the way to climate-neutrality by 2050, 
driven by a market-based climate policy, will lower energy bills 
and bring economic benefits to the society at large. Eurelectric 
also believes that carbon removals will play an indispensable part 
in reaching the EU’s climate neutrality goal for 2050. Hence it is 
urgent that carbon removals are incorporated in the formulation 
of the EU 2040 climate target and fully supported by the policy 
framework that will be developed in the next step. Eurelectric 
moreover encourages policymakers to remain technology open to 
enable cost-efficient emissions reduction in the energy sector 
leading to full economy-wide carbon-neutrality by 2050 while 
ensuring security of supply, competitive energy prices and social 
acceptance. 

Business association  European Cement 

Belgium 

Association 
(CEMBUREAU) 

Manufacturing 
industry 

Cement, emissions  CEMBUREAU welcomes the Commission initiative to set an EU 

2040 target but does not have a strong view on the desirable 
level. They state that a realistic pathway and supportive 
measures will be critical to decarbonise energy-intensive sectors 
like cement. From that perspective CEMBUREAU consider that 
the prolongation of the current ambition level is adequate and 

138 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

correct and will deliver the carbon neutral society in 2050. 

Business association 

International Association of 
Oil and Gas Producers 
Europe (IOGP Europe) 

Belgium 

Energy 

Climate, emissions   

Business association  Confederation of Finnish 

Finland 

All sectors 

Climate, industry  

Industries EK 

Business association  The Danish Chamber of 

Denmark 

All sectors 

Climate, emissions  

Commerce (Dansk 
Erhverv) 

Business association  Eurogas 

Belgium 

Energy 

Emissions, gas 

In the position paper, IOGP emphasises regulatory simplification, 
technology inclusiveness and security of supply and domestic 
production as areas to consider when formulation the 2040 
climate targets. IOGP Europe also call on the EU to take a much 
broader approach to the applications of low-carbon solutions, 
such as carbon management and carbon removal technologies, 
rather than envisaging their potential only for residual emissions. 

In their position paper, the Confederation of Finnish Industries 
state that the climate framework for 2040 should rely on 
technology neutrality, cost-efficiency, market-based approaches 
like the emission trading schemes, flexibility in measures, and at 
the same time it should take care of coherency, competitiveness, 
sustainability and security (energy, food etc). European industry 
should furthermore be raised in the significant role as a solution 
provider globally. They also emphasise the need for research and 
innovation finance. 

In the position paper, the Danish Chamber of Commerce argue 
that future EU climate policy should be developed around the 
following pillars: foster a market-based transition where price 
signals should be the driving force for the climate transition; 
Encourage innovation by making future EU climate policies 
technology neutral and broad 
enough to also encompass technologies and solutions that are 
not used today; Enable a cost-effective transition and ensure that 
policies must be simple and transparent. 

Eurogas argue that the evolution of the EU Emissions Trading 
System (EU ETS) should be done with a comprehensive and 
forward-thinking policy framework. By expanding coverage to all 
fossil fuel uses, exploring cross-border linkages and compliance 
with other carbon markets (e.g. UK, Japan, US), including non-
CO2 GHG emissions, and tailoring approaches for sectors with 
residual emissions, the EU can drive deep carbon cuts, foster 
carbon circularity, and advance the global fight against climate 
change. Moreover, Eurogas state that industrial based removals 
have a greater role to play than nature-based removals. They 
mention several obstacles, however. These include public 
acceptance, regulatory framework, technological maturity, CO2 
storage availability and economic signals.  

139 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Business association  Bioenergy Europe 

Belgium 

Energy 

covered: 

Bioenergy, 
electricity 

Business association  Aerospace, Security and 

Belgium 

Various sectors 

Climate, aviation  

Defence Industries 
Association of Europe 
(ASD) 

Business association  Central Union of 

Finland 

Agricultural Producers and 
Forest Owners (MTK) 

Land-Use, Land-
Use Change and 
Forestry 

Climate, forestry 

Business association  European Steel 

Belgium 

Association (EUROFER)  

Manufacturing 
industry 

Climate, carbon, 
transition   

Business association  FuelsEurope 

Belgium 

Energy 

Climate, carbon  

140 

Int the position paper, Bioenergy Europe underline that the EU 
must ban subsidies of fossil fuels. Moreover, they state that 
bioenergy provides clear benefits to all energy needs of the EU 
(heating and cooling, transport, and electricity).  

In this position paper, ASD argue that the development of several 
legislative frameworks on a European level will be critical to 
address some of the main challenges faced by the aviation sector 
in relation to the green transition. They also state that 
accelerating the take-up of renewables over the next decade is 
key to enable the transition towards a carbon-neutral economy. 
The organisation furthermore state carbon removal’s role for the 
aviation sector, both nature- and technology based. That the 
integration of carbon removals into ICAO CORSIA and the EU 
ETS will be key to support the emergence and the development 
of this market for aviation. 

In the paper, MTK urges the European Commission to focus the 
2040 climate targets on reducing fossil emissions and that the 
role of carbon sinks must be balanced. The importance of active, 
sustainable forest management should be seen as a solution to 
climate change mitigation and adaptation through carbon 
Sequestration, Storage and Substitution. 

In the position paper, EUROFER argues that the 2040 climate 
targets need to be set on the basis of a thorough impact 
assessment that takes into account multiple aspects and 
perspectives. The organisation furthermore states that all sectors 
of the economy need to contribute fairly to the transition and that 
sectors under EU ETS 1 have reduced their emissions at a much 
higher pace than others. EURUFER furthermore state that while 
some sectors such as construction and renewable energy will 
benefit from the transition, the impact on the energy intensive 
industries exposed to global competition such as steel will 
depend on the ability to create the right enabling conditions for 
implementing investments in Europe and to avoid carbon as well 
as investment leakage. If the priority of the decade until 2030 is 
to implement the first breakthrough technologies at industrial 
scale, the ‘30s will be crucial for the further market uptake and 
deployment of such technologies. This will require even higher 
access to competitive low carbon energy in order to increase the 
market penetration of breakthrough technologies. 

In their position paper, FuelsEurope argue that it is especially 
important to develop an enabling policy framework for the 
deployment of CO2 neutral fuels and stable price signals and for 
the EC to ensure coherence of any new, or revised legislation. 
FuelsEurope also emphasise the need for EU-wide legislation for 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

targets, rather than leaving it at the member state level when it 
comes to energy efficiency. 

Business association  COGEN Europe 

Belgium 

Energy 

Climate, carbon 

Business association  European Alliance to Save 

Belgium 

Energy 

Climate, energy 

Energy (EU-ASE) 

Business association  Confederation of European 

Belgium 

Forest Owners 

Land-Use, Land-
Use Change and 
Forestry 

Climate, carbon 

Business association 

International Federation of 
Industrial Energy 
Consumers (IFIEC-
Europe) 

Belgium 

Energy 

Climate, industry, 
energy 

Company/business 

Deloitte 

United Kingdom 

Various sectors 

Aircraft, Travel, 
Hydrogen, 
Aviation, Zero 
Emission, Zero 
Carbon, Emissions 

In the position paper, COGEN Europe highlights five principles to 
be considered when setting new climate objectives for 2040. 1) 
Consider both net-zero and the carbon budget, 2) Assess cost-
efficient pathways to decarbonisation, 3) Take a whole-economy 
approach to decarbonisation, 4) Consider all cost-effective 
decarbonisation solutions and 5) Accelerate green finance. 

EU-ASE argue that in order to achieve climate neutrality by 2050, 
the European Union should adopt a comprehensive and 
ambitious set of climate and energy targets. The synergy 
between energy efficiency, renewable energy sources and GHG 
emissions targets are furthermore stated to be crucial to 
strengthen EU's climate resilience and accelerate the energy 
transition. 

In the position paper, CEPF highlights the importance of forest 
owners in Europe in relation to the 2040 climate targets. The 
organisation emphasises that forest-based climate actions are 
based on long-term processes, which means that forest owners 
should be encouraged to continue managing their forests with a 
long-term perspective, to keep their forest resilient and ensure 
multiple societal benefits now and in the future. 

In the position paper, IFIEC argues that a successful industrial 
transformation towards climate neutrality requires the following 
framework conditions: a realistic time plan, improved energy 
security conditions and a stable economic environment as well as 
support for companies to invest in long-term green projects. It is 
furthermore stated to be important for energy-intensive 
companies to have access to affordable and cost-competitive 
prices for low-carbon energy; carbon leakage protection 
instruments should be improved and prolonged to ensure the 
competitiveness of European companies in the global market. 

The report provides an analysis of the developments in aviation 
technology and the options for zero-carbon and zero-emissions 
aircraft in the intra-European passenger travel market in 2040. It 
explores the projected roadmap of aviation technology and its 
expected performance for short-haul flights. The roadmap 
projects that, until 2040, intra-European flights can achieve zero-
carbon aviation, while from 2040 an onwards technology will 
eventually permit zero emission flights. Level of emission 
reductions, however, will depend on flight distances. Once the 
main low/zero emission technologies become available by 2040, 

141 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Company/business 

Suomen Yrittäjät 
(Federation of Finnish 
Enterprises) 

Finland 

All sectors 

covered: 

Emissions, Climate 
neutrality, Industry, 
Energy transition, 
Carbon removal    

it is expected that the sustainable fuels will cover circa 89% of 
intra-EU flights and will lead to a 59% decrease in climate impact. 

In their position paper, the Federation of Finnish Enterprises 
welcomes the EU wide climate targets for 2040. They say that 
the EU should accelerate the transition to climate neutrality. That 
a higher emission reduction target for 2040 would send a strong 
signal to other countries and regions to raise their climate 
ambition and join the global effort to limit the global temperature 
increase. They more specifically think there should be between 
80%-90% emission reduction. The Federation moreover state 
that a higher climate ambition will improve the competitiveness of 
the European economy and give EU industry a first mover 
advantage on global markets, will improve energy security, 
reduce the EU’s dependency on imported fossil fuels and reduce 
exposure to volatility in fossil fuel prices and will create green and 
high added-value jobs, including those that are difficult to 
outsource. 

Company/business 

PepsiCo 

Belgium 

Various sectors 

Climate, 
agriculture, energy  

In the position paper, PepsiCo recommends the European 
Commission to focus investments and create conditions for 
regenerative agriculture, renewable energy and GHG accounting. 

Company/business 

Climeworks AG 

Switzerland 

Various sectors 

Carbon removal, 
emissions 
reductions  

Company/business 

Heidelberg Materials 

Germany 

Manufacturing 
industry 

Emissions, climate 

Company/business 

Carbonfuture 

Germany 

All sectors 

Emissions, climate 

Climeworks AG state that carbon removal actors are calling for a 
clear distinction between emissions reductions and carbon 
removals and that these distinctions should be incorporated in 
future climate targets. The company  emphasise that CDR will 
enable the world to maintain net zero emissions. 

In the position paper Heidelberg Materials discuss the importance 
of an EU target signalling a consistent trajectory based on current 
ambition levels and leading towards climate neutrality by 2050. 
They furthermore state that the target needs to consider fair 
effort-sharing between the different sectors of the EU economy. 
The company moreover state that a strong political will is needed 
to support the transformation of process industries like cement 
production, which are investing in decarbonisation but face 
practical challenges like permitting and access to funding. 

In the position paper, Carbonfuture expresses its support for a 
more than -90% emission reduction target by 2040. The company 
argues that the target will require high-quality carbon removal 
and the technologies biochar carbon removal (BCR) and 
enhanced weathering (EW) are described as especially 
promising.  

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

Company/business 

French National Railway 
Company (SNCF Group) 

France 

Transport 

Climate, carbon  

Company/business 

Neste 

Finland 

Transport 

Climate, fuel 

Company/business 

OMV Aktiengesellschaft 

Austria 

Manufacturing 
industry 

Climate, industry  

Company/business 

ENGIE  

France 

Energy 

Energy, climate 

SNCF urges the EU to develop a policy and financial framework 
favouring modal shift; fully implement the Fit for 55 package; to 
implement an ambition that comes with resources and take into 
account the avoided GHG emissions thanks to rail. SNCF state 
that through shifting to rail, a lot of the emissions could be reduce 
and that the EU should form policies in favour of such a shift. 
SNCF also argues that the transport sector should be prioritised, 
especially regarding rail. 

In the position paper, Neste urges the Commission to remain 
committed to stable technology and neutral regulatory 
frameworks to de-risk the massive long-term investments 
required from the industry. The company state that the EU 
furthermore should set the rules and the direction while letting the 
companies create the solutions. Neste state that a key challenge 
is the decarbonisation of the transport sector. While electrification 
will continue to reduce the number of new ICE vehicles on the 
road, the majority of both light-duty and heavy-duty vehicles will 
operate on liquid fuels well into the 2040s. Successful 
implementation of EU’s net-zero climate commitments will require 
their transposition into consistent policy signals the industry 
needs to ramp-up the production of renewable fuels throughout 
the 2030s, regardless of the parallel policies of electrification and 
improved energy efficiency. 

In the paper, OMV emphasises the importance of making policies 
such as EU ETS, CO2 reduction and renewable targets as well 
as energy efficiency suitable, economically feasible and at the 
lowest cost for society. OMV also stresses its concerns about the 
lack of a national regulatory framework aiming at supporting the 
provisions of the proposed Net Zero Industry Act, such as the 
obligation of oil and gas producing companies to store CO2 and 
the associated financial and temporal feasibility. 

In this position paper ENGIE emphasises the importance of 
electric renewable energies in the EU decarbonisation pathway; 
the reduction of energy consumption across all sectors; the 
uptake of other energy vectors such as renewable and recovery 
heat, and decarbonised gases. Furthermore, ENGIE calls on the 
Commission to continue the transition towards climate neutrality 
at the current pace, which should be understood as the 
RePowerEU pace which is more ambitious and faster than the 
pace achieved by implementing the Fit for 55 package alone. A 
corresponding 2040 target for EU emissions reductions should be 
set between -75% and -80% compared to 1990 levels, with the 
right enablers activated. 

143 

  
 
 
In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Company/business 

ALRO S.A. 

Romania 

Manufacturing 
industry 

covered: 

Climate, industry  

Company/business 

Holding Slovenske 
elektrarne d.o.o. 

Slovenia 

Energy 

Energy, climate 

Consumer 
organisation 

Environmental 
organisation  

Germany 

Energy 

Energy, climate, 
technology  

VIK Verband der 
Industriellen Energie- und 
Kraftwirtschaft e.V.; 
German Association of 
Industrial Energy 
Consumers. 

WWF 

Belgium 

Various sectors 

EU, Climate, 
Emissions, WWF, 
Global 

Environmental 
organisation 

Climate Litigation Network 
(Urgenda Foundation) 

Netherlands 

Various sectors 

Climate, mitigation  

Environmental 
organisation 

Ecologistas en Acción 

Spain 

Various sectors 

Climate, emissions 

Environmental 
organisation  

Climate Action Network 
(CAN) Europe 

Belgium 

All sectors 

Climate, emissions  

Environmental 
organisation 

Umweltdachverband 

Austria 

Various sectors 

Climate, target  

ALRO S.A. presents several recommendations for the 2040 
climate targets, including: setting up the appropriate enabling 
conditions for a thriving European industry; creating a business 
case for decarbonisation; ensure global competitiveness of 
European industry; globally competitive electricity prices; ensure 
adequate carbon leakage protection. 

In the paper, HSE emphasises the importance of  investments in 
RES (wind, hydro, solar, geothermal), hydrogen, flexibility, and 
storage solutions (including pumped hydro), while going through 
the process of coal phase-out and restructuring of coal regions 
when formulating the 2040 climate targets.  

In the paper, VIK Verband, the German Association of Industrial 
Energy Consumers, argues that further efforts need to be 
undertaken by European climate diplomacy on the global level 
and that there is an urgent need for a new system that will 
harmonise climate change mitigation.  

In this paper, WWF calls for net zero emissions in the EU by 
2040. The organisation furthermore argue that the new EU long-
term strategy should set out what needs to happen to meet such 
goal and recommend for the alignment of the EU’s long-term 
climate strategy with this target. 

In the paper, the CLN urges the EU to pursue a fair and equitable 
approach to climate mitigation action and promptly accelerate the 
transition towards climate neutrality in Europe.  

In the paper, Ecologistas en Acción underline that the EU must 
recognise that the only objective to consider in the definition of 
the measures is guaranteeing a reduction in emissions 
compatible with limiting the increase of the global temperature 
by1.5 C. 

In this report CAN Europe presents their position on EU climate 
targets and an equitable GHG emissions budget for the EU. CAN 
Europe state that the process around setting a 2040 EU climate 
target needs to spur increased action in the near term and 
alignment to achieve EU-wide net zero emissions by 2040 at the 
latest. 

In their position paper, Umweltdachverband welcomes the EU to 
set an interim target for greenhouse gas emissions in 2040 - as 
long as they are not misused to implement the 2030 targets in a 
less ambitious way. 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Environmental 
organisation  

European Environmental 
Bureau 

Belgium 

All sectors 

Climate, ESR 

covered: 

In the paper, EEB discuss several areas to consider when 
formulating the 2040 targets, including the future role of ES with 
the ETS, labelling, ETS and IED and the role of carbon pricing. It 
is also noted that the current approach to climate protection e.g. 
the EU emergency regulation to accelerate renewable energy 
and the attack on nature conservation law such as the Habitats 
Directive, could be a potential threat to biodiversity. They call for 
the climate crises to be solved together with biodiversity. 

Cititzens' Climate Europe 

Netherlands 

All sectors 

Climate, emissions  CCE advocate for three pillars which support each other: a 

Environmental 
organisation 

Environmental 
organisation 

Strategic Perspectives 

France 

Various sectors 

Climate change, 
Targets, Strategic  

steadily rising price on all greenhouse gas emissions; recycling of 
revenues to citizens; and a carbon border adjustment 
mechanism. The organisation furthermore emphasises that given 
the humanitarian and financial cost of climate change, the EU 
should aim for negative emissions by 2040. 

The document discusses the organisation Strategic Perspectives’ 
view on the 2040 targets. They discuss this within five sectors: 
buildings, transport, industry, energy supply and AFOLU. 
Strategic Perspectives considers the -90% scenario a feasible 
pathway that provides a strong effort of the European Union in 
the global effort to fight climate change. They however mention 
that this would require the EU to slightly increase the pace of 
decarbonisation after 2030 compared to the trajectory to reach 
the 2030 target. 

In the paper, AEW presents recommendations for a successful 
Fit for 55 package, including aspects of distributional justice, 
ambitious sectoral policies and carbon pricing. The Energy Union 
Governance Regulation must be adjusted to reflect the higher 
2030 targets and the new intermediate climate target for 2040. 

In the paper, IEEP discuss factors to be considered when setting 
an emissions reduction target in the EU. This paper lays out 
several opportunities for higher climate ambition. It suggests that 
the EU has a significant role in leading the world in making the 
most ambitious climate targets. It also states that through 
innovation & stimulus that the green transition should be seen as 
an opportunity. 

ICCT’s paper comprise an analysis of manufacturers’ market 
readiness to develop and deploy zero-emission commercial 
trucks and buses to meet the long-term target of a 100% phase-
out of internal combustion engine medium- and heavy-duty 
trucks. 

Non-governmental 
organisation (NGO) 

Agora Energie wende 

Germany 

Energy 

Non-governmental 
organisation (NGO) 

Institute for European 
Environmental Policy 
(IEEP) 

Belgium 

All sectors 

Target, industry, 
renewable, 
regulation, 
directive, transport 

Emissions, Target, 
Climate, EU, Policy 

Non-governmental 
organisation (NGO) 

International Council on 
Clean Transportation 
(ICCT) 

United States 

Transport 

Trucks, Bus, 
Europe, Market, 
Buses, Battery 

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In-depth Report on the Results of the Public Consultation on the EU Climate Target for 2040 

Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Non-governmental 
organisation (NGO) 

Climate Analytics 

Germany 

All sectors 

covered: 

Climate, 
Transformative 
change, Energy 

Non-governmental 
organisation (NGO) 

Climate Action Network 
Europe (CAN Europe) 

Belgium 

All sectors 

Climate, Action, 
Targets 

Non-governmental 
organisation (NGO) 

Bureau Européen des 
Unions de Consommateurs 
(BEUC)  

Belgium 

All sectors 

Consumer costs, 
Heat, 
Decarbonisation 

Non-governmental 
organisation (NGO) 

Österreichischer 
Forstverein 

Austria 

Land-Use, Land-
Use Change and 
Forestry 

Forestry, climate 
neutrality  

Non-governmental 
organisation (NGO) 

Non-governmental 
organisation (NGO) 

Non-governmental 
organisation (NGO) 

Tapp Coalition  

Netherlands 

Land-Use, Land-
Use Change and 
Forestry 

Climate goals, 
food, consumption.  

Carbon Market Watch 

Belgium 

All sectors 

Carbon, emissions 

Carbon Gap 

United Kingdom 

All sectors 

Climate, carbon  

The report develops and applies a new framework for assessing 
and classifying low-carbon energy and emissions pathways in the 
EU. They quantify and classify pathways based on the level of 
transformation observed in the four cross-cutting core challenges 
at the heart of the long-term transformation effort, the 4i’s. These 
are: fostering innovation, mobilising investment and finance, 
rolling out infrastructure, and enabling greater integration across 
sectors. 

In the paper, CAN Europe presents their input on climate action 
under the 'Fit For 55' Package. Among other points, the 
organisation recommends the EU to make use of every measure 
possible to further decrease emissions before 2030 in order to 
achieve at least -65% emissions cuts no later than 2040.  

The report analyses the consumer costs of low-carbon heating 
options in the year 2040 in four European countries. In the report, 
BEUC does not take a stance on the EU 2040 targets. However, 
in their model they assume that the electricity grid in each of the 
studied countries has been significantly decarbonised by 2040, in 
line with the EU goals, indicating a support for an ambitious 
target. 

The theme of the document is the contribution of forestry to 
climate neutrality in 2050. In relation to this, the document 
discusses biodiversity, climate policy, forest management, carbon 
management, greenwashing and more. ÖF points out that the 
climate crisis is leading to increased tree mortality and thinning 
worldwide forests, the age, tree species and reserve structures in 
Austrian forests indicate a decrease in storage capacity in the 
medium term and greenwashing, which the Austrian forest 
association wants to ban. 

The position paper by the TAPP coalition discusses the EU 2040 
climate goals, mainly in relation to the food sector. For example, 
they emphasise that the EU 2040 goals should target the way 
Europeans consume, especially how they eat. 

In the paper, CMW presents their response to the European 
Commission’s public consultation on the EU climate target for 
2040. CMW argue that the EU needs to raise its ambition now.  

Among other points, Carbon Gap recommends the Commission 
to aim to achieve 95% net GHG emission reductions by 2040 
compared to 1990 levels; separately quantify the role of gross 
emission reductions; divide emission reduction and removal 
targets into biogenic and geological components. 

Non-governmental 
organisation (NGO) 

Climate Bonds Initiative 

Belgium 

Finance 

Climate, transition, 
finance   

In this position paper, Climate Bonds encourages the 
Commission to set ambitious 2040 climate targets, to avoid 

146 

  
 
 
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Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

countries experiencing a rising cost of capital and stunted growth.  

Non-governmental 
organisation (NGO) 

Transport&Environment 

Belgium 

Transport 

Climate, transport  

Non-governmental 
organisation (NGO) 

The Nature Conservancy 

Germany 

Various sectors 

Climate, carbon  

Non-governmental 
organisation (NGO) 

ISO - International 
Organization for 
Standardization 

Switzerland 

All sectors 

Climate, standard 

Non-governmental 
organisation (NGO) 

Environmental Defense 
Fund Europe 

Netherlands 

Non-governmental 
organisation (NGO) 

Greenpeace EU Unit 

Belgium 

Various sectors 

Climate, energy  

Climate, 
technology 

In the paper, Transport&Environment state that an EU target for 
2040 is fundamental to accelerate and deepen the process 
started with the EGD and provide long term planning and 
investment certainty for people and business. Concerning the 
approach to take on target setting, T&E suggests future emission 
reduction targets in the EU should: 1. be set every 5-years 2. be 
kept separate from carbon removals targets 3. include non-CO2 
greenhouse gas emissions, in particular aviation contrails 4. 
include all emissions with the absolute minimum of exceptions 5. 
include system efficiency targets for transport 6. keep a global 
carbon budget as guiding action. T&E’s Road to Zero scenarios 
shows that the transport sector can cut its emissions by around 
70% by 2040 compared to the 1990 baseline. 

In its position paper, The Nature Conservancy urges the EU to 
aim for climate neutrality as soon as possible and by 2040 at the 
latest. The organisation argues that a high ambition for 2040 also 
would send the right signal to the industry and redirect private 
investment towards green sectors, giving the EU a strong 
competitive advantage for green growth.  

ISO agrees with the Commission that without a 2040 climate 
target, the EU remains at risk of missing its domestic climate 
objective for 2050 and possibly undermines its capacity to spur 
further climate action internationally.  

The document is an addition to the organisation's responses to 
the standard questionnaire. The paper discusses the areas of 
energy, agriculture, transport and sustainable finances regarding 
future climate targets.   

In their paper, GP EU Unit underline that The EU’s targets for 
2030 were inadequate to begin with, as we should have been 
aiming for -65% greenhouse gas emissions by 2030 and climate 
neutrality by 2040, to stand a chance to meet the promise made 
in Paris to limit global heating to 1.5 degrees. Greenpeace also 
emphasise that to reach the target we cannot rely on technology 
alone. The organisation furthermore state that nature-based 
solutions for carbon capture are better than industrial based and 
that it is essential to tackle greenwashing. 

Other 

Alliance of liberals and 
democrats for Europe 

Belgium 

All sectors 

Emissions, carbon, 
economy, climate, 
energy 

The documents comprise a resolution by Alde to expand EU ETS 
to reach net zero in 2050. The party call on others to use market 
forces and include more sectors in ETS. 

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Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Other 

European People's Party 

Belgium 

All sectors 

Other 

The Left 

Belgium 

All sectors 

Other 

S&D 

Belgium 

All sectors 

Other 

Renew Europe 

Belgium 

All sectors 

Other 

Other 

European United Left/ 
Nordic Green Left 

Belgium 

All sectors 

The Coalition for Energy 
Savings 

Belgium 

Energy 

covered: 

Climate, EU, 
Sustainable, 
Emissions, Energy, 
EPP 

Climate, Energy, 
Action, Policies, 
EU, Global, Justice 

European, 
Industrial, Climate, 
Sustainable, 
Economy, Digital, 
Social 

Energy, Nuclear, 
Electricity, Climate, 
Renewable, Costs 

Climate, Green, 
Energy, Deal, 
Transition, 
Emissions, Public, 
Tax, Social 

Energy, climate 

Resolution by the EPP acknowledging the 2030 target and the 
long-term carbon neutrality objective. Among other points, EPP 
acknowledges that the green transition will require a paradigm 
shift across the whole economy, which requires a dynamic state 
but not one seeking to regulate every part of the process. 
Another challenge highlighted is to not load the whole burden 
related to the transition on the younger generation. The extra 
costs should be shared, and we need to design policy tools to 
fund elements which have a long social payback.   

The paper consists of a Statement on EU climate policy, 
including a discussion of different options for action and a call for 
carbon neutrality by 2040. In relation to the green transition the 
GUE/NGL mentions that our only chance  lies in a sustainable, 
decentralised and accessible energy supply, which provides jobs 
and guarantees our energy sovereignty. 

In the paper S&D calls for an EU long-term industrial strategy that 
should be aligned with the EU climate targets for 2030, 2040 and 
2050. The party furthermore calls for the establishment of clear 
and ambitious targets for 2030 and 2040. 

The document consists of an analysis of the costs and spatial 
demand of renewable and nuclear energy to achieve climate 
neutrality in 2050 in the EU. Discussion of the effectiveness of 
EU climate neutrality. Renew Europe furthermore give 
recommendations for a “nuclear renaissance” in Europe.  

In the paper, the party presents a proposal for a green and social 
new deal for Europe. The paper particularly focuses on 2030 
targets, but also mentions long-term carbon neutrality target. 

The Coalition for Energy Savings want to include a pathway that 
maximises the role of energy savings by aligning with the latest 
data on the EU's cost-effective energy savings potential, i.e., the 
energy savings that the EU can achieve by implementing 
measures that are economically viable and by deploying existing 
energy efficiency technologies. Furthermore, the Coalition wants 
to lower the discount rate used to model future cost and return on 
investment of energy efficiency improvements. Moreover, they 
argue that that the EU should fully consider and prioritise energy 
savings and energy efficiency as resources for the energy system 
and enablers for an affordable energy transition as they i) ensure 
a smaller, and more flexible, energy system with fewer stranded 
assets and ii) reduce the cost of energy for each kWh for 
businesses and consumers by shaving peak demand. 

148 

  
 
 
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Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

Other 

Bavarian State Parliament 

Germany 

All sectors 

Climate, carbon  

The Bavarian State Parliament supports the setting of a target for 
the reduction of greenhouse gas emissions (GHG emissions) of 
the EU by 2040. The closer a European climate protection target 
2040 would be to the state of climate neutrality set for 2050, the 
more this would also contribute to the implementation of the 
Bavarian climate protection targets. 

Sweden 

All sectors 

Climate, emissions   SALAR state that the organisation endorses that the EU 

Other 

Swedish Association of 
Local Authorities and 
Regions, SALAR 

Commission develops a proposal for a 2040 climate target, 
assessing scenarios and investigating consequences in several 
areas of society. It is furthermore stated that clear objectives and 
supportive regulatory frameworks are fundamental to local and 
regional government's own politically decided objectives and 
measures. It is therefore important that the EU avoids detailed 
regulation and mainly adopts a technology-neutral approach. 
SALAR moreover state that in several EU Member States, the 
lack of lending opportunities and project support for energy 
efficiency, renewable energy production and other societal 
infrastructure are important limiting factors that EU institutions 
and programmes can help address. 

AFLRA emphasises that investments in green transition depend 
on coherent policies and a predictable regulatory environment, 
and the Association of Finnish Local and Regional Authorities 
supports setting a high ambition level in climate targets for 2040. 
AFLRA moreover, argue for legislation that leaves room for local 
decision-making regarding the practical implementation and 
measures, with location-sensitive target setting to ensure that 
municipalities with different demographics, location economic 
structure and human and financial resources have realistic 
targets. 

The report provides an analysis of Ireland’s emissions reduction 
ambitions and an evaluation of different scenarios for 2021-2040. 
The Environmental Protection Agency in Ireland projects that its 
national emissions will decrease from 62 357 kt to 49 198 kt from 
2021 to 2040 with existing measures. With additional measures, 
this figure is 61 906 to 35 643. With regards to EU targets, they 
say: Ireland can meet its non-ETS EU targets of a 30 per cent 
emission reduction by 2030 (compared to 2005) assuming the 
implementation of planned policies and measures and the use of 
the flexibilities available. These include land use flexibility using 
the Climate Action Plan 2021 afforestation rate of 8,000 hectares 
per annum. 

Other 

Association of Finnish 
Local and Regional 
Authorities 

Finland 

All sectors 

Climate, 
municipalities  

Public authority 

Environmental Protection 
Agency (Ireland) 

Ireland 

All sectors 

Emissions, 
Measures, 
Scenario, 
Projections, Gas, 
Energy 

Public authority 

Umweltbundesamt 
(German Environment 
Agency) 

Germany 

All sectors 

Climate, EU, 
Policy, National, 
Neutrality, 

The position paper emphasises the need to update EU ETS and 
establish a process for this in the EU's climate governance 
landscape, as the information is needed to guide policymakers 

149 

  
 
 
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Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 
Governance, 
Commission 

Energy, 
Development, Gas, 
Power, Market, 
System, Electicyt 

Transport, Public, 
Network, 
Development, 
Future, 
Government, 
Regional 

Measures, 
Climate, 
Emissions, Plan, 
Energy, 
Transportation 

and the review of the existing targets, including the setting of the 
2040 goals. The issue highlighted is the lack of proper 
governance at the EU level, such as an adequate measuring of 
progress towards climate neutrality. Monitoring progress towards 
climate neutrality will require new indicators that can track 
structural changes inside and across sectors. A new EU-level 
methodology must be developed, according to 
Umweltbundesamt. Moreover, they argue for more dialogue with 
member states and the benefits of increased inclusion of citizen 
engagement activities, such as Climate assemblies. 

The energy policy of Poland sets the framework for the energy 
transition in Poland until 2040, including the strategic decisions 
regarding the selection of technologies for a low-emission energy 
system. It contains three pillars: just transition, zero-emission, 
good air quality. The paper furthermore mentions that the current 
regulations do not cover the operation of offshore wind energy. 
For this reason, a new legal framework for offshore wind farms 
needs to be put in place. 

The report outlines a series of action points and intentions from 
the Dutch government to face an increasing challenge of usage 
growth in the country's public transport, in some places already 
nearing overload. With an expectancy of 30-40% organic growth 
between 2030 and 2040, while at the same time there is a strong 
push for CO2 reduction, the government devised a set of plans 
and commitments to ensure that, by 2040, transport in the 
country will be fast, safe, sustainable, reliable and affordable. In 
terms of specific commitments, the paper indicates that, by 2030, 
(1) the sector will be emission free, especially due to the rapid 
adoption of electric buses, (2) transport operators will have 
adopted the principle of circularity, having halved the used of 
primary resources by 2030, and becoming fully circular by 2050, 
and (3) will take into account climate change when developing 
and re-modelling infrastructure. 

The paper mentions that the EU targets for 2030 and 2040 are no 
longer sufficient. It is also mentioned that for the Alto Adige 
region which the document is about it will be difficult to achieve 
the goal by 2030, but the goal of net climate neutrality is 
expected to be achieved by 2040. The paper also mention that a 
faster implementation of the climate transition generates a long-
term advantage for the area. However, a challenge mentioned is 
the time aspect of certain climate policies. For example, 
measures aimed at changing behaviour. 

Public authority 

Polish Ministry of Climate 
and Environment 

Poland 

All sectors 

Public authority 

Dutch Ministry of 
Infrastructure and Water 
Management 

Netherlands 

Various sectors 

Public authority 

Autonomous province 
Bolzano 

Italy 

All sectors 

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Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

Public authority 

European Central Bank 

Germany 

Finance 

Public authority 

Bavarian State Ministry of 
the Environment and 
Consumer Protection 

Germany 

All sectors 

Public authority 

Zero Emissions Platform 

Belgium 

All sectors 

covered: 

Climate, 
Transition, Risk, 
Capital, Energy, 
Financial, 
Scenarios 

Energy, Smart 
combinations  

Carbon, CCS, 
CCU  

Public authority 

City of Amsterdam 

Netherlands 

All sectors 

Carbon, emissions 

Public authority 

Government of Flanders 

Belgium 

Various sectors 

Climate, emissions 

The report provides an assessment of climate physical and 
transition risks for the euro area for different transition scenarios. 
The paper states that an orderly transition achieves important co-
benefits already in the mid-term with respect to CO2 emissions’ 
abatement, banks’ financial stability and distributive effects. In 
contrast, a late and disorderly transition fosters banks’ financial 
instability. 

The paper states that the focus should be on development of new 
technologies and intelligent combinations of sustainable energy 
production technologies. Moreover, that the EU should focus on 
defending the existing structure of climate bonds.   

In the position paper, ZEP gives its response to the public 
consultation on the EU climate target for 2040. ZEP argue that a 
strong political and legislative direction is needed to support the 
development and scale up of technologies as CCS and CCU. 
ZEP argues that the target needs to be in line with the climate 
urgency and recognise that early and strong action is needed. 
However, they also state that the target for 2040 should be set at 
a level appropriate for industry, allowing it to invest and adjust, 
and it must be backed by clear conducive policies and funding 
programmes to enable industry to take action. All in all, ZEP 
mentions that they support a target of -80%. 

In the paper, the City of Amsterdam argues that the EU needs to 
continue to develop the policy framework to accelerate the 
energy transition and to strengthen the eco-design rules and 
CBAM.  They believe the most effective policy that the EU could 
implement to foster a greener and more sustainable economy is 
to establish total environmental cost targets per sector for 2040 
and support corresponding policies. This approach aligns with the 
EU's current initiatives, such as the Critical Raw Materials Act, 
the New European Bauhaus initiative, the Renovation Wave, the 
Do No Harm principle, the Fit for 55% package, and the Farm to 
Fork strategy. 

The Flemish Region supports the objective endorsed by the 
European Council of 12 December 2019 to achieve a climate-
neutral EU by 2050. The 2040 target is the next step to achieve 
this target and with it the EU’s contribution to achieving the goals 
of the Paris Agreement. The Flemish government supports the 
principle to leave no one behind. A socially just and inclusive 
transition is required to achieve climate neutrality. Member States 
are best placed to ensure a socially just transition through 
national measures. The fight against climate change can only be 
won if global action is successful and if other trading blocs take 
responsibility. 

151 

  
 
 
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Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

Public authority 

Polish Ministry of Climate 
and Environment 

Poland 

Various sectors 

Climate, emissions 

Public authority 

City of Gothenburg 

Sweden 

Removals, 
emissions 

Public authority 

Eesti Vabariigi 
Keskkonnaministeerium / 
Ministry of Environment of 
the Republic of Estonia 

Estonia 

All sectors 

Climate, transition  

Public authority 

Denmark 

All sectors 

Climate 

The Polish Ministry of Climate and Environment argues that 
starting a substantive discussion on the reduction target for 2040 
is premature at the moment, because there are no grounds to 
reliably determine its size in environmental, social and economic 
terms, and even more so to determine effective tools for its 
implementation. They argue that this requires an assessment ex 
post, the effectiveness of the currently implemented solutions for 
the implementation of the 2030 target. The final decision, due to 
its importance, should be taken at the level of the European 
Council.  

The city of Gothenburg argue that the Effort Sharing Regulation 
and associated national targets should maintain the same scope 
of greenhouse gases as today, and should cover both emissions 
not covered by the EU ETS (e.g. methane and nitrous oxide 
emissions from agriculture) and emissions from fuels used for 
road transport and buildings (covered by the new emissions 
trading system). They also believe that carbon removals should 
have a limited role in reaching climate neutrality by 2050.  

In the document, the Estonian Ministry of Environment presents 
the country's progress in climate-related issues during the past 
years. The ministry furthermore presents a set of 
recommendation for the EU when formulating the 2040 climate 
targets. In the context of the 2040 target, Estonia emphasises the 
importance of the European Commission conducting 
comprehensive impact analyses on the planned goals at the 
global, EU, regional and member state levels, that a just 
transition must be ensured, that from a global perspective and 
considering the interests of society and the economy, the impact 
analyses should focus on the necessity of the goals for the 
climate and the environment, highlighting the importance of 
utilizing the best available technology and energy carriers for the 
green transition and that biodiversity goals must not be 
undermined when planning measures to meet climate goals. 

The Danish Ministry of Climate, Energy and Utilities presents the 
main priorities of Denmark for the 2040 climate target. It notably 
advocates to support a target aligned with the long-term goal of 
1,5°C, with an intermediate target for 2035. The EU Climate 
architecture should be based on three pillars: an ETS system 
covering all emissions from energy consumption and emissions, 
an agricultural pillar, and a forestry pillar. It supports the 
implementation of an ambitious and coherent climate and energy 
framework that enables sectoral standards and strengthened 
carbon leakage protection.  

152 

  
 
 
 
 
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Stakeholder Group 

Organisation name 

Country of origin 

Economic sector  Main theme(-s) 

Brief summary 

covered: 

Public authority 

United Nations 

United States 

All sectors 

Climate, global 

Public authority 

The Swedish Ministry of 
Climate and Enterprise 

Sweden 

All sectors 

Climate, target 

Trade union 

IndustriAll European Trade 
Union 

Belgium 

Manufacturing 
industry 

Transition, climate 

Trade union 

Federation of Private 
Foresters of France 
(FRANSYLVA) 

France 

Land-Use, Land-
Use Change and 
Forestry 

Climate, forestry  

153 

The United Nations argue that the EU’s level of ambition on such 
intermediary targets on the road to 2050 would be decisive in 
setting a new global standard, thereby helping to leverage similar 
(and necessary) additional engagements from other Parties. The 
UN recommends the EU to integrate the following: a global goal 
on adaptation, focusing on the adaptation gaps highlighted in the 
Adaptation Gap Report and the GST, inter alia, including the 
financing gap. The global goal should be able to both enhance 
the adaptation ambition and the ability to monitor the progress in 
achieving it. Loss and damage funding arrangements and fund, 
including opportunities for capitalizing these arrangements and 
providing resources that will provide significant support to 
vulnerable developing countries in responding to loss and 
damage due to extreme and slow onset events. The GST 
outcomes, and ways in which progress can be scaled, gaps can 
be plugged, and opportunities are maximized. The UN argues 
that it is crucial that the EU, as the world's third-largest economy, 
keeps this position to reach net zero and to showcase that 
human wellbeing and economic development is possible while 
phasing out fossil fuels.  

Sweden welcomes setting an intermediary climate target for 2040 
based on the best available science that can provide 
predictability for political choices and investment decisions as 
well as strengthen the EU's competitiveness and productivity, 
paving the way for a climate-neutral EU by 2050 at the latest. The 
Swedish Ministry of Climate and Enterprise believe that each 
Member State has a responsibility to reach net-zero emissions 
and that the 2040 target should be based on increased 
convergence of Member States commitments to strengthen the 
EU’s path to climate neutrality. 

In the position paper, IndustriAll Europe calls for stronger and 
more comprehensive industrial policy tools to support Europe and 
its different regions in implementing the 2040 target while 
preserving the competitiveness of our industrial base and 
achieving the Green Deal Industrial Plan’s target to increase 
Europe’s independence in clean technology manufacturing. 

In the position paper, Fransylva discuss the importance of 
sustainable forestry in the pathway towards climate neutrality. 
Fransylva points out that forest-based climate actions are based 
on long-term processes, which means that forest owners should 
be encouraged to continue to manage their forests with a long-
term perspective, to preserve the resilience of their forests and to 
ensure multiple societal benefits now and in the future. 

  
 
 
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