Opinion of the European Committee of the Regions – Climate Action implementation in view of the EU contribution to UNFCCC COP30
Date: 2025-07-03
Institutions: Commission for the Environment, Climate Change and Energy, European Committee of the Regions
Subjects: Just transition, UN Conference, UN Framework Convention on Climate Change, action programme, adaptation to climate change, climate change, environmental cooperation, greenhouse gas, pollution control measures, reduction of gas emissions








C_202504416EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/4416


29.8.2025






Opinion of the European Committee of the Regions
Climate Action implementation in view of the EU contribution to UNFCCC COP30
(C/2025/4416)














Rapporteur



:


Nadia PELLEFIGUE (FR/PES), Vice-President of the Region of Occitanie





Reference document



:


Report from the Commission to the European Parliament and the – EU Climate Action Progress Report 2024
COM(2024) 498 final









POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS (CoR)

Closing the ambition and implementation gap through stronger subnational diplomacy and EU leadership at COP30









1.


is concerned that 2024 was the warmest year on record globally and the first calendar year in which the average global temperature was 1.5 °C above its pre-industrial level. In this context, commends the enormous efforts of the EU negotiating team in preserving the process and keeping multilateralism alive at COP29 and welcomes the agreement on the New Collective Quantified Goal on Climate Finance (NCQG). However, it regrets the lack of overall ambition and commitment in the process;












2.


underlines that, in the current geopolitical context, the climate transition must remain a priority to ensure long-term economic resilience and energy security with realistic pathways to reach climate goals. Stresses that stability and consistency in regulatory frameworks are essential for businesses to continue investing in clean technologies, and calls on national governments to provide the necessary conditions, including long-term regulatory certainty, public incentives for decarbonisation, and effective policy coordination. Highlights that cities and regions are not merely implementing policies but actively shaping markets for clean industrial solutions and therefore must be equipped with the financial tools to deliver this transition;












3.


recognises the urgent need to deliver ambitious Nationally Determined Contributions (NDCs) ahead of COP30, respecting the UNFCCC deadline and in keeping with the recommendations in the UNEP 2024 Emissions Gap Report. Stresses the need for increased climate finance, robust adaptation indicators, and enhanced just transition pathways that foster an economy which respects planetary and ecosystem boundaries, job creation and energy security and protection of civilians and biodiversity at COP30, while ensuring that cities and regions are structurally included in climate negotiations;












4.


recalls the COP28 UAE Consensus, which introduced ground-breaking commitments on the energy transition and explicitly recognised the critical role of multilevel, inclusive, gender-responsive and cooperative action in delivering the Paris Agreement. Urges all parties to adopt a multilevel planning and governance approach when drafting their NDCs, Long-Term Strategies and National Adaptation Plans (NAPs). Welcomes NDCs from the UK, Brazil, Panama and Canada, which emphasise the roles of local and regional authorities (LRAs) in advancing climate action and outline clear actions across multiple levels of government to support their implementation;












5.


regrets the United States’ intention to withdraw from the Paris Agreement but welcomes the efforts of US subnational authorities to uphold commitments to the UNFCCC, as demonstrated by those in networks such as Climate Mayors and the United States Climate Alliance;












6.


points out that cities committed to climate action could achieve up to 40 % of the global emissions reduction gap between NDCs and a 1.5 °C pathway by 2030 (1). Stresses the importance in this connection of shifting transport – particularly heavy transit traffic – from road to rail. Highlights that cities and regions shape industrial and business conditions through land-use planning, infrastructure development, job creation and opportunities for skills development, education, and training – fostering a mutually beneficial dynamic that advances economic, social and environmental goals;












7.


highlights numerous examples from LRAs participating in both regional and international networks such as the Local Governments and Municipal Authorities (LGMA) Constituency, the Advisory Committee of Subnational Governments and Biodiversity (AC SNG), the European and Global Covenant of Mayors, ICLEI, Under2 Coalition, Regions4, C40 Cities, and the Climate Alliance, which play a key role in designing, implementing, financing and monitoring solutions to the climate and nature crises;












8.


recognises the fragility, rich biodiversity and critical climate role of the Amazonian ecosystems and the importance of indigenous knowledge in the COP30 host region. In this context, notes with concern the reports regarding the clearing of a 13-kilometre stretch of rainforest for highway construction to facilitate summit access, which may risk undermining the event’s ambitious environmental goals. Notes that Europe’s outermost regions, such as French Guiana – which neighbours the COP30 host country Brazil – face similar climate and nature challenges and stresses that the EU’s NDC and climate response should specifically consider its outermost regions;












9.


calls on the Polish and Danish Presidencies of the Council to recognise in the Council Conclusions on COP30 the leadership of LRAs in accelerating and broadening climate mitigation and adaptation action. Emphasises that the EU’s NDC and 2040 climate target should consider local and regional socio-economic circumstances, uphold the principle of subsidiarity, and ensure support for all sectors of the economy to foster Europe’s transition, sustainability and competitiveness;












10.


highlights the contradiction between COP30’s climate commitments and the environmental impact caused by large-scale travel and infrastructure development to host the conferences. Emphasises the need to develop measures to make UNFCCC COPs more sustainable, including reducing air travel, production of sustainable aviation fuel (SAF), supporting multimodal transport, and encouraging the use of virtual or hybrid formats, in particular for side-events, as well as requiring host cities to adopt a sustainability charter with strict criteria, developed in consultation with local stakeholders;





Towards an ambitious and multilevel EU NDC









11.


reiterates its call for a realistic, inclusive and economically sound EU NDC, together with the legislative proposal to amend the EU Climate Law for a 90 % net greenhouse gas emission reduction target by 2040, that aligns with the Commission assessment and the CoR opinion on The future of EU climate policy: aligning mitigation targets and adaptation challenges. Calls on the EU to recognise, in its NDC, the leadership and responsibilities of local actors, including LRAs, in accelerating and broadening socially just climate action and emphasises the need for LRAs to play a more formal role in EU climate planning and governance structures, including in sectoral legislation that will follow the 2040 target;












12.


reiterates its call to the European Commission and the Member States to step up cooperation with LRAs and communities in preparing, implementing and financing its 2040 climate target and NDC, in line with Article 161 of the Global Stocktake outcomes and in order to prevent misalignment between local, regional, national and EU-level policies to ensure cohesive climate action. Urges them to leverage initiatives such as the EU Missions on climate neutral and smart cities and on adaptation to climate change, the Covenant of Mayors and CHAMP;












13.


urges the EU to strengthen its partnerships with international stakeholders through investments, technology access, and knowledge-sharing to lead in technological innovation and economic models for decarbonisation, particularly by facilitating technology and knowledge transfer to the Global South;





Stronger subnational climate diplomacy for effective multilateralism









14.


highlights that subnational diplomacy enhances climate ambition by fostering cooperation between cities and regions worldwide, enabling LRAs to share best practices, scale up climate solutions, and influence national and global climate strategies. Notes that the engagement of LRAs through the LGMA Constituency plays a key role in shaping the global climate agenda;












15.


emphasises key COP initiatives, including the COP27 Sustainable Urban Resilience for the Next Generation (SURGe) and COP28 Coalition for High Ambition on Multilevel Partnerships (CHAMP). Welcomes the establishment of the Baku Continuity Coalition at COP29 as a crucial step toward ensuring consistency and continuity across COP presidencies;












16.


calls on the European Commission and Member States to support the subnational diplomacy and remains committed to contributing to the EU’s leadership in international climate negotiations through enhanced subnational climate diplomacy and to engaging all CoR external relations bodies (ARLEM, CORLEAP, Joint Consultative Committees, peer-to-peer cooperation) with a view to ensuring that commitments made at global level are translated into tangible action on the ground; underlines the importance of further recognising the contributions of subnational governments, encouraging more multilevel partnerships as a means to support implementation, and structurally involve subnational governments to strengthen partnerships within the COP process; in this regard welcomes the announcement of the organisation of a COP30 Local Leaders Forum to highlight local climate solutions, demonstrate how subnational actors accelerate progress on global climate goals and reinforce multilateralism through subnational diplomacy; expresses therefore its commitment to contribute to this initiative;












17.


underlines the importance of regional COPs, such as those organised by French regions, Townhall COP debates led by the LGMA and Local and Regional Conferences of Youth (LCOYs and RCOYs) and other local initiatives such as the Macaronesia Climate Change Observatory. Emphasises that the outcomes of such local dialogues should be integrated into NDCs and National Energy and Climate Plans (NECPs) to bridge the gap between local efforts and national and international climate frameworks. Special efforts should be made to include rural local authorities, peripheral and mountain regions in these dialogues to ensure that the perspectives and needs of remote communities are not overlooked in the multilevel governance process;





Delivering on the mitigation work programme









18.


regrets the lack of progress in the Mitigation Work Programme (MWP) at COP29, as well as the absence of commitments from parties to uphold their pledges made at COP28 to transition away from fossil fuels, double energy efficiency, and triple renewable energy capacity;












19.


welcomes the work of the co-chairs of the MWP throughout 2024 in advancing discussions on ‘Cities: Buildings and Urban Systems’. Looks forward to discussions in 2025-2026 on mitigation solutions in the industry, in the agriculture, forestry and other land use sector, and in the waste sectors. Highlights the key role that LRAs, including those from rural areas, play in waste management, fostering circular economy practices suitable to non-urban contexts, such as decentralised renewable energy and sustainable agriculture, permitting and fostering industrial-urban symbiosis, and calls for LRAs to be actively involved in this process;












20.


points out that cities are responsible for over 70 % of global greenhouse gas emissions and consume about 80 % of the world’s energy and that LRAs are the level closest to citizens, showcasing the visibility and credibility of climate action. Acknowledges the significant efforts of the EU’s LRAs in implementing the Paris Agreement, as demonstrated through initiatives such as the EU Missions, the Covenant of Mayors, the Climate Pact, the Circular Cities and Regions Initiative, and their active participation in initiatives like the Zero Pollution Stakeholder Platform;












21.


welcomes the ongoing efforts of the Intergovernmental Panel on Climate Change (IPCC) in preparing its Special Report on Climate Change and Cities, which will provide a scientifically robust and policy-relevant assessment of climate risks and solutions in urban areas. Furthermore, it welcomes the fact that the European Climate Risk Assessment included a specific study on climate risks in the outermost regions, which can help to better integrate their specific situations into European climate policies. Underlines in this context the importance of data produced by the European Earth Observation Programme Copernicus, in particular providing information to support public policies at the regional level, and the relevance of the Digital Twin of the Ocean developed by Mercator Ocean International, as a key tool to better understand, anticipate and address climate-related risks, particularly for coastal and island territories. Recognises the IPCC’s role in countering climate misinformation by offering evidence-based insights into the effectiveness of local climate policies, adaptation measures, and emissions reduction strategies. Calls on the EU to leverage this report to strengthen public understanding, support informed decision-making at the subnational level, and reinforce multilevel climate governance frameworks prioritising transparent, science-driven climate action;












22.


calls on the parties to ensure that the Global Stocktake Outcomes on the transition away from fossil fuels, doubling energy efficiency, and tripling renewable energy capacity – while ensuring a just transition for energy-intensive industries in fossil-fuel dependent regions and for people in vulnerable situations – are reflected in the Mitigation Work Programme outcomes for 2025-2026;





Scaling up finance for local climate action









23.


points out that, for climate mitigation alone, cities globally will need an estimated USD 4.3 trillion annually until 2030, and over USD 6 trillion per year from 2031 to 2050. While adaptation needs are harder to monetise at the global scale, it is estimated that cities in emerging and developing countries will require USD 147 billion per year until 2030, and USD 165 billion annually from 2031 to 2050;












24.


highlights that financing for subnational action remains limited (2), difficult to access and scattered, with less than 10 % of climate finance from global climate funds spent on local action and only 17 % of adaptation finance between 2017 and 2021 aimed at building local resilience;












25.


particular attention should be paid to rural and remote regions, where limited administrative capacity and sparse population density further hinder access to climate finance, requiring tailored support instruments and capacity-building mechanisms for local authorities. This is particularly relevant for structurally less developed regions in Central, Eastern and Southern Europe, including border and mountain areas, where economic disparities and limited absorption capacity hinder climate action. EU cohesion instruments should be aligned to support tailored access to climate finance in these areas;












26.


welcomes the COP29 decision on the NCQG and calls on parties to ensure the success of the ‘Baku-Belém Roadmap to 1.3T’. Stresses the need for this process to be transparent, inclusive, and consultative, ensuring that a significant portion of the USD 1.3 trillion per year by 2035 is allocated to direct access for cities and regions to locally responsive mitigation and adaptation measures;












27.


highlights the need to integrate LRAs into discussions on the reform of international financial architecture and Multilateral Development Banks (MDBs) reforms, ensuring they are not just implementers but active participants in the design process, with a view to addressing key barriers and enabling targeted solutions for mitigation and adaptation action;












28.


points out that most climate finance reaches LRAs through national governments, which often prioritise national-scale projects over local or regional ones. Calls on the parties to ensure that the MDB reforms include scaling up sovereign lending models that allow LRAs to access loans without requiring national government guarantees;












29.


underlines that many LRAs still struggle to secure private investment due to perceived risks. Calls on all parties to create guarantee mechanisms or credit enhancement tools that provide support for more bankable subnational projects through international financial structure reform;





Strengthening adaptation efforts and the nature-climate nexus approach









30.


highlights the important role of LRAs in protecting citizens and steering and supporting adaptation and reconstruction efforts, including by developing and rolling out regional early warning systems, in the face of frequent and severe climate-related disasters impacting regions and cities across the world, and causing enormous human, nature and economic losses. Emphasises that local knowledge and community engagement should be integral to NAPs as these are essential for identifying context-specific vulnerabilities and developing effective adaptation strategies. Stresses that certain territories face specific climate-related vulnerabilities and should benefit from targeted adaptation strategies integrated into the NAPs, enhanced financial support and faster implementation of pilot projects, with these regions thus acting as living laboratories and spaces for climate innovation. These include: outermost regions and island regions with high population density, which experience significant migration flows and increasing effects of climate change, such as rising sea level; mountain regions, exposed to erosion and with particular needs on sustainable water, forestry, and eco-tourism; and rural and remote areas;












31.


reminds of the decision for developed countries to at least double their collective climate finance for adaptation in developing countries from 2019 levels by 2025, ensuring a balance between adaptation and mitigation. Regrets that, despite improvements, subnational governments still lack direct access to international climate finance, and a significant adaptation finance gap remains, especially for developing countries, as highlighted in the UNEP Adaptation Gap report. Calls for urgent action to double adaptation finance to close this gap;












32.


welcomes the EU Mission on Adaptation’s work in supporting over 150 regions in Europe to become resilient by 2030 and considers that further efforts are needed to replicate this model globally;












33.


underlines that the Kunming-Montreal Global Biodiversity Framework provides an opportunity to integrate nature-based solutions as a central pillar of adaptation strategies at the subnational level. Stresses the importance of aligning climate adaptation with nature restoration and preservation, particularly in the context of COP30. This alignment should include mountain ecosystems, where nature-based solutions are particularly important for increasing climate resilience and preserving biodiversity. Calls on Brazil – home to some of the world’s most critical natural ecosystems – to ensure that the nature-climate nexus is more comprehensively addressed within the existing negotiation strand;












34.


calls for the UAE-Belém work programme to include measurable indicators that reflect local and regional adaptation efforts, such as multilevel collaboration mechanisms, financial support allocated at the subnational level, and the implementation of regional adaptation plans. Reiterates its call for these measures to shape the upcoming European Climate Adaptation Plan;












35.


reiterates the need for increased synergies between the Rio Conventions and calls on the EU to ensure that the outcomes of other UN tracks, such as the Convention on Biological Diversity (CBD) COP16, the Convention to Combat Desertification (UNCCD) COP16, and the 2025 UN Ocean Conference, further integrate climate and biodiversity agendas;












36.


welcomes the focus on water-related challenges in the COP29 Declaration on Water for Climate Action. Calls for enhanced international cooperation, including at river basin level, to address the growing water crisis, ensure clean and high-quality water, promote sustainable water management, and implement nature-based solutions. Recognises, moreover, the new EU Water Resilience Strategy as a crucial initiative to integrate water resilience into adaptation planning at all governance levels, ensuring sustainable water management, disaster preparedness, and cross-border cooperation on water resources. Likewise, stresses the specific value for outermost regions included in this strategy, which takes into account the structural vulnerabilities and constraints of these regions when it comes to accessing water resources;





Advancing the Just Transition Work Programme









37.


recognises that the Just Transition Work Programme (JTWP) is essential for ensuring a fair and equitable transition to a climate-neutral and resilient economy. Regrets that no decision on the JTWP was taken at COP29, which is crucial for workers and communities on the frontlines of the impact of climate change;












38.


stresses the need for the JTWP to establish clear funding pathways, linking it with the outcomes of the Global Stocktake, integrating just transition policies into NDCs and sectoral policies to ensure a consistent and inclusive global approach, one that prioritises direct financial access for LRAs to implement transition strategies effectively. Highlights the need for whole-of-governance approaches that actively involve LRAs, trade unions, industry representatives, and civil society in shaping and implementing Just Transition strategies;












39.


underlines that the just transition is a key pillar of the EU’s competitiveness agenda, ensuring economic resilience while driving sustainable job creation, industrial innovation and regional economic transformation. Calls on the European Commission and Member States to show leadership in discussions on a formal decision on the JTWP at SB62 or, at the latest, COP30, ensuring clear governance structures and financing mechanisms.






Brussels, 3 July 2025.


The President


of the European Committee of the Regions

Kata TÜTTŐ
               





(1)  Global Covenant of Mayors, https://www.globalcovenantofmayors.org/press/city-climate-ambition-could-reduce-the-gap-between-national-commitments-and-a-1-5oc-pathway-globally-by-up-to-40-new-gcom-research-suggests/.

(2)  
            https://www.iied.org/10178iied.

https://www.citiesalliance.org/sites/default/files/2024-11/citiesalliance_climate_finance_for_the_urban_poor_2024_web.pdf.

https://www.unep.org/resources/adaptation-gap-report-2023.


ELI: http://data.europa.eu/eli/C/2025/4416/oj
ISSN 1977-091X (electronic edition)