Proposal establishing provisions for the use of international credits towards the European Union’s GHG emissions target for 2040 under Regulation (EU) 2021/1119, the European Climate Law
Date: 2026-07-03
Institutions: Directorate-General for Climate Action, European Commission
Subjects: climate change policy

Factual Summary Report on the Open Public Consultation on the use of 
international credits to support the EU’s 2040 climate targets  

Disclaimer:  This  document  should  be  regarded  solely  as  a  summary  of  the  contributions  made  by 
stakeholders on the open public consultation on the limited use of high-quality international credits to support 
the achievement of the EU’s 2040 climate target. 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 population1. 

1.  Objectives and Methodology  

The aim of this work is to clarify how the limited use of high-quality international carbon credits, as set out in 
the revised European Climate Law (ECL), may best support flexibility and efficiency in how the EU’s 2040 
climate target is achieved. As part of this initiative, the EU carried out an open public consultation (OPC). The 
public consultation ran from 9 February 2026 until 4 May 2026. The objective of the open public consultation 
was to gather views from a wide range of citizens and stakeholders. 

2.  Overview of Responses  
Consultation  Participation  and  Key  Findings:  After  excluding  two  invalid  submissions,  a  total  of  217 
responses were analysed from the Open Public Questionnaire on international credits. Contributions came 
from business associations (57), companies/businesses (75), non-governmental organisations (NGOs) (48), 
EU  citizens  (8),  public  authorities  (11),  “Other”  (7),  environmental  organisations  (4),  academic/research 
institutes  (4),  non-EU  citizens  (2),  and  a  trade  union  (1). A  manual  reallocation  of  stakeholder  type  was 
performed for 15 out of 217 responses. Following this review, recoded stakeholder groups composed of 77 
responses  from  companies/businesses,  63  from  business  associations,  49  from  NGOs,  10  from  public 
authorities, 8 from EU citizens, 5 from “Other”, 3 from academic/research institutions, and 2 from non-EU 
citizens2. 

Geographic Distribution: Most respondents (177) were based in the European Union (EU), while 40 were 
from non-EU countries. The highest number of responses in the EU originated from Germany (19.8%) and 
Belgium (19.4%), and from outside the EU, the United States (6.9%) and the United Kingdom (6.5%).  

Organisation Size: Of respondents who were representing an organisation, institution, authority or other, 
there were a wide range of organisation sizes. This included 71 large organisations, 60 small organisations, 
42 medium-sized organisations, and 32 micro-enterprises. The 10 citizens were not shown this question. 

Economic Sectors Represented: Among respondents representing a business association or company, or 
trade union, 116 of 140 specified their economic sector, of whom 49 selected “other.” The largest identified 
shares  were  from  electricity,  gas  and  water  supply  (31)  and  manufacturing  (17),  followed  by  agriculture, 
hunting and forestry (7), transport, storage and communications (5), and financial intermediation (3), mining 
and quarrying (2), construction (1) and wholesale and retail trade (1).  

Stakeholder Involvement in International Carbon Credits: 83 out of 217 selected “none of the above,” 
indicating  no  direct  involvement,  however  48  respondents  stated  they  were  providing  expert  advice,  28 
producing, selling, or planning to sell credits, 22 trading or purchasing credits or offering related services, and 
19 buying, using, or planning to use credits. 17 respondents did not respond. 

1 This report was prepared by a contractor (Ricardo in association with Öko-Institut). 
2 NGO includes the responses from environmental organisations (4). 

1 

 
 
 
 
 
 
Contributions  were  collected  through  the  Commission’s  public  consultation  online  survey-management 
system using a structured questionnaire, which gathered both quantitative responses and qualitative input 
from stakeholders. 

2.1.  Data processing and security  

219  responses  were  received.  Two  responses  were  discarded,  leading  to  a  total  number  of  analysed 
responses of 217. One contribution was duplicated, and another was incorrectly attributed to a Member State 
national authority and did not contain any responses to the questions. The “type of organisation” has been 
reallocated  for  15  responses  to  correct  inaccuracies  in  respondents'  self-identification.  Finally,  two 
organisations were reclassified under the category “Providing expert advice on international carbon credits”. 

3.  Results from Public Consultation 

The OPC questionnaire included two sections, a general section (7 questions) and an expert section (17 
questions). 

3.1. General Section 

General considerations on the use of international carbon credits  

Overall, respondents showed support for the use of international carbon credits (69% - 140 out of 203) 
to contribute to achieve the EU’s 2040 climate target as set out in the European Climate Law (the majority 
favoured to cover 5% of 1990 emissions), while 29% (59 out of 203) of respondents prefer exclusive reliance 
on domestic action. Support for the use of credits was favoured by companies/businesses (93% - 68 out of 
73) and business associations (92% - 54 out of 59), whereas most NGOs (81% - 39 out of 48) and both EU 
(5 out of 7) and non-EU citizens (2 out of 2) opposed the use of credits.   

There is broad agreement on the need for a flexible approach (56% - 111 out of 200 ) allowing the EU and 
Member States to use credits to meet part of their targets. The flexible approach was the most popular choice 
amongst business associations (66% - 38 out of 58), company/businesses (78% - 58 out of 74) and public 
authorities (6 out of 10). Notably both (2 out of 2) academic/research institution that answered and only  non-
EU citizen stakeholders who responded opted for credits being a separate pillar of the EU climate architecture 
and to not be used as part of other targets and policies. NGOs largely selected ‘other’ (76% - 35 out of 46) 
and gave further detail in open text responses, with most arguing that credits should not be used to meet the 
2040 target – or only as a “last resort” or “safety net”.  

Respondents  were  asked  who  should  finance  international  credits  and  were  able  to  choose  multiple 
options including ‘The EU from the EU budget’, ‘EU Member states from Member State budgets’, ‘Companies’ 
and  ‘Revenues  generated  through  the  EU  ETS’. Views  were  mixed  across  these  multiple-choice  options. 
Financing  through  Member  State  budgets  was  the  most  popular  choice  (69%  -  127  out  of  185).  This 
preference was particularly strong among NGOs (90% - 36 out of 40) and non-EU citizens (2 out of 2) and 
was also supported by companies/businesses (73% - 51 out of 70) and business associations (57% - 31 out 
of 54). Financing from companies (64% - 119 out of 185) was the majority view of public authorities (7 out of 
10), EU citizens (5 out of 6) and business associations (74% - 40 out of 54). The least chosen option was 
‘Revenues generated through the EU ETS’ (24% - 45 out of 185). 

Of the multiple options given, the most chosen benefit from the purchase and use of international carbon 
credits across all stakeholders was that international credits can ‘incentivise the development and scaling 
up of new and innovative low-carbon technologies, and their implementation in non-EU countries’ (63% - 127 
out of 201) closely followed by the idea that international credits can ‘support investments and the economic 
development of other countries’ (62% - 125 out of 201). The least chosen option was ‘I do not see any benefits 
from the purchase and use of international carbon credits’ (19% - 38 out of 201). 

2 

 
 
Respondents were asked what negative aspects they could see in the purchase and use of internation carbon 
credits. Of the of multiple options given, respondents raised concerns regarding environmental integrity 
(including risks related to additionality, permanence, and impacts on ecosystems and biodiversity) (58% - 117 
out of 201) and administrative burden and implementation costs (50% - 100 out of 201).   

Respondents  were  asked  about  their  confidence  that  international  credits  can  deliver  claimed  emission 
reduction  on  a  scale  from  1  (not  confident  at  all)  to  5  (very  confident).  On  average,  respondents  were 
confident about the delivered emission reductions (Avg.: 3.18; 56% rating 4-5). Business associations (Avg.: 
3.75; 69% rating 4-5) and companies/businesses (Avg.: 3.99; 81% rating 4-5) expressed confidence about 
the integrity of international credits, whereas EU citizens (Avg.: 1.86; 14% rating 4-5) and NGOs (Avg.: 1.67; 
15% rating 4-5) were less confident about their use. Only 6 out of 198 respondents selected “I don’t know”. 

Finally,  in  relation  to  where  funding  for  climate  action  would  be  best  spent,  the  most  common  answer 
chosen (57% - 104 out of 163) was that the EU should finance investments for climate action in the EU rather 
than outside the EU.  

3.2. Expert Section 

EU regulatory framework  

Respondents expressed mixed views regarding the sectors in which international carbon credits should 
be used. The preference was to use international credits in sectors where transitioning to net zero is most 
expensive (56% - 96 out of 172 responses), followed by support for their use in sectors already covered by 
the EU Emissions Trading System (ETS 1) (38% - 66 out of 172). The least chosen option was ‘Efforts should 
be  equally  reduced  across  all  sectors’  (8%  -  14  out  of  172).  Opinions  were  evenly  distributed  across  the 
stakeholder groups. 

When considering the potential use of international carbon credits under the EU ETS and the type of 
credits that should be purchased, the preferred option was to restrict purchases to credits that only guarantee 
permanent emission reductions or removals (42% - 74 out of 175) compared to any kinds of credits (33% - 
57 out of 175) or none at all (25% - 44 out of 175). Restricting purchases to high quality credits was particularly 
prominent among business associations (56% - 30 out of 54) and public authorities (4 out of 9). Allowing any 
kind of international credits, was the most popular choice by companies/businesses (50% - 32 out of 64). A 
notable share of respondents (25% - 44 out of 175) chose option ‘none at all’ opposing the use of international 
credits altogether, a position strongly backed by NGOs (76% - 28 out of 37). 19% (42 out of 217) did not 
provide an answer. 

A similar pattern emerged with regards to the use of international carbon credits in the EU land use, land-
use change and forestry (LULUCF) sector. The most widely supported option was again to limit purchases 
to credits that provide permanent emission reductions or removals (39% - 62 out of 158), popular amongst 
NGOs (63% - 20 out of 32) and business associations (38% - 18 out of 47). After those that did not provide 
a response (27%- 59 out of 217), the next most popular choice was to allow any type of international credits 
(30% - 47 out of 158), which was the most frequently selected option by companies and businesses (32% - 
19 out of 59). 

Implementation  

Whilst varied, the most common selected answer regarding the criteria the EU should use when selecting 
countries for purchasing international carbon credits was for countries demonstrating a sufficient level 
of domestic climate ambition (62% - 110 out of 177 responses). This was followed by “other” criteria (54% - 
95  out  of  177);  in  open  text  responses,  stakeholders  emphasised  prioritising  countries  with  strong  MRV 
systems, alignment with the Paris 1.5°C target, and adherence to Article 6 rules.  

Similarly, responses were mixed with regards to which non-climate aspects the EU should consider when 
selecting  sectors  or  mitigation  activities  as  a  source  of  international  carbon  credits.  Most  frequently  cited 
priorities  were  co-benefits  linked  to  social  and  economic  development  (62%  -  107  out  of  173),  climate 

3 

 
 
adaptation  and  resilience  (60%  -  104  out  of  173),  and  the  protection  and  restoration  of  biodiversity  and 
ecosystems (57% - 98 out of 173). The least chosen options were ‘support for the development of EU-based 
entities involved in carbon credit activities’ (28%- 49 out of 173), followed by ‘support for the development of 
new innovative technologies’ (34%- 59 out of 173).  

Open-text  responses  indicated  a  strong  convergence  across  stakeholders  on  the  need  for  stricter,  more 
independent,  and more  transparent  systems  to  validate  and  verify  activities. Many  respondents  called  for 
strengthened oversight, the introduction of independent or randomised auditor selection, and greater levels 
of public disclosure. 

Participants  were  asked  ‘what  transparency  provisions  should  the  EU  implement  as  part  of  bilateral 
purchasing agreements to guarantee an adequate level of access to information for the public’. Open text 
responses  show  very  strong  alignment  across  stakeholders  on  the  need  for  high  levels  of  openness  and 
traceability. Most respondents emphasised that transparency is essential to ensure credibility, prevent double 
counting,  and  build  public  trust,  though  some  highlighted  the  need  to  balance  this  with  protection  of 
commercially sensitive information. Out of the 134 open text responses, 37% (49 out of the 134) were from 
companies/businesses, 27% (36 out of the 134) were from business associations, 26% (35 out of the 134) 
from NGOs, 4% (5 out of the 134) from public authorities, 3% (4 out of the 134) EU citizens, 2% (3 out of the 
134) other stakeholders, and 1% (2 out of the 134) from academic/research institutions. 

Respondents were split on how bilateral agreements should support adaptation and resilience beyond 
the existing levy of a share of proceeds under Article 6.2. Overall, the most common view was that no further 
adaptation benefits beyond the levy are needed (40% - 58 out of 146) - the most popular view from business 
associations (54% - 21 out of 39) and companies/businesses (55% - 30 out of 55). The second most frequent 
response was “other” (33% - 48 out of 146) where, in open text, a clear recurring position was that the EU 
should require at least 5% of Internationally Transferred Mitigation Outcomes (ITMOs) to be allocated to the 
UN  Adaptation  Fund,  aligning  with  Article  6.4.  Beyond  this,  stakeholders  were  split:  some  supported 
encouraging or prioritising projects with adaptation co-benefits or nature-based solutions, while others argued 
adaptation should remain separate, flexible, or not impose additional burdens on carbon markets. 

Regarding how mitigation outcomes generated should be shared with partnering countries, the most 
common preference was for a case-by-case approach (45% - 68 out of 151). This was the leading option 
across  academic  and  research  institutions  (2  out  of  3),  business  associations  (59%  -  24  out  of  41), 
companies/businesses  (53%  -  29  out  of  55),  and  public  authorities  (3  out  of  7).  A  fair  proportion  of 
stakeholders  (25%  -  54  out  of  217)  did  not  provide  a  response.  NGOs  showed  strongest  preference  for 
leaving more than 50% of mitigation outcomes to the benefit of the partnering country (65% - 24 out of 37). 

Quality of credits   

Overall, the majority of respondents supported a broad approach to the types of actions from which the 
EU should purchase credits, encompassing both emission reductions and removals (71% - 106 out of 
150). This option was the top choice across nearly all stakeholder groups. The next most chosen option was 
‘removals’ (25% - 37 out of 150). 31% did not provide a response (67 out of 217). 

Respondents  expressed  mixed  views  on  the  multiple-choice  question  related  to  the  quality  aspects  or 
criteria  the  EU  should  prioritise  when  purchasing  international  carbon  credits. The  most  frequently 
selected options were the robustness and transparency of the crediting programme governance, including 
third-party validation and verification (81% - 149 out of 185), and the robustness and conservativeness of 
monitoring and calculation of mitigation outcomes (76% - 141 out of 185). The least selected criterion was 
the avoidance of locking in high-emission technologies or practices in the host country (49% - 90 out of 185). 
Preferences were evenly distributed across stakeholder groups. 

Similarly,  responses  to  multiple  choice  question  regarding  which  mitigation  activities  the  EU  should 
prioritise when purchasing credits were mixed and stakeholder split were evenly distributed. The most 
popular  option  was  removals  (Direct Air  Carbon  Capture  and  Storage  (DACCS),  Bioenergy  with  Carbon 
Capture  and  Storage  (BECCS),  biochar,  and  marine  carbon  dioxide  removal)  (58%  -  98  out  of  170). The 

4 

 
 
“other” category also received considerable support (29% - 49 out of 170) where stakeholders, in open text 
responses, reveal a clear split between technology-neutral approaches and strict prioritisation of removals. 
In  contrast,  the  least selected  option  was  ‘other technologies  (e.g.,  efficient  cooking  stoves, reductions  of 
non-CO2 climate impacts of aviation and maritime activities)’ (21% - 36 out of 170). 

Open text responses showed mixed views on specific concerns or suggestions regarding the activity type 
that  the  EU  should  prioritise.  While  some  argue  no  clear  preference  can  be  established,  others  highlight 
particular risks linked to certain technologies or sectors. Respondents emphasised careful selection, strong 
safeguards, and context

dependent judgement rather than prescriptive rules.  

-

frequently  chosen  option  amongst  business  associations 

When looking at how the EU should approach Article 6.4 rules when setting its own quality criteria, the 
most common view was that the EU should follow existing Article 6.4 standards (59% - 93 out of 158). This 
was  most 
(86%  -  38  out  of  44), 
companies/businesses (72% - 43 out of 60) and public authorities (6 out of 7). By contrast, academic/research 
institutions (2 out of 3), EU citizens (3 out of 5), NGOs (91% - 32 out of 35) and other stakeholders (4 out of 
4) favoured overall second most chosen option for the EU to set higher standards than those in Article 6.4 
(41% - 65 out of 158). 27% (59 out of 217) of responses either did not provide a response or chose option ‘I 
don’t know’. 

Regarding  whether  the  EU  should  approve  methodologies,  projects,  or  both  under  its  cooperative 
approaches, the most  common  choice  was to  approve  both  projects  and methodologies  (52%  -  82  out  of 
158). From those that answered, this was favoured by NGOs (86% - 30 out of 35), public authorities (7 out 
of 7) and EU citizens (3 out of 4). In contrast, stakeholder group ‘other’ (2 out of 3), companies/businesses 
(41% - 26 out of 63) and business associations (44% - 19 out of 43) favoured approving only methodologies. 
It should be noted that 27% (59 out of 217) of respondents did not answer this question.  

The  most  common  view  regarding  whether  the  EU  should  follow  common  practice  to  implement 
validation  and  verification  rules  as  part  of  its  cooperative  approaches  under  Article  6.4,  was  that 
existing validation and verification practices are sufficient (43% - 66 out of 155). This was particularly popular 
among companies/businesses (58% - 35 of 60) and business associations (51% - 23 out of 45). However, a 
notable share of respondents supported keeping common practice with some changes (34% - 52 out of 155). 
29% (62 out of 217) did not provide an answer. 

Opinions  on  how  the  EU  should  ensure  that  the  desired  level  of  quality  of  the  credits  it  purchases  is 
achieved  were  mixed.  The  most  common  multiple-choice  options  chosen  were  establishing  whitelists  of 
acceptable  credit  types  or  methodologies  (45%  -  81  out  of  181)  and  recognising  existing  validation  and 
verification  bodies  accreditation  schemes  (44%  -  79  out  of  181).  The  least  chosen  option  was  the  EU 
establishing its own standards and methodologies (25% - 45 out of 181). 

5