Letters to Policy Makers

Dear Member of the ENVI committee,

On 30 May you will vote on the so-called “Effort Sharing Regulation (ESR)”. The ESR covers about 60% of the EU’s greenhouse gas emissions. If designed correctly, it can drive innovation in the sectors involved, and lead to great benefits for the society such as cleaner air, reduced energy poverty and more liveable cities.  

The effectiveness of the ESR as a climate instrument is however threatened by a too low ambition and the inclusion of several loopholes which, if adopted, will further water down the already weak proposal. The target of -30% compared to 2005 levels proposed by the Commission means the EU aims to reduce its emissions by merely 1% per year over the next 16 years, while in the last five years an annual reduction of almost 2% was achieved. It also means we postpone necessary reductions to much later. However, in order to fully decarbonize the non-ETS sectors by 2050 or earlier, much higher reductions will be necessary after 2030.

To be in line with the EU’s commitment to the Paris Agreement, a target of at least 47% for the ESR sectors would need to be adopted, alongside a starting point that reflects real emissions levels. On this regard, we call on you to support amendments which strengthen the current proposal, and reject any amendments which suggest to increase or establish new loopholes.  



  • Vote against Consolidated Amendment EA.

To contribute to the efforts of limiting global warming to 1.5C degrees, carbon removals from forests should be promoted in addition to, and not instead of, the efforts to cut emissions. For that reason, the use of LULUCF credits that undermine climate actions in the ESR sectors should be limited. Compromise EA leaves the use of LULUCF credits open-ended (‘at least’ 280 Mt CO2e). Given the faulty accounting rules in the LULUCF system, this further waters down the proposal as there is no guarantee that removals actually take place. This holds true in particular for credits from forest management.*

In the Commission proposal, nine countries are also allowed to exploit the ETS surplus to undermine climate action in the non-traded sectors. For that reason the use of ETS credits should be limited. Consolidated amendment EA increases the limit to 140Mt CO2e, which severely undermines the credibility of the system.

*The credibility of forest management credits is under serious doubt, see here for a simple explanation on why.


  • Vote against Consolidated Amendment DA.

The compromise amendments introduce a new ‘early action reserve’. If this reserve is not limited to a maximum amount of credits, restricted to specific cases, and linked to a better starting point and limited banking, the EU puts the implementation of the Paris climate goals at risk. Compromise DA (recital 9, article 5 paragraph 6a) allows an unlimited use of credits, which could increase the size of the reserve to 170 Mt CO2e. Under this proposal, countries can use ‘hot air’ from the pre-2020 period when many countries were still allowed to increase their emissions.



  • Vote against ITRE 17.

All bioenergy used in the ESR sectors (biomass in buildings, biofuels, etc.) is rated as carbon-neutral even when unsustainable sources of biomass are used. Bioenergy can have disastrous consequences and only sustainable sources should be promoted. 
Caroline Westblom
CAN Europe
EU Climate and Energy Policy Coordinator,
caroline@caneurope.org, +32 2 894 46 74

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