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Delivering 2030 targets: gaps in national contributions and policies

An analysis of gaps in 11 final national energy and climate plans

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Key insights: gaps in national climate and energy plans

This new ECNO analysis of final national climate and energy plans (NECPs) from 11 EU Member States submitted to date reveals several gaps in the contributions by Member States to the EU’s climate targets and the goals for renewable energy and energy efficiency for 2030, as well as the phase-out of fossil fuel subsidies. There are gaps in the respective national targets as well as the corresponding policies to achieve them. 

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Contributions match expected scope for the most part, but policy mixes put forward are insufficient to meet targets

Member States’ contributions to the Union targets for emissions reductions, natural sinks, renewable energy, and energy consumption match the expected scope for the most part. Eight out of the 11 countries fall short on their contributions to the primary energy consumption target. 

Explore more key insights below

KEY INSIGHTS

Policy mixes put forward are largely insufficient to achieve all targets and contributions

In all the eleven NECPs analysed, the policy mixes put forward are largely insufficient to achieve all EU targets and contributions - even with additional planned measures. Latvia comes closest with projections on the impact of their intended and actual policies that meet all but the energy consumption contributions. Across the four areas, five out of eleven countries have a policy mix effective enough to meet their renewables contributions. In all other areas, most countries' policy mixes fall short.

KEY INSIGHTS

Plans to phase-out fossil fuel subsidies are mixed

For direct subsidies: Member States seem well on track outlining in their NECPs that either none exists or that these are phased out by 2025, except for Spain which misses information thereof. For indirect subsidies: More than half of the NECPs analysed do not provide a clear phase-out plan. Four Member States plan the phase-out for at least some of their indirect subsidies, but only Latvia plans to phase out all fossil fuel subsidies until 2030. 

KEY INSIGHTS

Shortcomings on ESR, natural sinks and energy consumption targets

For the ESR targets, eight countries lack sufficient measures, seven fall short on natural sinks, and all countries anticipate that their current policies will not meet energy consumption targets. The latter is worrisome, given the potential to reduce energy costs and the need for renewables while increasing the resilience of the energy system; however, supporting energy efficiency seems difficult given that measures are spread across all demand sectors with each requiring an own approach. 

Insights for policy-making

Based on this analysis, the following insights for policy-making can be drawn to address the gaps identified

Contributions: Update NECPs with gaps with enhanced figures

The gaps identified on renewables and energy consumption risk the achievement of the EU-level targets for 2030, adopted as legally binding for all Member States. National contributions – designed to ensure that all Member States deliver their fair share – that are not in line with EU targets cast doubt on the overall buy-in from Member States. NECPs with contribution gaps should be updated with enhanced figures. 

Policy projections: Update NECPs with gaps with projections including further additional measures.

The fact that some Member States’ projections reveal a gap in meeting their required contributions poses a risk to achieving the EU-level objectives, strongly indicating the need for additional measures. Member States could make better use of NECPs as a tool to identify where these are needed to arrive at an effective policy mix to meet their climate and energy targets. This analysis shows a particular need to develop further energy efficiency measures. NECPs that show a policy gap should therefore be updated with projections including further additional measures.

Fossil fuel subsidies: Revise the Energy Taxation Directive

While there is progress in phasing out direct fossil fuel subsidies, the analysed NECPs fail to acknowledge various indirect subsidies, which should be addressed in the same fashion. The EU’s overall commitment cannot be achieved if a significant set of incentives for fossil fuel use are not tackled. A revision of the Energy Taxation Directive would provide a common ground for all countries to remove exemptions and reduced tax rates that support and encourage the use of fossil fuels.

Improved practice: Request update of NECPs sooner and make targeted changes to underlying legislation
  • The gaps in contributions and in policy could be addressed through improved practice, particularly by Member States providing updates to NECPs removing clear deficiencies. 
  • Additionally, closer follow-up by the European Commission on inadequate or incomplete submissions, along with a request for updates again in 2025, could help resolve these issues. 
  • Finally, the gaps found could ultimately be addressed through targeted changes to the underlying legislation, especially the Governance Regulation, which provides the rules for NECPs, their content and respective adoption process. 

Four key laws to help achieve the 2030 climate target

National climate action is crucial to achieve the 2030 climate target of a net 55% greenhouse gas emission reduction. Four key EU laws have been adopted that include national targets and actions.

Key law adopted

Effort Sharing Regulation (ESR) 

Requiring Member States to reduce their GHG emissions covered by this Regulation

Key law adopted

Land Use, Land Use Change and Forestry Regulation (LULUCF-Regulation) 

Requiring Member States to enhance their natural sinks 

Key law adopted

Renewable Energy Directive (RED)

Requiring Member States to increase the share of renewables in the energy mix

Key law adopted

Energy Efficiency Directive (EED)

Requiring Member States to reduce their energy consumption. 

Member States are obliged to draw up individual national energy and climate plans (NECPs). The plans must include information on targets and contributions to the EU objectives as well as policy scenarios that outline how the Member States will develop with the current policy mix and with additional measures until 2030 and beyond. 

On 30 June 2024, the final updated NECPs were due. However, as of 15 October 2024, only 11 final updated NECPs had been submitted to the EU Commission. This means that formal compliance with the deadlines for submitting NECPs is lacking.  

Analysis of NECPs: Gaps in national contributions and policies

The NECPs were analysed for two different aspects: 

  1. Whether the Member States’ contributions to the EU climate and energy targets are sufficient (contribution gap)
  2. Whether they include an adequate policy mix to be able to meet the targets (policy gap)

Final updated NECPs have so far been submitted by Denmark, Finland, France, Germany, Ireland, Italy, Luxembourg, Latvia, the Netherlands, Spain, and Sweden.

Effort Sharing Regulation 

All Member States put their binding national emission reduction target from the ESR into their NECP. Luxembourg has decided to even go beyond this, including a 5%-points higher target. Three countries expect to reach their respective target with their planned policy mix. Their projected emission reductions can, however, not compensate for the other eight Member States with a policy gap of around 130 Mt CO2eq mainly from France and Germany.

Gap in the national contribution to the EU target

All Member States mention their respective ESR target in their NECP. A positive exemption is Luxembourg, setting a 55% emission reduction target, which is 5%-points higher than its legally binding ESR target of 50%. 

Gap in the policy mix to achieve the required contribution

Most of the Member States (eight out of the 11) do not reach their binding ESR target with the planned or existing policy mix. Denmark, Finland, and Italy expect a gap of around 5%-points; Germany, Ireland, the Netherlands, and Sweden one of around 10%-points. Ireland expects a gap of more than 15%-points. In sum, this means that emission reductions of around 130 Mt CO2eq are not accounted for under the suggested policy mixes. 

Only Latvia, Luxembourg, and Spain expect that their planned policy mix will be sufficient to meet their 2030 target. As the former two countries have a comparably low share in total EU emissions, their expected overachievement is about 1 Mt CO2eq, the one of Spain about 17 Mt CO2eq, which is far from the total gap of the eight other countries. 

Natural sinks

All Member States put their binding LULUCF target into their NECP. Four countries expect to reach their respective target with their suggested policy mix. Their additional removals can, however, not compensate for the gap that the six other Member States indicate with their policy mix, which is about 70 Mt CO2 in total and mainly coming from Germany, France, and Finland.

Gap in the national contribution to the EU target

All Member States mention their mandatory LULUCF target in their NECPs.

Gap in the policy mix to achieve the required contribution

Seven countries expect that their planned or existing policy mixes will not be sufficient to meet their national LULUCF targets. However, Ireland is close with just one million tonnes of CO2 (Mt CO2) removals short. Sweden, Spain, and Italy are also not far off with a gap of around 5 Mt CO2. Compared to their target, Sweden, Spain, and Italy miss their target by 11%, 12%, and 21%; Ireland, in contrast, misses it by 24% due to a lower target. Finland, France, and Germany show the largest policy gap. They expect to miss their target by more than 10, 15, and close to 30 Mt CO2 with their policy mixes, whereby France and Germany include planned additional measures. This means that Finland and France miss their target by 50% while Germany misses it by close to 90%. The gap across the six countries amounts to 70 Mt CO2 or 12 Mt CO2 on average. 

Denmark, Latvia, Luxembourg, and the Netherlands assume that they can reach their target with their policy mixes. Denmark, which is legally allowed to emit greenhouse gases until 2030, significantly reduces its LULUCF emissions in its current policy projections, exceeding its target.

Renewable energies 

Most Member States put their required renewables contribution in their NECPs, with only France presenting a lower contribution and Spain setting a higher one. Sweden does not report a figure. The policy mix is effective enough in six countries, which is not enough to compensate for the other five countries. This means that both the contributions and the projections lead to a slightly reduced aggregate across the 11 Member States.

Gap in the national contribution to the EU target

Eight Member States communicate a contribution in line with the Renewable Energy Directive. France includes a 10%-points lower, and Spain a 10%-points higher contribution, while Sweden does not provide a contribution in its NECP. The lower contribution reported by France outweighs the higher contribution by Spain

Gap in the policy mix to achieve the required contribution

Five Member States are projected to overachieve their contributions by an average of 4.6%-points, with Denmark displaying the highest level of ambition. Another five Member States project that they will underachieve their contribution with their suggested policy mix by an average of 4.6%-points, with Sweden and Luxembourg being the clearest laggards at around 9%-points. Overall, Denmark, Spain, and to a limited degree the Netherlands do not outweigh the expected shortfalls observed from France, Germany, and Sweden

Energy consumption 

Most of the Member States put their required contribution to the final energy consumption target in their NECPs, except for Luxembourg and Spain. In contrast, for the primary energy consumption, almost all Member States – eight out of 11 – present a lower contribution than required. The projections highlight that the policy mix in all 11 Member States is insufficient to meet the required energy consumption contributions, despite the ‘energy efficiency first’ principle by the EU.

Gap in the national contribution to the EU target
Final energy consumption

The contributions to reducing final energy consumption are in line with the EED, except for Luxembourg and Spain. Thereby, Luxembourg states a 13% lower contribution, albeit with small overall impact. Spain outlines what the country can achieve with its policy mix, presenting the result as its contribution. It is 8% lower than what the contribution should be according to the EED. Sweden reports a very small deviation of 0.2%, as the country bases the calculation on its own long-term scenarios instead of the EU reference scenario.

 
Primary energy consumption

The contributions to reducing primary energy consumption are significantly lower across most of the countries except for Sweden and Ireland. Spain, Luxembourg, and Denmark deviate from the required contribution most notably – all other countries deviate 3% or less. Finland mentions what its contribution would be according to the EED, without further clarifying and backing this commitment. Instead, it references an upcoming strategy to define the contribution.

Gap in the policy mix to achieve the required contribution

The policy gap is significant for all countries for final and primary energy consumption, as none of the countries’ policy mixes are effective enough to meet the required contributions. 

 
Final energy consumption

For final energy consumption, countries project a gap of between 5% and 33% and most (nine out of 11) expect to miss it significantly, by more than 10%. Germany and France show the highest absolute policy gap of 31 Mtoe and 12 Mtoe, and Sweden and Denmark display the highest relative discrepancies to the required contribution of 33% and 24%, respectively. 

 
Primary energy consumption

The policy projections for primary energy consumption show a similar result with all policy mixes being insufficient to meet the required contributions. For six countries the policy gap is even higher for primary than for final energy consumption; two have a smaller gap and one country outlines the same gap. Luxembourg and Sweden do not provide the projection outcome. The Netherlands provide a large range of projected energy levels in 2030, highlighting the high uncertainty that exists around energy consumption projections. 

Phasing out fossil fuel subsidies 

Member States planning to phase-out fossil fuel subsidies is mixed. The 11 assessed NECPs outline that the countries are well on track to phasing out direct subsidies to fossil fuels. But plans are lacking when it comes to indirect subsidies, such as tax reliefs that directly or indirectly support fossil fuels: half of the countries do not provide a clear phase-out plan at all, while five countries plan the phase-out for at least some of their subsidies. Only one country, Latvia, plans to phase out all subsidies by 2030.

Gap in the national contribution towards phasing out direct fossil fuel subsidies

Member States are well on track to phasing out direct subsidies to fossil fuels. All but Ireland, Latvia, and Spain state that they have no direct subsidies anymore. The former two countries want to phase out the remaining direct subsidies by 2030 the latest. There is no clear information on existing direct subsidies and related phase-out plans in the Spanish NECP. Luxembourg states that it still has temporary subsidies that run until 2024 to help households in the energy price crisis.

Gap in the national contribution towards phasing out indirect fossil fuel subsidies

The phase-out of indirect subsidies, including tax reliefs and benefits, has not happened yet in any of the countries. Latvia plans to phase out all remaining indirect subsidies by 2030 the latest, providing a good description and a table on their subsidies. Four countries, Finland, France, Germany, and the Netherlands, plan to phase out some of their indirect fossil fuel subsidies by 2030. Thereby, Germany and Finland provide no date for the other listed subsidies. France and the Netherlands provide only good examples. 

The other countries do not clearly state either which indirect subsidies are in place nor do they mention a phase-out date. For example, Denmark provides no information but refers to an ongoing process, in which an overview of Denmark’s possible indirect fossil subsidies is being prepared. Ireland provides a good description of their subsidies but mentions no phase-out date. Italy also provides a good description but refers to an ongoing process to eliminate harmful and inefficient subsidies. Luxembourg, Spain, and Sweden provide a limited description and mention no phase-out date. Spain recognises the need to align subsidies with climate mitigation goals and states that no new hydrocarbon exploitation concessions will be granted.

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