Skip to main content

EU Member States’ 2030 climate targets at risk because of “inconsistent and contradictory” planning on hydrogen, biofuel and carbon capture, warns climate observatory



  • Research by the European Climate Neutrality Network (ECNO) has identified major planning issues in key sectors of hydrogen, land use, bioenergy and the geological storage of carbon dioxide in Member States’ draft National Energy and Climate Plans (NECPs)
  • Forecasted demand for bioenergy could result in land grabs and accelerated deforestation around the world, while projected demand for green hydrogen could outstrip the available supply of renewable electricity risking continued reliance on fossil fuels 
  • Vague and contradictory plans around carbon capture suggest the distinction between storage and utilisation technologies is not well understood, and could drive investment in CCU infrastructure that harms long-term climate goals
  • “Transparency gap” among five Member States analysed highlights combined shortfall of 101 million tons of carbon dioxide equivalent relative to stated targets, which is more than Austria’s 2021 net emissions  
  • With final NECPs due for submission in June 2024, European Climate Neutrality Observatory calls on Member States to improve the quality and consistency of their plans to ensure 2030 climate targets are met in this critical decade of climate action

Europe’s climate neutrality goal is in jeopardy due to “insufficiently detailed, inconsistent, and even contradictory” national plans, experts at the European Climate Neutrality Observatory (ECNO) have warned.

Released today, ECNO’s report, “Net zero risk in European climate planning: A snapshot of the transparency and internal consistency of Member States' NECPs”, finds that countries have so far failed to deliver robust plans for climate progress over the next 6 years in this decisive decade of action.

The report focuses on the crucial cross-sector resources of renewable electricity, hydrogen, land, bioenergy and the geological storage of carbon dioxide. It assesses the completeness, consistency and quality of information on those sectors within draft NECPs from Italy, Hungary, the Netherlands, Spain and Sweden, and calculates the “transparency gap” for the projected shortfall on emissions reductions targets by 2030. 

Our analysis shows an urgent need for Member States to up their game with regards to charting out how they will meet their 2030 climate targets. Getting onto a climate-neutral pathway in this critical decade of action requires much more coherent and integrated cross-sectoral planning for the near term.

Key Findings 


  • The projected combined shortfall across all five countries is 101 MtCO2e (million tons of carbon dioxide equivalent) per year by 2030 - more than Austria’s net annual emissions in 2021 at 77 Mt CO2e.
  • Sweden’s plans imply net negative emissions by 2030, which ECNO’s experts do not deem credible as they have not been properly updated since the previous version, while Hungary’s plans may lead to an increase in greenhouse gas emissions. 
Key Findings 


The plans do not take a properly joined-up view of economy-wide renewable energy supply  and the scaling up of renewable hydrogen. This brings a risk that insufficient renewable electricity will be available to produce enough green hydrogen to meet demand, and that carbon intensive hydrogen will be used to make up for supply gaps.

Key Findings


The NECPs lack well-quantified domestic production targets for bioenergy, as well as detail on inputs, infrastructure development, imports and funding. This carries a risk of failing to meet demand. as well as driving deforestation abroad. There is also a risk of over-reliance on bioenergy as it can increase competition with other land uses, including food production.  

Key Findings 


A lack of distinction in some NECPs between Carbon Capture Storage (CCS) and Carbon Capture Utilisation (CCU) leads to planning inconsistencies and uncertain climate outcomes, as utilisation often implies storage only in the short- to medium-term, as opposed to the more permanent benefits provided by long-term geological storage (LTGS) of CO2. Excessive reliance on CCS also carries the risk of locking in fossil fuel dependency as it distracts from reducing avoidable emissions. 

Julien Pestiaux, lead author of the report and a Partner at CLIMACT, one of ECNO’s consortium partners, said:

We need to avoid a situation where Europe’s demand for bioenergy results in land grabs and accelerated deforestation around the world, or where our demand for green hydrogen outstrips the available supply of renewable electricity to generate it alongside other clean energy needs. We also cannot pretend that carbon capture utilisation is the same as carbon capture storage - the former is not always a long-term climate solution, and the latter must be used only where strictly necessary.

Aneta Stefańczyk, a contributing author to the report and a Public Policy Analyst with Reform Institute, another of ECNO’s consortium partners, said:

“We hope policymakers take heed of the shortcomings identified by our report and take steps to ensure their final plans are robust and transparent. Member States should seize the NECP process as an opportunity to enhance collaboration and coordination both between sectors and between countries, and set themselves up for success in meeting their targets.

“Considering the next round of plans isn’t due for another five years, we need to get it right this time around. Good planning will be the bedrock of a smooth and successful transition that enables everyone to reap the economic and social benefits that climate neutrality can bring.”

The NECP process is designed to make sure that Member States plot out in detail the actions to be taken across their economies to deliver their climate targets. If the identified planning inadequacies are not addressed, Member States may face shortages and competition for vital resources, both between sectors and with their European partners, and ultimately, missed economic opportunities.

The report shows that Member States urgently need to take a more holistic view of the interdependencies between sectors and countries in their planning, address inadequate infrastructure and technology investments, and ensure that the combined reliance on key resources is realistic. By shining a light on key areas where these early drafts typically lack coherence and clarity, the report aims to support governments across the EU to improve their NECPs ahead of their final submissions.

The five plans were selected for analysis to give a view of the geographic spread of the European Union, based on those that were available as of June 2023 when they were submitted to the European Commission for review.

Member States have until June 2024 to finalise their plans and submit them to the Commission. Some countries, including Poland and Austria, have yet to even submit a draft, while the Commission urged all Member States to “enhance their efforts” in December after reviewing the draft submissions. 

Read the report Download the Summary for Policymakers
Share this page