The following comments were submitted on September 3, 2025 in public consultations of the European Commission, in regards to the European Climate Law and the proposed 2040 climate target.
The Institute for Agriculture and Trade Policy (IATP) Europe welcomes the EU’s efforts to make its 2040 climate target legally binding.
Europe is the world’s fastest-warming continent. Climate extremes, especially drought, are already costing farmers billions per year and will only get more frequent and more severe without strong action to cut climate pollution. Every 0.1°C of additional warming matters, so Europe should strive to cut its greenhouse gas emissions as fast as possible.
Opening the door to international carbon offsets weakens the EU’s climate action and should not be relied upon to achieve the EU’s 2040 target. The qualifiers of “high-quality” and “limited use” in the proposed regulation are no comfort. History shows that offset credits have not only failed to produce genuine climate benefits, but caused grave human rights violations. The suggested limit on credit use is much larger than it first appears and may increase further during negotiations on the regulation’s adoption. Permitting the use of international offsets goes against the 2023 advice of the EU’s own advisory body, which issued a special report earlier this year to reaffirm this point. The impact assessment evaluating credit use should evaluate both these climate and social concerns.
The EU’s food and farming system has much potential to deliver climate action with wider benefits for nature, human health and rural vitality than the risks associated with relying on loopholes, like international offset credits. The EU’s own analysis shows that even modest shifts to healthier diets can yield substantial emission reductions, with greater pollution cuts possible with more transformational change.
In preparing the post-2030 policy architecture, a sectoral target for agricultural emissions is needed for the same reasons the overarching 2040 target is important: to provide farmers and agrifood businesses with “predictability and a clear indication of the transition pathway needed”.
The policy package to support achieving this sectoral target should focus on shifting to agroecological and organic farming practices, as these holistic approaches not only address climate pollution but increase the farming sector’s resilience. A narrow focus on technological fixes to cut emissions will not deliver the system change needed, nor the level of pollution cuts required. It also risks further entrenching industrial animal farming. The entire agrifood value chain — including middle of the chain actors like grocery retailers — have a role to play in supporting the transition, which should be reflected in the policy design. Farmers will need new and attractive alternative markets if they are to shift to growing more fruits, vegetables, legumes and fiber crops.
We support and are encouraged by the EU’s commitment to a just and socially fair transition for all affected. Farmers and rural communities will need this support as they shift away from industrial animal farming — particularly in high livestock density regions. Dedicated funding for livestock transition plans in the EU’s next budget is needed to make this a reality.
Europe’s farmers are already facing the adverse impacts of a warming planet. Helping them cut climate pollution helps protect the long-term viability of the sector and the resilience and prosperity of our rural communities, and can help EU meet and exceed its 90% target at home.
Download the PDF of the submission here.
