Most of the draft updated NECPs were submitted late. By 3 July 2023, only six countries had submitted their draft updated NECPs: Spain, Croatia, Slovenia, Finland, Denmark and Italy. On 18 December 2023, the European Commission published its
general assessment of the 20 out of 27 drafts submitted thus far, as well as a
detailed assessment of each draft plan. It found that the measures presented in the drafts would only result in a net 51% emissions reductions by 2030, falling short of the 55% net emissions reductions target. The measures foreseen in the submitted NECPs would also fail to deliver the 40% emissions reductions target in the sectors covered by the
Effort Sharing Regulation, resulting only in emissions reductions of 33.8%.
The assessment also showed that the LULUCF net removals target of 310MtCO2e set in the LULUCF Regulation would be missed by 40 to 50Mt with the current measures, showing a significant gap between the target and the actual measures in place to deliver on the target. The 8th Environment Action Programme Mid-Term Review further underscored the presence of such a gap, stressing that maintaining and enhancing the capacity of Europe’s natural sinks should be a top priority in the final updated NECPs, alongside increasing the sinks’ resilience to climate change.
Current versions versus draft updated versions
The current versions of the NECPs in force, which were submitted at the end of 2019, fail to consider the role of carbon dioxide removal (CDR) in reaching national and EU climate targets. None of the 27 plans include targets for CDR, nor do they take into consideration novel carbon removal methods. Even conventional CDR methods such as afforestation or soil carbon sequestration are insufficiently addressed in the majority of NECPs.
Compared to the current versions, the draft updated NECPs submitted by member states show improvements on several fronts when it comes to CDR. Over half of current NECPs discuss the role of CCS and CCU in achieving national 2030 climate targets; yet almost all new draft NECPs now consider these technologies. Yet, despite some overlaps, CCS, CCU and CDR vary in terms of their climate benefit and CDR must be distinguished as a separate suite of methods. Specific to CDR, more than half of member states included at least one measure that would be relevant specifically to its research, development and innovation. Moreover, more than a third of member states now include some sort of removal target, compared to zero in the current versions, and several other NECPs mention novel CDR methods. Finally, close to half of the NECPs include some considerations around the need to develop CO2 transport and storage infrastructure.

Rating of all draft updated NECPs


We have rated all draft NECPs based on a previous report from the Ecologic Institute.
Denmark has produced the strongest submission when it comes to CDR, including provisions such as:
- It includes indicative targets for CCUS and bio-CCS for 2030;
- It provides details about national deployment incentives for CDR (through its NECCS and CCUS funds);
- It explores the role that several novel CDR methods could play, such as bio-CCS and biochar;
- It gives a clear overview of potential CO2 storage capacities, as well as the projects currently being developed.
However, the Danish submission leaves room for improvement. The Danish draft lacks measures to increase net LULUCF removals, which is especially concerning since the LULUCF sector is currently a net emitter in Denmark. The NECP also lacks a clear RD&I plan to develop CDR technologies. By addressing these missing elements in its final NECP, Denmark would stand out as a champion of CDR in the EU.
Other countries are on the right path to producing a coherent NECP when it comes to CDR. For example, Sweden and Germany score well in some of the seven criteria. In general, deployment incentives and CDR targets are the least addressed criteria.
Why all types of CDR should be considered as part of the NECPs
As highlighted by the European Commission in the Sustainable Carbon Cycles communication, the EU should aim for a minimum annual capacity of 5MtCO2 of permanent removals by 2030. Following the publication of the European Commission 2040 Target and ICMS communications, it is clear that the EU will need to develop large permanent CDR capacities to reach its 2040 climate goals and a state of climate neutrality by 2050. Reaching these ambitious goals in time requires urgent action to develop and start to deploy permanent CDR already today.
Recommendations for the final updated NECPs
To align their updated NECP to the 2030 climate targets and the EU-wide objective of climate neutrality by 2050, member states should consider the following aspects in their final updated versions:
- National (binding) twin targets for emissions reductions and CDR, and separate CDR targets for LULUCF and permanent removals;
- A plan for restoring and maintaining LULUCF sinks;
- Dedicated research, development and innovation funding for CDR;
- The needs and the potential to transport and store CO2.