The European Commission released an official communication today that offers its positions on core elements of what it calls the “Paris Protocol,” as well as a first glimpse at what the EU could include in its “intended nationally determined contribution” (INDC) for the forthcoming international climate negotiations in Paris this December.

The draft proposal calls for the EU to cut emissions at least 40 percent below 1990 levels by 2030, as well as for a gradual increase in reductions from the current target of 20 percent by 2020. With these major climate commitments—which are in line with the EU’s 2030 Framework for Climate and Energy Policies adopted last October —the EU has reconfirmed that it will stay the course towards a low-carbon future. It will be important, however, for the EU to ensure that including the land-use sector, which it has decided to do, does not reduce the level of effort in other key sectors.

The EU is among the first countries to outline the basic elements of its post-2020 climate target, and therefore, its draft policy document provides important lessons for other countries on how or how not to put forward INDCs. For example, while the draft is transparent on many items, it lacks clarity on the accounting and treatment of the land-use sector, a key sector for some countries. It also lacks details on how it considered the criteria of “fairness” in the development of its INDC. The draft INDC, which accompanies a longer draft policy document on the 2015 agreement, is expected to be signed off by the EU Environment Council on March 6 before it is formally submitted to the United Nations in late March.

Major Strengths of the EU’s Draft INDC

The European Commission’s policy document is strong in several ways:

1) Reinforces the EU’s commitment to addressing climate change:

The Commission’s version of the INDC signals that the EU is committed to keeping the door open to increasing ambition in the future. By recommending an emissions reduction target of “at least 40 percent,” the Commission makes clear that the EU will not cap its own potential and will hopefully be in a position to raise ambition, along with others, in the conclusion of negotiations in Paris. A gradual increase in the level of reductions from 2021 to 2030 reflects the EU’s commitment to consistently deepen emissions reductions over time.

2) Provides transparency in a number of ways:

Clarity and transparency are critical for understanding whether all countries’ INDCs are collectively ambitious enough to limit global temperature rise to 2°C and to foster accountability, trust and equity among countries. WRI is working through its Open Book Project with countries to enhance transparency of the INDCs, and has developed a draft list of information for countries to use as a reference when communicating their INDCs ahead of the Paris climate negotiations.The Commission provides a simple table of information that is clear and relatively comprehensive. While there are some improvements that can be made (e.g. land use sector and how the EU considers its INDC fair), the table provides key details that all country commitments should include, such as the sectors and gases covered, percentage of emissions covered, contribution of international market-based mechanisms and assumed inventory methodologies.

3) Sets a benchmark for other countries to follow:

By putting forward its contribution in a transparent manner well in advance of the Paris negotiations, the Commission is clarifying the intent of the EU’s INDC and subjecting it to meaningful scrutiny by a range of stakeholders. This kind of openness is necessary for building trust and creating an environment of positive pressure in which governments can come forward to announce their contributions. By adding in further details when it formally submits the INDC, the EU could provide an excellent model for others.

Room for Improvement

The elements above are very encouraging and deserve recognition. At the same time, we would be remiss to not mention a few areas that were less strong than others. As ministers from the EU’s 28 member states review the proposal, officials should consider improving ambition within the draft INDC in three key ways:

1) Strengthen the emissions-reduction target.

A study by Ecofys shows that renewable energy and energy efficiency measures in industry, buildings and energy production—such as combined heat and power generation, improved building insulation and more efficient power plants—could cut natural gas imports by half and reduce the EU’s greenhouse gas (GHG) emissions 49 percent below 1990 levels by 2030, almost 10 percent higher than the minimum of EU’s emissions reductions goal.

2) Provide more transparency and clarity.

The EU’s draft INDC leaves some room for increased transparency. The proposal would be stronger with more clarity about how to account for emissions from land use, demonstrating how the accounting methodology will not weaken the integrity of the “at least 40 percent” target. It should also indicate the base year emissions level and clarify whether the target is single- or multi-year. Similarly, a more robust explanation of how the EU sees its contribution as ambitious and fair would enhance other countries’ understanding of the EU’s proposed actions. For example, the EU could explain fairness through metrics that highlight the EU’s economic capacity, such as GDP per capita, as well as the relative costs and benefits of taking action that provide cost savings and efficiency gains.

On the Paris Protocol

The draft policy for the 2015 agreement includes many positive elements which demonstrate the EU’s commitment to a strong, rules-based multilateral agreement. With a few additional details, this proposal would position the EU well to work with other countries seeking the same objectives.

1. State readiness to put forward a 2025 target and link it to the regular five-year cycle of action

The broader policy document on the Paris agreement importantly supports the role of five-year cycles for countries to review and modify their actions over time. However, the draft does not indicate whether the EU will put forward a 2025 mitigation target and connect that to the five-year cycles of improvement it calls for. In addition, the strategy proposal notes only that every five years the process should “encourage Parties” to raise their level of mitigation ambition, rather than ensuring that ambition increases over time. This language should be strengthened. The draft policy also notes the need for regular review and strengthening of adaptation efforts, which is welcome. It also explicitly notes that, in addition to mitigation, the process should include mobilizing climate finance, technology transfer and capacity building. These are positive signals from the EU, and it will be important for the region to bring further details of its support for cycles on adaptation and support to the next UNFCCC negotiation session in Bonn in June.

Charting the Course to a Low-Carbon Future

The EU has put forward a proposal that is promising, but could use some strengthening on ambition and transparency before it is formally submitted in late March. With these few improvements, the EU’s INDC will serve as a good example for other countries to follow as they submit their own post-2020 climate plans in the weeks and months to come.