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National Commitments, Global Stakes: The EU’s Credibility after COP30
Ten years after the Paris Agreement, there is still a clear difference between climate policy targets and actual emissions reduction outcomes. Under the Agreement, every member must submit their own climate commitments (or NDCs) to the UN. These collectively determine the global emissions trajectory. However, current contributions are insufficient to keep global warming well below the Agreement’s 2°C target, let alone 1.5°C. The present trajectory risks warming of 2.3–2.8°C, significantly impacting nature, the economy, and global quality of life. 2025 was a turning point in many regards: while the International Court of Justice in The Hague issued an advisory opinion confirming the legal responsibility of states to combat climate change, the COP30 climate summit in Belém illustrated the procrastination of political action. Below is the last article in a three-part NECP critique by the Institute for Energy Strategy.
COP30 in Belém: Great Ambitions, Modest Results
The Brazilian presidency defined COP30 in Belém as a climate summit focusing on implementation: it aimed to complement grand climate declarations with tangible actions and funding frameworks. Both the venue—with the symbolic Amazon—and the presidency’s motto, mutrião, referencing community cooperation, suggested that the focus is shifting from setting new targets to finding ways to deliver implementation.
The results, however, did not match prior expectations. By the end of COP30, 119 out of the 195 Parties to the Paris Agreement had submitted a new or updated NDC. They collectively cover 74% of global emissions. The commitments offered modest progress: many countries increased their 2030 targets, adopting new sectoral measures and investment directions. However, this additional ambition covers only 15% of the global emissions reductions required through 2035 to keep average global warming under 1.5°C.
According to the UN Environment Programme’s Emissions Gap Report 2025, projected 21st-century global warming is between 2.3 and 2.5°C, provided that every country fully implements its national commitments. With the current policy measures, however, the projected warming can reach 2.8°C.
Accordingly, the Belém decision package attempted to bridge the gap between ambition and implementation. The final text proposes tripling climate adaptation funding by 2035, though it fails to specify the base year. The summit also launched multiple initiatives to support the implementation of NDCs and adaptation plans. This strengthens the institutional and financial conditions for implementation, although most commitments are voluntary.
Resistance from oil-exporting states prevented a timeline for reversing deforestation and fossil fuel phase-out from being included in the official closing document, even though the latter was supported by more than 80 states. Instead, under a compromise proposal from the COP30 president, these issues received political support as roadmaps outside the UN process. Nevertheless, the timeline for phasing out fossil fuels remains on the agenda. Brazil has already announced that, beyond deforestation, it will continue to treat fossil fuels as a priority, while Colombia and the Netherlands will hold an international conference this spring to advance the agenda.
Taken together, the Belém summit indicates a need to strengthen the implementation capacity of global climate governance and also highlights how tight the political constraints on global climate commitments remain. NDCs have expanded in scope, and institutional frameworks have grown stronger, but it remains doubtful whether emissions trajectories are aligned with long-term temperature targets.
Key Findings of the International Court of Justice on NDCs
On July 23, 2025, the International Court of Justice delivered an advisory opinion providing a landmark interpretation of state obligations related to climate change. Even though the advisory opinion is not legally binding, it is expected to significantly impact practices in national and regional courts.
The advisory opinion provides a unified interpretative framework for the Paris Agreement provisions, international environmental treaties, and human rights norms, and it reinforces that the protection of the climate system, the prevention of significant transboundary environmental harms, and the reduction of greenhouse gas emissions are obligations erga omnes (i.e., the concern of all states). Violation of these obligations may constitute a breach of international law and may entail the responsibility of the state concerned.
Regarding NDCs, the International Court of Justice emphasized that states do not have discretionary powers in determining their national contributions. Legally, under the Paris Agreement, the 1.5°C target must be considered a guideline, and NDCs must align with it. The Court noted that the formulation, publication, regular updating, and implementation of NDCs were not mere political commitments but due-diligence obligations under international law. Although these are not “obligations of result,” which would make the specific outcome accountable, they must still be assessed against strict content standards.
The requirement of due diligence means that the expected ambition level will increase as time passes and technology develops. Accordingly, states must submit and implement increasingly ambitious NDCs that are commensurate with the worsening effects of climate change and the necessity of global action.
The International Court’s conclusion, according to which states are internationally responsible for efficiently protecting the climate system against greenhouse gas emissions, can serve as a guideline for developing the content of NDCs. Permitting fossil fuel extraction and utilization, or the disbursement of grants supporting these activities, can greatly impact this protection.
The EU NDC
NDCs provide the foundation for the implementation framework of the Paris Agreement. These documents define each Party’s emissions reduction and adaptation measures to keep global warming under 2°C, targeting 1.5°C. Although NDCs are developed at each Party’s discretion, the global emissions trajectory is determined by their intersection. This is why the Paris Agreement has a fundamental duality: NDC content is flexible nationally, but at the same time, NDCs are traceable and accountable.
By the start of COP30, most major emitters had submitted their updated commitments to 2035. The European Union submitted its modified NDC on November 5, reaffirming at least a 55% emissions reduction target by 2030 (compared to 1990); defined a new 2035 indicative target (a 66.25–72.25% net emissions reduction); and set 2050 climate neutrality as the endpoint. Indeed, this is an ambitious target; however, the International Court of Justice’s conclusions suggest that the real question today is whether it is in line with the 1.5°C trajectory and whether it can be realistically implemented with the existing and planned policy measures. According to Climate Action Tracker analysis, under the current EU actions, there is still a 3–9% gap between projected 2030 emissions and the minimum 55% climate target.
Thus, the updated version of the EU NDC seeks to meet two sets of conditions simultaneously. On the one hand, it tries to maintain its global leadership in climate policy. On the other hand, along with the 2040 target proposal, it tries to chart a consistent emissions trajectory within the EU. This, however, clashes with harsh political realities. A growing number of member states and Members of the European Parliament are citing competitiveness risks in debates over the 2040 90% climate target, advocating, among other things, the increased use of external carbon credits. Moreover, the implementation of key green legislation (including corporate sustainability rules) is being delayed or weakened, while energy price shocks and geopolitical tensions are forcing member states to make short-term interventions, despite their detrimental effects on long-term climate targets.
The Role of National Energy and Climate Plans
The EU and its member states ratified the Paris Agreement jointly, and their commitments are enshrined in a joint NDC. There are no separate member state NDCs; instead all members must record in their National Energy and Climate Plans (NECPs) the sectoral targets, policy measures, and investments they contribute to EU emissions reductions and to renewable energy and energy efficiency targets. Moreover, NECPs must cover the five dimensions of the Energy Union. The legal basis for NECPs is Regulation (EU) 2018/1999 (Governance regulation). The European Commission regards NECPs as a key instrument for strategic planning to reach the 2030 climate targets and implement the European Green Deal.
Thus, NECPs are not only EU reporting tools but also the pillars of the joint EU NDC implementation. This role carries dual implications: on the one hand, EU climate targets apply to the whole EU; on the other, under the International Court’s advisory opinion, shared implementation responsibility does not exempt any member state from meeting the due-diligence obligations.
Consequently, NECPs that are overly general, incomplete, or unfeasible not only undermine the EU’s credibility but can also pose risks under international law. The Commission’s evaluation of the updated NECPs, published on May 28, 2025, presents a mixed picture. Although it is promising that member state trajectories, taken together, project a 54% net emissions reduction by 2030, the Commission notes that there is still a significant gap between the target values and specific measures. EU Commissioner for Climate, Net Zero, and Clean Growth Wopke Hoekstra said of the Commission’s 2025 assessment of NECPs: “the ambition on paper needs to be matched by ambition in the real world.”
This means that targets must be accompanied by implementable, well-founded, and accountable policy measures; otherwise, the climate targets stay as mere declarative statements of intent.
The main expert concerns regarding member state NECPs can be put into three distinct categories. First, generally there is a lack of coherence between climate targets, energy-related commitments, and the emissions reduction trajectory. The goals to be achieved do not include a detailed policy breakdown or timeline. Second, it is often unclear who bears responsibility for a particular measure, when it is planned to be implemented, and what financial resources support it. Social impact assessments are frequently perfunctory or missing. Third, NECPs rarely function as genuine investment roadmaps. Both the required public and private investments and their planned means of mobilization through either EU or national tools are barely addressed. Under the International Court’s advisory opinion, these deficiencies can prevent implementation of international climate commitments.
Shifting Balance of Power in Global Climate Policy
The assessment of the NDCs and NECPs cannot be separated from the global power dynamics. The EU seeks to remain a top actor in climate politics: the 2040 90% climate target, the new 2035 NDC trajectory, and the long-term climate neutrality strategy would all bolster this role. However, internal member state disputes were present throughout the COP30 negotiations. According to press reports, member states, including Italy and Poland, were among those opposing a tighter timetable for fossil fuel phase-out, while in the end, the EU supported the compromise unanimously during the official procedure.
Throughout the negotiations, several countries—including Arab states, China, India, and Bangladesh—criticized EU measures imposing a carbon tariff on certain carbon-intensive imports, citing international trade procedures. This criticism mainly affected the EU’s Carbon Border Adjustment Mechanism (CBAM). Nevertheless, other states, such as the United Kingdom and Norway, are also implementing similar systems. Following a proposal by the Brazilian presidency, a COP30 resolution emphasized the importance of an open and supportive international economic system. This principle is also intended to guide climate-action instruments.
In the last few years, the United States has launched an unprecedented green industry stimulus with the Inflation Reduction Act. Moreover the US NDC aims at a 50–52% and a 61–66% emissions reduction by 2030 and 2035, respectively, compared to 2005. In January 2025, President Donald Trump announced the United States’ withdrawal from the Paris Agreement, citing national economic interests. Under Article 28, a Party may withdraw from the Agreement “at any time after three years from the date on which the Agreement entered into force”, but “such withdrawal shall take effect upon expiry of one year from the date of receipt by the Depositary of the notification” (the UN Secretary-General).
In 2017, the first Trump administration made a similar announcement, but the USA did not complete its withdrawal because President Joe Biden signed an instrument expressing the US intention to rejoin in February 2021. Following Trump’s decision, the federal government conspicuously stayed away from COP30. To compensate for the missing Washington presence, US state and city representatives and corporate actors were present.
Meanwhile, China is consciously positioning itself as a responsible, green-technology superpower. Its NDC remains modest, pledging to peak emissions before 2030, to achieve a 7–10% reduction by 2035, and carbon neutrality by 2060. However, China has expanded its solar and wind capacities at an unprecedented pace between 2024 and 2025, with installations often exceeding those of the rest of the world combined. Today, China is one of the main drivers of the global clean technology boom, while the country continues to expand its coal-based power generation capacity at a considerable rate. This raises questions about the coherence of its climate policies, even as the country strengthens its position in climate technology competition and in energy policy sovereignty.
In this context, upholding the EU’s leading position does not primarily depend on setting new target values or making diplomatic declarations, but on its capacity to formulate an efficient, socially accepted, and legally substantiated implementation framework through the NDC and NECPs system.
Conclusion
The advisory opinion of the International Court of Justice gave a new interpretive framework for climate commitments. It was the first to define the content of states’ international legal obligations regarding climate change in a comprehensive manner while clarifying the increasingly stringent requirements for emissions reduction, due diligence, and cooperation.
The European Union still seeks to remain the normative leader in climate policy by setting ambitious targets. In the future, however, its credibility will not depend on these targets but on the quality of implementation. Member state NECPs must follow a coherent, technically sound, and financially viable implementation trajectory that effectively serves to deliver on EU climate targets.
If this fails to occur, the EU may see its political legitimacy jeopardized and its political significance on the international stage weakened. The rise in climate litigation is a warning sign that fulfilling international plans in the future will become less a matter of political will and more a legally enforceable issue.
