International (Article 6) Credits under the EU 2040 Climate Target

The full analysis can be found here: ANALYSIS_International Credits EU 2040 Climate Target

On 10 December 2025, the EU institutions reached a political agreement on a 2040 climate target of –90% net greenhouse gas emissions compared to 1990, with a structural role for international (Article 6) credits in delivering that goal.

Our analysis unpacks how up to 5 percentage points of the target may be met through “high-quality” international (Article 6) credits, equivalent to 232 Mt CO₂-equivalent in 2040, and what this means for the EU’s domestic ambition and for emerging carbon markets. It highlights a linear build-up and phase-out of credit use as the most realistic demand profile, totalling around 900 Mt CO₂-equivalent over 2036–2040, and contrasts this with a constant-maximum use case that should be seen only as a legal upper bound.

The analysis also examines the role of the 2031–2035 pilot phase, the importance of robust quality and integrity criteria, and governance choices such as centralised EU-level procurement versus fragmented national purchasing. These elements will determine whether the 5% window supports transformational mitigation in partner countries or risks becoming a large offset-type loophole in the EU’s 2040 architecture.