It’s been an action-packed first few days in Baku. As of Wednesday morning, three countries—Brazil, the UAE, and the UK—have all released parts or all of their new nationally-determined contributions, or NDCs, months ahead of the February 2025 deadline.
Experts have welcomed the leadership these countries have shown by announcing early NDCs, and praise the ambitious targets set by the UK government. But experts also say that two of these new plans—from Brazil and the UAE, two of the three Troika members tasked with leading COP29 to success—are not aligned with Paris targets, and do not sufficiently move their countries off fossil fuels.
Nationally-determined contributions, or NDCs, are commitments made by countries under the Paris Agreement to reduce their greenhouse gas emissions and adapt to climate change impacts. Each country determines its own contribution based on its national circumstances and capabilities. Experts say that appropriately aggressive NDCs must pass a series of thresholds, including commitments to phase out fossil fuels and scaling up commitments for climate finance.
According to the Intergovernmental Panel on Climate Change (IPCC) and the first Global Stocktake of the Paris Agreement, emissions cuts of 60% by 2035 compared to 2019 are recommended in these new NDCs. But thus far, only the UK goes above and beyond this benchmark, while Brazil and the UAE’s plans are lacking the aggressive leadership promised by the Troika.
“We had a catastrophic year with events we’ve never seen before, but what people didn’t understand is that this is the new normal,” Prof Niklas Höhne, NewClimate Institute, a Climate Action Tracker partner, said. “National governments have set net-zero targets and acknowledged the need to decarbonize, but what’s missing is short-term action. That’s why new NDCs for 2035 are so important. If we look at all the NDCs on the table so far, GHGs will remain stable until 2035, and if we stay on this course, we will emit twice as much as what is necessary to keep 1.5°C within reach.”
What’s in the new NDCs? Here’s what you need to know.
The UK
First, the good news. On Tuesday, UK PM Kier Starmer rolled out the country’s NDC during a speech, pledging to cut emissions 81% by 2035. This puts the country on a path to achieve the net-zero-by-2050 goal it enshrined into law in 2019, when it amended the Climate Change Act 2008.
“The United Kingdom’s new emissions reduction target is a shining example of climate leadership,” said Stientje van Veldhoven, World Resources Institute’s Vice President and Regional Director for Europe. “Let’s hope it will inspire other G20 economies to follow suit.”
There are significant questions remaining around how the UK will go about fulfilling its promises. In July, the UK Climate Change Committee (CCC), the UK’s independent climate advisory body, found that only around one third of the UK current emissions target is covered by credible plans. The country will release a Net Zero Strategy Update by May 2025, which will contain significantly more detail on UK climate policy than the NDC, including information on how the UK will meet its NDC.
“Setting this target is a critical step, and the country will now need to strengthen its policies and ramp up its green investments if it is to deliver in full,” van Veldhoven said. “We strongly encourage the UK government to complement its ambitious, economy-wide goal with bold, sector-specific goals for energy, transport, and land use and agriculture when it submits its new national climate commitment in early 2025. This would build on the recommendations from the Global Stocktake at COP28 and help deliver the country’s ambitious targets. Goals for specific sectors will offer the necessary detail to drive implementation, establish clear policies and send clear signals to the private sector both domestically and abroad.”
The UAE
Last Thursday, the UAE, which held the Presidency of COP28 last year and spearheaded the UAE Consensus mandating countries transition away from fossil fuels, became the first country to formally submit its NDC ahead of the February 2025 deadline. The NDC aims to cut emissions by 47% by 2035.
Analysts say the plan is insufficient, deceptive, and falls short of aligning with 1.5 degrees C temperature goals. While the text of the NDC claims the country is committed to “ transition away from fossil fuels in energy systems in a just, orderly and equitable manner,” under its current expansion plans, the UAE is projected to increase oil and gas production by 34% over the next decade.
An analysis of the NDC by 350.org and Oil Change International throws up some more red flags in the details of the new commitment. The UAE’s topline target is misleading, the analysis states, as it excludes exported emissions and includes offsetting. The NDC also does not include exported emissions, despite the fact that 63% of all crude oil of the UAE is exported. Finally, the analysis finds that the 30% “clean energy” target for 2030 is no improvement from the previous target and does not specify what “clean energy” means.
“The UAE’s so-called climate target is essentially a greenwashing exercise and it decided to bury its bad news on the day of the US election results,” said Andreas Sieber, Associate Director of Policy and Campaigns at 350.org. “Science unequivocally warns that fossil fuel expansion is incompatible with a livable future, yet the UAE now leads the world in oil and gas expansion approvals since December 2023, even after assuming the role of COP president with a mandate to transition away from fossil fuels. This ‘climate commitment’ brazenly undermines its own credibility and COP Presidential legacy.”
Brazil
Brazil, which is running the Presidency of the G20 this year and hosting COP30 next year, announced on Friday a plan to cut emissions between 59% and 67% by 2035. That would equal emissions levels of 850 Mt to 1050 megatonnes of carbon dioxide equivalent (MtCO2eq) by 2035. On Wednesday, officials released full details of the plan to cut emissions.
Analysts welcomed Brazil’s early submission and improvement on its previous NDC, which highlights its prioritisation of adaptation measures, strong domestic policy plans, and its reaffirmed commitment to COP28 agreements to transition away from fossil fuels, triple renewable energy capacity, and double energy efficiency gains.. But experts also say this target is not aligned with the 1.5C goal of the Paris Agreement and falls significantly short of a civil society analysis led by the Observatório do Clima, which found that Brazil should reduce emissions by at least 92% by 2035 compared to 2005. And while the NDC demonstrates a strong commitment to deforestation, it lacks explicit targets, detailed measures, and clear timelines on the country’s goal to phase out fossil fuels, which fails to strengthen its transparency and long term effectiveness.
Civil society called on the country to push for higher emissions cuts and to release further detail and transparency on its plan to transition away from fossil fuels. The country is currently projected to increase oil and gas production 36% by 2035.
“Brazil will host the next climate conference and today we have excellent figures to put on the table—reducing deforestation, in addition to the commitments already signed by the government on the agenda,” said Marcio Astrini, executive secretary of the Climate Observatory. “For all these reasons, we expected more from the Brazilian NDC. To be leaders, as President Lula preaches, we need more boldness and ambition. Our country has the potential to do much more than what we have promised.”
What does this mean for future NDCs?
Despite less ambitious NDCs from two of the three Troika countries, the aggressive UK targets set the bar for other world powers—including the United States and the EU—to step up and deliver with their NDCs. And countries that stand the most to gain from the green transition still have a chance to submit ambitious NDCs that will push them—and the rest of the world—into the future.
“It is critical for the EU to showcase its climate leadership, as the UK did,” said Manon Dufour, Executive Director of E3G’s Brussels office. “EU emissions dropped by 8.3% in 2023, the greatest annual drop in EU emissions in decades (with the COVID exception of 2020). President von der Leyen has tasked her new team with presenting a 90% net reduction target by 2040, in line with independent scientific advice. This week, EU representatives at COP29 need to reiterate this message and demonstrate their support for a timely, robust, and ambitious NDC. It’s the moment to show global leadership.”
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