Europe’s landmark environmental policy is a weak global climate strategy and a far stronger industrial, security and financial one.
In 2024 the European Union accounted for about 6 percent of global greenhouse-gas emissions. China produces around 29 percent. India is accelerating. If you were designing policy whose primary purpose was reducing the total amount of carbon in the atmosphere, you would direct your resources toward where most of the carbon is: technology transfer, clean-energy finance for the developing world, and low-carbon alternatives cheap enough for fast-growing economies to adopt at scale. Europe did some of this. The EU and its member states are the world’s largest providers of public climate finance, about €32 billion in 2024, but the sums are small beside the problem. Its heaviest machinery went elsewhere: it built tariff walls, subsidized its own industries, and constructed an elaborate regulatory architecture governing itself. The architects of the European Green Deal knew this arithmetic.
Consider what a climate-first European policy would look like. It would funnel serious money into clean technology transfer to China, India, and Indonesia, the economies where emissions are growing. It would export cheap nuclear technology while keeping Europe’s own reactors running, rather than letting Germany shut its last three in 2023. Carbon-market revenues would go to developing-world energy access rather than into domestic programs, which is where member states put most of them: EU law allows the money to fund climate action abroad, yet in 2024 just 0.4 percent went to international climate and energy purposes. Above all, it would make decarbonization cheap and exportable before making it mandatory and European. The Green Deal did little of this. Instead it erected a carbon border charge that shields European manufacturers from foreign rivals who pay no carbon price, built financial infrastructure that continental capital markets hoped to dominate after Brexit, and steered its subsidies toward European industry.
None of this means the climate concern was fake. The people who built the Green Deal have internalized climate risk. But belief in a problem does not settle what a policy is aimed at. Four other agendas ran alongside the climate one, all of them rational and only some of them stated as plainly.
The Industrial War
By the time the Green Deal was announced in December 2019, China had effectively destroyed the European solar panel manufacturing industry. European manufacturers had led the world in the late 2000s, and Germany’s Q-Cells was the largest solar-cell maker in 2007 and 2008. Q-Cells filed for insolvency in 2012, and by 2023, 98 percent of the solar panels the EU imported came from China. Battery supply chains for electric vehicles were being constructed in China, South Korea, and the United States, with European manufacturers either absent or dependent on foreign cell suppliers. Wind turbine components, a clean energy sector where European companies like Vestas and Siemens Gamesa had built real global strength, were heading into the same squeeze: within a few years, Chinese turbine makers offering lower prices and generous state-backed financing were winning European orders, and in 2024 the Commission opened a foreign-subsidies investigation into them. European manufacturing’s share of global industrial output had been declining for a decade. In Brussels the implications for employment, tax base, and strategic autonomy were well understood.
Europe needed to respond. The problem was that the most direct responses, from large-scale state subsidies to outright trade barriers, were tightly constrained by WTO commitments, EU state-aid law and the single market. They were not impossible: the EU had imposed anti-dumping measures on Chinese solar panels from 2013 to 2018, and in December 2019 Brussels approved €3.2 billion of state aid for a seven-country battery project, with Germany contributing up to €1.25 billion. But the big moves needed case-by-case approval from Brussels, and trade defence came only after lengthy investigations. France could not unilaterally protect its steel sector from Chinese imports, because trade policy belongs to Brussels. The rules that had disciplined European competition policy for decades were now a binding constraint on the most urgent strategic priority Europe faced.
The Green Deal was, in significant part, the solution to this problem. International trade law lets environmental objectives justify measures that would otherwise breach trade rules, provided they do not discriminate arbitrarily or disguise protection, and Russia has already taken CBAM to the WTO on discrimination grounds. Carbon pricing is defensible as climate policy even when its primary economic effect is to raise the costs of imports relative to domestic production. The financial rules embedded in the Green Deal functioned as industrial policy instruments that were far harder to challenge than naked subsidies: a taxonomy that labels which activities count as sustainable, climate-risk requirements for banks and insurers, and mandatory supply chain disclosures. Whether or not anyone planned it that way, the architecture ran through the paths the legal constraints left open.
Take the Carbon Border Adjustment Mechanism. CBAM imposes a charge on industrial imports equivalent to the carbon cost that would have applied had those goods been produced under the EU’s carbon pricing system. It covers iron and steel, cement, aluminum, fertilizers, electricity and hydrogen: the sectors where European producers face the sharpest competition from lower-cost foreign manufacturers operating without comparable carbon regulation. At the border it works much like a tariff, though it was built to be defended under WTO rules as a carbon equalization measure. The charge follows each product’s embedded emissions, and a carbon price already paid abroad is deducted, so a cleaner or carbon-taxed foreign plant pays less. For exporters with neither, the effect is a tariff’s: foreign producers lose the advantage of paying no carbon price just as European producers’ free emission allowances are phased out. The mechanism entered its definitive phase in January 2026, and the charge rises step by step as those free allowances are withdrawn, with the first certificates on sale from February 2027. In July 2026 the Commission proposed stretching that phase-out from 2034 to 2038.
The consultancy industry saw the business early. McKinsey, Deloitte, BCG and their peers built practices around ESG compliance, taxonomy interpretation, carbon accounting and transition planning, work the Green Deal’s regulatory complexity will keep generating for years. Complexity creates its own constituency: every new reporting standard is a new revenue line for the firms that interpret it, and a lobby with every reason to defend that complexity once it exists.
The Security Calculation
In 2019, the year the Green Deal was announced, Europe paid Russia more than €110 billion for fossil fuel imports. The money amounted to a systematic transfer of European wealth to a government whose intelligence services were running assassination operations on European soil, whose military had already occupied parts of a neighboring country, and whose publicly stated objective was the revision of the post-Cold War European security order. The contradiction between this financial relationship and European foreign policy positions was understood clearly. It was named in public: after the annexation of Crimea, the Commission’s 2014 Energy Security Strategy set out the EU’s dependence on Russian gas in plain terms. But it was never acted on at a scale that reduced the dependence, because there was no politically palatable short-term solution, particularly given the influence of a German industrial lobby deeply dependent on cheap Russian gas.
Renewables dissolve this problem in a way that no amount of diplomatic negotiation can. Wind and solar are geographically captive: no foreign government can cut off French solar with a pipeline decision. The more of Europe’s power comes from wind and sun, the less fuel it has to import, whatever its adversaries decide. With nearly all of Europe’s imported solar panels made in China, though, the dependence shifts from fuel to equipment rather than disappearing. This logic was not new: a secure and affordable EU energy supply was one of the three energy principles the Commission set out when it launched the Green Deal in December 2019. Russia invaded Ukraine in February 2022, little more than two years after the Green Deal was launched. The invasion confirmed European fossil fuel dependency as a strategic vulnerability in front of the entire world, and the emergency REPowerEU plan that followed was built on the Green Deal’s existing machinery.
The American dimension operates in parallel. In 2017 Donald Trump announced that the United States would leave the Paris Agreement, and in doing so he handed Europe a geopolitical identity at a moment when Europe badly needed one. The withdrawal took effect in November 2020, and he repeated it in his second term, effective January 2026. European military capability is marginal beside American capability and increasingly beside Chinese capability. Its technological leadership in decisive sectors is under sustained challenge, and its economic weight, while still significant, is a declining share of global output. Climate leadership offered something that hard power cannot easily provide: a form of moral authority that is difficult to challenge or replicate, that requires no military investment, and that positions Europe as the institutional guardian of the international rules-based order that American withdrawal was vacating.
Europe’s previous targets were also not the triumph they appeared. The EU did meet its three 2020 goals, for emissions, renewables and efficiency, but the efficiency target was reached largely because COVID-19 lockdowns crushed energy demand in 2020, France missed its national renewables target by almost four percentage points, and several member states hit theirs only by buying “statistical transfers” of renewable energy from others. The Green Deal had already raised the bar again, with a tougher 2030 emissions target and a commitment to climate neutrality by 2050, so by the time the 2020 results were in, attention had moved to the new goals.
The Political Machinery
On July 16, 2019, Ursula von der Leyen stood before the European Parliament to ask for a job she would win by nine votes. She had been nominated not as any party’s lead candidate but through a closed-door deal struck by the EU’s heads of government after a three-day summit, bypassing the Spitzenkandidat system the Parliament had expected to govern the selection. Her confirmation required an absolute majority of 374 from a 747-member parliament. She got 383. In her speech that day she made a specific promise: a European Green Deal, delivered within her first hundred days. She delivered it on December 11, 2019, ten days after her Commission took office and five months after the vote.
The policy’s merits alone do not fully explain why the Green Deal was announced so boldly and so fast. Part of the explanation lies in the political circumstances of its sponsor: a nominee who might fall short of a majority needs a historic project immediately, and needs to announce it before the votes are cast.
Greta Thunberg had addressed the European Parliament three months earlier, in April. Extinction Rebellion had occupied central London that same month. The May elections produced historic gains for Green parties across the continent. Standard accounts treat these facts as causes: public pressure demanding action, institutions responding. But the climate concern inside the Commission predated the activist surge: in November 2018 the outgoing Juncker Commission had already proposed a climate-neutral EU by 2050. What the street protests and election results provided was permission: they showed there were voters to be won and a price to be paid for doing nothing. The new Commission used the movement to press ahead on a course Brussels had already charted.
Delivering the Green Deal required the support of member states that would bear disproportionate transition costs. Poland generated about three-quarters of its electricity from coal in 2019. It was not going to accept a binding decarbonization timeline on the basis of persuasion, and in December 2019 it did not: Poland was the one member state that declined to commit to the 2050 climate-neutrality goal at the summit that endorsed it. Brussels answered with money: the Just Transition Mechanism was designed to mobilize around €55 billion for coal-dependent regions, anchored by a Just Transition Fund, €17.5 billion at 2018 prices, that pays only half a country’s allocation unless it commits to climate neutrality, and it was built to make the transaction financially manageable. This is how the European Union builds coalitions on large questions: construct a package where enough of the parties with the most to lose receive enough compensation to stop blocking.
Running through all of this was the Brussels Effect, Europe’s structural capacity to turn its market access requirements into de facto global standards that no other government has to sign. When Europe mandates certain product standards, every company in the world that wants to sell into the European single market must comply. The Green Deal carried that reach into a global industrial transition: standards written in Brussels would constrain industrial decisions in Seoul, Detroit and Shenzhen.
The Architecture and Its Costs
The Green Deal was also a financial architecture project. With the City of London outside the EU after Brexit, Frankfurt and Paris saw a chance to win products and prestige. The pieces, several of them first proposed under a 2018 sustainable-finance action plan and carried into the Green Deal, were the EU Taxonomy, which classifies economic activities as sustainable or not; mandatory sustainability reporting for large companies; the EU’s own NextGenerationEU green bonds, whose 2021 debut was the largest green bond issued up to that time; and the reformed and expanded carbon market. None of this was only climate policy. Together it built a new financial ecosystem, and Frankfurt, Paris and Amsterdam competed to host the business that Brexit had put in play. The reporting rules have since been narrowed: under the 2026 Omnibus I reform, from financial year 2027 an EU company must report only if it has more than 1,000 employees and over €450 million in turnover. European financial institutions had their own reasons to embrace ESG investing: a new asset class offered new instruments to price, new compliance requirements generating advisory revenue, new indices to construct, new funds to launch.
The EU Emissions Trading System sits at the center of this architecture. It has been operational since 2005, and for much of its life its carbon price was too low to force big decisions, averaging around €7 per tonne from 2012 to 2017, far below the levels at which fuel-switching or major capital investments become rational. It still had an effect: plants inside the system cut their emissions by an estimated tenth between 2005 and 2012, relative to similar plants outside it. The system was also vulnerable to serious abuse. Europol estimates that carousel VAT fraud in carbon allowances cost European taxpayers €5 billion in 2008–09. The 2018 reform that finally pushed prices above €20 and the Green Deal’s tougher 2023 overhaul answered a system that had become hard to defend on its own stated terms. That overhaul set a 62 percent cut on 2005 levels by 2030 and created a second carbon market for heating and road fuel, now due to start in 2028.
The officials who write the rules do not farm land in eastern Poland or work at the plants the transition will close. The costs that the Green Deal imposes in the near term, in energy bills and in jobs at plants built around carbon, fall hardest on people with the least say over how the policy was designed or how it will be revised. The gap is structural: it is what happens when the people designing the policy and the people living under it inhabit very different economic worlds.
The farmer protests that erupted across Europe in late 2023 and into 2024, in Germany, France, Belgium, Poland and beyond, followed earlier Dutch revolts over nitrogen rules. They forced the Commission into rapid retreat: in February 2024 von der Leyen announced the withdrawal of her pesticide-reduction bill, days after Brussels had proposed relaxing the rule requiring farmers to leave part of their land fallow. The triggers were often national, such as cuts to German farm-diesel tax relief and cheap Ukrainian grain in Poland, but the protests converged on the Green Deal’s agricultural rules, which imposed real costs on people operating on tight margins in physically difficult conditions. That Brussels did not see this coming says something about the distance between its rule-writers and the farms those rules govern.
Then there is nuclear power. France generates about two-thirds of its electricity from nuclear power, giving it one of the lowest-carbon grids in Europe. It wanted nuclear included in the EU Taxonomy as a sustainable investment. Germany, which had first agreed a nuclear exit in 2001, recommitted after Fukushima to closing all its plants, largely for political reasons, and opposed inclusion. These are irreconcilable positions on a proven source of dispatchable low-carbon power at industrial scale. The Green Deal left this contradiction to be settled later. Nuclear entered the Taxonomy only in 2022, through a Commission delegated act that classed it, alongside fossil gas, as a “transitional” activity. Austria challenged the act in court, and the EU General Court upheld it in September 2025. Germany kept its objections until 2025, when the Merz government stopped blocking nuclear’s equal treatment in EU law; by then its own last reactors had been closed for two years.
The Coherence Paradox
The EU produces about 6 percent of global emissions. Beyond climate finance and a handful of energy-transition partnerships with countries such as South Africa, Indonesia and Vietnam, the Green Deal does little that is serious about the other 94 percent. As global climate policy, it is largely incoherent: too small for the problem and aimed mostly away from the places where the carbon is accumulating.
Judged by its other purposes, it hangs together far better: it gives industrial policy legal cover, reduces Europe’s need for fuel from hostile states, exports European standards and gives continental finance a new asset class. It also gave a Commission president confirmed by nine votes the project she had staked her confirmation on.
As of 2026, the political coalition that produced the Green Deal is under visible strain. Farmers revolted, and parties hostile to the green transition gained ground in the 2024 European elections. The Commission has given ground too. It withdrew the pesticide law, gave carmakers three years to average their CO2 targets, and has a pending proposal to soften the 2035 zero-emission rule to a 90 percent cut. The new carbon market for heating and road fuel has slipped a year, and sustainability reporting now reaches only the largest firms. The most telling retreat is still only a proposal: industry would keep free carbon allowances until 2038, which would also slow the border charge that was meant to replace them.
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World Nuclear News. Nuclear has a place in EU taxonomy, court rules. September 2025. (General Court dismissed Austria’s challenge to the 2022 Complementary Delegated Act.) https://world-nuclear-news.org/articles/nuclear-has-a-place-in-eu-taxonomy-court-rules
oEnergetice.cz. Thaw in relations: Merz and Macron announce closer energy cooperation and end to nuclear dispute. August 2025. https://oenergetice.cz/en/international-energy/thaw-in-relations-merz-and-macron-announce-closer-energy-cooperation-and-end-to-nuclear-dispute
Linklaters. EU regulation on 2040 climate target published in the Official Journal of the EU. March 2026. (Regulation (EU) 2026/667: 90% cut by 2040, international credits up to 5% of 1990 emissions from 2036, ETS2 postponed to 2028.) https://sustainablefutures.linklaters.com/post/102mne1/eu-regulation-on-2040-climate-target-published-in-the-official-journal-of-the-eu
Regulation (EU) 2025/1214 (flexibility for car and van CO2 targets, 2025–2027 averaging), EUR-Lex; and European Parliament Legislative Observatory, procedure 2025/0420(COD) on CO2 standards for new cars and vans (Commission proposal of December 16, 2025). https://eur-lex.europa.eu/eli/reg/2025/1214/oj/eng · https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0420(COD)
Bioenergy International. Commission launches “ambitious yet pragmatic” Automotive Package. December 23, 2025. (Proposed 2035 target of a 90% cut in fleet CO2.) https://bioenergyinternational.com/commission-launches-ambitious-yet-pragmatic-automotive-package/
European Commission, DG Climate Action, with Canada, France, Germany, Italy, the UK and the US. Joint article on Just Energy Transition Partnerships. January 20, 2025. (Partnerships with South Africa, Indonesia, Viet Nam and Senegal.) https://climate.ec.europa.eu/news-other-reads/news/joint-article-just-energy-transition-partnerships-2025-01-20_en
SWP Berlin. Divided But Dangerous: The Fragmented Far-right’s Push for Power in the EU after the 2024 Elections. 2024. https://www.swp-berlin.org/en/publication/divided-but-dangerous-the-fragmented-far-rights-push-for-power-in-the-eu-after-the-2024-elections
