Five months into the new European Commission, the Heinrich-Böll-Stiftung European Union is releasing an updated European Green Deal Risk Radar, spotlighting critical risks to the EU’s climate, environmental, and sustainability laws in the 2024–2029 legislative term.

Evaluating more than 20 major Green Deal laws, the updated Risk Radar uses scorecards to assess each law’s impact on five core objectives: climate neutrality, 100% renewables, fair participation of citizens, biodiversity and zero pollution.
It reveals where progress on key EU Green Deal laws may stall, and where implementation risks are mounting. It flags financial conflicts, ranging from distributional tensions to a lack of funding, as well as attempts to weaken impact and delay delivery.
The analysis also highlights loopholes that may reopen the door to fossil fuel or nuclear energy support, as well as legal grey zones that risk undermining the polluter-pays principle by granting implicit licences to pollute.
Finally, the Risk Radar warns that some measures may reinforce rather than reduce global inequality, challenging the EU’s commitment to just and fair climate action worldwide.
The Risk Radar serves as a vital tool for lawmakers, civil society, and advocates to track legislative developments and anticipate potential threats to the EU’s climate and environmental agenda.
Roderick Kefferpütz, Director of the Heinrich-Böll-Stiftung European Union:
“The Risk Radar shows that key legislation is at risk of being delayed, watered down, simplified away, or left unfunded. It is hard to see how the EU plans to reach its climate and environmental targets by undoing measures designed to deliver them. This hurts not only the EU’s climate ambition, but also the investment environment since it punishes first-mover businesses. The Green Deal risks being quietly dismantled, yet Europe’s future competitiveness and jobs depend on its success.”
Jörg Mühlenhoff, Head of Programme European Energy Transition, Heinrich-Böll-Stiftung European Union: “As the new EU legislative term unfolds, it will be essential to use this insight to hold institutions accountable and ensure that climate ambition is not derailed by mounting political and economic pressures. The EU's emission reduction target for the years 2035 and 2040 will be the litmus test in that regard. EU institutions should follow the recommendations of their own European Scientific Advisory Board on Climate Change, namely cutting greenhouse gas emissions by 90% to 95% by 2040.”
Read the updated European Green Deal Risk Radar.
Note:
The Institute for European Environmental Policies (IEEP), the independent climate and energy policy expert Wendel Trio and the Heinrich-Böll-Stiftung European Union are the co-authors of this new version of the Risk Radar, an update of the September 2024 edition. The ranking was discussed with an expert community of external peer reviewers.
New Green Deal scorecards: Carbon Border Adjustment Mechanism (CBAM), Common Agricultural Policy Strategic Plans (CSPs), Corporate Sustainability Reporting Directive (CSRD), Count Emissions EU, Critical Raw Materials Act (CRMA), Ecodesign for Sustainable Products Regulation (ESPR), Industrial and Livestock Rearing Emissions Directive (IED 2.0), Land Use Land Use Change and Forestry (LULUCF) Regulation, Soil Monitoring Law.
Updated Green Deal scorecards: CO2 Emission Performance Standards for Cars, Deforestation Regulation (EUDR), Effort Sharing Regulation (ESR), Electricity Market Reform, Emissions Trading System (ETS), Emissions Trading System 2 – ETS2 (covering fuels used in buildings and road transport), Energy Taxation Directive, European Climate Law, Gas Market Reform, Governance Regulation, Nature Restoration Regulation, Pesticides Regulation, Renewable Energy Directive.
The updated European Green Deal Risk Radar will be discussed at a webinar on Monday 12May 2025 at 14:00 CEST, with co-authors Nora Hiller (IEEP) and Wendel Trio (climate and energy policy expert), MEP Jutta Paulus (Greens/EFA), Hans Roust Thysen (Danish Agriculture and Food Council), Adeline Rochet (Corporate Leaders Group Europe) and Jörg Mühlenhoff (Heinrich-Böll-Stiftung EU).
ENDS
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