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Imported Emissions: The Missing Link in Climate Policy

Mathilde Dupré & Stéphanie Kpenou, 29 September 2026

[English] [français]

In a context of globalised trade, states’ climate action suffers from a major blind spot: it ignores imported emissions, i.e. the greenhouse gas emissions that a country’s final consumption generates in third countries (1). With its third national low-carbon strategy, France has become the first state to adopt an indicative target for reducing its carbon footprint — and therefore its imported emissions. Discussions are under way with other European countries to invite the EU to adopt an equivalent target. In a new paper, the Veblen Institute takes stock of the issue and puts forward recommendations for integrating this indicator into European climate objectives.

More than 20% of greenhouse gas (GHG) emissions are currently linked to international trade, and since 1995 these emissions have been growing faster than global emissions themselves. Yet under the Paris Agreement, countries’ commitments rest exclusively on territorial emissions. To date, the sum of current commitments falls short of the challenge. The warming trajectory that would result from countries meeting their current climate commitments is estimated at between 2.3°C and 2.5°C by 2100, according to the United Nations Environment Programme (UNEP) (2).

Accounting for imported emissions is necessary to make the role of consumption visible and to hold net-importing countries accountable for their greenhouse gas emissions.

  • Tracking this indicator should help prevent "carbon leakage." This phenomenon occurs when a country reduces its territorial emissions while increasing its imported emissions, thereby shifting the burden of mitigation efforts onto its trading partners.
  • Accounting for imported emissions would help highlight the interdependencies between countries and coordinate the actions needed to decarbonise international value chains.
  • Accounting for and reducing imported emissions is also a matter of justice for producing countries, which directly bear the consequences of other countries’ consumption.

Imported emissions need to be better measured and progressively integrated into climate objectives. In this context, a precondition for any progress is to measure these imported emissions by improving the way emissions from land use, land-use change and forestry (LULUCF) are accounted for, as well as emissions linked to digital technology and data centres.

[Key 2023 data]

This month the European Climate Foundation launched the [Traded Emissions Tracker→https://emissions.netzerotrade.org/] to integrate climate impacts in third countries into domestic and international policymaking. Based mainly on Eurostat’s FIGARO data (excluding LULUCF), this tool covers the 2010–2023 period and maps 45 countries (accounting for nearly 75% of global emissions) across 64 economic sectors.

Global level

  • Global GHG emissions: 51,831.53 MtCO₂e
  • Traded emissions: 11,249.25 MtCO₂e (i.e. 21.7% of global emissions)
    More than a fifth of global emissions are thus generated by countries for other countries’ final consumption
  • Leading importers: China (15%); United States (15%); EU (13%); India (6%); Others (51%)
  • Leading exporters: China (27%); Russia (7%); EU (6%); United States (6%); Others (54%)

European Union

  • Territorial emissions: 3,341.56 MtCO₂e (4th rank)
  • Imported emissions: 1,410.15 MtCO₂e (3rd rank) (i.e. 42% of EU territorial emissions)
  • Carbon footprint: 4,048.01 (4th rank) (21% higher than EU territorial emissions)
  • Main sectors of dependence on imported emissions
    Energy production (377.93 Mt CO₂)
    Mining and fossil fuels (344.8 Mt CO₂)
    Agriculture and livestock (139.19 Mt CO₂)
  • Main exporters of emissions
    China (370.08 Mt CO₂)
    USA (95.26 Mt CO₂)
    Russia (88 Mt CO₂)

France

  • Territorial emissions: 408.23 MtCO₂e (17th rank)
  • Imported emissions: 275.02 MtCO₂e (8th rank) (i.e. 67.36% of territorial emissions)
  • Carbon footprint: 553.70 MtCO₂e (16th rank) (35% higher than territorial emissions)
  • Main sectors of dependence on imported emissions
    Energy production (63.25 Mt CO₂)
    Mining and fossil fuels (53.39 Mt CO₂)
    Agriculture and livestock (33.08 Mt CO₂)
  • Main exporters of emissions
    China (48.2 Mt CO₂)
    Germany (15.13 Mt CO₂)
    United States (14.99 Mt CO₂)

Trends since the Paris Agreement:

  • Between 2015 and 2023, the EU’s territorial emissions fell by 2.32% per year, while imported emissions kept rising by 1.41% per year over the same period.
  • French territorial emissions fell by 2.25% per year, while imported emissions declined by only 0.42% per year — a pace more than five times slower.

France leading the way. The third national low-carbon strategy (SNBC3), adopted in July 2026, sets a carbon footprint reduction target, making France the first country in the world to set such a quantified target (3). The carbon footprint must be reduced by 38% to 43% by 2030 (i.e. between 426 and 464 Mt) and by 71% to 79% by 2050 (i.e. between 160 and 215 Mt) relative to 2010 (749 Mt), bringing the average footprint down to between 2.3 and 3.1 tCO₂e per capita (4). That said, the footprint reduction target is not binding, only indicative. The SNBC’s targets imply reducing French imported emissions by 3.1% to 5.3% per year (5).

For both institutional and economic reasons, however, the potential of isolated action by a single member state in this area remains limited. The European level appears more relevant for mobilising all possible levers. All the more so as the EU already has initial regulatory instruments in place, such as the CBAM, the regulation on imported deforestation, the ecodesign regulation, and initiatives aimed at better regulating value chains (notably the corporate sustainability due diligence directive).

But the sometimes chaotic development of these European tools so far seems to have been designed more to avoid exposing European producers to environmentally less-compliant imports than to genuinely reduce the carbon footprint of European consumption — an objective that remains a major blind spot at European level.

France must take the lead in pushing for changes to the European framework in order to:

  • Track the trend in imported emissions (create a harmonised, regular EU-wide monitoring system for imported emissions)
  • Set targets for reducing imported emissions (complement territorial GHG reduction targets with a European trajectory on imported emissions).
    Other member states also already account for their imported emissions or carbon footprint and could become allies in securing the definition of an EU-wide target.

Recommendations:

  • Encourage the adoption of carbon footprint or imported emissions reduction targets at European and international level, to complement the territorial approach. At European level, this objective should be integrated into the revision of the Energy Union and Climate Action governance framework — which underpins the National Energy and Climate Plans (NECPs) — expected in Q4 2026.
  • Unify and improve the carbon footprint calculation methodology: in the longer term, the challenge will also be to properly account for LULUCF-related emissions and emissions linked to digital technology and data centres.
  • Speed up data publication for the EU and its member states (currently published with longer delays than territorial emissions). Properly reallocating, as planned for 2027, emissions from electricity, gas and steam production (currently grouped into a single "Energy production" sector) to the consuming economic sectors would provide a more accurate picture of each sector’s carbon intensity. Note that these publication delays for imported emissions, together with the failure to break down the energy production sector, risk leaving the EU and its member states ill-equipped to define, in time, the sustainability rules needed to address the growing challenge of imported emissions linked to digital technology and artificial intelligence.

Notes to editors
(1) Imported emissions should be distinguished from a country’s carbon footprint, which covers all emissions associated with a country’s consumption, wherever they were emitted (domestic territory or third countries).
(2) UNEP, Emissions Gap Report 2025: Off Target. Continued collective inaction puts global temperature goal at risk, November 2025. Current policies alone would put warming at 2.8°C.
(3) France’s third [National Low-Carbon Strategy→https://www.ecologie.gouv.fr/strate...], July 2026.
(4) The range reflects the influence of decarbonisation in the rest of the world, under global 1.5°C to 2°C scenarios.
(5) Nicolas Riedinger, [The carbon footprint: reconciling climate and sovereignty→https://www.strategie-plan.gouv.fr/...], Point de vue, Haut-Commissariat à la stratégie et au plan, September 2026.

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