Implementing moving targets: the EU green deal and domestic implementation during the renegotiation of EU climate policy

The ecological transition has little time to spare. As sufficiently ambitious climate policies remain elusive, climate policies will likely be rapidly updated over time to meet the objectives in the Paris Agreement. Hence, the latter includes an ambition mechanism for regular strengthening of targets and policies. Policy changes occurring even as they are in the process of being implemented raise the issue of how this affects national policy implementation. Launched in 2019, the European Green Deal (EGD) entailed ratcheting up not only the EU’s climate targets, but also its more specific climate policies. The latter had only recently been subject to extensive reforms, with a tightened emissions trading scheme (ETS directive), a ramped-up approach to annual carbon budgets per member state for sectors outside the ETS (effort-sharing regulation, ESR) and novel accounting of CO2 emissions and uptake from land, land use change and forestry (LULUCF regulation) adopted in 2018. Coinciding with the entry into force of these policies in 2021, and riding on the tailcoats of the EGD, the Fit for 55 legislative package was proposed. Adopted in 2023, this package entailed significant changes to the ETS, ESR and LULUCF, including by further tightening the specific targets under each. Hence, member states were in the process of implementing and applying the EU climate policies just as the same policies were being reopened for negotiations due to the EGD. This also affects countries affiliated with the EU. Norway cooperates with the EU via the European Economic (EEA) Agreement. Via the latter, Norway had been part of the ETS since 2008, and in 2019, Norway and Iceland signed an agreement with the EU that entailed joining the ESR and LULUCF as well. This paper examines whether, how and why the implementation of EU climate policies was affected by the EGD-triggered revision process of the same policies. While EU implementation research has mainly examined EU directives, EU regulations too often require national rules to enter into effect (Blom-Hansen et al., 2023). The latter is indeed required by the three above-mentioned climate laws, which largely provide a framework within which further national policies and instruments are needed. The paper will examine domestic implementation of the 2018 versions of the three EU climate policies prior to and during the launch of the EGD and the negotiations of the Fit for 55 package. What responses were triggered at the national level in response to the anticipated and observed changes? The paper theorizes different national responses based on affiliation with the EU, path-dependencies of domestic climate politics and the preferences of the involved actors. National implementation may be put on hold due to uncertainty surrounding application of the revised EU policies, or due to uncertainty regarding their content. Alternatively, national implementation may be preemptively adjusted to accommodate anticipated changes. The paper is based on case studies of the implementation process for the three climate policies in a member state (Denmark) and an affiliated country (Norway), selected for expected variation in domestic responses across policies and countries.