Expert Council sees climate targets 2022 only partially achieved and assesses the planned amendment of the Federal Climate Change Act

Berlin, April 17, 2023 – Today the Council of Experts on Climate Change published its Review Report of the German Greenhouse Gas Emissions for the Year 2022. In the report, which is provided annually in accordance with the Federal Climate Change Act, the Expert Council reviews the German Environment Agency’s calculation of the previous year’s greenhouse gas emissions broken down into seven sectors. In addition to the review, the report contains an in-depth analysis of the development in individual sectors and an assessment of the coalition committee’s plans to an amendment of the Federal Climate Change Act issued on March 28. 

Review of data confirms renewed failure to meet targets in sectors transport and buildings  

Apart from a minor correction in the calculation of the emissions of the transport sector, the Expert Council finds no indication that the Federal Environment Agency should have arrived at different results of the previous year’s emissions. For the year 2022, the Federal Environment Agency has switched to a more model-based method in the data basis, which is welcomed by chairman Hans-Martin Henning: “The procedure now largely follows that of the official emissions reporting to the United Nations, which we welcome. However, the early date of the calculation of the previous year’s emissions continues to hold high uncertainties, especially in connection with the significantly changed circumstances in 2022 as a result of the war in Ukraine.”  

In 2022, emissions decreased by 1.9% compared to 2021, from 760 to 746 million tons carbon dioxide equivalent (Mt CO2-e). As in the previous year, the reported emission values for the transport and buildings sectors in 2022 were again above the annual target values specified in the Federal Climate Change Act. In the buildings sector, the target was missed for the third year in a row. According to Section 8 (1) of the Federal Climate Change Act, the responsible ministries now have three months to present an immediate action programme. 

Emission reductions are partly crisis-related and may not be permanent 

The exceedance in the buildings sector would have been much greater without various favorable effects on emissions—such as the mild weather and savings due to changes in heating behavior. In addition, the necessary trend reversal in the transport sector is still not observable; emissions development remained at a consistently high level. 

Without the lower-than-expected economic growth as a result of the war in Ukraine, greenhouse gas emissions would have been about 9 Mt CO2-e higher according to a rough calculation. “The emissions development in 2022 was strongly influenced by the energy price crisis. In particular, the significant drop in the industrial sector is essentially due to energy price-related production declines in energy-intensive industry and could therefore be temporary,” Council member Barbara Schlomann classifies the development and continues: “Moreover, with the knowledge of today and the updated data from the National Inventory Report, an immediate action programme would also have been due for the industrial sector last year.” 

Although the energy sector just met its sector target in 2022, emissions increased by about 11 Mt CO2e compared to the previous year. “It is clear that all sectors are struggling with their targets. This also means that there is little room to balance out the sectors in such a way that the overall target is achieved in the future,” Barbara Schlomann explains. 

Cornerstones for planned amendment of the Federal Climate Change Act harbor risks 

It is also against this background of the sectors’ challenges to achieve their targets, that the Expert Council assesses the key points from the coalition committee’s plans on the amendment of the Federal Climate Change Act. While some of the planned amendments can help meet the targets of the Federal Climate Change Act in a recognizable and sustainable way and partly also take up suggestions from earlier reports by the Council of Experts on Climate Change, others bear the risk of weakening the law’s effectiveness.  

“The decisive factor is that the amount of emissions currently specified in the Federal Climate Change Act may not be exceeded cumulatively over the decade. This budget approach is a central idea of the law,” emphasizes deputy chair Brigitte Knopf. “A possible blurring of a clear departmental responsibility as well as the various considerations to change the control mechanism in the Federal Climate Change Act increase the risk for future missed targets,” Brigitte Knopf continues and adds: “This is especially critical in light of our enormous challenges to achieve the yearly targets until 2030, which we identified in our Biennial Report 2022.” 

However, a final assessment of the coalition committee’s planned amendment will be only possible on the basis of the concrete formulations of the legal text, which in its current form leaves many questions open with regard to its design. The Expert Council provides recommendations on this in the report. 

Read the Review Report and accompanying Technical Document here: 

Download press release (PDF, 46 kB)

Further information 

The Council of Experts on Climate Change (ERK) is an independent panel of five experts from different disciplines. It is mandated by § 11 and § 12 of the Federal Climate Change Act (KSG) and its members are appointed by the Federal Government for a period of five years. The panel consists of the five members Prof. Dr. Hans-Martin Henning (chair), Dr. Brigitte Knopf (deputy chair), Prof. Dr. Marc Oliver Bettzüge, Prof. Dr. Thomas Heimer and Dr. Barbara Schlomann. In addition to other legally defined tasks, the Council of Experts on Climate Change reviews the emissions data of the Federal Environment Agency in accordance with Section 12 (1) KSG and submits an assessment of the published data to the Federal Government and the German Bundestag within one month. 

Visit for more information on the Council of Experts on Climate Change and its publications. Follow us on Twitter: @ERK_Klima 


Cynthia Schmitt, Public Relations and Publications
Expertenrat für Klimafragen (ERK)
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10117 Berlin 
Tel: +49 (0) 30 8903 3336