Government Must Take Active Measures to Ensure the Implementation of the 2035 Greenhouse Gas Reduction Target
– Ministry of Climate, Energy and Environment and the 2050 Carbon Neutrality and Green Growth Commission Partially Accept NHRCK’s Recommendations on the 2035 NDC –
The National Human Rights Commission of Korea (NHRCK, Chairperson Ahn Chang-ho) announced that on June 25, 2025, it had issued recommendations to the Minister of Environment (currently the Minister of Climate, Energy and Environment) and the Chairperson of the 2050 Carbon Neutrality and Green Growth Commission regarding the establishment of the 2035 Nationally Determined Contribution (NDC).
The recommendations called for:
1. Setting a 2035 NDC aligned with international standards;
2. Establishing a greenhouse gas reduction pathway that does not impose excessive burdens on future generations; and
3. Developing a corporate support system to facilitate emission reductions.
Partial Acceptance of NHRCK Recommendations
Upon reviewing the government’s implementation plan and the finalized 2035 NDC, the NHRCK determined that the government had “partially accepted” its recommendations.
Regarding the first two recommendations, the NHRCK acknowledged that the upper target of a 61% reduction from 2018 levels aligns with international standards. However, because the NDC is expressed as a range rather than a single, binding target, there remains uncertainty about its actual implementation.
Similarly, while the government indicated plans for financial support to assist companies in meeting reduction targets, it did not present any concrete implementation measures, leading the NHRCK to also classify this response as partial acceptance.
Background on the Government’s 2035 NDC
On November 11, 2025, the government finalized its 2035 NDC at a 53–61% reduction from 2018 net greenhouse gas emissions.
While the upper target (61%) aligns with the NHRCK’s recommendations and international standards, the lower target (53%) has been linked to the national Emissions Trading Scheme, raising concerns that actual implementation may follow the lower, less ambitious trajectory.
Furthermore, the lower target envisions equal annual reductions throughout the period, meaning that the share of reductions will become heavier toward the latter years, thereby shifting an excessive burden to future generations.
Need for Stronger Policy Implementation
The NHRCK recognized as positive the government’s inclusion of a 61% reduction target consistent with international benchmarks. However, it emphasized that achieving the upper target will require active policy measures, including:
1. Strengthened linkage between regulatory mechanisms and the upper reduction goal;
2. Expanded financial, fiscal, and technological support for companies; and
3. Enhanced implementation capacity across relevant ministries.
While the government responded that it would “present fiscal support measures for carbon neutrality across all sectors of society,” it did not provide a detailed execution plan. The NHRCK stressed that a coherent and comprehensive support framework, covering tax incentives, financing, and technology assistance, is urgently needed to ensure that emission reductions in the industrial sector are effectively realized.
Need for Legislative Alignment
Following the Constitutional Court’s decision declaring Article 8(1) of the Framework Act on Carbon Neutrality and Green Growth for Coping with Climate Crisis unconstitutional, several amendments to the Act have been proposed in the National Assembly.
These bills all include reduction targets and pathways consistent with or exceeding the NHRCK’s recommendations. The NHRCK expressed its expectation that the law will be amended by the constitutional deadline of February 28, 2026, ensuring a more ambitious and enforceable national reduction framework.
The NHRCK reaffirms its commitment to continue addressing the human rights implications of the climate crisis, promoting public dialogue, and working with the government to ensure that a human rights-based approach is fully integrated into climate policies and legislative reforms.
