[Column] How to Avoid the Pitfalls of Range-Based NDC Targets
The government has finalized the 2035 Nationally Determined Contribution (NDC) to be a 53–61% reduction from 2018 emissions, following a Cabinet meeting on the 11th.Although the numbers appear more ambitious than the 2030 target of 40%, the direction is closer to a step backward. The government defined 53% as the “practical target linked to regulatory instruments such as the Emissions Trading Scheme,” while 61% was described as a “declaratory target premised on expanded support and technological innovation.” The lower bound remains a “practical limit,” and the upper bound remains “rhetorical without commitment.”The government claimed that the NDC reflects a comprehensive consideration of the urgency of the climate crisis, the Constitutional Court’s ruling, IPCC recommendations, and industrial conditions. In reality, however, the decisive factor behind the lower bound was the burden on industry. This is not “balanced consideration” but a political compromise, turning the target into a negotiated outcome rather than a science-based commitment.Last year, the Constitutional Court held that because future generations will bear greater exposure to the impacts of the climate crisis while lacking any voice in today’s democratic decision-making, the government has a heightened duty to design long-term mitigation pathways with utmost care. Therefore, the NDC is not merely declaratory—it is a constitutional obligation. The International Court of Justice also stated this year that a country's discretion in setting its NDC is limited to levels consistent with achieving the 1.5°C goal. Despite this, the government again relied on “industrial conditions” rather than scientific evidence to determine the lower bound, repeating incentives to avoid near-term mitigation obligations mandated by the Constitutional Court.This approach does not benefit industry either. The government’s proposed 2035 reduction rate for the industrial sector is 24.3%, far lower than that of Japan or Germany — countries with similar manufacturing shares. Industry’s argument that “our structure makes it difficult” is essentially a declaration of giving up on technological innovation. Global decarbonization has already shifted into a technology-driven race for industrial transformation. A low reduction target does not reduce short-term risk; instead, it signals the forfeiture of long-term competitiveness and investment opportunities. When the National Assembly legislates the long-term mitigation pathway in the future, it must correct these issues and seriously consider raising the industrial reduction target. The range-type target system creates perverse incentives in administrative practice. To minimize risk, the government and industry will likely plan around the lower bound — the target most achievable. In effect, “53% reduction” becomes the real target, while the upper bound (61%) remains an ornamental figure. This increases the likelihood that the NDC will devolve into a minimum-compliance target, signaling that “only the lower bound needs to be met.”For Korea to achieve real progress through its NDC, fiscal investment and research & development (R&D) plans must be set based on the upper bound, and incentive systems for exceeding targets must be introduced. The structure must shift from “meeting the minimum” to “being rewarded for approaching the upper bound.” This is the beginning of institutional reform that ensures both legal accountability and policy credibility. The 2035 NDC should not be seen as a mere confirmation of targets, but as an opportunity to reset the nation’s climate policy.NDCs can no longer remain within the realm of climate and environmental policy. Climate policy must serve as a platform for technological innovation, industrial transformation, and new market creation. A collaborative planning process between the public and private sectors and a performance-linked institutional design are essential. Korea needs a system in which constitutional responsibility, international expectations, and market signals work together.What is needed now is not adjusting numbers but restoring institutional integrity and accountability. A lower-bound NDC cannot meet the 1.5°C goal, sustain industrial competitiveness, or create new opportunities for growth. The government must step out of its political comfort zone and return to the science- and constitution-based obligations. That is the only way for Korea to remain competitive amid global transition.
2025.11.14 / Seungwan Kim
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