At first glance, Switzerland looks like a model climate student: Since 1990, their greenhouse gas emissions have fallen by around a quarter, contrary to the global trend. By 2030, emissions are to fall by a total of 50 percent compared with 1990. In view of the measures taken so far, this is unfortunately too ambitious a goal, says Thomas Frölicher, climate researcher at the Oeschger Centre for Climate Change Research (OCCR) at the University of Bern: “I think it is unlikely that Switzerland will achieve its climate targets and reduce emissions by half again in the next five years. But at least we are moving in the right direction.”

More worries are caused by the “gray emissions”. If these factors are included in the greenhouse gas inventories, the image of Switzerland as a model climate student becomes considerably gloomier at a second glance. Behind the term “gray emissions” lies the share of greenhouse gas emissions that arise from the production and use of imported services and products as well as from the utilization and depreciation of the latter.

Switzerland is world champion – in terms of gray emissions

If you think of gray emissions from avocados imported from Peru or cheap T-shirts from Bangladesh, you are not wrong in principle. The emissions generated by digital media and streaming are also significant – Netflix and other servers are located in the United States. However, mobility and infrastructure are at the forefront: With Holcim, for example, Switzerland is home to one of the largest cement producers in the world, but it is still produced almost only abroad.

As a financially strong but resource-poor country, Switzerland imports a comparatively large number of goods. At around 75 million tons of CO₂ equivalents per year, its gray emissions are well over twice as high as domestic emissions (currently around 41 million tons). Since 2000, according to Thomas Frölicher, the proportion of gray emissions has risen slightly. In almost no other country in the world do gray emissions account for such a high proportion of the total carbon footprint. “From this point of view, Switzerland is world champion,” says Frölicher, “but unfortunately not in football.”

A legal gray area

Despite their scope, gray emissions play a minor role in the public debate on climate protection. For climate law expert Charlotte Blattner, the reason for this is also to be found in the law: “Climate change law primarily addresses domestic emissions. Gray emissions, on the other hand, are in a legal gray area where responsibility is inadequately regulated.”

Blattner, who has recently become a professor at the Centre de droit public at the University of Lausanne and an associate researcher at OCCR, conducts research on international and national climate protection law. The legal aspect is becoming increasingly important in the climate debate, she says – not least because of the growing number of climate lawsuits. For example, the successful lawsuit against Switzerland brought by KlimaSeniorinnen before the European Court of Human Rights (ECtHR) made headlines. For the first time, the Court recognized protection against the consequences of global warming as a human rights issue.

With its advisory opinion published in July 2025, the International Court of Justice (ICJ) has now also made it clear that states are obliged under international law to take into account the cross-border effects of their climate policy – according to Blattner a point that is of particular relevance when dealing with gray emissions.

“We are outsourcing responsibility abroad”

As far as climate law is concerned, Switzerland lags behind numerous countries, says Blattner. The situation regarding gray emissions is particularly sensitive because Switzerland wants to achieve its climate targets to a large extent by means of offsetting projects abroad. In Peru, for example, the federal government is financing the construction of 60,000 low-emission stoves for private households and allowing climate certificates to be credited towards this. However, it is difficult to reliably prove whether such projects actually bring additional emission savings.

In this way, two forms of outsourcing arise: On the one hand, local consumption causes a disproportionately large number of emissions abroad, on the other hand, savings are also to be achieved there. “This means that we are not only outsourcing our CO₂ emissions, but also a large part of our legal responsibility abroad,” says Blattner.

Climate Law Conference pools expertise for the first time

For the first time, gray emissions will be the subject of a dedicated conference, “2nd Bern Climate Law Conference,” which will take place at the end of October at the University of Bern (see box). The conference, co-organized by Charlotte Blattner, examines the gray emissions from a climate science, international law, trade law and national law perspective. In addition to leading researchers, representatives from administration, business and NGOs will also take part. The aim is to examine the phenomenon of gray emissions from different perspectives, and how to explore the legal and political scope for action.

The following questions will be discussed during the conference: Where and with which economic processes do gray emissions arise – and how are they recorded? Who is legally responsible: Consumers, importing countries such as Switzerland or internationally active companies? And finally: Which policy or market-based instruments can actually help reduce gray emissions?

“Public debate needs momentum”

In addition to researchters from Bern, Lausanne, Zurich and abroad, representatives from practice also have their say. For example, Christina Meier, Head of Sustainability at SBB, reports on how a large transport company measures and reduces its gray emissions.

“Gray emissions are such a big problem that we can only tackle them if we find the broadest possible interdisciplinary approach,” says Charlotte Blattner. Climate researcher and keynote speaker Thomas Frölicher adds: “The public debate on gray emissions urgently needs momentum. Switzerland could not only fail to meet its domestic climate targets; it also continues to contribute to high emissions abroad through imports.”