ClientEarth

ClientEarth calls on the Commission to seize the opportunity presented by the revision of the Public Procurement Directives to reinforce strategic public procurement as a means of better aligning and bridging the EUs competitiveness and sustainability objectives. To achieve this, ClientEarth has the following suggestions for a revision of the Public Procurement Directives. 1.

These submissions provide recommendations based on ClientEarths experience working to tackle greenwashing in the financial sector using the law. We do not comment on all aspects of the SFDR proposal or make detailed proposals as to the shape of a revised SFDR framework. Instead, we focus primarily on the proposed fossil fuel exclusions as a key element in achieving the objectives of the SFDR reform.

ClientEarth's response offers reflections and recommendations based on our experience working to tackle greenwashing in the financial sector using the law. We make no attempt to comment on all aspects of the SFDR review or make detailed or comprehensive proposals as to the shape of a revised SFDR framework. We believe these comments to be relevant regardless of the precise shape of the revised SFDR framework.

We acknowledge and support the Commission's efforts to promote waste recovery and the transition to a circular economy. However, we note that the Delegated Act would extend the existing exception for "waste" products to second-hand and used products.

Environmental safeguards are essential tools to prevent pollution, biodiversity loss, industrial accidents and long-term damage to public health and ecosystems. Further weakening of the Birds and Habitats Directive, EIA Directive, Water Framework Directive, Industrial Emissions Directive and Waste Framework Directive would not only damage nature and public health but would also result in heightened long-term…

Both, the lack of coherence and implementation including the lack of enforcement are key problems identified by the European Commission, as well as observed in practice by ClientEarth and stakeholders across the EU, including the Marine Strategy Framework Directive, the Birds and Habitats Directives, the Common Fisheries Policy, the Maritime Spatial Planning Directive and other ocean-related laws and policies.

ClientEarth welcomes the opportunity to respond to this consultation. Although the purpose of this implementing decision is to establish criteria for reporting data for the purposes of assessing whether Member State level obligations are met, this implementing decision will set a precedent with knock-on implications for decisions regarding how recycled content is to be assessed for other purposes, including those…

With the Vision 2040 for fisheries and aquaculture, the Commission can provide a real, coherent pathway, aligning all stakeholders behind the same objective to turn the tide for fishers and coastal communities, and ensuring a resilient and sovereign Europe. Todays unstable supply chains and tense geopolitical context demand strong action to ensure Europe's strategic autonomy and resilience.

Public debate focuses mainly on deforestation and illegal logging in the countries of the Global South, however, forestry crime is a common problem across the world – including the EU. Cyprus, Greece and Latvia are mentioned in this context, as well as Bulgaria and Slovakia.

ClientEarth welcomes the Commissions initiative to provide guidance to the Member States in the mapping and designation of renewables acceleration areas. While it is pivotal for the clean energy transition that the EU become more energy-independent and resilient, safeguards for environmental protection and peoples rights must be upheld in this process.

On 7 December 2023 the European Commission published two proposals for a Regulation as regards the re-attribution of scientific and technical tasks and improving cooperation among Union agencies in the area of chemicals, and for a Directive as regards the re-attribution of scientific and technical tasks to the European Chemicals Agency as part of the One Substance One Assessment package.

ClientEarth welcomes this opportunity to provide comments to the legislative proposal COM(2025) 386. We fully support the objective of the initiative to strengthen the governance and financial flexibility of the Chemicals Agency, while ensuring it can deliver on its tasks deriving from the REACH Regulation and several other pieces of Union legislation relevant for chemicals.

ClientEarth welcomes the possibility to give feedback on this important initiative. We agree with the key points identified by the roadmap as the necessary scope of the action. Our comments address each of them. “Need to consolidate the purpose of ECHA considering the evolution of tasks” We are looking forward to the changes the Commission sees as needed on this aspect.

The recent State of EU fisheries report is unequivocal: Minimising negative impacts of fishing on the marine environment, its habitats and species must continue in order to safeguard the very basis of fisheries prosperity. This imperative must lead any discussion on a potential Fisheries Omnibus on Multiannual Plans (MAPs).

ClientEarth welcomes the opportunity to provide feedback on the European Commissions call for evidence regarding the amendment of the European Maritime, Fisheries and Aquaculture Fund (EMFAF) Regulation (EU) 2021/1139. Please find attached the full contribution of ClientEarth this call for evidence.

We appreciate the opportunity to provide our feedback on the European Maritime and Fisheries Fund 2014-2020 (EMFF) and its successor the European Maritime, Fisheries, and Aquaculture Fund 2021-2027 (EMFAF). In line with the objectives of the Common Fisheries Policy (CFP), we believe that these funds must be more effectively aligned with sustainable fishing practices and the protection of marine ecosystems.

ClientEarth supports the European Commissions proposal to ban CMRs in childcare products. We urge the Commission to prioritize the highest level of protection for children above all other considerations. Additionally, the proposed exemptions require refinement, and further restrictions are necessary to ensure childcare products meet the same stringent safety standards as those set by the Toy Safety Regulation.

The setting of fishing opportunities for 2027 will shape the future of fisheries for years to come. Despite positive trends in some areas, the European Commission itself recently recognised in its Common Fisheries Policy (CFP) evaluation report that progress on stock rebuilding is lacking and the number of stocks threatened by collapse due to impaired recruitment has increased during the reporting period…