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.

ClientEarth acknowledges the European Commission's initiative to revise the Renewable Energy Directive (REDII) in line with a new climate ambition. However, ClientEarth does not agree with the 55% emissions reduction target recently proposed by the European Commission and calls for a more ambitious 2030 emissions reduction target of at least 65%, without including offsetting by carbon sinks in the land use sector.

ClientEarth Roadmap consultation response – summary ClientEarth welcomes the Commission’s initiative to write into law the goal in the European Green Deal of climate neutrality by 2050. We assume here that the European Climate Law (ECL) will not deal directly with elements of the European Green Deal beyond those aiming at climate action. We consider that: 1.

ClientEarth welcomes the public consultation and strongly supports the EU’s initiative aiming to create legal certainty regarding companies’ duty to identify, assess and mitigate adverse impacts in the value chain. We strongly agree with the shortcomings of a baseline scenario laid out in the IIA.

Decarbonized heating is a priority for the European Union And has already been reflected in the RePowerEU strategy. This is crucial to protect human health (reduction of air pollution in many EU regions) and climate.

We would like to thank the European Commission for the opportunity to provide comments on the Energy Efficiency Directive proposal ('recast EED'). In summary, we generally find that the recast EED is strengthening the existing framework to achieve the new EU climate ambition of cutting carbon emissions by at least 55% by 2030 and the ultimate climate neutrality objective by 2050.

We welcome the European Commission (EC)’s proposal on the combined evaluation roadmap/inception impact assessment for the revision of the EU Energy Efficiency Directive (EED). Energy efficiency (EE) is a key means to limit climate change, ensure energy security while improving air quality and creating jobs.

Revising the EU Emission Trading System Directive (ETSD) and improving the proposal COM(2021) 551 are of utmost importance – but given today’s urgency of industry’s decarbonisation, the ETS needs complementary measures via the EU Industrial Emissions Directive (2010/75/EU (IED)) that is being revised in parallel. ClientEarth’s feedback focuses on crucial changes to the interactions between the ETSD and IED.

We welcome both the opportunity to comment on the Roadmap and the progress the Commission has made in the much-needed reform of CLP, the keystone of the generic risk approach in EU law. B. Problem the initiative aims to tackle We agree with the problems identified, but regret that the current, serious issues with self-identification are not explicitly mentioned or highlighted.

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.

ClientEarth strongly supports the Nature Restoration Regulation, as a comprehensive instrument aimed at tackling the twin biodiversity and climate crises, through restoring key habitats across the EU. This legal proposal comes at a critical time for the Union's biodiversity, which -according to the "State of Nature" report of the European Environmental Authority- is declining at a rapid rate, with the vast majority…

ClientEarth welcomes the EU Nature Restoration Plan of the EU Biodiversity Strategy and fully endorses the development of ambitious legally binding nature restoration targets, as the only adequate policy response to the alarming results of the EEA’s State of Nature Report and the CBD’s Global Biodiversity Outlook 5.

The revised IED has huge potential to become one of the legislative flagships translating the European Green Deal’s objectives into tangible legal obligations. Main issues of today’s IED have been described in our submission 2021 (https://www.clientearth.org/latest/documents/revision-of-the-industrial-emissions-directive/).

ClientEarth supports the EEB's position on this inception impact assessment, as well as its submissions to the IED fitness check roadmap and targeted consultation. We made our own submissions on issues of access to information, public participation and access to justice as part of the fitness check (https://www.documents.clientearth.org/library/download-info/ied-fitness-check-response-aarhus-issues/).

We thank the Commission for the opportunity to provide comments on this initiative. We applaud DG SANTE’s manifest commitment to the goals of the Green Deal as set, in particular, in the Chemicals Strategy for Sustainability and the Circular Economy Action Plan. We agree with the problems listed in the Inception Impact Assessment, and welcome a majority of the solutions proposed.

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…

ClientEarth welcomes the review of the Non-Financial Reporting Directive (NFRD) which intends to provide more robust provisions to tackle the poor quality of sustainability disclosures. Reporting requirements under the NFRD have resulted up to now in the disclosure of limited information for investors and other stakeholders including civil society organisations.

ClientEarth’s response to the roadmap consultation for the inception impact assessment of the revision of the Non-Financial Reporting Directive ClientEarth is a non-profit environmental law organisation based in London, Brussels, Berlin, Warsaw, Madrid, New York and Beijing. Please do not hesitate to contact Tatiana Lujan ([email removed]) for further information on anything contained in this response.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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 provide feedback in the present Commission Call on its proposed "Roadmap towards Nature Credits". To that end, ClientEarth has prepared a submission (cf below, attachment). Generally, while there is a need for a significant quantitative increase and qualitative improvement in biodiversity finance, the concepts formulated in the present Roadmap bring little added value.

A. Context, Problem definition We fully support the analysis of issues related to the knowledge gaps, combination effects, communication in the supply chain, evaluation, and enforcement. However it is both surprising and problematic that the description of the current issues with authorisation does not account for the problems that are the direct consequences of the incorrect interpretation of REACH.

ClientEarth welcomes the opportunity to contribute to the Call for Evidence on the Housing Simplification Package and calls on the Commission to ensure that housing policy addresses the structural factors of the housing crisis and protects the environmental and building standards that safeguard EU citizens wellbeing.

Given the significant economic and climate risks of overinvesting in methane gas, ClientEarth’s response to the Roadmap/IIA consultation focuses on measures to avoid investment in methane gas and hydrogen projects at the cost of clean alternatives.

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…

ClientEarth supports the Commission’s proposal for a legislative act to reduce emissions in the energy sector. Evidence of the climate damage being caused by poorly regulated methane emissions from fossil fuel industries is concerning and requires urgent action.

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.

Revision of the Ambient Air Quality Directive January 2023 January 2023 Revision of the Ambient Air Quality Directive ClientEarth’s key recommendations to improve Commission Proposal COM/2022/542 ClientEarth welcomes the European Commission’s proposal for a recast Ambient Air Quality Directive (the “Proposal”) for its ambitious intentions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

January 2021 Consultation on inception impact assessment for the revision of the Ambient Air Quality Directives Feedback from ClientEarth Top Lines • • • • ClientEarth welcomes the start of the initiative to revise and strengthen the Ambient Air Quality Directives Legally enforceable air quality standards (“limit values”) fully aligned with the WHO recommendations should be the backbone of the revised Ambient Air…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ClientEarth welcomes the Proposal for a Regulation establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook framework for chemicals published by the European Commission on 7 December 2023 as part of the One Substance One Assessment package.

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.

Delivery of the Green Deal depends on the implementation and enforcement of EU environmental law by EU institutions. To ensure compliance in practice, the EU needs strong mechanisms that allow civil society to hold EU institutions to account when they fail to deliver for the environment and human health.

ClientEarth welcomes the publication of this Roadmap. As we have emphasized in the response to previous consultations, we firmly believe that the amendment of the Aarhus Regulation (Regulation 1367/2006) is the only way for the European institutions, other than the CJEU, to significantly improve access to justice concerning acts of the EU institutions and to bring the European Union in compliance with its…

ClientEarth welcomes the Roadmap and the commitment of the Commission to carry out an impact assessment of regulatory and non-regulatory options for additional demand-side measures to minimise the risk that products linked to deforestation are placed on the EU market. ClientEarth invites the Commission to promptly adopt robust regulatory measures.

ClientEarth welcomes the Roadmap as an acknowledgement that the Commission needs to amplify its action to address deforestation and forest degradation. However, we are concerned about the proposed reliance on existing policies and tools to step up EU action, as the Roadmap does not expressly recommend filling gaps in the existing framework with new and targeted policy actions / new regulatory measures.

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.

Please see attached ClientEarth's full submission in response to the European Commission's proposal for the review of Solvency II. As set out more fully in our attached submission, ClientEarth welcomes that the Commission is introducing enhanced rules on climate change scenario analysis, in its proposal for amendments to Solvency II (the “Proposal”).

Amendment of the Aarhus Regulation is the only means available to the EU legislature to bring the EU into compliance with its international law obligations. On 17 March 2017, the Aarhus Convention Compliance Committee (ACCC) found the EU to be in violation of the Aarhus Convention by failing to provide members of the public with access to the EU courts.

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…

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.

ClientEarth considers that both the EUTR & FLEGT Regulation have contributed to more legality and transparency in the global timber supply chain and have made progress towards achieving the objectives of the FLEGT Action Plan.

ClientEarth is a non-profit European environmental law organisation with offices in Brussels, London, Madrid, Berlin, Warsaw and Luxembourg (as well as Beijing and Los Angeles). We welcome several components of the proposal including the aim to accelerate the transition to a climate-neutral, resource efficient, clean and circular economy in a just and inclusive way that helps achieve the SDGs; The broad 6 thematic…

See contribution attached. First, ClientEarth supports and welcomes the very positive developments in the Proposal, which tighten the obligations of Member States to provide to Eurostat precise and comparable data on the sale and use of pesticides in the EU. We highlight also other benefits of the Proposal that need to be integrated (I).