The proposed exclusion of second-hand or used products from the EUDR scope must be clarified and defined to avoid EUDR circumvention. While it is reasonable to exempt products already placed on the market, the delegated act lacks clear definitions and proof requirements for identifying such products.
EIA
Environmental Investigation Agency
NGO · United Kingdom · EU Transparency Register 03960197927-62
2
positions filed
in the 326 files tracked
2
legislative files
of 326 tracked
2
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 784 non-governmental organisations on this site, they rank #333 by legislative files engaged — a count of participation, not a measure of influence.
7.3
declared lobbying FTE
self-declared
—
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2012
in the register since
Declares membership of
- EIA is a member of the Species Survival Network (SSN)
- UK LINK whales and marine groups
- CAN-Europe
- Ecosystems Climate Alliance
- the Forest Legality Alliance
- EEB Waste Working Group
- Seas at Risk →
- Break Free From Plastics.
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Non-governmental organisations
- Head office
- London, United kingdom
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Environmental Investigation Agency filed 2 positions between 13 May 2025 and 29 Apr 2026, across 2 of the 326 legislative files tracked here, attaching a full position paper 2 times.
2025 · 1 filed2026 · 1 filed
What they argued
The use of international carbon credits towards the EUs 2040 climate target would undermine ambition, risk environmental integrity and delay the urgent, structural transformations required to meet the Paris Agreements 1.5°C target, all while increasing the overall cost of decarbonisation. Achieving climate neutrality by 2040 without the use of credits is feasible and necessary (CAN, 2024).
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- Cefic · 2 files in common
- Deutsche Umwelthilfe e.V. · 2 files in common
- BASF SE · 2 files in common
- Bioenergia ry - the Bioenergy Association of Finland · 2 files in common
Is this your organization?
Everything on this page comes from Environmental Investigation Agency’s own submissions to the European Commission — we have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.