Competition policy supporting the Green Deal
Summary
ClientEarth argues that EU competition policy must be reshaped to internalise environmental externalities and support the Green Deal. The organization calls for an end to state aid for fossil fuels, a more holistic 'consumer welfare' test in antitrust and merger assessments that includes future generations, and increased transparency in state aid decision-making. It specifically recommends prohibiting aid to forestry biomass and fossil-based hydrogen, while introducing a 'green bonus' to incentivize truly sustainable innovation.
Key insights
- ClientEarth recommends that the European Commission explicitly state in all state aid guidelines that aid to fossil fuels is incompatible with the internal market because it contradicts decarbonisation objectives.
- The document argues for a revised 'consumer welfare' standard in antitrust and merger control that expands the definition of 'consumer' to include society as a whole and future generations.
- ClientEarth proposes a 'green bonus' mechanism to increase aid intensities or ease terms for projects that provide significant environmental benefits and substantially improve the state of the art.
- The organization calls for a systematic requirement that any activity receiving state aid must be proven compliant with all relevant EU environmental, nature, and climate laws throughout the duration of the grant.
- ClientEarth identifies 'greenwashing' as a form of unfair competition and suggests a 'greenwashing test' requiring companies to substantiate sustainability claims with sound, updated science.
- The document recommends prohibiting state aid for forestry biomass and fossil-based hydrogen, arguing that the former is not truly carbon-neutral and the latter is inconsistent with the Paris Agreement.
- To improve transparency, ClientEarth recommends that the Commission publish pre-notification and notification files for state aid, as well as the dates of various procedural steps in the state aid register.
- In the fisheries sector, the document argues for the prohibition of subsidies that contribute to fishing overcapacity, such as the construction of new fishing vessels.
- ClientEarth advocates for the application of the Aarhus Convention to state aid decisions to allow NGOs to request internal reviews when there is evidence of failure to verify environmental law compliance.
Cite the original document
- APA
- ClientEarth (2020). Competition policy supporting the Green Deal. https://www.clientearth.org/media/kthkuhb4/clientearth-reply-to-call-competition-policy-and-green-deal_20-11-2020.pdf
- Chicago
- ClientEarth. Competition policy supporting the Green Deal. 2020. https://www.clientearth.org/media/kthkuhb4/clientearth-reply-to-call-competition-policy-and-green-deal_20-11-2020.pdf.
- Wikipedia
- {{cite press release |author=ClientEarth |title=Competition policy supporting the Green Deal |date=November 2020 |url=https://www.clientearth.org/media/kthkuhb4/clientearth-reply-to-call-competition-policy-and-green-deal_20-11-2020.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{clientearth2020competition, author = {{ClientEarth}}, title = {{Competition policy supporting the Green Deal}}, publisher = {ClientEarth}, year = {2020}, month = nov, url = {https://www.clientearth.org/media/kthkuhb4/clientearth-reply-to-call-competition-policy-and-green-deal_20-11-2020.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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