Factsheet - Environment and Climate

The document argues that the proposed CSDD is insufficient to meet EU Green Deal ambitions because it uses a restrictive definition of 'adverse environmental impact' based on a limited list of international conventions, omitting key agreements like the Paris Agreement. It highlights that the current framework allows companies to ignore impacts on water, soil, and plastic pollution if no specific international prohibition is violated. Furthermore, the briefing criticises the proposed climate transition plans for lacking prescriptive content and failing to mandate the inclusion of Scope 3 emissions, which often constitute the majority of a company's climate footprint.

• The European Commission's proposed definition of 'adverse environmental impact' is overly restrictive because it relies exclusively on the violation of a limited list of prohibitions and obligations from specific international environmental conventions.
• The current proposal fails to include several critical international agreements in its Annex, most notably the Paris Agreement, as well as the UN Convention on the Law of the Sea and the UNECE Convention on Long-range Transboundary Air Pollution.
• The proposed framework allows companies to avoid accountability for environmental harms that are not yet covered by binding international instruments, such as soil rehabilitation or plastic pollution.
• The proposal's approach to climate due diligence is delayed and insufficient, as it only considers including adverse climate impacts as a requirement seven years after the Directive enters into force, contradicting IPCC warnings that emissions must peak by 2025.
• The proposed climate transition plans under Article 15 are criticized for being too vague, risking 'greenwashing' due to a lack of prescriptive content and a failure to define what constitutes a 'principal' risk or impact.

APA

ClientEarth (2022). Factsheet - Environment and Climate. https://www.clientearth.org/media/qgcfpgvt/factsheet-environment-climate-csddd-june-2022-final.pdf

Chicago

ClientEarth. Factsheet - Environment and Climate. 2022. https://www.clientearth.org/media/qgcfpgvt/factsheet-environment-climate-csddd-june-2022-final.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=Factsheet - Environment and Climate |date=June 2022 |url=https://www.clientearth.org/media/qgcfpgvt/factsheet-environment-climate-csddd-june-2022-final.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2022factsheet, author = {{ClientEarth}}, title = {{Factsheet - Environment and Climate}}, institution = {ClientEarth}, year = {2022}, month = jun, url = {https://www.clientearth.org/media/qgcfpgvt/factsheet-environment-climate-csddd-june-2022-final.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }