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Natural Justice argues that the Climate Change Bill is insufficient due to a lack of urgent timeframes, the absence of concrete emission reduction targets aligned with the Paris Agreement, and inadequate provisions for funding and capacity-building at the local and provincial levels. The submission calls for the Bill to explicitly recognize nature-based solutions like forest protection, ensure transparency through automatic public access to information, and facilitate a just energy transition by phasing out fossil fuels.

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.

Global Witness argues that the EU's proposed Corporate Sustainability Due Diligence Directive risks becoming a 'box-ticking exercise' unless it is strengthened. The briefing recommends establishing a clear 'duty to prevent' harm, mandating ongoing and outcome-oriented due diligence, and ensuring meaningful stakeholder engagement, particularly for human rights and environmental defenders. It calls for the inclusion of mandatory climate due diligence aligned with the Paris Agreement, the removal of exemptions for financial institutions, and the reduction of legal barriers to justice for victims of corporate abuse.

Natural Justice critiques the draft Forest Law of Mozambique for failing to distinguish between native and planted forests, neglecting sustainable forest management, and ignoring the socio-cultural rights of local communities. The organization warns that the law's focus on economic exploitation and lack of deterrent sanctions for illegal logging and corruption could lead to the extinction of precious tree species by 2029. Key recommendations include incorporating the principle of non-regression, establishing clear community consultation processes, and implementing robust monitoring and training systems to combat organized forest crime.

The document claims that France is lagging behind internationally in the use of shareholder climate resolutions during general meetings. It asserts that major companies like TotalEnergies and Vinci have discouraged investors by claiming such resolutions are inadmissible under corporate law, a position the author describes as a 'tactique de dissuasion'. The text calls for urgent intervention from the French government and supervisors before the 2022 general meetings to ensure legal certainty for investors seeking to align portfolios with climate goals.

The European Commission's proposed regulation aims to minimize the EU's impact on global forests by establishing a 'deforestation-free' standard for cattle, cocoa, coffee, oil palm, soya, and wood. The framework relies on mandatory supply chain due diligence, requiring full traceability to the point of production via geolocation coordinates. While it improves upon the EU Timber Regulation by introducing objective science-based standards and stronger penalties (up to 4% of annual turnover), it contains a 'simplified due diligence' loophole for low-risk countries. ClientEarth identifies critical gaps compared to the European Parliament's 2020 INL Report, specifically the lack of mandatory human rights protections, the exclusion of non-forest ecosystems like peatlands, the omission of the financial sector, and the absence of civil liability for victims of deforestation.

ClientEarth evaluates the Environment Act 2021, noting that as a framework law, its success depends on future targets and rules. The organization criticizes the Act for failing to align air quality targets with WHO guidelines and for creating a loophole in deforestation laws by only restricting commodities produced illegally under local laws, which may fail to protect the Amazon rainforest.

ClientEarth argues that Clause 1 of the Judicial Review and Courts Bill, specifically the introduction of prospective-only quashing orders, would weaken the public's right to an effective remedy when public bodies act unlawfully. The briefing contends that these proposals conflict with the UK's obligations under Article 13 of the European Convention on Human Rights and Article 9(4) of the Aarhus Convention, thereby damaging environmental democracy. It further warns that such remedies could allow unlawful decisions to stand, reducing accountability and preventing the protection of the environment from irretrievable harm.

The submission argues that third-party funding (TPF) acts as a "financial engine" for investor-state dispute settlement (ISDS) and should be addressed through a holistic reform approach. The authors critique specific draft provisions, questioning the validity of using "access to justice" or "sustainable development" as justifications for permitting TPF. They express concern that current proposed sanctions may not effectively deter rule breaches and call for stricter, more tailored sanctions and clearer policy aims to guide the regulatory framework.

ClientEarth argues that the draft CEEAG contains political compromises that undermine environmental ambitions, specifically criticizing the continued support for fossil gas, low-carbon hydrogen, and biomass. The organization advocates for the strict integration of the 'Energy Efficiency First' principle, the 'energy solidarity principle', and more rigorous safeguards to prevent 'carbon lock-in'. Key recommendations include limiting hydrogen aid to renewable sources, phasing out support for high-efficient cogeneration and small hydropower, and implementing stricter conditions for the closure of coal activities to ensure they occur by 2030.

ClientEarth's contribution to the REACH reform IIA emphasizes the need for stricter enforcement of existing rules, the fulfillment of Chemicals Strategy promises without further impact assessments, and the inclusion of specific criteria for PMT, vPvM, and EDC substances.

ClientEarth argues that the draft Implementing Regulation fails to distinguish between legal harvesting and sustainable sourcing, relies on a 'box-ticking' approach to compliance, and excludes critical evidence provided by civil society organisations. The organisation calls for clearer definitions of 'significant lack of enforcement', a broader scope of applicable biomass facilities, and stronger obligations for Member States to verify information and maintain up-to-date databases.

The letter asserts that DG GROW has misinterpreted EU chemicals law and applied a lenient policy to the REACH authorisation process for ten years. It calls for the Commission to align its practices with a recent Court of Justice judgment, specifically by rejecting applications with non-negligible uncertainties or data gaps and by ending the illegal practice of requesting necessary information after authorisation has already been granted.

The statement highlights a gap between Kenya's robust legal framework—including the Constitution and the 2016 Water Act—and the reality of water pollution caused by industrial activities. It cites specific examples of contamination from battery recycling and the salt industry, and warns against the water-related risks associated with oil and gas production, calling for stronger regulatory oversight and corporate accountability.

Natural Justice (NJ) submits that while the Upgrading of Land Tenure Rights Amendment Bill is necessary to address the unconstitutionality of the 1991 Act—which discriminated against women by automatically converting tenure rights to ownership for men—the proposed mechanisms remain flawed. NJ argues that the reliance on Government Gazette notifications is unrealistic for rural women and that the top-down state-led arbitration process ignores local family-level tenure structures. The submission calls for the permanent adoption of the Interim Protection of Informal Land Rights Act and a shift toward local knowledge-based tenure determination.

The submission by Natural Justice (NJ) evaluates the draft Expropriation Bill, 2020, which aims to replace the 1975 Act and allow for expropriation without compensation in South Africa. NJ argues that the Bill fails to account for climate change and agro-ecological constraints, which are critical given South Africa's limited arable land. The organization expresses concern over the state-centric approach to expropriation, the potential for state-owned land to be shielded from reform, and the risk that state-subsidized land held by disadvantaged people could be expropriated for nil compensation. NJ recommends the creation of an ombudsperson to represent public interests, the adoption of a Land Redistribution Framework Act for better oversight, and the implementation of a Land Records Act to protect the tenure of millions of people with unregistered rights.

ClientEarth and IISD Europe argue that the Energy Charter Treaty (ECT) acts as an obstacle to climate action due to its investor-state dispute settlement (ISDS) mechanism, which allows energy companies to challenge environmental regulations. They contend that the European Commission's current modernisation proposal is insufficient because it maintains the ability for investors to bypass national courts and seek high damages awards. The authors propose a specific ISDS carve-out for climate measures, a requirement for investors to exhaust domestic legal remedies first, and a redesign of the treaty to differentiate between low-carbon and carbon-intensive energy investments.

The authors contend that while the Public Procurement Bill seeks to create a coherent legal framework and expand preferential procurement for disadvantaged groups, it lacks a robust enforcement mechanism. They propose that the Bill should allow whistle-blowers to bring civil claims for the recovery of damages caused by procurement fraud and corruption, rewarding them with a percentage of the recovered funds. This is framed as a necessary measure given the struggling state of South Africa's criminal justice system and declining figures in corruption-related freezing orders.

The document contends that the 4th PCI list is legally and environmentally flawed, specifically regarding gas projects. It argues that the selection process failed to meet TEN-E Regulation standards for cost-benefit and sustainability assessments. Furthermore, it asserts that investing in natural gas infrastructure creates stranded asset risks and is incompatible with the 1.5°C warming limit of the Paris Agreement and the EU's own Green Deal and climate emergency declaration.

The document criticizes the EPA's August 31, 2020, final rule that weakened the 2015 effluent limitation guidelines (ELGs) for coal-fired power plants. It asserts that the rollback allows utilities to avoid investing in modern wastewater treatment technologies, thereby increasing the volume of toxic pollutants entering U.S. waters. The text highlights specific loopholes for plants planning retirement by 2028 and those with limited operating hours, and notes that the 2015 rule was originally intended to prevent 1.4 billion pounds of pollutants annually.