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Reach-ing further: what do we want to see in the EU’s reformed chemicals law?
ClientEarth argues that the current REACH law is inadequate, noting that over 70% of chemicals produced and used are hazardous. The organization calls for 'REACH 2.0' to implement a non-essential use ban with specific phaseout deadlines, strengthen 'no data, no market' registration requirements, and enable the fast-track restriction of entire chemical groups. Additionally, it advocates for stronger enforcement mechanisms—comparable to GDPR fines—and the creation of legal tools for citizens to demand action against pollution in 'toxic hotspots'.
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Document type: Statement
G7: It’s time to transition from fossil fuels to clean energy
The We Mean Business Coalition calls on G7 leaders to accelerate the transition to clean energy through specific policy targets, including the phase-out of coal by 2030 and the elimination of fossil fuel subsidies by 2025. The document argues that such policies provide the necessary clarity for the private sector to invest in renewables, electrification, and energy efficiency, while noting that clean energy investments could boost global GDP by 4% by 2030.
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Document type: Statement
HUMAN RIGHTS AS A COMPASS FOR OPERATIONALIZING THE LOSS AND DAMAGE FUND
The document argues that the Loss and Damage Fund must be grounded in human rights to effectively protect marginalized communities and provide substantive redress. It recommends a governance structure with representative board membership, the use of rights-based needs assessments, and the implementation of strict social and environmental safeguards. To ensure adequacy and equity, the authors advocate for public, grants-based funding derived from historic polluters and innovative sources like a Climate Damages Tax, rather than loans that increase debt in the Global South.
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Document type: Policy brief
An Innovative IFI Operating Model for the 21st Century
The document argues that MDBs must shift from a project-by-project approach to coordinated country and sector platforms, utilizing 'Just Term Sheets' to standardize transition investments. It recommends scaling risk-sharing instruments, such as guarantees and local currency loans, to lower the cost of capital in EMDEs. Furthermore, it calls for a business model overhaul, transitioning from an 'originate to hold' to an 'originate to distribute' model to recycle capital and increase lending capacity. The paper also emphasizes the need for standardized KPIs, improved data sharing via entities like the GEMS risk database, and the institutionalization of crisis-response toolkits for regular climate action.
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Document type: Research paper
PUBLIC CONSULTATION INPUT
Carbon Market Watch urges Verra to move away from the 'tonne-for-tonne' offsetting model, particularly for AFOLU projects, due to permanence risks and the potential for corporate greenwashing. The submission recommends adopting a 'contribution model' where finance supports climate action without claiming neutrality. It also calls for greater financial transparency regarding intermediaries, a more accessible and independent grievance mechanism for indigenous peoples and local communities, and the banning of methodologies that support fossil fuel infrastructure.
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Document type: Statement
Reforming the Competition Act to Address Deceptive Green Marketing and Integrate Sustainability
The submission by Ecojustice and the Canadian Association of Physicians for the Environment (CAPE) proposes comprehensive amendments to the Competition Act to align it with Canada's net-zero and environmental commitments. The authors argue that current laws fail to address 'greenwashing'—deceptive environmental claims—which distorts the market, penalizes genuinely sustainable businesses, and misleads consumers. Key recommendations include amending the Act's purpose clause to recognize sustainability, legislating specific prohibitions against common forms of greenwashing (such as misleading carbon offset claims and generic 'eco-friendly' labels), and expanding the public's ability to challenge deceptive marketing through the Tribunal without needing to prove specific damages. Additionally, the document suggests establishing a sustainability taskforce within the Competition Bureau, allowing for 'public benefit' considerations in merger assessments, and creating exemptions for competitor collaborations that advance environmental protection.
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Document type: Report
Sustainable Agriculture Strategy Discussion Document
CAPE argues that Canada's Sustainable Agriculture Strategy must move beyond climate change to include a 'planetary health' lens, specifically addressing the health risks of conventional agriculture, the need for pesticide reduction, and the integration of environmental justice and Indigenous rights.
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Document type: Statement
Indias Lithium Resources in Kashmir Highlight Conflict Risks Around Critical Minerals
The document examines the implications of India's discovery of 5.9 million tons of lithium in Jammu and Kashmir, arguing that while it could bolster India's energy independence and EV goals, it risks exacerbating internal communal tensions and international conflict with Pakistan. It highlights environmental threats to the Chenab River watershed and suggests that the U.S. should promote global mining governance, technological alternatives like sodium-ion batteries, and demand-reduction policies to mitigate these risks.
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Document type: Briefing
Briefer: Russian Nuclear Weapons and Belarus—NATO Should Continue to Stand Steady
The briefing recommends that NATO avoid reactive expansions of its nuclear arsenal or mirroring Russia's suspension of the New START Treaty following Putin's announcement to operationalize tactical nuclear weapons in Belarus. The authors argue that NATO's current deterrence is sufficient and that overreacting would play into Russian narratives of NATO aggression. Key recommendations include continuing transparency regarding B61-12 deployment, prioritizing the reduction of tactical nuclear weapon risks, and strengthening crisis communication channels with Russia to prevent accidental escalation.
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Document type: Briefing
Decarbonising the Indian Steel Industry: Roadmap towards a Green Steel Economy
The document outlines a strategy for India to transition to a green steel economy, identifying five primary technical levers—green hydrogen, renewable electricity, CCUS, scrap usage, and energy efficiency—and six policy objectives to drive the transition through standards, procurement, R&D, and sustainable finance.
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Document type: Report
Climate priorities to watch for in Budget 2023
The Canadian Climate Institute identifies two primary priorities for Budget 2023: attracting clean investment to compete with the U.S. Inflation Reduction Act and expanding the national electricity system. The Institute recommends using carbon contracts for difference to leverage carbon pricing and implementing investment tax credits and 'electric federalism' to modernize electricity infrastructure.
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Document type: Statement
Les priorités environnementales à surveiller dans le budget 2023
The Canadian Climate Institute identifies two main priorities for the 2023 federal budget: attracting clean investment to compete with the US Inflation Reduction Act and expanding the electrical grid. It recommends using carbon contracts for difference instead of direct subsidies and implementing an 'electro-federalism' approach to coordinate grid improvements with provinces.
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Document type: Statement
Mobilizing private capital to support Canada’s clean growth
The Canadian Climate Institute recommends a strategic approach to clean growth that leverages limited public funds to attract private investment. Key proposals include fixing market failures, releasing carbon price schedules beyond 2030, implementing clear exit strategies for public support, and ensuring the Canada Growth Fund maintains political independence and promotes Indigenous majority ownership.
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Document type: Policy brief
Mobilisation de capitaux privés pour financer la croissance propre du Canada
The report recommends a strategic approach to clean growth in Canada, emphasizing the use of public funds to correct market failures rather than simply matching US subsidies. Key recommendations include extending the carbon pricing schedule beyond 2030, implementing carbon contracts for difference, and ensuring the Canada Growth Fund operates with political independence and a mandate for Indigenous-led projects.
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Document type: Report
Reducing methane emissions from B.C.’s oil and gas sector
The document argues that current British Columbia regulations are insufficient to meet 2025 methane reduction targets, as emissions are often underestimated and compliance is low. It recommends implementing more stringent standards by 2025, including the elimination of routine venting and flaring, lower tank emission limits, and monthly instrument-based leak detection and repair (LDAR). The coalition also urges the province to accelerate its target for near-zero methane emissions from 2035 to 2030, aligning with the Oil and Gas Climate Initiative (OGCI). Specific technical recommendations cover the adoption of zero-bleed pneumatic equipment, tighter standards for reciprocating and centrifugal compressors, and the implementation of a 'super emitter' response program based on third-party remote monitoring.
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Document type: Statement
CMW inputs on the grievance process in Article 6.4
Carbon Market Watch (CMW) argues that the Article 6.4 Supervisory Body must establish a robust, independent grievance mechanism before registering any carbon crediting projects to protect indigenous peoples and local communities. Drawing on a review by Perspectives Climate Research, CMW finds that most voluntary carbon market (VCM) standards—including Verra, American Carbon Registry, and Climate Action Reserve—have inadequate mechanisms, while the Global Carbon Council lacks one entirely. Only the Gold Standard and the Green Climate Fund's Independent Redress Mechanism are identified as high-quality models. CMW recommends that the Article 6.4 mechanism be fully independent, transparent, and accessible, featuring a public grievance repository and the power to overturn Supervisory Body decisions.
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Document type: Statement
CMW inputs on emission avoidance under Article 6.4, in response to the invitation for observer comments
Carbon Market Watch opposes the inclusion of emission avoidance in Article 6.4 and 6.2, warning that inconsistently defined avoidance activities could lead to the issuance of 'hot air' credits and potentially increase overall emissions.
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Document type: Statement
CMW inputs on removal activities in Article 6.4, in response to the invitation for observer comments
Carbon Market Watch (CMW) urges the Article 6.4 Supervisory Body to avoid shortcuts in developing recommendations for removal activities, emphasizing that temporary carbon storage should not be equated with permanent emission reductions. CMW argues that current forestry and land-use credits lack permanence, and that buffer pools are insufficient to manage reversal risks. The organization specifically opposes the inclusion of tonne-year accounting, claiming it creates a false equivalence between temporary storage and permanent removals, and criticizes the proposed definition of removals for including 'products' and 'processes' rather than focusing solely on outcomes.
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Document type: Statement
Comments on the White House Council on Environmental Quality Implementing Instructions for Executive Order 14057 Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability
The Clean Air Task Force, The NorthBridge Group, and Green Strategies, Inc. argue that current greenhouse gas accounting rules are outdated and fail to incentivize the diverse portfolio of carbon-free energy (CFE) resources needed for full grid decarbonization by 2035. They recommend adopting a 'bottom-up' book and claim approach for energy attribute certificates (EACs) to prevent double counting and suggest a 'Carbon Facts' label to track both attributional emissions (associated with electricity use) and consequential avoided emissions (actual carbon reductions). The authors specifically urge CEQ to define the 50% hourly match goal by 2030 as either a minimum of 50% CFE in every hour or a high annual average of at least 80% hourly time-matching to ensure the development of firm CFE and storage resources.
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Document type: Statement
Report on Development Finance and Human Rights
The document argues that development finance institutions (DFIs) often cause harm to communities and must strengthen Independent Accountability Mechanisms (IAMs) to provide effective remedy. It calls for DFIs without IAMs to create them through public consultation, urges DFI networks to mandate these mechanisms for membership, and asserts that States must facilitate access to remedy for DFI-funded projects.
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Document type: Statement