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The NewClimate Institute argues that while the second draft of the SBTi Automotive Net-Zero Standard shows improvement, it requires mandatory volume targets for procured materials and mandatory zero-emission vehicle (ZEV) sales share targets to prevent uneven ambition. It also recommends maintaining disaggregated ZEV sales targets by geography and vehicle type to avoid masking slow progress in specific markets.

ClientEarth argues that the MSFD has failed to achieve Good Environmental Status (GES) by its 2020 deadline and proposes a revision that turns GES into a binding 'obligation of result'. The response calls for clear, quantifiable EU-wide thresholds, the introduction of interim targets, and a strict non-deterioration obligation. It emphasizes the need for policy coherence between the MSFD and the proposed Ocean Act, as well as the alignment of fisheries management and climate obligations with marine protection. Furthermore, it advocates for dedicated funding streams and the introduction of robust compliance mechanisms, including access to justice, dissuasive penalties, and a right to compensation for damages resulting from breaches of the directive.

The submission argues that voluntary measures are insufficient for industrial decarbonisation and proposes a phased transition to mandatory embodied emissions reporting by 2029. It recommends a life-cycle assessment (LCA) based methodology, the integration of green procurement into Government Buying Standards, and a 'twin-track' expansion strategy prioritising construction-related sectors for immediate action while developing frameworks for complex sectors like chemicals.

Reclaim Finance criticizes the Net-Zero Asset Owner Alliance (AOA) for failing to align its Target Setting Protocol Version 4 (TSPV4) with UN High-Level Expert Group (HLEG) recommendations. The organization argues that the AOA allows members to use relative intensity metrics that can disguise absolute emission increases and fails to mandate Scope 3 targets for high-emitting sectors like oil and gas. Reclaim Finance calls for mandatory absolute targets, robust transition plans for asset owners, and a strict prohibition on investing in companies expanding coal, oil, and gas infrastructure. Additionally, it urges the AOA to define concrete escalation procedures for investor engagement and to adopt the updated September 2023 IEA Net Zero Roadmap.

Reclaim Finance argues that the proposed ISR label framework lacks sufficient guarantees for investors and requires stronger sectoral exclusions, particularly for unconventional fossil fuels and coal. The organization calls for the label to mandate alignment with a 1.5°C warming scenario, the use of specific scientific benchmarks for transition plans, and increased transparency in shareholder engagement and voting policies.

Reclaim Finance argues that the GFANZ consultation draft lacks sufficient rigor and clarity, specifically regarding 2030 emission reduction targets, the cessation of fossil fuel expansion, and the definition of net zero. The organization advocates for the adoption of Race to Zero (RTZ) criteria, including a 50% reduction in financed emissions by 2030 and the requirement for permanent carbon removals (at least 1,000 years) to neutralize residual emissions. Reclaim Finance further challenges the classification of fossil gas as a transition fuel and calls for more stringent accountability mechanisms, such as the exclusion of financial institutions from alliances if they fail to implement credible, RTZ-aligned transition plans.

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 welcomes the 8th Environment Action Programme's goals for a climate-neutral and circular economy but argues that the proposal lacks concrete targets and explicit commitments to phase out fossil fuel subsidies. The organization highlights discrepancies between the EAP's ambitions and existing policies like the Common Agricultural Policy and the European Maritime and Fisheries Fund. It calls for stronger monitoring based on scientific evidence, increased resources for DG Environment, and the integration of the rule of law and access to justice to ensure effective implementation.

ClientEarth argues that the UK government's proposed approach to retaining EU CO2 emission standards is insufficient and potentially weakens regulatory requirements. The organization urges the government to adjust the vehicle mass baseline (M0) to reflect UK averages, reduce sales volume derogation thresholds, and introduce a binding zero exhaust emission vehicle (ZEEV) mandate to phase out petrol, diesel, and hybrid vehicles by 2030.

Carbon Market Watch criticizes the proposed Green Claims Directive (GCD) for allowing the continued use of carbon neutrality and offsetting claims, which the organization asserts are inherently misleading due to quantification uncertainties, low carbon credit quality, and consumer misunderstanding. The response argues that the GCD's substantiation rules are too weak to prevent greenwashing and that the directive lacks clear definitions for 'significant' environmental impacts and specific requirements for future performance claims.

Sandbag argues that a standalone UK ETS would be dysfunctional due to its small size and vulnerability to volatility and speculation. The organization recommends that the UK either remain part of the EU ETS or implement a carbon tax with a floor based on the average EU ETS price. Key proposals include expanding carbon pricing to fossil gas and fugitive methane, ending the zero-emissions treatment of large-scale biomass burning, and distributing carbon revenues to citizens as a 'climate dividend'.

Reclaim Finance responds to the Bank of England's consultation on the Corporate Bond Purchase Scheme (CBPS), urging the Bank to prioritize the exclusion and divestment of fossil fuel assets to mitigate climate-related financial risks. The organization argues that engagement is often ineffective for high-carbon companies and recommends that the Bank set ambitious, short-term portfolio targets, integrate scope 3 emissions, and implement a heavy negative tilt strategy. Reclaim Finance further suggests that the Bank should lead the market in climate risk management by increasing capital requirements for fossil fuel exposures and expanding its environmental focus to include nature-related financial risks.