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Taxonomie 101
The document outlines a four-phase framework for sustainable finance taxonomies: governance, design, implementation, and expansion/revision. It emphasizes 'interoperability'—the ability of different taxonomies to share common principles and scientific bases, such as the Paris Agreement, to facilitate cross-border financial flows. The guide details the creation of technical selection criteria (TSC), the integration of transition activities using 'binary' or 'traffic-light' approaches, and the application of 'Do No Significant Harm' (DNSH) and Minimum Social Safeguards (MSS) principles. It also provides a step-by-step alignment guide for activities, entities, and portfolios, while offering strategies to make taxonomies accessible to small and medium-sized enterprises (SMEs).
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Document type: Guide
Open Letter - Gas Attack in Taxonomy
A coalition of 226 scientists, financial professionals, and civil society organizations argues that including fossil gas in the EU Taxonomy contradicts climate science and risks turning the framework into a greenwashing tool. The authors highlight the high climate impact of methane leaks and assert that such a move would undermine the EU's global climate leadership and the goals of the Green Deal.
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Document type: Statement
Making ambition enforceable: Enshrining NDCs 3.0 into Framework Climate Laws
ClientEarth advocates for the implementation of comprehensive framework climate laws (FCLs) to bridge the gap between political ambition in NDCs and domestic action. The brief highlights that current climate commitments are insufficient, with a projected temperature rise of 2.4°C to 2.6°C even if existing NDCs are met. It calls on countries to submit science-driven NDCs by February 2025 and to enshrine these in binding national laws by COP30. The document also details recent international legal precedents from the ICJ, ITLOS, and ECHR that strengthen the legal obligations of states to protect human rights and the environment from climate harm.
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Document type: Policy brief
Using the power of the law to respond to the climate crises
The report advocates for the use of legal frameworks to bridge the gap between climate ambition and action following the COP28 Global Stocktake. It calls for the enactment of comprehensive national framework climate laws by COP30, the operationalisation of the loss and damage fund with a human rights focus, and a legally mandated phase-out of fossil fuels. ClientEarth emphasizes the role of international courts in clarifying state obligations and suggests adopting demand-reduction strategies for fossil fuels similar to the WHO Framework Convention on Tobacco Control to combat greenwashing.
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Document type: Report
Misalignment of EMFAF Operational Programmes with EU Environmental and Social Objectives (2021–2027)
The document argues that EMFAF funds are being used in ways that contradict EU environmental goals and international obligations, specifically by underfunding marine biodiversity and failing to prioritise small-scale fisheries. It highlights a systemic gap where 5–12% of funds are allocated to environmentally harmful subsidies, exceeding biodiversity spending by more than twofold. Analysis of several Member States shows that most fall far below a recommended 25% allocation for conservation and restoration. The brief also warns that proposed changes to the next Multiannual Financial Framework (MFF) risk further diluting these priorities by removing the EMFAF as a stand-alone fund and lacking mandatory spending targets for biodiversity and the decarbonisation of the fishing fleet.
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Document type: Policy brief
Intervention Update
The document asserts that climate change and the net zero-carbon transition create material financial risks for all UK listed companies, making detailed disclosure a legal necessity. It claims that the Financial Reporting Council (FRC) and Financial Conduct Authority (FCA) have failed to hold companies accountable, citing a series of complaints made by ClientEarth where regulators took no public enforcement action despite evidence of non-compliance. The report urges regulators to close this 'accountability gap' and encourages institutional investors to use their power to demand TCFD-aligned disclosures.
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Document type: Report
Written submission by GCHA to the First Conference on Transitioning Away from Fossil Fuels
The GCHA argues that the transition away from fossil fuels is hindered by structural barriers, including economic dependence, infrastructure lock-in, subsidies, and industry lobbying. To address these, the GCHA proposes three primary solutions: implementing health cost accounting to reveal the true economic burden of fossil fuels, redirecting fossil fuel subsidies toward clean energy and public health, and banning fossil fuel marketing and sponsorships. The submission emphasizes that air pollution from fossil fuels causes approximately 5.3 million premature deaths annually and cost the global economy US$2.9 trillion in 2018.
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Document type: Statement
Do berço ao túmulo
The report 'Do berço ao túmulo' (From Cradle to Grave) by the Global Climate and Health Alliance details how fossil fuels cause systemic health damage at every stage of their life cycle. It highlights the disproportionate burden on marginalized communities and the 'sacrifice zones' created by industrial pollution. The document argues that the current energy system creates a 'triple crisis' of environmental devastation, widespread human health impairment, and instability in health systems. It calls for a just transition that prioritizes public health, eliminates fossil fuel subsidies, and holds polluters accountable through the 'polluter pays' principle.
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Document type: Report
De la cuna a la tumba
The report 'De la cuna a la tumba' (From Cradle to Grave) details how fossil fuel production and use cause systemic health damage across all human life stages, from fetal development to old age. It highlights the disproportionate burden on marginalized communities and indigenous peoples, who often live in 'sacrifice zones.' The document maps specific health risks associated with extraction, refining, transport, and combustion, while also addressing the social disruptions and human rights violations linked to the industry. It concludes with a set of policy recommendations to end fossil fuel exploration, eliminate subsidies, and internalize health costs under the 'polluter pays' principle to achieve a just energy transition.
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Document type: Report
Fueling the Transition: Categorizing emissions-reducing oil and gas projects according to Canada’s climate investment taxonomy
The Canadian Climate Institute outlines criteria to ensure oil and gas projects eligible for a 'transition' label align with 1.5°C pathways. The proposed framework requires projects to be part of existing facilities, demonstrate significant Scope 1 and 2 emissions reductions against sectoral benchmarks, and ensure upstream Scope 3 suppliers are also aligned with 1.5°C pathways. It specifically excludes new oil and gas developments to prevent carbon lock-in and stranded asset risks.
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Document type: Report
La catégorisation des projets pétrogaziers selon la taxonomie des investissements climatiques du Canada, gage d’une transition harmonieuse
The Canadian Climate Institute outlines a proposed framework to integrate oil and gas projects into the Sustainable Finance Action Council's (SFAC) climate investment taxonomy. To maintain scientific credibility and avoid 'greenwashing,' the report argues that only decarbonization projects within existing facilities should be eligible for the 'transition' label. It proposes a three-step eligibility process: general corporate requirements (net-zero targets), project-specific requirements (existing facility status and emission intensity alignment with 1.5°C pathways), and 'do no significant harm' criteria. A key proposal is a 50% threshold for downstream Scope 3 emissions to identify projects where demand-side risk is the primary transition risk. The report emphasizes that new oil and gas installations must be excluded to prevent carbon lock-in and align with global net-zero goals.
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Document type: Report
Carbon Finance
The document provides a comprehensive overview of carbon finance, detailing instruments such as carbon taxes, credits, and cap-and-trade systems. It analyzes the operational requirements for implementing these mechanisms, the differences between shallow and mature markets, and the specific impacts on sectors like industrial decarbonization and AFOLU. The briefing also highlights the role of the EU ETS and CBAM, as well as the challenges related to monitoring, reporting, and verification (MRV) and the policy uncertainty surrounding Article 6 of the Paris Agreement.
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Document type: Briefing
Carbon Market Watch’s Submission to India’s Central Consumer Protection Authority request for public comment on its draft guidelines to combat greenwashing
Carbon Market Watch argues that the Central Consumer Protection Authority should explicitly ban "carbon neutral" and offsetting claims rather than merely requiring their substantiation. The organization contends that offsetting is fundamentally flawed due to quantification uncertainties, lack of permanence in biological sinks, and consumer misunderstanding. Instead, it proposes a "contribution" or "beyond value chain mitigation" (BVCM) model. The submission also recommends stricter requirements for future climate targets, including science-based commitments, full scope 1, 2, and 3 emissions disclosure, and alignment of corporate lobbying with the Paris Agreement.
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Document type: Statement
Carbon Market Watch response to the UN High-level expert group on net zero
Carbon Market Watch argues that current corporate net-zero claims are often vague and lack sufficient action, frequently excluding scope 3 emissions and relying excessively on offsets. The organization proposes a rigorous framework for net-zero targets that requires full-scope emission coverage, absolute reduction targets, and transparency regarding lobbying activities. It suggests that the UN facilitate a standardized global repository for reporting and advocates for a transition from voluntary actions to strict international and national regulations to prevent greenwashing.
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Document type: Statement
RACE AGAINST THE CLIMATE CLOCK
The Corporate Climate Responsibility Monitor (CCRM) 2025 finds that corporate climate action is frequently treated as a marketing exercise rather than a business model redesign. While some companies like Inditex and Adidas have improved their target setting, the report highlights widespread 'creative accounting' and greenwashing. Key issues include the use of unbundled Renewable Energy Certificates (RECs) in tech and fashion, the conflation of land-based carbon removals with emission reductions in agrifood, and the use of unsubstantiated carbon credits to claim carbon neutrality. The document argues that voluntary standards are insufficient and calls for stringent government regulation, specifically citing EU directives like the CSRD and CSDDD, to mandate transparent reporting and ban product-level carbon neutral claims.
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Document type: Report
CRCF background information
The briefing examines the EU's Carbon Removals Certification Framework (CRCF), specifically criticizing the Delegated Act for permanent removals. It argues that the current methodologies for Direct Air Capture with Storage (DACCS), Biomass with capture and storage (BioCCS), and Biochar fail to account for environmental knock-on effects, lack proper monitoring and liability, and breach the 'Do No Significant Harm' principle. The author warns that these flaws could lead to certified activities increasing atmospheric emissions and undermine the EU's path to climate neutrality, potentially exposing buyers to greenwashing accusations if integrated into the EU Emission Trading System or voluntary markets.
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Document type: Briefing
人と気候の両方に役立つ、公平で効果的な 排出量取引制度の重要なポイント
The report by Carbon Market Watch outlines a framework for 'carbon pricing done right,' arguing that such systems must be integrated into broader policy packages and based on strict emission caps to be effective. It emphasizes the 'polluter pays principle,' warning against free allocations and offsets, which it claims can weaken price signals and lead to greenwashing. The document advocates for transparency, the reinvestment of revenues into climate action and vulnerable communities, and a cautious approach to carbon leakage and border adjustment mechanisms to avoid protectionism while ensuring climate justice.
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Document type: Report
Carbon Market Watch’s Submission to the Federal Trade Commission’s (FTC) request for public comment on potential revision of its “Green Guides”
Carbon Market Watch argues that the FTC's 'Green Guides' are outdated and fail to align with the Paris Agreement's 1.5C goal. The submission recommends a total ban on claims such as 'carbon neutral' and 'net zero' because they falsely imply that emissions can be 'neutralised' through carbon credits, which the author describes as scientifically unsound. Instead, the document proposes a 'contribution' model where companies fund mitigation projects without claiming to offset their own emissions. It also suggests that the Guides be made enforceable under the FTC Act to provide oversight of the voluntary carbon market and protect consumers from greenwashing.
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Document type: Statement
Green Claims Directive: Open Consultation
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.
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Document type: Statement
시민과 기후를 위해 작동하는 공정하고 효과적인 배출권거래제(ETS)의 핵심 요소
The report by Carbon Market Watch provides a framework for implementing 'right' carbon pricing, arguing that such systems must be integrated into a broader policy mix, feature declining emission caps, and avoid loopholes like free allocations and carbon offsets. It emphasizes the need for transparency, the reinvestment of revenues into climate action and vulnerable communities, and the use of carbon border adjustments to prevent leakage while maintaining equity.
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Document type: Report