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Biogas Policies in the EU: Levelling up or locking in?
The briefing argues that the EU's RePowerEU target to produce 35 billion m3 of biomethane by 2030 lacks an environmental impact assessment, creating risks of methane leakage and the intensification of industrial livestock farming. It finds that no existing EU policy sufficiently mitigates the environmental and social impacts of the sector, and that financial frameworks may channel over €37 billion into projects without robust sustainability checks. The report highlights a systemic issue with methane leaks, noting that real-world losses may be higher than official estimates, and warns that using biomethane to maintain existing gas grids could delay the phase-out of fossil fuels.
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Document type: Briefing
Fishing for Catastrophe
The document argues that the aquaculture industry's dependence on wild-caught fish for feed is ecologically and financially unsustainable, exposing investors and retailers to systemic resource risks, price volatility, and reputational damage. It highlights links between major European aquafeed producers and destructive fishing practices in India, Vietnam, and The Gambia, while asserting that current certification schemes, specifically those from the Marine Ingredients Organisation (IFFO), are ineffective 'smokescreens'.
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Document type: Briefing
WHY THE FOOD INDUSTRY AND REGULATORS NEED TO WAKE UP TO THE ACRYLAMIDE CRISIS
The policy brief critiques the European Commission's proposed approach to reducing acrylamide—a probable carcinogen—in food, arguing that voluntary industry measures have failed. It advocates for the transition from 'indicative values' to legally binding maximum levels and a shift from industry self-monitoring to rigorous oversight by national Food Safety Agencies.
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Document type: Policy brief
Biogas in the EU: A policy and financial analysis
The European Union is the global leader in biogas production, reaching 22.8 billion m3 in 2024. While promoted as a renewable energy source, the report argues that the sector risks causing significant environmental harm through methane leakages, the incentivisation of industrial animal farming, and the use of food crops as feedstock. It further contends that the injection of biomethane into existing gas grids may postpone the transition to truly sustainable energy systems by locking in fossil gas infrastructure. The report examines the policy landscapes of seven European countries, noting that while most support biogas expansion, regulatory safeguards against these environmental risks are often insufficient. It also details the role of major oil, gas, utility, and agri-food companies in the sector and identifies the primary financial institutions providing credit and investment to biogas producers.
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Document type: Report
Open Letter to the European Commission Revision of Annex V and VI of the Renewable Energy Directive (Directive (EU) 2023/2413, RED III): Ensuring Accurate Greenhouse Gas Accounting for Manure-Based Biogas and Biomethane
The authors argue that the current RED III methodology over-credits manure-based biomethane by using unrealistic baseline assumptions for manure management and incorrectly treating manure as a zero-emission waste feedstock. They call for a revision of the default avoided-emissions credit and a reassessment of system boundaries to include upstream livestock emissions.
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Document type: Statement
ACRYLAMIDE LEVELS IN FOOD: PASSING THE HOT POTATO
The report analyzes EFSA data from 2007-2014, finding that acrylamide levels in many European foods remain unchanged or are increasing despite voluntary industry 'toolboxes'. It highlights significant benchmark exceedances in baby foods and specific products in Belgium and Denmark, concluding that the European Commission's proposal to mandate codes of practice without setting enforceable legal limits is insufficient to protect consumers.
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Document type: Report
Hasta que los mares se sequen
The report examines the industrial aquaculture sector's dependence on fishmeal and fish oil (FMFO), highlighting how the extraction of forage fish disrupts marine food webs and undermines food security in vulnerable coastal regions. It criticizes the lack of transparency in supply chains and the inadequacy of current certification schemes, while calling for a transition toward herbivorous species and alternative proteins to protect ocean health.
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Document type: Executive summary
Declaração sobre Resíduos Contendo Nanomateriais
The document argues that the increasing use of manufactured nanomaterials (MNMs) in consumer and industrial products creates significant risks in the waste stream due to unknown toxicity and difficulties in characterization. It demands that governments and companies implement extended producer responsibility, restrict the transboundary movement of MNM waste, and establish public registries of nano-products, particularly within the European Union, to ensure safe recycling and disposal.
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Document type: Statement
Declaración sobre residuos que contienen nanomateriales
The document argues that manufactured nanomaterials (NM) in waste streams pose risks to health and the environment due to incomplete toxicity understanding. It demands the implementation of extended producer responsibility, restrictions on transboundary movements of NM waste, and the creation of a public registry of nano-products in the EU to ensure transparent quantification of waste flows. Additionally, it advocates for public funding of research into waste prevention and the development of safe recycling and disposal technologies that prevent cross-contamination of secondary materials.
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Document type: Statement
Human Rights Impacts of DecaBDE Pollution on People
The report details how decaBDE, used in plastics and textiles, acts as an endocrine disruptor and neurotoxin, disproportionately affecting children and workers. It frames these health risks as violations of international covenants, such as the ICCPR and CESCR, and calls for a global ban under the Stockholm Convention.
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Document type: Report
The LRTAP POPs Protocol and its Relevance to the Global POPs Negotiations
The document assesses the Protocol to the Convention on Long-Range Transboundary Air Pollution on Persistent Organic Pollutants (LRTAP POPs Protocol) against the needs of global negotiations. It argues that while the Protocol is a useful first step, it is an inadequate model for a global treaty because it focuses on risk management and emission control rather than total elimination, lacks provisions for developing countries, and relies on a regional framework of developed nations.
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Document type: Briefing
Déclaration sur les déchets contenant des nanomatériaux
The document argues that the increasing use of manufactured nanomaterials (MNMs) in consumer, industrial, and medical products is leading to their proliferation in waste streams, posing risks to human health and the environment that are not yet fully understood. Signatories demand that governments and companies implement extended producer responsibility, restrict the transboundary movement of MNM waste, and establish a public registry of nano-products in Europe to ensure transparency. The statement also advocates for the development of safe recycling technologies and the integration of waste prevention into publicly funded nanotechnology research to support a safe circular economy.
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Document type: Statement
Declaration on Waste Containing Nanomaterials
The Declaration on Waste Containing Nanomaterials argues that the increasing presence of manufactured nanomaterials (MNMs) in waste streams poses risks to human health and the environment due to uncertainties regarding their toxicity. The signatories call for the implementation of full producer responsibility, the restriction of transboundary waste movements, and the creation of an EU-wide public nano-product registry to ensure transparent quantification of waste flows. They further advocate for innovation in waste prevention, the development of safe recycling and disposal technologies, and the establishment of verifiable end-of-waste criteria to support a circular economy without introducing new environmental risks.
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Document type: Statement
The Public Participation Convention and Export Credit Agencies
The document examines the three pillars of the Public Participation Convention—access to information, access to decision-making, and access to justice—and argues that export credit agencies, as government agencies, should be subject to these transparency and accountability requirements. It notes that while the Convention is not yet in force, signatories are obligated not to act contrary to its purpose. The paper also discusses the Convention's limited direct application to multilateral development banks and its weak compliance review mechanisms.
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Document type: Research paper
JOINT SUBMISSION FROM THE CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL), THE INTERNATIONAL INSTITUTE FOR SUSTAINABLE INVESTMENT (IISD), AND CLIENTEARTH ON THE CALL FOR INPUTS FROM THE SPECIAL RAPPORTEUR ON HUMAN RIGHTS AND THE ENVIRONMENT INVESTOR-STATE DISPUTE SETTLEMENT (ISDS) MECHANISMS AND THE RIGHT TO A CLEAN, HEALTHY, AND SUSTAINABLE ENVIRONMENT
The document examines the negative impacts of ISDS on environmental and climate policy, noting that at least 175 cases are tied to environmental measures. It argues that the threat of arbitration disincentivizes states from enacting climate laws and that current treaty reforms are insufficient, suggesting that treaty termination and a shift toward domestic courts are the most effective solutions.
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Document type: Statement
Repurposing EU Subsidies for an Effective Agrifood System Transition to Net Zero
The report highlights a significant gap between current EU agricultural emissions trends and the 2030 and 2050 climate targets. It identifies the absence of agriculture from the EU Taxonomy as a major barrier to defining sustainable activities. The author proposes repurposing the CAP, which accounts for approximately 30% of the EU budget, to fund a transition that requires an estimated annual public investment of EUR 155bn to reduce emissions by 53% by 2050. Key recommendations include adopting science-based sectoral criteria, reforming payment structures to reward green practices, and potentially extending the Carbon Border Adjustment Mechanism (CBAM) to agrifood products to prevent carbon leakage.
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Document type: Report
ClientEarth Guide on access to justice
The document analyzes the legal mechanisms for accessing justice in environmental matters within the European Union, structured around the three pillars of the Aarhus Convention: access to environmental information, public participation in decision-making, and access to justice for breaches of environmental law. It details the scope of review, standing requirements for individuals and NGOs, and the standards of judicial scrutiny required to ensure effective legal protection. The guide specifically highlights the disparities in implementation across Member States and the restrictive nature of judicial review for decisions made by EU institutions.
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Document type: Guide
ClientEarth’s feedback to the Offshore Renewable Energy Strategy Roadmap
ClientEarth's feedback on the EU's Offshore Renewable Energy Strategy emphasizes the need for high environmental standards, public transparency, and regional cooperation. It argues that the strategy must adhere to the 'do no harm' principle and the precautionary principle, ensuring that the deployment of offshore wind and other ocean energies does not compromise biodiversity or ignore the rights of public participation under the Aarhus Convention. The document suggests a regional approach to grid development and targeted financial support for technologies that have not yet reached grid parity, such as wave energy.
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Document type: Statement
Access to documents and environmental information held by EU institutions and bodies
The document outlines the legal framework and practical procedures for requesting information from EU institutions, specifically contrasting general access under Regulation 1049/2001 with the broader rights for environmental information under the Aarhus Convention and Regulation 1367/2006. It details the application process, the timelines for institutional responses, the mechanisms for challenging refusals—including the European Ombudsman and the General Court—and the specific legal exceptions institutions may invoke to withhold information.
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Document type: Guide
Access to documents and environmental information held by EU institutions and bodies
The document outlines the procedures for requesting information from EU institutions under Regulation 1049/2001 and the Aarhus Convention. It explains the broader definition of 'environmental information' under EU law, the specific obligations of institutions to provide access, and the various exceptions they may invoke to refuse requests. It further guides users through the process of making initial and confirmatory applications, and the legal avenues available for challenging denials, including the European Ombudsman and the General Court.
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Document type: Guide