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The document evaluates the 2013 Common Fisheries Policy (CFP), noting that while the share of stocks exploited at or below Maximum Sustainable Yield (MSY) rose from 50% in 2014 to 63% in 2022, environmental and socio-economic progress remains uneven. It highlights a disparity in the fishing fleet where small-scale coastal fisheries saw net profits grow by 131.9% between 2013 and 2023, while large-scale and distant water fisheries saw profits fall by 244.5% and 90.6% respectively, despite receiving significantly higher operating subsidies. The authors argue that current failures are due to implementation gaps rather than framework flaws, calling for the prohibition of capacity-enhancing subsidies, the protection of 30% of EU seas via a proposed European Ocean Act, and a shift toward low-impact, decarbonised fishing gear.

The report advocates for a 'New Security Agenda' that treats clean energy and ecosystem health as critical national security infrastructure. It argues that breaching planetary boundaries and relying on volatile fossil fuel markets create systemic risks to food security, public health, and economic stability. The authors call for binding legislative measures to phase out fossil fuels, the adoption of national restoration plans for biodiversity, and the alignment of public budgets to eliminate environmentally harmful subsidies.

The document analyzes the CSDDD's environmental scope, due diligence obligations, and enforcement mechanisms following the Omnibus I Directive amendments. It argues that the current scope is too narrow, particularly regarding downstream activities and climate transition plans, and recommends that Member States use their transposition discretion to strengthen environmental protections, ensure a comprehensive definition of environmental impacts, and establish robust civil liability and administrative enforcement regimes.

A coalition of European and international organisations calls on the EU leadership to launch an independent report to end fossil fuel dependence. The proposed report would quantify the economic burden of fossil fuels, chart a competitive phase-out pathway using proven technologies, align financial subsidies with the exit, ensure a just transition for workers and vulnerable households, and prioritise nature-based solutions for climate action.

ClientEarth argues that the SEAC draft opinion on Cr(VI) restriction is based on systemic information gaps and biased evidence, failing to prove that a restriction would better promote substitution or reduce risks than the current authorisation process. The organization urges SEAC to stay its opinion until a robust dossier is provided, suggesting that a ban with transition periods would be a more proportionate and effective risk management measure.

ClientEarth argues that CSDDD guidelines must explicitly include greenhouse gas emissions under 'harmful emissions' and adopt a risk-based approach to environmental due diligence. The submission recommends a strict hierarchy for remediation—prioritising prevention and restoration over offsetting—and suggests the creation of industry-funded remediation funds to address complex value chain harms.

ClientEarth argues that the European Commission's proposed revision of the EMFAF lacks a necessary Impact Assessment and fails to address the misalignment of public resources. The organization recommends the full transposition of WTO fisheries subsidy prohibitions into EU law, specifically by strengthening inadmissibility criteria for funding. It advocates for a strategic reallocation of funds toward small-scale, low-impact fisheries, which it describes as more economically resilient and employment-efficient than industrial fleets. Additionally, ClientEarth calls for a binding minimum of 25% of national envelopes to be dedicated to biodiversity restoration and the removal of fossil fuel tax exemptions for the fishing sector to support a genuine energy transition.

The study concludes that an EU prohibition on deep-sea minerals is legally feasible under Article 192(1) TFEU and potentially justifiable under WTO law via Article XX GATT, provided the measure is comprehensive, non-discriminatory, and grounded in the precautionary principle.

ClientEarth responds to the European Commission's Call for Evidence regarding a potential Fisheries Omnibus on Multiannual Plans (MAPs). The organisation argues that the priority should be the effective implementation and enforcement of existing tools rather than the deletion or weakening of key safeguards, such as the provisions on most vulnerable stocks (MVS) in the Western Mediterranean MAP and the 5% rule in the Northern MAPs. It asserts that failing to rebuild depleted stocks perpetuates 'choke risks' and that the only sustainable solution is to prioritise the recovery of stocks below sustainable levels. The document also suggests that the upcoming EU Ocean Act and the revision of the Multiannual Financial Framework (MFF) should be used to strengthen coherence in ocean policies and redirect harmful subsidies toward climate and biodiversity targets.

The report examines the legal and administrative challenges of removing obsolete river barriers in Poland, Finland, and France. It finds that while France employs a systemic approach with prioritised lists and dedicated funding, Poland lacks a comprehensive registry and effective enforcement of removal obligations. Finland relies heavily on voluntary cooperation and funding through the NOUSU program but struggles with the permanence of water permits. The document recommends that Member States adopt systemic policies, maintain field-verified barrier registries, establish clear prioritisation criteria for 'obsolete barriers', and create inclusive funding schemes to meet EU nature restoration targets.

The report finds that the UK lacks a robust system for publicly identifying the ultimate beneficial ownership of commercial fishing vessels, with UBO easily identifiable in only 24% of sampled vessels. It argues that current vessel registration and licensing processes do not require UBO disclosure, and the Companies House 'People with Significant Control' (PSC) register is often insufficient due to high ownership thresholds and the use of foreign corporate structures. To combat illegal, unreported and unregulated (IUU) fishing, the report recommends reducing the UBO disclosure threshold to 10% or less, mandating UBO collection during registration and licensing, and establishing a centralised, publicly accessible UBO register for commercial fishing vessels.

The document argues that TotalEnergies SE has misled investors by claiming alignment with the Paris Agreement while continuing to increase fossil fuel production. It highlights the systemic financial risk climate change poses to global portfolios and asserts that TotalEnergies' disclosures—including claims about the role of natural gas as a transition fuel and the 'substitution' argument for continued extraction—are inaccurate. The authors call for an AMF investigation into potential breaches of the AMF General Regulations, the European Market Abuse Regulation (MAR), and the French Monetary and Financial Code.

The letter argues that high-emitting companies, particularly 'Carbon Majors' like TotalEnergies, provide misleading information to investors regarding their alignment with the Paris Agreement while continuing to expand fossil fuel production. It asserts that climate change poses a systemic financial risk, with potential GDP losses of 50% by 2070-2090, and that current economic models underestimate these damages by ignoring tipping points. The authors highlight a 2025 Paris Judicial Court ruling that TotalEnergies misled consumers and call for ESMA to encourage national authorities to take enforcement action against investor-facing greenwashing to protect market integrity.

ClientEarth, Amis de la Terre France, and Notre Affaire à Tous allege that TotalEnergies SE has misled investors by claiming alignment with the Paris Agreement while continuing to increase fossil fuel production. The report argues that such misinformation obscures systemic financial risks, as climate change threatens global economic stability and asset valuations. It specifically challenges the company's claims regarding the role of natural gas as a 'transition energy' and its 'net zero' ambitions, citing a 2025 Paris court ruling that found the company's consumer communications to be misleading.

ClientEarth warns FMCG companies that relying on recycling is insufficient to mitigate legal risks and urges a shift toward upstream plastic reduction. The document details risks from mandatory due diligence laws, product liability for health harms, and anti-greenwashing enforcement, specifically targeting misleading 'recyclable' claims. It also highlights the impact of the EU's Corporate Sustainability Reporting Directive (CSRD) on plastic-related disclosures.

ClientEarth argues that the European fashion industry must advocate for the inclusion of leather in the EU Deforestation Regulation (EUDR) to ensure supply chains are free from illegal deforestation and human rights abuses. The letter challenges industry claims that leather is a harmless by-product or that traceability is impossible, noting that Brazil generates over US$1.1 billion annually in leather exports and that several major exporting nations already possess compatible traceability systems. It warns brands that failing to support the EUDR leaves them exposed to legal and reputational risks as consumers increasingly demand deforestation-free products.

The document argues that the DNSH principle should be a binding eligibility requirement for EU funding rather than a general guideline, ensuring that no activity funded by the EU budget causes significant harm to any of the six environmental objectives. It calls for a strict interpretation of derogations, the creation of an explicit exclusion list—specifically including fossil fuels—and the implementation of transparent, independent assessment procedures to prevent the 'watering down' of environmental standards.

ClientEarth opposes the revision of the Water Framework Directive (WFD), arguing that current evidence supports full implementation over legislative changes. The organization warns that weakening the WFD would undermine legal certainty, jeopardize freshwater ecosystems, and shift economic costs from polluters to society. It specifically highlights risks from the mining sector and argues that the current revision process fails to comply with the European Commission's Better Regulation Guidelines.

ClientEarth argues that the JRC's preparatory study for textile ecodesign criteria under the ESPR is insufficient. The organization advocates for full alignment with REACH for reporting Substances of Very High Concern (SVHCs), the inclusion of all substances with harmonised classification and labelling (CLH), and the removal of exemptions for process chemicals. It further contends that the JRC has failed to implement legal requirements to reduce 'significant risks' to health and the environment and has overlooked the need for performance restrictions based on circularity concerns, such as the use of phthalates.

Centrica plc denies allegations from ClientEarth that it is suppressing heat pump adoption, asserting its role as a major UK provider with a target of 20,000 annual sales by 2030. The company defends its historical involvement in hydrogen campaigns and rejects claims of anti-competitive behavior, while highlighting its commitment to net zero targets for operations by 2040 and customers by 2050.