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ClientEarth has issued a letter to the Global Public Policy Committee (GPPC) detailing the GPPC's stance on climate-related financial reporting. ClientEarth argues that most companies on the Climate Action 100+ (CA100+) focus list and their auditors fail to fully consider or explain climate-related matters in financial statements. While the GPPC maintains that its member networks (including the 'Big Four') comply with existing standards and that reporting has improved since 2020, ClientEarth disputes these claims and calls for greater transparency and reform of accounting and audit standards to better reflect material climate risks.

The report examines the legal friction between the EU's Common Fisheries Policy (CFP) and the proposed Nature Restoration Law (NRL). It argues that the CFP's Article 11 'joint recommendation' process—used to protect marine areas from fishing—is plagued by delays, a de facto veto for fishing states, and a lack of accountability, which risks undermining the binding restoration targets of the NRL. The author proposes that the NRL be drafted with specific triggers and deadlines to force the CFP process forward and recommends that the European Commission take a more active role as a facilitator and mediator to prevent the watering down of environmental protections.

The document details the transition from the EU Timber Regulation (EUTR) to the new EU Deforestation Regulation, specifying that Member States must designate competent authorities with adequate powers, functional independence, and resources within six months of the Regulation's entry into force. It further describes the necessity of establishing effective, proportionate, and dissuasive sanctions—including fines of at least 4% of annual EU turnover—and the requirement to implement annual risk-based compliance plans and customs controls within 18 months.

The EU Deforestation-free Products Regulation imposes significant new obligations on EU Member States to ensure products consumed in the EU do not contribute to global deforestation. Member States must designate competent authorities within six months that possess adequate powers, functional independence, and resources. Within 18 months, they must establish national penalty rules that are effective, proportionate, and dissuasive, including fines of at least 4% of annual Union-wide turnover. The Regulation also requires the creation of annual risk-based compliance check plans and enhanced coordination between competent and customs authorities.

The revised General Block Exemption Regulation (GBER), approved on 9 March 2023 and applicable until the end of 2026, allows EU Member States to grant State aid for green transition projects without prior European Commission notification if specific conditions are met. While it introduces new support for clean mobility, biodiversity restoration, and renewable energy communities, it also maintains loopholes for fossil gas through high-efficiency cogeneration, gas-fired district heating, and carbon capture, use and storage (CCUS). The regulation significantly raises financial notification thresholds and aid intensity rates to accelerate the Green Deal Industrial Plan, though it lacks an explicit 'energy efficiency first' principle and faces criticism for poor transparency in aid reporting.

ClientEarth has filed a legal complaint with the US National Contact Point alleging that Cargill's due diligence processes in Brazil are insufficient to prevent deforestation and human rights abuses. The complaint highlights failures in monitoring soy sourced from the Cerrado and Atlantic Forest, as well as issues with indirect land use change and the displacement of Indigenous Peoples. While Cargill has committed to being deforestation-free in the Amazon and Cerrado by 2025, ClientEarth argues these policies lack necessary commitments to be 'conversion free' and fail to address the systemic risks associated with its vast operations in Brazil.

The document argues that the EU fisheries sector must shift away from carbon-intensive, high-impact fishing to meet the goals of the European Green Deal and the European Climate Law. It recommends a comprehensive approach including the creation of national emission-reduction roadmaps, the transition from active mobile bottom-contacting gears to passive techniques, and the elimination of fossil fuel subsidies. The brief emphasizes the need to quantify all greenhouse gas emissions, including those from seabed disturbance and the removal of fish biomass, and suggests integrating fisheries into the EU Emission Trading System (ETS). It also advocates for fairer funding access for small-scale coastal fisheries and the use of ecosystem-based fisheries management to protect 'blue carbon' habitats.

ClientEarth has filed a complaint with the OECD against Cargill, arguing that the company's due diligence fails to address deforestation and human rights abuses in Brazil. The document details specific allegations regarding the Cerrado, Amazon, and Atlantic Forest biomes, and calls for the full disclosure and implementation of effective environmental and human rights policies.

ClientEarth has filed a complaint with the US National Contact Point (NCP) of the OECD against Cargill, arguing that the company's due diligence processes violate OECD Guidelines. The complaint focuses on Cargill's soy supply chain in Brazil, specifically alleging failures to monitor deforestation in the Cerrado and Atlantic Forest, a lack of traceability for indirectly sourced soy, and a failure to address indirect land-use change. Additionally, the complaint highlights risks of human rights violations against Indigenous peoples and quilombolas. ClientEarth is seeking the full disclosure of Cargill's due diligence policies and the implementation of more effective procedures aligned with OECD-FAO and UN guidance.

ClientEarth has filed a complaint with the US National Contact Point for the OECD, alleging that Cargill fails to conduct adequate due diligence to prevent deforestation and human rights abuses in its Brazilian soy supply chains. The complaint highlights specific failures regarding the Cerrado and Atlantic Forest biomes, indirectly sourced soy, non-owned soy handled at Cargill ports, and indirect land use change. ClientEarth seeks full disclosure of Cargill's policies and the adoption of effective due diligence measures aligned with OECD-FAO and UN guidance.

The report argues that the EU's Restrictions Roadmap is failing to meet its ambition of creating a 'non-toxic environment' due to narrow chemical grouping, excessive industry derogations, and systemic regulatory delays. While the roadmap provides a list of priorities, the authors find that most current restriction initiatives are too limited in scope to effectively tackle the risks of hazardous substances like bisphenols and PFAS.

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'.

The document defines greenwashing in the financial sector as false or misleading representations of environmental impact and warns that it can misallocate capital and undermine the Paris Agreement. It outlines five categories of evolving regulation—disclosure, labelling, ratings, taxonomies, and net zero integrity—and classifies enforcement actions into brand, product, financing, and reporting greenwashing. To mitigate risk, the guide proposes 'five pillars' of guarding against greenwashing: screening claims, ensuring transparency, aligning internal actions with public image, monitoring regulatory changes, and adhering to fiduciary duties.

A coalition of environmental organisations opposes the Swedish EU Presidency's effort to delete Article 16 from the proposed Nature Restoration Law, which would have granted citizens and NGOs the right to challenge the legality of national restoration plans. The signatories argue that relying on recitals or the Aarhus Convention is insufficient due to inconsistent compliance across EU Member States and the risk of irreparable environmental damage, as seen in Poland and Romania.

ClientEarth and other NGOs argue that the draft Temporary Crisis and Transition Framework (TCTF) risks undermining the EU's climate goals due to a lack of mandatory green conditionalities, inconsistencies with the Guidelines on State aid for climate, environmental protection and energy (CEEAG), and a lack of transparency and public consultation.

The document proposes integrating an essential use (ESU) framework into EU chemical regulations, specifically REACH and sectoral laws, to streamline the phase-out of hazardous substances. It argues that current cost-benefit analyses are too technical and favor 'business as usual'. The proposed ESU approach would evaluate chemicals across three functional levels—technical, product, and societal—to determine if a use is truly critical. It suggests that non-essential uses (e.g., luxury, cosmetics, toys) should be banned by default, while essential uses (e.g., life-saving medical devices) may receive limited, time-bound derogations. The brief emphasizes shifting the burden of proof to companies and establishing clear criteria for 'acceptable loss of performance' when substituting hazardous chemicals.

ClientEarth proposes that REACH reform should introduce a clear objective to eliminate the most harmful chemicals, specifically suggesting a 2030 target for consumer products to be free of such substances. The document argues that current REACH processes lack a guiding goal for restrictions, creating a gap in implementation and predictability for investors. It further asserts that preventing toxic exposure is a legally binding human rights obligation and calls for a new regulatory mechanism to discourage the registration of new harmful substances.

The document outlines specific demands for the 'REACH 2' reform to address systemic data gaps in the EU chemical market. It argues that the original 'no data, no market' principle failed because registration requirements were too vague and did not cover all substances, such as polymers and low-tonnage chemicals. ClientEarth proposes expanding registration obligations, introducing new reporting duties for downstream users, and increasing transparency for investors and consumers regarding substances of very high concern (SVHCs).

The policy brief proposes reforming the EU's REACH regulation to ensure that exceptions for the use of hazardous substances are rare, short-term, and limited to 'essential uses'. It identifies current failures in the burden of proof and information asymmetry between companies and authorities, suggesting a system where the onus is on companies to prove necessity. Proposed measures include a maximum 10-year limit on exceptions, growing fees to incentivise substitution, and a strict 'essential use' criterion based on the Montreal Protocol.

ClientEarth asserts that current REACH enforcement is insufficient and inconsistent across EU Member States, creating an uneven playing field and failing to protect human health and the environment. The document details high non-compliance rates across registration, supply chain, downstream user, restriction, and authorisation obligations. It proposes a comprehensive reform package including a Commission-led EU audit system, the power for ECHA to revoke registration numbers ('no data, no market'), 'name and shame' transparency measures, and turnover-based fines of at least 8% for serious breaches of authorisation and restriction decisions.