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The document outlines the complex regulatory environment of Ghana's cocoa sector, highlighting the central role of the Ghana Cocoa Board (COCOBOD) and the tensions between production targets and forest conservation. It details the hierarchy of Ghanaian law, specific primary legislation affecting land and agriculture, and the roles of various state institutions. The briefing also addresses socio-economic challenges, such as poverty and child labour, and examines international treaties and emerging sustainability standards like the Ghana Climate-Smart Cocoa Production Standard (GCSCPS) and the African Regional Standard for Sustainable Cocoa (ARS 1000).

ClientEarth argues that the UK government is trending toward deregulation after Brexit, replacing mandatory environmental rules with voluntary schemes and guidance. The submission highlights critical gaps in regulating nitrogen pollution, ammonia emissions, and pesticides, and warns that the shift away from enforceable regulation threatens the 'Green Brexit' goals and the health of England's rivers and air.

ClientEarth argues that the current UK listing regime allows carbon-intensive companies to list on the LSE despite business models incompatible with the Paris Agreement, creating systemic financial risk. The paper recommends that the FCA make demonstrable Paris-alignment a condition for listing, treat climate-exposed applications as 'high risk' for heightened scrutiny, and issue authoritative technical guidance to the market and sponsors.

ClientEarth calls on the European Parliament to veto the Taxonomy Complementary Delegated Act, asserting that the inclusion of fossil gas and nuclear energy as sustainable activities undermines the EU's climate leadership and violates several legal requirements, including the European Climate Law and the Taxonomy Regulation.

ClientEarth and partners assess the trilogue agreement on SAIO regulation, noting progress in the potential for annual pesticide data collection from 2028 and the inclusion of veterinary products. However, they warn that annual collection is conditional upon future legislation requiring electronic records from professional users, and that data will not be available at a regional level or include biocidal products.

The 2021 progress assessment of the Blue Manifesto reveals that most targets are not being met, with only one of eight 2021 milestones on track for full completion. The report highlights significant gaps in the implementation of Maritime Spatial Plans, the failure to eliminate bycatch of sensitive species, and a general lack of ambition in the Council of Ministers regarding fisheries control. While some progress is noted in the EU's Emissions Trading System and international biodiversity negotiations, the overall outcome for 2020 was revised to be more negative, indicating that current EU efforts are insufficient to meet the ambitions of the EU Green Deal and Biodiversity Strategy 2030.

ClientEarth contends that the proposed delegated acts on RFNBOs undermine the principle of additionality, potentially cannibalising renewable electricity needed for other sectors and violating the European Climate Law and the energy efficiency first principle.

The document critiques the REPowerEU proposal's attempt to accelerate renewable energy permitting, claiming it bypasses essential environmental assessments and violates EU administrative procedures.

The document argues that the proposed CSDD is insufficient to meet EU Green Deal ambitions because it uses a restrictive definition of 'adverse environmental impact' based on a limited list of international conventions, omitting key agreements like the Paris Agreement. It highlights that the current framework allows companies to ignore impacts on water, soil, and plastic pollution if no specific international prohibition is violated. Furthermore, the briefing criticises the proposed climate transition plans for lacking prescriptive content and failing to mandate the inclusion of Scope 3 emissions, which often constitute the majority of a company's climate footprint.

The document contends that global and European food insecurity is a problem of distribution, access, and utilization rather than production. It highlights that the EU is a net exporter of agri-food products and that a significant portion of its cereal production is used for animal feed and biofuels rather than human consumption. The text argues that industrial agricultural practices drive the climate and biodiversity crises, which in turn threaten food yields through pollinator loss and extreme weather. It advocates for a transition to agro-ecological practices and the adoption of the EU Nature Restoration Law with ambitious, enforceable targets to capture carbon and protect ecosystem services.

The document addresses industry resistance to the proposed EU deforestation regulation, specifically the 'Geolocation Requirement' which mandates that operators collect latitude and longitude coordinates for all plots of land where covered products (cattle, cocoa, coffee, oil palm, soy, and wood) were produced. ClientEarth argues that traceability is indispensable for ensuring products are 'deforestation-free' and produced legally. It refutes claims that the regulation mandates specific supply chain models like 'identity preserved' or 'segregated' chains, clarifying that mixed-origin supply chains remain permissible as long as they are traceable. The briefing also contends that geolocation requirements will not necessarily exclude smallholders, noting that many in the cocoa and palm oil sectors already support transparency to improve their market position. Furthermore, it argues that compliance costs are likely to be negligible when implemented at scale and that voluntary certification schemes, while useful tools, cannot serve as automatic evidence of compliance due to documented shortcomings in governance and reliability.

ClientEarth and other NGOs express disappointment over a CEFAS report revealing that only 35% of 2022 UK-relevant fisheries catch limits were set in line with scientific advice, with nearly two-thirds exceeding those limits. The authors argue this failure violates the Fisheries Act and the 'Leader’s Pledge for Nature', and they request transparency regarding which TACs the UK advocated to set above scientific advice.

ClientEarth argues that the UK Government's proposed 2040 air quality targets are insufficiently ambitious and urges respondents to advocate for a 2030 deadline for PM2.5 concentration targets to protect public health and reduce economic costs.

ClientEarth argues that the proposed EU Framework for Forest Monitoring and Strategic Plans must prioritize the accessibility of remote sensing data and public transparency to combat forestry crime and mismanagement. The document highlights a significant decline in the carbon sequestration capacity of EU forests by 28% between 2013 and 2018 and criticizes the low rate of compliance checks under the EU Timber Regulation (EUTR), where 99% of domestically-harvesting companies were excluded from checks between 2015 and 2020. ClientEarth advocates for a common EU-wide platform for real-time data to support risk-based compliance planning and the 'substantiated concerns' mechanism for public reporting of illegal logging.

ClientEarth asserts that a proposed climate resolution at Credit Suisse is a legally appropriate use of shareholder rights under Swiss law, countering the bank's recommendation to vote against it. The resolution seeks to amend the articles of association to require annual reporting on progress toward the 1.5°C goal of the Paris Agreement and plans to reduce fossil fuel asset exposure. ClientEarth argues that while the Board manages day-to-day affairs, shareholders can set the general framework via the articles of association, providing a binding legal requirement that exceeds the bank's non-binding promises in sustainability reports.

The report concludes that the Energy Charter Treaty (ECT) is incompatible with EU law because it allows international tribunals to interpret EU law and undermines the regulatory autonomy of EU institutions. While the European Court of Justice (ECJ) has already ruled that intra-EU arbitration under the ECT is illegal (Komstroy), the report argues that extra-EU arbitration also poses significant risks. It highlights that the ECT lacks the procedural and substantive safeguards found in modern agreements like CETA. The authors suggest that the most effective remedy is a combination of withdrawal from the ECT, inter-se modification to eliminate the sunset clause between withdrawing parties, and interpretative declarations to prevent investors from circumventing these measures by relocating their seats outside the EU.

ClientEarth proposes comprehensive reforms to the REACH regulation to address deficient accountability systems. Key recommendations include creating clear, mandatory obligations for companies, harmonising enforcement across Member States, increasing transparency for public and investor due diligence, and establishing a robust system of dissuasive sanctions and compensation for health and environmental damages.

ClientEarth proposes four key reforms to the REACH regulation: requiring full data for market access, simplifying and accelerating the restriction of hazardous chemicals, incentivizing companies that transition to safe alternatives, and enhancing enforcement and transparency to ensure compliance.

ClientEarth argues that the current REACH risk management system is unable to match the volume and rate of chemicals entering the market. The document proposes simplifying restriction processes, introducing a 'high concern' trigger for action, and creating a tiered system for transition periods to ensure the significant reduction of hazardous chemicals.

ClientEarth welcomes the European Commission's draft Horizontal Guidelines on Sustainability Agreements but argues that the Commission must move away from a "full compensation" theory for consumers toward a "fair share" and "polluter pays" approach. The submission advocates for the recognition of global out-of-market benefits—such as biodiversity protection and greenhouse gas reduction—and suggests that competition rules should not protect unsustainable production. It further recommends that agreements ensuring compliance with statutory requirements should fall outside the scope of Article 101 TFEU and calls for greater transparency through comfort letters and published guidance.