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ClientEarth argues that the ECB's Corporate Sector Purchase Programme (CSPP) and Pandemic Emergency Purchase Programme (PEPP) exhibit a structural bias toward greenhouse gas-intensive companies, which undermines EU climate targets and increases systemic financial risk. The organization asserts that the ECB has legal obligations under EU treaties and the Charter of Fundamental Rights to integrate environmental protection into its monetary policy. ClientEarth proposes three specific actions: the immediate exclusion of bonds from companies incompatible with Paris Goals (including coal and unconventional oil and gas), requiring companies to adopt credible net-zero transition strategies by January 2023, and implementing annual TCFD-aligned reporting starting in 2022. The letter challenges the ECB's 'market neutral' approach, claiming it locks in high-carbon business models and fails to account for climate-related financial risks.

The European Commission has opened formal investigations into compensations provided to RWE (EUR 2.6 billion) and LEAG (EUR 1.75 billion) for the closure of lignite plants in Germany by 2038. The Commission preliminarily concludes these payments constitute state aid and expresses doubts regarding their proportionality, specifically whether the calculations for foregone profits and mine rehabilitation costs are realistic or lead to overcompensation. ClientEarth argues that the aid may violate the 'polluter pays principle' regarding mine recultivation and that declining market conditions and rising CO2 prices make the assumed long lifespans of the plants unrealistic.

The document advocates for a transition from an industrial food system to one based on agroecology and rights-based governance. It calls for the European Parliament to endorse the Farm to Fork Strategy's targets, make them legally binding, and align the Common Agricultural Policy with the European Green Deal. Key recommendations include reducing pesticide and fertiliser use, cutting livestock numbers, regulating new GMOs, improving animal welfare, and ensuring a socially just transition for food workers and global south partners.

ClientEarth urges the European Commission to prioritize the preservation of forests over their economic exploitation in the new EU Forest Strategy. The organization advocates for the strict protection of primary and old-growth forests, the integration of the Strategy with existing anti-illegal logging frameworks like the EUTR and FLEGT, and the complete exclusion of forest biomass from the definition of renewable energy. It further emphasizes the need for the legal recognition of Indigenous Peoples' and local communities' tenure rights, the use of remote-sensing data for monitoring, and the inclusion of binding forest protection criteria in EU trade agreements.

ClientEarth argues that the BEIS proposals for climate-related financial disclosures are inadequate and recommends a mandatory approach aligned with the full TCFD framework and Paris Agreement goals, supported by stronger regulatory enforcement and auditor assurance.

ClientEarth argues that the revised Notice should explicitly allow NGOs and individuals to challenge State aid measures that breach environmental law and should emphasize the need for greater transparency in aid granting to facilitate private enforcement. While maintaining that the Commission holds exclusive competence to assess the overall compatibility of aid with the internal market, the document suggests that national courts can provide critical evidence of environmental violations to assist the Commission. It further highlights systemic failures in the EU State aid Transparency Register, noting missing data for Member States such as Romania and Cyprus.

ClientEarth argues that the GBER must be revised to eliminate aid for environmentally harmful activities and prioritise sustainable energy transitions. The organisation recommends integrating the 'do no harm' principle, increasing transparency in state aid reporting, and excluding fossil-fuel-based technologies like high-efficient cogeneration and hydrogen from block exemptions. Conversely, it proposes new aid categories for energy communities, zero-exhaust-emission vehicles, and sustainable battery storage to accelerate the green transition.

The document outlines the legal case Friends of the Earth Netherlands v Royal Dutch Shell plc, arguing that Shell's current net-zero strategy is insufficient compared to IPCC standards. It details the legal basis of the claim—centered on Dutch civil law and human rights—and warns investors of the reputational and financial risks associated with climate litigation and emerging EU due diligence legislation.

ClientEarth's submission to the UK government's judicial review reform consultation expresses strong opposition to proposals that would limit court discretion, introduce prospective-only remedies, or strengthen ouster clauses. The organization argues that such reforms could lead to non-compliance with the Aarhus Convention and the European Convention on Human Rights. While supporting the removal of the 'promptitude requirement' and the introduction of a formal 'Reply step', ClientEarth cautions against a 'track' system for claims and the restriction of interveners. The document emphasizes that environmental litigation is a critical tool for public accountability and that any reform must be evidence-based and cumulative in its impact assessment.

ClientEarth argues that State aid for IPCEIs must be strictly conditioned on compliance with EU environmental law and the 'do no harm' principle. The organization specifically advocates for the exclusion of fossil fuel projects and non-renewable hydrogen from aid eligibility, while calling for increased transparency in the Commission's State aid decisional process and the use of competitive procedures for selecting beneficiaries.

ClientEarth argues that the IED revision must shift from a static, activity-based approach to one that promotes the industrial activity with the least environmental impact for a given service. The organization advocates for expanding the IED's scope to include mining, upstream oil and gas, and aquaculture, while making greenhouse gas (GHG) emission limit values and energy efficiency standards binding, even for installations covered by the EU ETS. Key recommendations include restricting Article 15(4) derogations to a maximum of 48 months, introducing a right to compensation for victims of pollution, and strengthening Aarhus Convention rights through periodic permit renewals every four years and mandatory public participation for all permit updates.

ClientEarth argues that the draft Implementing Regulation fails to distinguish between legal harvesting and sustainable sourcing, relies on a 'box-ticking' approach to compliance, and excludes critical evidence provided by civil society organisations. The organisation calls for clearer definitions of 'significant lack of enforcement', a broader scope of applicable biomass facilities, and stronger obligations for Member States to verify information and maintain up-to-date databases.

ClientEarth argues that the European Commission's interim findings on illegal logging rules fail to adequately account for the positive systemic impacts of the EUTR and FLEGT Regulation while overlooking critical enforcement gaps. The organization recommends harmonizing obligations across the supply chain, creating a centralized public registry for compliance data, and adopting a legal definition of 'substantiated concerns' to aid prosecutors. Regarding FLEGT, ClientEarth contends that the slow pace of licensing is a result of the necessary complexity of legal reforms in partner countries and warns that weak EUTR enforcement reduces the incentive for third countries to engage in VPA processes.

The document assesses six policy options to raise cocoa prices and farmer incomes to combat poverty, deforestation, and child labour. It concludes that most trade-based interventions, such as export price regimes or import duties, are unsustainable in the long term due to risks of over-supply, reduced consumer demand, and WTO compatibility issues. The author identifies bilateral partnership agreements as the most promising approach to create the governance and sustainability standards necessary for a comprehensive sector reform.

The report examines the legal landscape for (agro)forestry in Côte d’Ivoire, highlighting that while the state aims for 20% forest cover by 2030, land tenure insecurity remains a primary risk. It details the distinctions between land titles, land certificates, and customary rights, noting that only Ivorian individuals, the State, and public authorities can hold land titles. The analysis emphasizes that investors should prioritize contracts with land certificate holders to avoid the legal uncertainty associated with customary rights, which can lead to eviction. It also explores the potential for investors to own planted trees and benefit from carbon credits through specific agreements, though it notes that carbon regulations are still being finalized.

The briefing argues for a mandatory product-based due diligence framework for Forest and Ecosystem Risk Commodities (FERCs) and their derivatives. It recommends that the regulation cover not only forests but all natural ecosystems and human rights violations, specifically the rights of Indigenous Peoples and local communities. The authors call for equivalent obligations for financial institutions, a robust enforcement mechanism including criminal penalties and access to EU courts for harmed third parties, and accompanying measures to support producer countries and reform EU consumption patterns.

The LIFE-A2J-EARL project focused on bridging the 'implementation gap' of EU environmental laws by empowering the judiciary, public administrations, and public interest lawyers. Operating across eight EU Member States, the project produced a comprehensive legal guide, national toolkits, and a digital platform to facilitate access to justice. It delivered 48 training sessions and 12 webinars, reaching over 2,000 participants. Despite delays caused by the COVID-19 pandemic and shifting judicial attitudes in some regions, the project successfully increased stakeholder awareness of the Aarhus Convention and EU case-law. Key outputs included a database of 117 public interest lawyers from 15 countries and a final virtual conference attended by 285 participants.

A coalition of food, farming, and environmental organisations calls for a fundamental reform of the EU's Common Agricultural Policy (CAP). The letter argues that the current unsustainable food system contributes to climate breakdown and biodiversity collapse, threatening the survival of farmers. The coalition proposes five overarching priorities for the post-2022 CAP: integrating Green Deal targets into national Strategic Plans, implementing the 'do no harm' principle, supporting sustainable farming practices, regulating markets to limit overproduction, and ensuring governance through transparency and accountability.

The letter asserts that DG GROW has misinterpreted EU chemicals law and applied a lenient policy to the REACH authorisation process for ten years. It calls for the Commission to align its practices with a recent Court of Justice judgment, specifically by rejecting applications with non-negligible uncertainties or data gaps and by ending the illegal practice of requesting necessary information after authorisation has already been granted.

Environmental NGOs are calling for the European Commission to ensure equal access for all stakeholders, including the creation of a formal observer status, in fisheries negotiations between the EU and the UK. The letter highlights an uneven playing field where industry members have more access than eNGOs, noting that only the Netherlands and Ireland have opened their delegations to eNGOs. The authors demand comprehensive documentation of negotiations and timely stakeholder consultations to align with the Aarhus Convention and sustainability commitments under the Trade and Cooperation Agreement (TCA).