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Environmental NGOs are calling for formal observer status and improved documentation to ensure equal access for all stakeholders in fisheries negotiations between the UK, EU, and Norway, arguing that current access is inconsistent and depends on the goodwill of parties.

The Court of Justice confirmed that State aid for nuclear power plants is permissible under Article 107(3)(c) TFEU provided it is compatible with the internal market. Crucially, the ruling establishes that EU environmental law—including the precautionary and sustainability principles—applies to the nuclear sector, and any aid to an activity violating these laws is necessarily incompatible with the internal market. ClientEarth argues that the Commission should use this precedent to systematically enforce Green Deal objectives and the 'do no significant harm' principle across all State aid, recommending updated notification forms and stricter compliance checks for climate neutrality targets.

The document argues that the EU's current legal framework, which excludes installations under the Emissions Trading System (ETS) from certain Industrial Emissions Directive (IED) requirements, is insufficient to meet the goals of the Paris Agreement and the European Green Deal. ClientEarth contends that the ETS alone cannot drive full decarbonisation because it lacks a focus on prevention technologies and allows for the displacement of pollution. The brief proposes a synergetic approach where the IED provides mandatory, scientifically-based greenhouse gas (GHG) emission limit values (ELVs) and energy efficiency standards based on Best Available Techniques (BAT). This would align EU policy with the 'prevention principle' and the 'Hierarchy of action on pollution', ensuring that emissions are avoided by design rather than just traded. The author concludes that deleting Art. 9 IED and Art. 26 ETSD would create a 'win-win-win' for operators, the climate, and the environment by stimulating technological innovation and ensuring a level playing field.

The document analyzes the distribution rules for the EU's €7.5 billion recovery budget for agriculture, specifically the new Article 58a of Regulation (EU) 1305/2013. It argues that the 'non-regression principle' and other spending thresholds are insufficient to ensure environmental progress, as they include non-ecological payments and allow Member States to prioritize socio-economic investments over green ones. The author concludes that the framework encourages 'business as usual' and fails to align with the European Green Deal.

ClientEarth argues that the EU is overinvesting in methane gas infrastructure and urges the Commission to implement a methane product standard by 2025 to integrate climate costs into gas prices. The document recommends that public financial support for methane gas or gas-derived hydrogen be precluded or strictly conditioned on carbon capture and storage (CCS) and lifecycle emission caps. It further calls for institutional reform to ensure independent energy system planning, the prioritisation of energy efficiency over new infrastructure, and the cessation of the term 'natural gas' to avoid greenwashing.

The document analyzes the legal framework for shareholder climate proposals in Japan, noting that amendments to articles of incorporation are the only viable legal pathway for such proposals under the Japanese Companies Act. It highlights a landmark proposal at Mizuho Financial Group that received 34% support and argues that such proposals, while requiring a two-thirds majority to pass, can still influence corporate behavior, as seen with Mizuho's pledge to stop financing coal projects by 2050. The briefing compares these Japanese mechanisms to 'special resolutions' used in the UK and encourages boards and investors to support proposals aligned with the Paris Agreement.

Commissioner Virginijus Sinkevičius acknowledges the absence of NGOs in Member States' delegations during recent consultations with Norway and the UK, stating a desire to change this for future plenary meetings. He emphasizes that the Commission has maintained continuous engagement and debriefings with NGOs to shape the Union's position. Additionally, he affirms that negotiations on sustainability and the European Green Deal will be based on scientific advice and maximum sustainable yield (MSY) objectives to avoid overfishing.

The document argues that Hungarian freshwater lakes, including Lake Balaton, Lake Fertő, Tata Old Lake, and Lake Velence, are facing irreversible environmental risks from state and private tourism investments. The NGOs claim that Hungarian national legislation has been used to streamline permitting processes and limit the ability of the public and NGOs to challenge harmful projects, potentially violating EU Habitats and EIA Directives. They specifically request an infringement procedure regarding a complaint about a 60-hectare tourism complex at Lake Fertő.

ClientEarth argues that HSBC faces significant financial, reputational, and legal risks by continuing to finance fossil fuels. The organization supports a shareholder resolution calling for a Paris-aligned strategy with short, medium, and long-term targets, specifically starting with coal. ClientEarth contends that HSBC's current net zero ambitions and transition financing pledges are insufficient without a concrete plan to reduce fossil fuel exposure, noting that the bank is Europe's second largest financier of fossil fuels.

The report analyzes the legal and governance void created by Brexit, specifically the loss of the European Commission's enforcement role and the CJEU's jurisdiction. It examines the proposed Office for Environmental Protection (OEP) under the Environment Bill, the shift to 'retained EU law', and the risks associated with increased secondary legislation and resource shortages in agencies like the Environment Agency and Natural England. Case studies on air quality and pesticides illustrate the potential for regressive environmental standards and the loss of independent scientific oversight.

ClientEarth's review of 250 large UK-listed companies reveals a systemic failure to provide material climate-related financial information, with only 4% including such factors in financial accounts and 4% of auditors explicitly addressing them. While narrative risk disclosures are improving, they are often boilerplate. The report recommends mandatory TCFD-aligned reporting, stronger regulatory enforcement to prevent 'greenwash', and increased investor stewardship.

The document provides a template letter for pension scheme members to request information from their providers regarding the management of climate-related financial risks, including physical risks to assets and the impact of low-carbon technological innovation.

The document argues for a stronger legal basis under Article 192 TFEU and proposes rigorous standards for measurement, reporting, and verification (MRV), leak detection and repair (LDAR), and a ban on routine venting and flaring (BRVF). It specifically highlights the need for granular data, the inclusion of abandoned wells and mines, and the implementation of methane intensity limits to drive innovation and align with EU climate targets.

The document is a joint letter from a coalition of NGOs calling for greater transparency and accountability in the negotiations between the EU, the UK, and Norway regarding fishing opportunities and catch limits for 2021. The authors argue that while the UK has granted NGOs equal access to its delegation, the EU continues to exclude civil society while allowing the fishing industry inside negotiations. They urge the EU to align its processes with the Aarhus Convention and the European Green Deal to prevent overfishing in the Northeast Atlantic.

ClientEarth argues that EU State aid rules must be transformed into sustainability instruments that prohibit support for fossil fuels and harmful biomass, while prioritizing energy efficiency and renewable energy. The document calls for the strict application of the 'Energy Efficiency First' principle, the exclusion of low-carbon (fossil gas-based) hydrogen from subsidies, and the removal of aid for high-efficiency combined heat and power (CHP) plants. It further recommends increasing support for energy communities, zero-emission vehicles, and energy efficiency in buildings, while introducing a 'greenwashing test' to ensure the environmental integrity of aid beneficiaries.

ClientEarth argues that current EU Food Contact Materials (FCM) regulations fail because they treat symptoms rather than root causes, specifically citing a mismatch between regulatory tools and goals, a lack of clear accountability in the supply chain, and an over-reliance on self-regulation. The organization advocates for 'Option 2' from the Commission's Roadmap—a full regulatory overhaul—which would shift responsibility to the manufacturer or importer of the final product, align FCM rules with food contaminant and chemical laws (REACH/CLP), and introduce a more holistic approach incorporating life-cycle sustainability and stricter enforcement mechanisms, including NGO access to documentation and GDPR-inspired sanctions.

The document advocates for a specific amendment to the UK Environment Bill to ensure the country adopts the 2005 WHO air quality guidelines for PM2.5, which recommend an annual mean concentration of no more than 10 µg/m3. It argues that current UK legal limits, derived from EU Directives, are twice as high as WHO recommendations and are insufficient to protect public health. The briefing highlights that approximately 15 million people in the UK live in areas exceeding WHO guidelines, including 8,549 schools and colleges. It asserts that achieving these targets by 2030 is technically feasible, citing Defra and King's College London analysis, and argues that setting these parameters on the face of the Bill prevents delays in target-setting that would otherwise occur until October 2022.

The report examines how fuel subsidies artificially lower operating costs, enabling overfishing and the expansion of industrial fleets at the expense of small-scale fishers and marine ecosystems. It posits that removing these subsidies is essential for meeting EU climate and biodiversity goals, as well as international obligations under the WTO and the Paris Agreement. The author identifies the revision of the Energy Taxation Directive (ETD) as a critical opportunity to end fuel tax exemptions, suggesting that resulting revenues and existing funds like the Just Transition Fund be used to support low-impact fisheries.

The analysis asserts that the current environmental acquis of the Energy Community Treaty is inadequate to prevent biodiversity loss and water deterioration caused by energy projects. It recommends the adoption of selected articles from the EU Birds, Habitats, and Water Framework Directives, arguing that such measures would not impose significant additional burdens since many Contracting Parties already have existing obligations under the Bern Convention or EU accession processes. The document details the specific risks posed by various energy sources—including coal, nuclear, wind, and hydropower—and provides a tailored legal framework for implementation within the Energy Community.

The report examines Spain's SIGCPI system, a digital tool introduced in 2010 to manage fish import requests and digitise catch certificate (CC) data. While SIGCPI allows for 100% documentary checks of CCs and processing statements (PS), it lacks automated risk analysis and connectivity with other EU Member States, leaving a gap where the same CC could be used for multiple imports across different countries. The document recommends that Spain voluntarily adopt the EU's CATCH system, built on TRACES.NT, to enable EU-wide data cross-referencing and standardised risk analysis, thereby reducing fraud and IUU fishing.