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ClientEarth warns that further delays to the EU Deforestation Regulation (EUDR), currently set to apply to the private sector on 30 December 2025, would cause significant environmental damage and create legal vulnerabilities. The document asserts that such delays lack proper impact assessments and conflict with EU environmental protection principles, the principle of legitimate expectations for businesses that have already invested in compliance, and international law regarding State climate obligations as clarified by a 2025 ICJ Advisory Opinion.

The briefing argues that proposed 'Omnibus I' amendments to weaken or delete Article 22 of the CS3D—which requires companies to adopt and implement 1.5°C-compatible climate transition plans (CTPs)—would contradict the International Court of Justice's (ICJ) July 2025 Advisory Opinion. The ICJ confirmed that States have a binding legal duty to regulate private sector emissions using 'stringent' due diligence. The authors warn that diluting these requirements would increase the liability risks for EU Member States, heighten the legal exposure of companies to climate litigation, and leave the final Omnibus I Directive vulnerable to legal challenges for failing to meet international and EU climate obligations.

The position paper argues against abolishing the formal complainant's right to a rejection decision and opposes the discontinuation of stricter national laws on unilateral conduct. It advocates for harmonising the rights of non-investigated parties and improving coordination between National Competition Authorities (NCAs) and the Commission to support public interest and the decarbonisation of the EU economy.

ClientEarth argues that the GBER lacks effective environmental safeguards and continues to permit harmful subsidies, particularly for fossil gas. The organisation proposes introducing horizontal conditionalities, such as the 'Do No Significant Harm' principle and the 'Energy Efficiency First' principle, and calls for the removal of block exemptions for fossil gas activities and tax reductions on fossil gas-fired electricity. Additionally, it suggests creating a tailored block exemption to support small-scale coastal fishing.

The document argues that UK local authorities have a solid legal foundation under the Road Traffic Regulation Act 1984 to implement weight- or size-based parking tariffs for SUVs. It highlights that SUVs increase fatality risks for pedestrians and cyclists, contribute more to air pollution via tyre and brake wear, and cause greater road surface damage. To avoid legal challenges, the briefing advises councils that such charges must be justified by traffic management and safety goals rather than revenue generation, and must be supported by robust public consultation.

ClientEarth advocates for the UK government to mandate the development, disclosure, and implementation of transition plans aligned with the Paris Agreement. The organization argues that a 'comply or explain' framework is insufficient and that mandatory requirements are necessary to prevent 'greenwashing' and 'say-do gaps'. It specifically highlights the need for pension schemes to manage systemic climate risk through Paris-aligned anchors and robust stewardship. ClientEarth further asserts that legal risks for directors are often overstated due to the 'dishonesty standard' in English law, and that alignment with the 1.5°C goal is essential for the UK to fulfill its international obligations following the 2025 ICJ Advisory Opinion.

ClientEarth argues that environmental safeguards are constitutional obligations, not administrative burdens, and that the EU should address implementation bottlenecks—such as lack of staffing and poor digitalisation—rather than deregulating. The document specifically opposes the discontinuation of the SCIP database, the simplification of the EU Deforestation Regulation (EUDR), and the weakening of the Industrial Emissions Directive (IED) or Nature Restoration Regulation (NRR). It emphasizes that robust environmental assessments provide legal certainty and risk mitigation for investors.

ClientEarth argues that CSOs in the EU, particularly those focused on environment and climate, face a deteriorating environment characterized by shrinking civic space, legal harassment (SLAPPs), and financial insecurity. The document criticizes the European Commission for restricting public access to documents and prioritizing corporate interests in 'strategic dialogues' over civil society. It calls for a binding framework for civil dialogue, systemic consultation at all legislative stages, and increased funding for protection mechanisms like the Aarhus Rapid Response Mechanism. Specific national examples of repression are cited in Poland, France, Italy, Germany, and Hungary, while Finland and Denmark are noted for positive engagement models.

The briefing details the 2024 revisions to the Industrial Emissions Directive (IED), focusing on expanding access to justice, strengthening non-compliance and suspension mechanisms, increasing penalties, and introducing a new compensation right for health damages. It emphasizes alignment with the Aarhus Convention and provides recommendations for Member States to ensure these provisions are effective and dissuasive in practice.

ClientEarth critiques the European Commission's 'Roadmap towards Nature Credits', warning that a market for biodiversity credits could undermine EU environmental law if not strictly separated from regulatory obligations and offsetting. The organization argues that the biodiversity financing gap—estimated at 19 billion euros per year in the EU—should first be addressed by scaling up public funds and redirecting the 48 billion euros in annual harmful subsidies. ClientEarth recommends that any future credit system be strictly outcome-based, exclude 'business-as-usual' practices, and prohibit the use of credits for ecological compensation (offsetting) to avoid 'net loss' of biodiversity. It further highlights the scientific complexity of measuring biodiversity compared to carbon, cautioning against reductionist proxy metrics that could lead to greenwashing.

The statement argues that current scientific advice for fishing limits is insufficient for ecosystem recovery and that the EU has failed its legal obligations to end overfishing and achieve Good Environmental Status. It calls for catch limits to be set significantly below maximum scientific advice, particularly for forage fish and mixed fisheries, to safeguard marine biodiversity and resilience against climate change.

A coalition of NGOs calls on the UK Minister for Environment, Food and Rural Affairs to adopt a precautionary approach to 2026 fishing limit negotiations with the EU. The letter argues that current scientific advice is insufficient for ecosystem recovery and that the UK is failing to meet Good Environmental Status (GES) targets, with 13 out of 15 indicators not met in 2025. The authors recommend setting catch limits well below ICES single-stock advice, respecting a 5% risk limit for stock decline, and increasing transparency in negotiations.

ClientEarth and nine other organisations challenge the European Commission's 'Sixth Omnibus on chemicals' proposal, asserting that it introduces dangerous exceptions for carcinogenic, mutagenic, and reprotoxic substances (CMRs) in cosmetics and rolls back hazard communication rules in the CLP Regulation. The briefing contends that these changes violate the EU Charter of Fundamental Rights, fail to genuinely improve EU competitiveness, and were developed without the legally required public consultations, relying instead on industry-dominated workshops.

A coalition of 15 NGOs calls on EU fisheries ministers to align 2026 Baltic fishing opportunities with the Common Fisheries Policy (CFP) to ensure fish populations remain above biomass levels capable of producing the maximum sustainable yield (MSY) and to protect ecosystem health.

The document identifies fundamental shortcomings in the scientific advice provided by the International Council for the Exploration of the Sea (ICES) regarding fishing opportunities in the EU and UK. It asserts that current advice and the requests guiding it do not fully align with legal requirements and policy goals. The authors call on EU and UK decision-makers to request that ICES clarify these shortcomings, address identified issues, and provide interim recommendations to ensure fisheries decisions effectively support stock recovery and ocean health.

The document is an open letter addressed to the Prime Minister of Denmark, calling for the resumption of negotiations on the EU Green Claims Directive to combat greenwashing and provide legal certainty for businesses. The signatories argue that existing enforcement under the Unfair Commercial Practices Directive is insufficient, citing EU Commission data that 53% of green claims are vague, misleading, or unfounded, and 40% lack supporting evidence. They contend that the Directive would establish minimum standards for substantiating and verifying environmental claims, thereby protecting consumers and ensuring fair competition without creating an undue administrative burden.

The document is a formal letter from ClientEarth and other civil society organisations to the European Commission expressing strong opposition to the Sixth Omnibus on chemicals. The authors argue that the proposal, which seeks to simplify requirements in the CLP, Cosmetic Products, and Fertilising Products Regulations, actually promotes deregulation and undermines EU competitiveness by creating regulatory instability. They specifically highlight 'severe cases of maladministration' regarding the proposed rollback of CLP Regulation formatting rules, claiming the Commission bypassed public consultation and lacked a proper evidence basis. The letter warns that these procedural flaws violate EU primary law and the Charter of Fundamental Rights, potentially leading to the legislation being annulled by EU courts.

A coalition of 63 European entities calls on the European Commission to retain horizontal spending targets for climate and environment in the post-2027 EU budget to ensure a clean industrial transition and economic competitiveness.

The document argues that current fishing opportunities are often set above scientific advice, perpetuating overfishing in the Baltic, Northeast Atlantic, and Mediterranean. It recommends setting Total Allowable Catches (TACs) well below the 'headline' scientific advice from ICES and STECF to account for ecosystem dynamics and climate change. The authors highlight shortcomings in current scientific advice, noting it lacks concrete recovery timeframes and ecological objectives. Key proposals include implementing a quantitative precautionary approach to TAC-setting, increasing transparency in negotiations, and fully enforcing the Landing Obligation.

The document argues that many fish populations not managed by a Total Allowable Catch (TAC) have been exploited unsustainably, despite legal requirements in the EU and UK to apply precautionary and ecosystem-based approaches to all harvested species. It calls for the introduction of effective management measures for all non-TAC stocks, the use of Remote Electronic Monitoring (REM) to improve data, and the implementation of clear criteria for the prohibited species list. Specific urgent actions are recommended for the European eel, including adding it to the prohibited species list and stopping all targeted fishing, and for sea bass, including limiting catches below headline scientific advice to ensure recovery.