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ClientEarth urges the UK government to extend mandatory Adaptation Reporting Power (ARP3) reporting to all major financial regulators, including the FCA, FRC, tPR, and PPF, alongside the PRA. The document highlights that while the PRA previously reported on the insurance sector in 2015, systemic climate risks—including physical, transition, and liability risks—remain poorly understood across other financial sectors such as banking and pensions. It emphasizes the urgency of the 2017-2018 reporting cycle to prevent a five-year delay in addressing these vulnerabilities.

The assessment found that 89% of 80 reviewed products were sourced in alignment with the SSC Sourcing Code, and 85% of 52 products with environmental claims adhered to the Labelling Code. While SSC members generally showed high compliance, non-members were more likely to use misleading terminology or lack verifiable sourcing data. The report notes a 15% improvement in the prevalence of misleading claims since 2011, though it recommends better on-pack catch area and method information to help consumers use seafood guides.

The document examines the application of the Unfair Commercial Practices Directive (UCPD) to corporate 'deforestation free' pledges, arguing that such commitments can be legally challenged if they are used in commercial practices to mislead consumers. It details the criteria for 'misleading' claims, the role of 'codes of conduct', and the enforcement mechanisms available in EU Member States.

The document is an open letter from ClientEarth and several environmental NGOs to the First Vice-President of the European Commission. It highlights a March 17, 2017, finding by the Aarhus Convention Compliance Committee (ACCC) that the EU failed to provide adequate access to justice for individuals and NGOs in environmental matters, specifically breaching Article 9(3)(4) of the Aarhus Convention. The authors argue that while Member States and businesses can defend their interests, no individual or NGO has been granted legal standing before the Court of Justice of the EU to challenge institutional decisions on environmental issues, except for document disclosure refusals. To remedy this, the letter proposes that the European Commission amend Regulation 1367/2006 and that the European Court of Justice revise its interpretation of standing criteria under Article 263 TFEU to ensure environmental NGOs are considered to have "direct and individual concern" regarding acts impacting the environment.

The document is a joint statement from multiple NGOs calling on the European Parliament to oppose the reintroduction of subsidies for the construction of new fishing vessels, citing the EU's existing ban since 2004 and the goals of the Common Fisheries Policy and UN Sustainable Development Goal 14.

ClientEarth argues that the European Commission has improperly withheld conformity checking studies by applying a general presumption of confidentiality to documents that do not meet the legal criteria for such an exception. The complaint asserts that the Commission failed to conduct individual assessments of requested documents, particularly those related to EU Pilot cases and preliminary assessments, in violation of case C-612/13 P and the Aarhus Regulation. Additionally, ClientEarth claims the Commission is neglecting its duty to actively and systematically disseminate environmental information to the public.

The document outlines Denmark's EUTR framework, noting that the Danish Environmental Protection Agency serves as the Competent Authority. It details a penalty regime involving fines, confiscation of profits, and potential detention, while highlighting a trend of increasing checks from 2013 to 2016. The brief identifies significant challenges for NGOs in pursuing substantiated concerns due to a lack of formal decision requirements and limited appeal options.

The document outlines France's EUTR enforcement, noting that the Ministère de l’Agriculture, de l’Agroalimentaire et de la Forêt (MAAF) and the Ministère de l'Environnement, de l'Énergie et de la Mer (MEEM) serve as competent authorities. It details a penalty system including fines up to €100,000 and detention for individuals, with higher penalties for companies and organized gangs. While it highlights strengths such as the ability for 'approved' NGOs to file criminal complaints, it identifies weaknesses including a low number of checks by the MEEM and a lack of sanctions for traceability obligation failures.

The document outlines the Dutch legal framework for EUTR enforcement, identifying the Nederlandse Voedsel- en Warenautoriteit (NVWA) as the Competent Authority. It details the penalty regime, which includes criminal sanctions such as imprisonment and pecuniary penalties, and reports that as of March 2016, approximately 25% of the 150 operators checked were found to be non-compliant. The briefing also explains the processes for NGOs to submit substantiated concerns and challenge operators through civil or criminal proceedings.

ClientEarth argues that the European Commission's Roadmap on the Strategy on Plastics in a Circular Economy incorrectly treats the elimination of hazardous chemicals as a secondary issue or a trade-off against recycling, rather than a cumulative goal for human health and environmental protection.

The document argues that the TCMF Proposal contains wording and targets that may conflict with and weaken the protections of the Nature Directives and the MSFD. It recommends aligning the TCMF's objectives with the requirement to maintain or restore 'favourable conservation status', clarifying the distinction between 'incidental' and 'deliberate' bycatch based on CJEU case law, and ensuring that bycatch and habitat targets are measurable and consistent with existing Union and international standards.

ClientEarth and a coalition of organisations argue that the current VED system incentivises diesel vehicles, which contribute to illegal air pollution levels and significant health costs in the UK. They propose an additional £800 first-year VED charge on new diesel cars to fund air quality measures and accelerate the transition to ultra-low emission vehicles.

A coalition of civil society organisations, including Green10 and ClientEarth, requested that Members of the European Parliament reject the Comprehensive Economic and Trade Agreement (CETA) during a vote scheduled for 15 February 2017. The signatories argue that the agreement contains "fundamental flaws" and does not serve the interests of "people and the planet", calling instead for the development of a "fair and sustainable trade regime".

The document argues that many LGPS funds are failing their fiduciary duties by ignoring climate risk or incorrectly delegating its management. It identifies five misconceptions: that climate change is not a financial risk, that delegation to managers is sufficient, that delegation to the LAPFF is sufficient, that pooling removes the need for fund-level consideration, and that taxpayers bear all the risk. The authors request that TPR investigate these issues, issue guidance, and engage with Defra for an Adaptation Report.

ClientEarth broadly supports the TCFD's industry-led guidance but identifies three critical deficiencies: the potential to confuse voluntary recommendations with existing mandatory legal duties in G20 jurisdictions, the misstatement of the Paris Agreement's objectives by suggesting a 2°C scenario is sufficient for alignment, and a lack of prescriptive requirements for organisations to publish the assumptions underpinning their scenario analyses.

The report argues that the European Commission and various Member States are undermining the 2013 bans on four bee-harming pesticides, including neonicotinoids and fipronil, by exploiting a legal loophole for 'emergency authorisations'. Analysis of 62 notifications reveals that these authorisations are frequently granted without evidence of a genuine emergency, without considering alternative pest control methods, and are often driven by the pesticide and seed industry. The document highlights Romania as a primary example of this abuse, noting it granted one-third of all EU derogations for neonicotinoids between 2014 and 2016 despite evidence of bee colony losses and a lack of research into sustainable alternatives. The authors call for the Commission to increase transparency, systematically scrutinise notifications, and reject industry-led requests.

The report criticizes the European Commission's 2016 proposal for EDC identification criteria, arguing that limiting these criteria to pesticides and biocides violates the 7th Environmental Action Programme's mandate for harmonized, hazard-based criteria. The authors contend that this sector-specific approach creates legal uncertainty, risks inconsistent identification of chemicals across different regulatory frameworks (such as REACH and the Cosmetics Regulation), and may lower overall health and environmental protections. They recommend that the Commission adopt horizontal criteria based on the UN Globally Harmonised System (GHS) and the CLP Regulation, utilizing three hazard categories based on the strength of evidence: known, presumed, and suspected EDCs.

The report examines how the EU's legal framework for chemicals, products, and waste interacts within a circular economy. It argues that a critical failure to pass information about hazardous substances along the material life cycle makes using recovered materials more costly and riskier than using virgin ones. Through case studies on mattresses and LCD TVs, the document demonstrates that while waste-stream specific legislation (like the WEEE Directive) can facilitate safe recovery, the general framework is insufficient. The authors recommend limiting hazardous chemicals at the entry point, improving information systems for chemical composition, and ensuring that recovered materials are held to the same safety standards as virgin materials.

The document explains that 'site integrity' under the Habitats Directive necessitates achieving 'favourable conservation status' for both Annex I habitats and their associated 'typical species'. For sandbanks, this includes a range of invertebrates and fish, some of which are commercially valuable. In the UK, these sites are at high risk from bottom-towed fishing gear, which inhibits the recovery of static communities and biogenic reefs. The author argues that the precautionary principle requires prohibiting such gear unless it is proven to have no adverse effect, challenging 'partial protection' management plans that lack robust scientific data. A case study of The Wash demonstrates how protecting Sabellaria worm reefs and their buffer zones supports commercial fish species like plaice, dab, and sole.

The report concludes that the Polish Draft Act on the Capacity Market constitutes State aid and is incompatible with EU law. Key issues include the exclusion of foreign capacity providers, potential environmental harm through subsidies for high-emission units, and a lack of competitive pricing mechanisms. The report estimates that the capacity market will cost end users approximately EUR 16.8 billion (PLN 73.5 billion) between 2021 and 2035. Furthermore, the Draft Act conflicts with the EU's 'Winter Package' proposal, particularly regarding decarbonisation goals and the requirement for cross-border participation.