New project: Climate Accountability in EU Trade
Through its new project “Climate Accountability in EU Trade: Testing the SEP and DAGs for Climate-Linked FTA Enforcement” Both ENDS, with support from the European Climate Foundation, is exploring how the European complaints mechanism (SEP) and Domestic Advisory Groups (DAGs) can be more effectively used to advance climate accountability. The project runs for 13 months, until end of 2026.
As emissions data play a bigger role in EU policy, more attention is being paid to the carbon footprint of international trade. Yet the greenhouse gas emissions linked to EU trade, especially those caused by deforestation, fossil fuel extraction, and the mining of Critical Raw Materials, are still not properly regulated in Free Trade Agreements (FTAs). They also remain largely absent from current monitoring systems.
At the same time, the European Commission is moving quickly to conclude new trade agreements that may increase emissions and reinforce extractive economic models. The EU–Chile modernised agreement and the EU–Mexico Global Agreement are examples. In both cases, the Commission has been criticised for a “sign now, fix later” approach: prioritising access to Critical Raw Materials for geopolitical reasons while postponing strong environmental and human rights safeguards. Civil society organisations warn that this risks locking in carbon-intensive trade patterns and weakening accountability and public oversight.
Since 2011, all EU FTAs have included legally binding Trade and Sustainable Development (TSD) chapters, designed to uphold labour, environmental, and climate standards. These are implemented through Domestic Advisory Groups (DAGs), which bring together civil society and other stakeholders to monitor and support implementation. However, experience from Both ENDS’ participation in DAGs under the Andean and Central America agreements since 2021 shows that these groups often lack sufficient resources, influence, and practical tools. As a result, emissions linked to trade value chains may be measurable, but they are rarely monitored or enforced under existing rules.
The European Commission has also introduced a complaints mechanism — the Single Entry Point (SEP) — which allows civil society to raise concerns about TSD commitments. So far, only one formal complaint has been submitted: a 2021 case by Ecuadorian trade unions, supported by Dutch organisations including CNV and Both ENDS, regarding labour violations under the EU–Andean Agreement. Although this led to recommendations, the process was slow, lacked transparency, and produced no binding outcome. This experience highlights both the promise and the limitations of the SEP, particularly for organisations from the Global South.
Strengthening the watchdog role of civil society is therefore essential. Without it, EU climate policy risks entrenching trade models that drive extraction and high emissions, especially in the Global South.
To address this gap, Both ENDS, with support from the European Climate Foundation, has launched a project to explore how the SEP and DAGs can be more effectively used to advance climate accountability. The project will gather evidence and develop case briefs illustrating the gap between trade commitments and climate goals. It will also produce practical guidance for civil society on using the SEP to address climate-related violations, along with a policy brief on how data on embedded emissions and value chains can support stronger trade enforcement.
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